ML20244A874
| ML20244A874 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 08/03/1984 |
| From: | Atomic Safety and Licensing Board Panel |
| To: | |
| Shared Package | |
| ML20097F079 | List:
|
| References | |
| FOIA-84-487 NUDOCS 8906120176 | |
| Download: ML20244A874 (102) | |
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~ CMTED'$fATBS OF AME3fc4 LNCCLEAR REGULATORY COMMismew la the maner of: TEXAS UTILITIES ELECTRIC COMPANY, ec~al Doete No. 50-445-2 50-446-2 (Comancht Peak Steam Electric Station, Units 1 & 2) y + ( t. ~ _,, ;_q _, b, ~b t, Y l j Deposition-of: W.: Ivani Vogelsang - ib _ .VOLtlME II - y,. av a lm Glen Rose,. Texas pages: 77,300-77,387 /II dd5f(h[I!$r: Friday, August.3,' 1984 i b[M.
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l 77,300 1 1 UNITED STATES OF AMERICA NUCIZAR REGULATORY COMMISSION 2 3 BEFORE THE ATOMIC SAFETY & - LICENSING BOARD 4 5 In the Matter of: 6 l TEXAS UTILITIES ELECTRIr 7 COMPANY, et al. Docket Nos. 50-445 50-446 8 (Comanche Peak Steam Electric Station, Units 1 and 2) 9 10 11 l Glen' Rose Motor Inn Highway 67 & FM Road 201 12 Glen Rose,, Texas 13 August 3, 1984 1 14 1 1 15 Deposition of: W. IVEN VOGELSANG 16 called for examination by counsel for Applicants 17 j; taken before Sandra Harden, Court Reporter, d 3 18 0 beginning at 9:27 a.m., pursuant to agreement. I' l 1 l 2 VOLUME II i 21 ! i i 22 l I 23 f I 24 ! l 25 i i l'
77,301 1 1 APPEARANCES: 2 For the Applicants, Texas Utilities Electric Company, et al.: 3 MARK L. DAVIDSON, ESQUIRE-4- Bishop,_ Liberman, Cook, Purcell & Reynolds 1200 Seventeenth Street, Northwest 5 Washington, D.C. 20036 6 For the Nuclear Regulatory Commission Staff: 7 GEARY S. MIZUNO, ESQUIRE. Office of.the Executive Legal Director 8 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 9 For the Intervenor, Citizens Association for Sound 10 Energy: 11 ANTHONY Z. ROISMAN, ESQUIRE Trial Lawyers for Public Justice, P.C. 12 2000 P Street, Northwest, Suite 611 Washington, D.C. 20036 13 - 14 15 16 17 l l 18 1. 20 l 4 21 22 i i 23 1 24 25 )
j 77,302 1 ._I _N _D _E _X 2 WITNESS DIRECT CROSS REDIRECT RECROSS 3 W. Iven Vogelsang 77,305 77,370-77,374 -77,310 77,383 4 77,358 5 6 7 8 9 l 10 11 12 EXg1g1IE 13 NUMBER FOR IDENTIFICATION l 14 Vogelsang Deposition Exhibit No. 4 77,383 15 3 } 16 (Exhibits previously identified, referred to, and attached.) 17 Camp Deposition Exhibit No. 4 f i l 18 Camp Deposition Exhibit No. 5 i r j u j 19 Camp Deposition Exhibit No. 7 i 20 Camp Deposition Exhibit No. 9 l l 21 4 23 24 l l 25 i 1 i 4
77,303 1 PROCEEDINGS i 2 MR. DAVIDSON: On the record. 3 We are recommencing the adjourned cross-1 4 examination of Mr. Vogelsang. 5 Last night, I committed to Mr. Roisman and 6 -Mr. Mizuno that I would secure for them a copy of the 7 memorandum Mr. Vogelsang testified about that he had 8 prepared in response to a request that he make an evaluation 9 of the SDAR, that is the Significant Deficiency Analysis 10 Report, that had been filed so that it could be determined 11 whether a reportable deficiency would have to be filed, 12 that is, what is known as a 50.55 (e). 13 As I recollect, the testimony was that 14 Mr. Vogelsang said that he had prepared a memorandum for 15 Mr. Popplewell and that that was used as the basis for 16 the preparation of Vogelsang 3, which was a memornndum that 17 carried Mr. McBay's signature and was addressed to Mr. 18 Tolson. I 19 MR. ROISMAN: No. Just to correct the l 2 record. I'm sorry. Vogelsang 3 is the document from 21 Westinghouse. I 22 MR. DAVIDSON: Okay. I'm sorry. 23 MR. ROISMAN: I think it's a Camp exhibit, f 24 MR. DAVIDSON: Is it a Camp exhibit? 25 l MR. ROISMAN: Yes. I don't happen to have it. I ) i n___-_._______ l
1 77,304 .1 i MR. DAVIDSON: I'm sorry. We don't have the-l f 2 exhibit before us at this time, so I may have misrecollected. 3 But thank you for the correction, Mr. Roisman. 4 In any event, it was the predicate memorandum 5 testified which Mr. Vogelsang testified that he and Mr. 6 Baker used to prepare the memorandum that was-- 7 (Document provided to counsel.) 8 Yes, thank you, Mr. Roisman. 9 --prepared the memorandum which was for 10 Mr. McBay's signature to be sent to Mr. Tolson indicating 11 that a 50.55(e) would have to be filed. 12 And Mr. Roisman has handed me Camp Exhibit 14, 13 which is that document. 14 And I have received from Mr. Vogelsang a 15 handwritten, three-page memorandum which Mr.'Vogelsang has 16 told me is the memorandum in question. l i Accordingly, I would like to have that I 17 18 marked. I have provided copies to Mr. Roisman and to Mr. i 19 Mizuno. I'd like to have the document marked for the l N record as Vogelsang Exhibit 4 l 21 (The document referred to was 22 marked for identification as 23 Vogelsang Deposition Exhibit { 24 No. 4.) j 25 MR. DAVIDSON: Mr. Roisman, do you require j 4
l 77,305 1 1 I that I establish any foundation for this document? 2 l MR. ROISMAN: No, I was going to ask the j 3 witness a couple of questions myself about it. 4 MR. DAVIDSON: I understood that. But do 5 you want me to do anything more? 6 MR. ROISMAN: No, it's not necessary. 7 MR. DAVIDSON: All right. I'll allow you 8 to ask the questions. If there's any additional question, 9 I can always, of course, ask it on redirect'if that's to necessary. 11 Thank you, Madam Reporter. 12 Mr. Roisman, if you would recontinue your 13 examination. 14 MR. ROISMAN: Yes. 15 Whereupon, 16 W. IVEN VOGELSANG, 17 having been previously duly sworn, was further examined and l 18 upon his oath testified as follows: i 18 CROSS-EXAMINATION (Resumed) 20 BY MR. ROISMAN: 21 Q Mr. Vogelsang, looking at what has now been 22 marked as Vc alsang Exhibit 4, is that the document that 23 you previously testified you sent to Mr. Popplewell that 24 represented your evaluation of the SDAR? 25 A This is a document that I had remembered that
E 77,306 l 1 I had prepared in response to the SDAR, yes, sir. { 'I 2 Q And is this the document that you sent to 3 Mr. Popplewell? I 4 A I didn't send this to Mr. Popplewell? 5 Q What did you send to Mr. Popplewell? 6 A Nothing. 7 Q I'm not-- I don't want this to be a perjora-B tive question, but is your memory now that you, in fact, 9 didn't ever send anything to Mr. Popplewell at this particu-10 lar time? 11 A Yes, sir. 12 Q Okay. Fine. 13 So, you want to clarify that point from last 14 night's transcript; is that correct? 15 A Yes, sir. 16 MR. DAVIDSON: What he's asking you, tir. l 17 Vogelsang, is: Did you misrecollect what memorandum you l 18 prepared or to whom you sent it. That's all. 19 THE WITNESS: Yes, sir. l 20 MR. DAVIDSON: Okay. 21 BY MR. ROISMAN: 22 i Q Now, was this memorandum actually sent to i 1 23 anybody? 24 A No, sir. 25 0 What was the purpose of your preparing the 4
77,307 I memorandum? l 2 A This was my draft response to the STAR that I 3 had been assigned to me. When I finished this draft, I 4 took it by Richard Baker, who is a staff engineer for Mr. 5 Popplewell. And I asked-- And I gave it to him, and I 6 asked him to review and comment on it, and I left it in his 7 office. 8 O All right. And then what happened next 9 with it? 10 A The next day, Mr. Baker brought'back-- 11 brought the memo-that is-- the memo from McBay to Tolson 12 by my office, and he said that he had reviewed this and he had compiled this memo, and he wanted my initial on it. 13 He wanted me to review it for correctness to put my initial 14 15 on it and-- 16 (Document placed before the witness.) i 17 Yes, sir. This is the memo. I 18 Q Just mention it by exhibit number so we'll i 19 Know. k 20 A It's Camp 14 21 MR. DAVIDSON: You have to understand, Mr. 1 Vogelsang, that when you shake your head "yes" or say 22 23 "That's the document" that the record doesn't reflect it 24 unless you say "Yes, the document you have handed me, Mr. 25 Roisman, Camp 14, is the document. I'm referring to." (:
i 77,308 j I-1 THE WITNESS: .Yes, sir. l 2 BY MR. ROISMAN: 1 3 O All right. And to your/ knowledge, what { i 4 additional use was made of this memorandum that's been l 5 marked Vogelsang. Exhibit 14-- Excuse me. Exhibit 4? 6' A I don't understand that question, sir. 7 Q Was Vogelsang Exhibit 4 used for any purpose, 8 other than that you wrote up a draft of your response to the 9 SDAR, gave it to dr. McBay, and then he brought it,- in what 10 is now Camp Exhibit 14, back to you? 11 MR. DAVIDSON: I think, Mr. Roisman, first 12 of all, that he gave this memorandum, the dra f t memorandum, 13 to Mr. Baker. 14 MR. ROISMAN: I'm sorry. Correct. To 15 Mr. B&ker. 16 BY MR. ROISMAN: I 17 Q Is that-- Was there any other use made of 18 it? 19 A No, sir. l t 20 0 In preparing your response to the SDAR, did 21 you prepare any other document, other than-- prepare 22 personally any other document, other +han what we've marked-23 as Vogelsang Exhibit 4? 24 A No, sir. 25 Q I assume that this is your handwriting?
77,309 1 1 1 A Yes, sir. l ) 2 MR. ROISMAN: I'd like to offer Vogelsang 3 Exhibit 4 into evidence at this point, 4 MR. MIZUNO: The Staff does not object. 5 MR. DAVIDSON: I would only make one notation 1 6 for the. record, Mr. Roisman, and that is that the three-l 7' page dacument does apparently contain Mr.- Vogelsang's hand-8 writing. He.has, in fact, so testified. But there seems 9 to be some second handwriting on the document. 10 MR. ROISMAN: I appreciate your noting that. 11 Let me ask the witness: 12 BY MR. ROISMAN: 13 O Mr. Vogelsang, do you know or recognize that 14 notation in the upper, right-hand corner, appears to say 15 "From WIV 2-1-83"? 16 A Yes, sir. 17 ' O Could you please describe it to us? 18 A That's Mr. Baker's handwriting. i 19 0 And did you see him put that on there? l 1 20 A No, sir. 1 21 Q But your understanding is that that is his ] 22 handwriting that's on there. 23 A That is his handwriting. l 24 MR. ROISMAN: Well, with the exception of that I 25 piece of it., which I will not offer for anything \\ J
77,310 l' 1 except that it happens to be there, that he believes that 2 it is Mr. Baker's handwriting, I will offer it into evidence. 3 Any objection? 4 MR. DAVIDSON: I have no objection. 5 MR. ROISMAN: I have no further questions of 6 the witness. 7 MR. DAVIDSON: Off the record. 8 (Discussion off the record.) 9 MR. DAVIDSON: Let's go back on the record. 10 MR. MIZUNO: May I have the exhibits, please? 11 I would like to have Nr. Vogelsang have a 12 set because I will be examining him on some of them. 13 MR. DAVIDSON: All right. Let's bring them 14 over here and see. 15 CROSS-EXAMINATION 16 BY MR. MIZUNO: l 17 y Q Mr. Vogelsang, I believe that you stated l 18 yesterday in response to some questions from your counsel I j ) 19 that you reviewed Camp Exhibit 4? i 2 (The document referred to was placed-before 21 the witness.) 22 MR. D "?IDSON : Mr. Mizuno, we have that docu-I 23 ment before us. I 24 A (By the witness) Yes, sir. 25 0 (By Mr. Mizuno) And I believe you also 1 i J
77,311 1 indicated that you agreed with this-- with the substance 2 of this document? 3 A Yes,. sir. 4' o I would like to refer you to paragraph 1 on 5 the first page of that document, and, in particular, to the 6 sentence that starts "In this regard". 7 A Yes, sir. 8 Q Okay. Do you' 0 gree with that sentence? 9 A Yes, sir. 10 Q Can.you provide an explanation of why you 11 agree with that sentence? 12 MR. DAVIDSON: Mr. Mizuno, I think the record 13 will be easier to follow if we get that sentence into the 14 record and then you have the questions follow. 15 MR. MIZUNO: Would you like me to read the 16 sentence out loud? 17 MR. DAVIDSON: In any way that you think you 18 want to get that sentence.in the record, and then we can 19 see what he's agreeing with and you can ask him why he agrees 20 with it. 21 MR. MIZUNO: Fine. 22 BY MR. MIZUNO: 23 Q Mr. Vogelsang, I will read out the sentence 24 which I pointed to you on the record, and after I finish 25 reading it, will you please explain why you agree with that
77,312 1 sentence? 2 And the sentence reads: "In this regard, 3 a conduit system provides enclosure integrity far superior 4 to that of enclosed tray with covers and/or solid bottoms 5 and splice plates between sections." 6 MR. DAVIDSON: Period, close quote. 7 MR. MIZUNO: That's right. 8. A (By the witness) The reason I agree with 9 this statement, our rigid, galvanized steel conduit is a 10 Schedule 40. The tray system is a thinner gauge, approxi-11 mately a 14-gauge of sheetmetal. 12 Conduit is a completely enclosed system 13 with a tray segment at a splice plate where openings between 14 the tray and the cables. 15 So, again, with this statement, conduit does, 16 indeed, form a superior enclosure than trays. i 17 0 What do you mean by " Schedule 40"? { 1B i i A Schedule 40 is about approximately a quarter I j 19 inch in thickness. i i l [ 20 0 It refers to a thickness of the metal. \\ 21 A Thickness of the metal, yes, sir. 22 O Now, referring to paragraph 2 on'page 2 of i 23 the same document, and I will refer you to the second 24 i sentence, which I will read for you in the second paragraph: i 25 " Circuits in trays located above conduits i i
77,313 1 pose no hazard to circuits in the conduit by virtue of their 2 orientation (i.e., above the conduit)." 3 Do you see that sentence, Mr. Vogelsang? 4 A Yes, sir. l 5 Q Do you agree with that sentence? 6 A Yes, sir. 7 Q Now, can you explain how orientation of 8 trays above the conduit affects their susceptibility of the 9 circuits in the conduit below the tray? 10 A Yes, sir. 11 What we're looking for is the tray, an open-12 bottom tray, we're protecting the cables against a fire 13 is what we're looking for. So, the open-bottom tray, the 14 heat from the fire will rise up, not down. 15 Any pieces or things that might fall from the f 16 tray to the conduit, the conduit is round. So, it won't l I 17 collect on top of the conduit. So, again, the conduit isn't j i 18 in the direct heat of the flame of.whatever is burning. l 19 Derbis (sic), burning derbis (sic), can't collect on top of l M the conduit. So, the conduit underneath would be protected-- 21 would protect the circuits inside that conduit. l 22 Q Okay. Going down a little bit #*2rther, there 23 is a sentence that states: 24 "When cables are air-dropped, there is no 25 assurance that cable separation or orientation will be w________
77,314 1 maintained." 2 Do you see that sentence, Mr. Vogelsang? 3 A Yes, sir. 4 Q First, can you explain to me what air-dropped \\ 5 cabics are? 6 A Yes, sir. An air-dropped cable is a cable 7 that is just contained in free air space. It's not in any 8 type of raceway. It would be a transition, possibly, 9 between a tray and a piece of equipment, a tray and a 10 conduit, or something of that nature. 11 Q In other words, it would not be protected 12 by either conduit or a tray. 13 A It would be in free air. It would have no 14 protection, yes, sir. j 15 Q Now, after the sentence that I just read you, 16 I will continue reading the next sentence after that, which 17 is: 18 "Thus, effectiveness of the conduit as a 19 barrier may be compromised." 2 Do you see that sentence? 21 A Yes, sir. 22 O Okay. Now, can you explain how effectiveness 23 of a conduit as a barrier may be compromised as a result 24 of a cable being air-dropped? 25 A Yes, sir.
77,315 1 Q Please go ahead. 2 A An air-dropped cable, if it doesn't have 3 adequate separation from adjacent raceway, can move and 4 actually ccme in contact with that adjacent raceway. 5 The Reg Guide 1.75 clearly states that a 6 minimum of one inch must always be maintained between 7 redundant, safety-related raceways and between safety-related 8 raceways and non 1-E raceways, so a cable in free air could 9 come in and violate that minimum separation distance,'thus 10 compromising the effectiveness of the barrier. 11 O okay. Let us suppose that a cable, a bare 12 cable, an air-dropped cable or a section of a cable came 13 into contact with a conduit, would that by its-- other than 14 the fact that a separation criteria may be violated, is 16 there any safety hazard from that? 16 A It would be a direct' violation-- I guess-- t 17 If that cable and the conduit were redundant trains or a 18 safety train and a non 1-E cable or conduit, we would-- 19 that would be in direct violation tf the Reg Guide 1.75 20 It would be in violation of ES-100. And that would compro-21 mise the safety, yes, sir. 22 O okay. Mr. Vog ' sang, what I'm trying to 23 get at is the fact that there is-- Presumably, the separa-24 tion criteria in the Reg Guide had some underlying reason 25 or purpose, and what I'm trying to establish is that if the l
77,316 I separation criteria were violated with regards to an air-2 dropped cable and a conduit, what would be the actual-- 3 is there a safety reason that-- such that you may have 4 some sort of hazard in that fashion? 5 A The Reg Guide specifically states that the 6 absolute minimum clearance between redundant train cables 7 and between train cables and non 1-E cables is one inch, 8 so anytime I violate that in the plant in my raceway system, 9 I am in violation of the Reg Guide. So, it does have 10 safety implications. Even though a cable is air-dropped, 11 air is considered the raceway. 12 O And_what would be the safety implications 13 that you're referring to? 14 A The minimum separation criteria is developed 15 where the one inch is a minimum separation criteria. That 16 has been developed that you have excluded external items l 17 from the plant, high energy equipment, things of this i l 18 nature. So, the only thing that you are protecting against, 19 or what you're really looking out for, is the fire within, 20 a failure in one of the trays, one of the raceways that's 21 going to cause the cables to burn or something of that nature. 22 So, you are protecting against the fire 23 within. 24 O
- Okay, 25 One final cuestion before we leave this area.
i
77,317 I 1 A Yes, sir. I 2 Q I assume-- I t-ake that back. 3 Are you familiar with Reg Guide 2.75? 4 A. Yes,' sir. 5 0 Were you given to understand the reason for 6 the separation criteria set forth in the Reg Guide? 7 A I don't understand that question. 8 Q Okay. Do you know whether there are reasons 9 for the separation criteria in the Reg Guide? 10 A Yes, sir. 11 Q Okay. One of them would be fire protection, 12 prevention of fire in one cable being-- affecting another 13 cable tray. 14 A Yes. 15 Q Okay. Are there any other reasons? 16 A Yes. 17 O And what are they, to the best of your 18 knowledge? 19 A The separation in general plant area takes Al several things into consideration. One of them is obviously 21 because of-fire. Another one is because of high energy, 22 rotating equiprrnt. Another would be because of high energy 23 power cables. Another would be because of high pressure 24 pipes. 25 So, it takes in account a lot of things that ______________m
77,318 1 could damage the cable system. 2 0 .Thank you very much. 3 A Yes, sir. 4' O Now, I think'the remainder of my questions 5 are going to focus on the ferro-resonant transformer'situa-6 tion. 7 To the best of your knowledge, is there a 8 procedure at the plant for startup organization to report 9 trends of failure to engineering for review? 10 A Yes, sir. 11 Q And could you identify that procedure? 12 A No, sir. I'm just-- I'm aware that it's 13 reported to us and it's by their procedures. 14 Q Okay. Thank you. 15 Now, is there a site procedure that governs 16 the writing of potential 50.55 (e) reports? 17 A Yes, sir. IB Q And could you identify that procedure? 19 A Yes, sir. It's CPEP 16.3, I believe. 2 MR..DAVIDSON: Mr. Mizuno, you know I've been 21 regularly impressed by the ability of individuals that we've 1 22 examined here to recollect the identity numbers of. proc.aures. 23 I had given some thought _to objecting to that,. 24 but I see that that will not be necessary. 25 // ___.______________________.___m____--_____
~1 2 i 77,319 j 1 BY MR. MIZUNO: 2 O Now, this same procedure that governs the 3 writing of 50.55(e) reports, does this aoply only to the t 4 electrical area? 5 A No, sir.. 6 Q Okay. Does it_ set forth the criteria for 7 evaluating whether a 50.55 (e) - report or a potential 50.55 (e) 8 report should be written or not? 9 A Yes, sir. 10 Q Okay. Now, I will-- One more question. 11 I assume you're familiar with that procedure? 12 A Yes, sir. 13 O Could you please turn to Camp Exhibit 5? 14 (The document referred to was placed before 15 the witness.) 16 Contine my questions to the cover office 17 memorandum on Camp 4 18 MR. DAVIDSON: I think that's camp 5, sir. 19 MR. MIZUNO: Camp 5. Thank you. l 2 O (Continuing) And I draw your attention to 21 the last paragraph, which consists of one sentence, which 22 states: 23 "Please evaluate these failures and provide 24 a description of corrective actions that should be taken 25 to mitigate or reduce reoccurrence."
t 77,320 ~ 1 Do you see that sentence? 2 A Yes, sir. 3 O okay. Before I ask you a question about this, did you receive this-memorandum in the course of your 4 5 business? 6 A Yes. 7 Q And you reviewed this memorandum. 8 A Yes. 9 O Okay. Does this last sentence preclude the 10 writing of a 50.55 (e) report? 11 A No. 12 O Q Does anything else in the memo preclude 13 writing of a 50.55(e) report? 14 A No. 15 Q Okay. In that last sentence, it states that: 16 "Please evaluate these failures and provide 17 a description of corrective actions that should be taken..." 18 Would a person aware of the site procedures 19 for governing the writing of 50.55(e) reports interpret { 1 20 this sentence ac-- .as a direction to consider-writing of ' l 21 a 55(e) report as a possible corrective action? i 22 A Yes. 23 Q To consider it' 1 24 A No. %5 Q "No", okay, l I __________o
77,321 1 MR. ROISMAN: Objection. 2 (Pause.) 3 MR. ROISMAN: I just noted the objection. 4 Sorry. 5 MR. MIZUNO: It was answered. 6 BY MR. MIZUNO: 7 Q Okay. Let's turn to Vogelsang 3 8 MR. DAVIDSON: Vogelsang 2-- 9 THE WITNESS: Three. 10 MR. DAVIDSON: I'm.sorry. Did you say 37 11 BY MR. MIZUNO: 12 g red just like you to turn to the second page 13 of that, which is, I believe, a letter on Westinghouse 14 letterhead? 15 A Yes, sir. 16 Q And I'd just like to have you define what 17 "hi-pot" is. i 1 } l A Hi-pot is a high potentical voltage' test 18 I i 19 that you run on a davice to determine what its insulation 1 i N resistance is. This gives you an indication of how good 21 of an insulator it is. 22 0 Okay. Thank you. 23 I believe you also indi-- Well, would 24 hi-potting be an appropriate test to determine the degrada-25 tion of a ferro-resonant transformer over time due to i 4 l
1 mechanical obregion of tha inculation? 2 A No, sir. 3 Q And why is that? I 4 A When hi-potting equipment, you can't really-- 5 The results of a'hi-pot are such that unless you have a 6 lot of background data over a long period of time, years 7 of hi-potting and testing, you can't really compare one l 5 8 to the other because the relative humidity, the temperature, l 9 there are a lot of variables that take in effect that will-- 10 can affect the results you reach on a hi-pot test. 11 Q Okay. Now, I will draw your attention to a 12 sentence which states: 4 13 "You are aware that of Texas k. 14 Utilities per telecon 12/16/83 questioned whether or not 15 the new unused ferros should be high potted at a higher 16 level?" i 17 j Do you see that? 18 I A Yes, sir. 3 I 19 Q Now, because the sentence is ambiguous, I'm t j 20 going to ask you whether you were aware at the time that 3 21 this letter was written that had questioned t _,.t-22 whether or not new unused ferros should be high potted at i 23 a higher level? 24 A No, sir. C 1984, " 25 O So, as of January 3rd, had '\\ ) 1
.77,323 1 not told you that he had done so, that'he had made this O-2 telephone call. 3 A That's correct. 4 Q Okay. Now, I will draw your attention to the 5 last sentence there, which says: 6 "We request the result data taken b} 7 be supplied when available." 8 Do you see that sentence? 9 A Yes, sir. 10 0 Were hi-pot tests performed on the ferro-11 resonant transformers at Comanche Peak? 12 A Yes, sir. g 13 O Were those tests performed after your receipt 14 of this memo-- or this letter? 15 A Yes, sir. 16 Q Were those tests done at your direction? 17 A I don't understand that question. 18 O Okay. Did you authori::e those tests? Or 19 did you ask somebody to perform them? 20 A I asked somebody to help perform them, yes, 21 sir. l 22 1 Q Do you know whether those tests were completed 1 23 A Yes, sir. I 24 O O And how do you know that? 25 A The raw data was given back to me.
77,324 l l 1 O And who gave you that: raw data? 2 A Fred Hunstable. 3 0 Hunstable? 4 A Hunstable. 5 O When did you request that those-tests be 6 done? 7 .A This was after'I had reveiwed.the Westinghouse 8 memo. Or, again, part of our evaluation during evaluation 9 stage to determine if it was a reportable. 10 0 Okay. Well, do you recall.when you received-11 this-- Oh, you do recall when you received this. 12 A Yes. 13 O And that date was, I believe, the 18th of 14 January 19847 15 MR. ROISMAN: 16th, I believe. 16 MR. DAVIDSON: I think Mr. Roisman's correct. I 17 I THE WITNESS: Mr. Davidson-- k { 18 I MR. DAVIDSON: Do you wish to speak with me' J 19 THE WITNESS: I'm not for sure. 20 MR..DAVIDSON: Will you excuse us? 21 (Conference between the witness and counsel 22 for the *pplicant.) 23 MR. DAVIDSON: Mr. Mizuno, Mr. Vogelsang 24 says to me that while he understands the date, he's not 25 sure which document you're asking him that he received on i
=77,32511 + 1
- that datei 2,
MRi t MIZUNO: JYes,LI! realize that. 3' 'MR.-DAVIDSON: That:was,hisiquestionLtc me.1 .' 4 : .He said, "hhich.' document.t is he as'ki'nglme'about?"' 5
- And'I said, "Well,'I think1we better have 6
Mr. Mizuno' form the question'and:telliyouLwhat he was- -7 referring'to, rather than have you try to, guess."' B '. MR.~MIZUNO: Let me~ withdraw that. question? 9 so I can restate it-more1 clearly.. 10 BY MR. MIZUNO:- 11 0 I believe you testified'that you. received the-12 . document which-has been labeled Vogelsang 3 onLtheL16th of-13
- January, 14 A'
Yes, sir. 15 0 And-that' document. includes ~this~ Westinghouse- ~ 16 letter. 17 A Yes, sir. 18 Q. Did you-review it onLthat.date?~ 19 A. Yes, sir. 20 0 Do you recall what period of time' elapsed 21 between the time you. reviewed this letter and'the. time thatl .] 22 you directed that the hi-pot test on the; ferro-:.dsonant 23 - transformers'be performed? 241 A Yes, sir. M Q And what period of' time was that? o n
77,336 j 1 A It was within about two days. 2 O And relative to the time that you authorized 3 the test be conducted, when did you receive the test results 4 back from Mr. Hunstable, I believe it was? 5 MR. DAVIDSON: I'm going to object to the 6 form of that question. I don't think you meant "with 7 relation to when he asked". You really want to know what 8 time elapsed between the time he commissioned that test andL 9 the time he received the results. 10 If you'll accept that amendment, I think 11 Mr. Vogelsang can answer the question. 12 MR. MIZUNO: Yes. 13 A (By the witness) I received the results 14 either on January the 31st or February the 2nd, 1984. 15 0 Were the results considered by you in-- 16 when you were preparing the document which has been labeled 17 Vogelsang Exhibit 4? 18 A Yes, sir. 4 i 19 Q Now, leaving that area and moving on to the 3) NOTEPAD. I believe you indicated that NOTEPAD was a computer k 21 system that allows all nuclear power sites to generate l 22 inquiries and to have remaining nuclear sites respond to 23 that inquiry. l 24 If that is not an accurate statement of what j 25 NOTEPAD is, can you provide your explanation of what NOTEPAD i l j
j 77,327; 1 1 is? 2 MR. DAVIDSON: I'm going to object to the s 3 form of that question. I think, perhaps, what you really 4 mean to ask is: What is NOTEPAD? 5 If that's the question, I think the witness 6 should~ answer it. 7 Is that the question, Mr. Mizuno? 8 MR. MIZUNO: Well, the way I originally 9 phrased it, I was trying to have him refresh his recollection 10 of what he stated. 11 MR. DAVIDSON: The best way.for him to 12 refresh your recollection as to what NOTEPAD is is to have 13 him.tell you what NOTEPAD is, as he understands. 14 I think that's the way to ask the question. 15 One of the problems we've had during many of these examinations is the attempt by the examiner.to 16 17 rephrase, characterize, summarize, or otherwise put together i 18 testimony previously in the record as a predicate for i 19 questions. And that often leads to confusion, makes for l 20 long questions, and simetimes, through inadvertence or 21 otherwise, the summaries or characterizations are' inaccurate. 22 It's.better if'ynn have a' direct question 23 to ask it that way. { 24 MR. ROISMAN: I think the concern is always 1 l 25 the " asked and answered", but I would hope that we have a l
4 77,328 j 1 1 gentleman's agreement,.given.that we ran that deposition j 2 last night until 12:30,'that not any.of us are sure either i 3 what was asked or what was answered and that there'll be a l 4 certain leeway in allowing " asked", even though it may, 5 in fact, have been asked before.- 6 MR. DAVIDSON: I take it, then, that Mr. 7 Roisman is saying that he recollects this question was 8 asked and was answered. 9 MR. ROISMAN: I think it was, but if I were 10 put under' oath, I'm not sure I could tell you what I thought 11 was asked, much less what I thought was answered. 12 MR. DAVIDSON: Mr. Roisman, I-- 13 MR. ROISMAN: And I think'it's a good way 14 for Mr. Mizuno to make sure he's got the predicate right 15 to a series of questions. 16 But as long as it's not done excessively, j 17 I would hope that neither of us would raise the " asked and i i 18 answered". l 19 MR. DAVIDSON: Exactly. I wasn't, in fact, j i i N raising the " asked and answered" objection,-- 21 MR. ROISMAN: No, no. I know you weren't. l 22 MR. DAVIDSON: --and didn't intend, although 23 I recognize that it might have been appropriate here. 24 No, I do want you to ask the question. I 25 just want you to make it a simple question, so that Mr. i l _______________--Q
j 77,330 dj 1 d 1 . operating nuclear: sites? U 2 A~ I' don't understand that question. 1 '3 Q .I believe that you' testified yesterday that that(T-l 4 you found out that-- 'had made:aniinquiry-5 on NOTEPAD about the- - aboutLferro-resonant transformers;. 6 is-that-true? 7-AL Yes, sir. 8 0 .Okay. When did you-- When-did that 9 conversation with 'take place? '10 MR. DAVIDSON: .I'm going to-object. That 11 isn't the testimony that you just' summarized. 12 MR. MIZUNO:.Right. / 13 BY MR. MIZUNO:- r 14 Q When idd you find out:that ad _m 15 used NOTEPAD to inquire about ferro-resonant transformers? 16 A I heard sometime in. September Iha had 17 used NOTEPAD or was considering to.use. NOTEPAD. I never 18 saw the results of any data that,he might-have gathered ~ 19 from NOTEPAD. 20 Q This was September of!19837. 21 A Yes,. sir. 22 0 And this would be prior;to your receipt or 23 Vogelsang 3. 24 A Yes, sir. .O 2$ Q Okay. Now, during that Septembe'r~'83 time
77,331 r' I frame, which was when you found out thatq _. had 2 considered using or had'used NOTEPAD to ask about ferro-I 3 resonant transformers, in your mind did you think that the l l 4 ferro-resonant transformer situations that you had uncovered 5 at Comanche Peak might be generic, in other words,. applicable l 6 I, to other operating plants? 7 MR. DAVIDSON: I'm sorry, Mr. Mizuno, I o 8 didn't hear the question. Could you repeat it for me? 9 MR. MIZUNO: Yes. 10 BY MR. MIZUNO: I 11 0 During the September 1983 time frame, had 12 you come to a conclusion with regards to the generic nature g{ 13 of the, and I will say, problem with the ferro-resonant 14 transformers? 15 MR. DAVIDSON: I object to the form of the 16 question, but you may answer it if you un-erstand it, Mr. } 17 Vogelsang. i 18 THE WITNESS: I don't understand the question. 19 BY MR. MIZUNO: I 20 0 I believe you testified you were-- you 21 understood from the-- I From the approximate time that the 22 failures of the first i two ferro-resonant transformers at 23 Comanche occurred that other operating nuclear power plants 24 used similar ferro-resonant transformers; isn't that true? k 2 MR. DAVIDSON: Mr. Mizuno, I don't think
77-329 ~ 1 Vogelsang can give you your answer and you can go ahead with. 2 whatever you need to do. 3 MR. MIZUNO: All right. Mr. Roisman was ) 4 correct in that I was merely asking the question to-- I as 5 a predicate for asking several questions based on NOTEPAD,-- 6-MR. DAVIDSON: Sure. 7 MR. MIZUNO: --and my concern was the " asked 8 and answered" objection. 9 MR. DAVIDSON: Fine. Why don't you do that. I 10 MR. MIZUNO: Yes, I will. i l 11 BY MR. MIZUNO: 12 0 Mr. Vogelsang, what is NOTEPAD? g 13 A NOTEPAD is a service that operating nuclear 14 plants can subscribe to where if they have questions of any 15 type, they can put it up on a wire service, and they get 16 a response from some of the different plants within a couple 17 of weeks. Or depending on the type of information that's 18 available. 19 0 Did tell you that he was oing 20 to use NOTEPAD.about the operating history of ferro-21 resonant transforme:ts at other operating nuclear sites? 22 A No sir. i 23 0 when did it first come to your attention 24 that had used NOTEPAD to inquire about the e 25 operating history of ferro-resonant transformers at other 1 l
77,332 1 that's an accurate characterization of his testimony. 2 What is it you're trying to ask? 3 MR. MIZUNO: I'm asking him whether he knows 4 whether these ferro-resonant transformers were used at 5 other plants at whatever time' prior to Setpember of 1983. 6 And I believe he indicated that he did have 7 that knowledge when-- as early as when the problem first-- 8 you know, the ferro-resonant transformer failures at 9 Comanche Peak first came to his attention. 10 In other words,.it wasn't-- The. fact that 11 these transformers were-- 12 MR. IAVIDSON: Let me just point out to you-13 Number one, it wasn't after the two failures. 14 It was a notation of a trend, which would be after the 15 third failure. 16 And a trend memo, which was marked here i 17 as Camp Exhibit, I believe-- Well, I don't have the exact 18 number. But it was a May 31 memorandum, which he testified I 19 he received in early June. i I N So, that would be the first time that issue l 21 came up. So, that would be one place where your summariza-22 tion of his testimony isn't accurate. Tr : re are a couple 23 of others. 24 I don't want to get into a debate about l 25 what was testified. We've got a whole record here. l I
77,333 1 MR. MIZUNO: I'll withdraw the question. 2 MR. DAVIDSON: The question has, in fact, 3 been asked. 4 MR. MIZUNO:' I'll withdraw the question. S' MR. DAVIDSON:- But if there something you 6 want to get, I want to make sure'you get it. 7 It's just that I really have a problem when 8 you-- 9 MR. MIZUNO: Okay. 10 MR. DAVIDSON: --especially since we all do have some difficulty remembering what.the testimony was. 11 12 The more you summarize it, the more there are going to be problems with the kind of questions you are'asking-- 13 14 MR. MIZUNO: Fine. 15 MR. DAVIDSON: --the more there are going 16 to be form objections. 17 MR. MIZUNO: Mr. Davidson, I withdrew the i IB question. I will ask it in another fashion. 19 MR. DAVIDSON: Thank you. 20 BY MR. MIZUNO: 21 O Okay. Mr. Vogelsang, when did you become-- 22 At the time that you had reviewed Camp Exhibit 5, was it 23 your belief that ferro-resonant transformers and Westinghouse 24 inverters were used at other nuclear power plants? 25 Operating nuclear power plants.
77,334 1 1 i i 1 MR. DAVIDSON: -Mr. Mizuno, when you refer j 2 to Camp Exhibit 5, you refer to the May 31 memorandum from 3 Mr. Camp addressed-to Mr. McBay, regarding the notation of 4 a possible trend? 5 The question is, Mr. Vogelsang,-- 6 THE WITNESS: No, sir. 7 MR. DAVIDSON: --were you aware at the time 8 you received that memorandum that these ferro-resonant 9 transformers were in use at other nuclear installations? 10 Is that correct? 11 MR. MIZUNO: No, sir. 12 .BY MR. MIZUNO: 13 0 When did you first come to understand'that 14 these transformers and inverters were used at other 15 operating power plants? 16 A When I received the Ray Moller memo. 17 O And which Ray Moller memo is that? Before I 18 you go on. 19 (Document placed before the witness.) 20 Mr. Vogelsang, is that the Ray Moller memo 21 you were referring to? Camp Exhibit 7? 22 A Yes, sir, Camp Exhibit 7 23 MR. DAVIDSON: That is the July memorandum 24 from Mr. Vogelsang to Mr. Moller; is that right, Mr. Mizuno? 2 MR. MIZUNO: Yes.
77,335' 1 BY MR. MIZUNO: 2 Q. Okay. At the time that you became aware that 3 ferro-resonant transformers and Westinghouse inverters were 4 in use at other operating plants, did you have any opinion 5 as to whether the problem at Comanche Peak might be a 6 generic one? 7 A I don't understand that question. 8 O Okay. Do you think that at the time that 9 you reviewed Camp Exhibit 7, once you had finished reviewing to that, did you believe that there may-- that the ferro-11 resonant transformers and the Westinghouse inverters, which were the same as those being used at Comanche Peak, may also 12 13 be subject to the-- to a possible problem-- 14 MR. DAVIDSON: I'm going to object to that 15 question, Mizuno-- Mr. Mizuno, because last night in Mr. 16 Roisman's cross-examination, he asked exactly the same l 17 question. He asked, "Did you have an opinion at that time?" 18 The witness said, "No." 19 And based on the statement in the Moller 20 memorandum, he said, "They'd been proven in operation. So, l that time he didn't have information as to whether or.not 21 at 22 it was likely generic.'" 23 MR. MIZUNO: I think-- That was my problem j 24 with that. There is a difference between not believing that 25 it was a problem, which is a fine answer, or saying-- having -t w__--___-__.__.___
77,336 1 no opinion because you don't have any basis for saying it, 2 which is also a fine answer. 3 But I wasn't exactly sure which it was. 4 MR. DAVIDSON: No, Mr..Mizuno. In fact, 5 Mr. Roisman asked him what he meant by that, and Mr. Vogel-6 sang said: When an engineer develops an opinion, he has 7 to have a factual basis and derive a logical conclusion from 8 that factual basis to formulate an opinion. 9 He said that he didn't have the facts 10 necessary to make a logical conclusion for him to develop 11 an opinion as to whether it was a likely 50.55(e) situation, 12 In fact, I think he may have testified that 13 based on the statements Mr. Moller made he thought perhaps 14 it wouldn't be, but that he didn't have enough information 15 to draw a conclusion one way or the other. I think that 16 was his testimony, Mr. Roisman, in response to your questions 17 because you went through this quite carefully. i 18 i MR. MTf,UNO: Well, I still want-- g 19 MR. DAVIDSON: I don't want to argue, Mr. M Mizuno. Please go ahead. i 21 MR. MIZUNO: --want him to answer that ques-22 tion. Or at least to clarify his answer. He did give 23 an answer, and I want him to clarify whether it was one or 24 the other. 25 And if you would want him to summarize what ___..-_.____.._-_____._.._____a
- l 37,33.7L
.\\ 1 I-believe,I-~ ~well, what.the:two alternatives;may be'-- 2 MR. DAVIDSON: Why' don't. youask the questi' n.. o -3 again so that the witness will:have it,' fresh'in..his. mind,. 4 and then maybe he'can1 answer. J 5.- MR.~MIZUNO: :. Fine.- .6 BY-MR. MIZUNO: 7' .Q-Mr. Vogelsang,.at the' time;.that;you received 8 and. reviewed Camp Exhibit 7, did' you,have an~ opinion.as-to' 9 whether..the failures.with ferro-resonant transformers andL 10 Westinghouse inverters could also occur in other operating 11 nuclear plants that use:.these same transformers and. invertersi 12 A Yes,:si'r. 13: O And what was'that opinion? 14 A I felt that- ' My. opinion'was that it:was~ 16-probably what we had'done at Comanche Peak, that this was.- 16 unique 1to Comanche Peak. 17 Q "Probably" or you're not quite sure?- 18 A Probably. .i 19 Q So, it was unclear in your, mind. 20 A No, sir. 21 -Q Okay. 1 L 22 'g You indicated-that'it would-. that the failure of"ferro-resonant transformers ~in Westinghouse-23 24' inverters was probably not a-problem atlother coerating 25. nuclear power plants; is that true? I just heard you say- ^ - ^ ^ ^ ^
77,338 l 1 that. 2 MR. DAVIDSON: I think you've taken his 3 remark out of the line of questioning in which it was made, 4 Mr. Mizuno. What is the purpose of that question? 5 MR.lMIZUNO: I'm trying to determine whether 6 he had a-- Again, same thing. Whether he had a definite 7 opinion that it was not a problem or whether he had not 8 basis. 9 I asked him the question again, and he answered 10 it by saying-- Do you have an opinion? Yes. 11 And then I asked him what that opinion was. 12 And he said that it was probably not a problem. 13 And I just wanted to make sure that that's 14 what he meant. Because, as I. understand it, you indicated 15 that last night, his question to a similar-- his answer to l 16 a similar question was that he had no basis for forming an 17 opinion one way or the other. I 18 NR. DAVIDSON: That is correct, he did say l i 19 that. But what he said was that based on what he had learned i 20 from the Moller memorandum, he thought it more likely that i 21 it wasn't a generic problem, but he didn't form an opinion 9' about it. 23 Because Mr. Vogelsand made plain that for 1 24 an electrical engineer, he 'd have to have a factual basis 25 so be can draw a logical conclusion in order to formulate
77,339 1 an opinion. 2 To me, his testimony is entirely consistent. 3 What he's saying is that he didn't have the factual basis to develop an opinion one way or the other but that he did 4 5 think that it probably wasn't, but that wasn't, in his view, 6 a formal opinion. 7 That's all he's saying. Now, is that the 8 problem? 9 MR. MIZUNO: Well, Mr. Davidson, I think to we'll just mov-2 on here. I think we're just arguing. 11 MR. DAVIDSON: No, don't move on if you feel 12 that you want to ask more questions of the witness. I just 13 don't understand what the problem is. 14 MR MIZUNO: I'm going to ask more questions. 15 I think, at this point, we're just arguing about whether I ( Mr. Vogelsang's answers are consistent or not. i 16 17 MR. DAVIDSON: We are not arguing and there i is no question about consistency. The problem I'm having i { 18 is with the questions you're asking because you continue to 19 summarize the testimony and characterize it, and you don't 20 21 ask a direct question of my witness. And.he's having diffi-22 culty answering you. 23 I'm trying to see to it that you get a full l and clear explanation in response to each of your questions. 24 25 And you're suggesting that you cannot defer i l I t-i
77,340 ( forming an opinion on something and yet have a feeling 1 2 about it. And I think that's the problem. 3 MR. MIZUNO: Mr. Davidson, that is precisely 4 what I meant by argument as to the sub-- as to how you 5 should interpret Mr. Vogelsang's answers. 6 MR. DAVIDSON: All right. Mr. Mizuno, please 7 ask the question of Mr. Vogelsang. I'm sorry I interrupted 8 you. .I'm sorry you feel we're arguing about it. I didn't 9 mean to do that. I thought the witness was having difficulty 10 answering the question. Perhaps he isn't. 11 Why don't.you continue and re-ask the question 12 that you left off with, and let's finish up and make sure that you get all the questions you want answered. I want 13 14 you to have all the answers. I want you to have the record 15 that you want. 16 Please, don't take it any other way. I'm just trying to make certain that my witness understands what's1 17 going on, so that his questions are responsive. 18 19 MR. MIZUNO: Yes, I understand that. 20 MR. DAVIDSON: So, please ask the question 21 again. J t 22 MR. MIZUNO: No, I'm not going to ask that 'I 23 question again. I withdraw that question. 24 However, I will continue on the line. 25 // I l
77,341 1 BY MR. MIZUNO: 2 Q Mr. Vogelsang, in your opinico, would an 3 inquiry through NOTEPAD obtain information which would help 4 determine whether the failure with ferro-resonant transformers 5 in Westinghouse inverters was or was not a generic problem 6 at other operating nuclear power plants? 7 A No, sir. 8 O And why is that? 9 A Westinghouse had advised me in their memo 10 that they had operating experience on the inverters with the 11 ferro-resonant transformers in-them and that they had a low 12 failure rate and that there was nothing that indicated that 13 it something that happened at Comanche Peak. 14 MR. DAVIDSON: Mr. Vogelsang,,now I'm going 15 to have to tell you to listen to the questions carefully. 16 That's not what Mr. MIzuno asked you, although that is an 17 answer, certainly. 18 What he asked you was, basically, sort of a 19 general question. He didn't ask whether, based on this 20 memorandum, you felt that you should then go to NOTEPAD. I 21 That is, Camp 7 Exhibit. 1 22 Whr' he asked you was: Do you think that an 23 inquiry on NOTEPAD would have produced information that 24 could have been helpful in determining whether or not the 25 failure of the ferro-resonant transformers was generic? i j }
77,342 1 A (:By the witness) No, sir. 2 MR. DAVIDSON: All right. That's your answer. 3 MR. MIZUNO: Okay. 4 BY MR. MIZUNO: s O And you say that it would not--- I would like 6 to-- And I believe you explained the basis for your answer 7 earlier? 8 A Yes, sir. 9 (Conference between the witness and counsel 10 for' Applicants.) 11 Q Do you believe-- Oh, escuse me. 12 (Continuation of conference. ) 13 MR. DAVIDSON: Mr. Mizuno, please continue. 14 MR. ROISMAN: I'm a little concerned about 15 the condition of the record at this point. 16 I believe that the last question that Mr. 17 Mizuno asked-- the next to the last question that Mr. i i 18 j Mizuno asked, the witness gave an answer, gave it to him, j 19 and Davidson indicated that he thought the answer was not l 20 responsive to the question. 21 Mr. Mizuno then asked a different question, 22 which was a yes-no question. I think it was two questions 1 earlier, which the witness again answered directly. 23 24 And it is now on the record that the question 25 which Mr. Mizuno asked which Mr. Vogelsang's counsel says l l'
s 77,343 i l ~ l 1 the answer is not responsive. 2 Now, if Mr. Mizuno is satisfied he did not 3 have a responsive answer, but we now have what I would call 4 conclusive proof that the witness didn't give a responsive l 5 answer because his counsel said he hadn't. And I just don't 6 want to let the record alone. l 7 I f Mr. Mizuno wants a responsive answer to l 8 that question, I think he ought to ask the question again. 9 MR. DAVIDSON: That is the reason that I 10 suggested that it was not responsive to his questions because 11 I didn't feel that he had given you the answer-- 12 I didn't think that he had understood exactly 13 what you had asked. And, therefore, I tried to explain it 14 to him to get a responsive answer. 15 But instead of following up on it, Mr. Mizuno, 16 as Mr. Roisman points out, you went elsewhere. And that 1 17 may have also further confused the witness. ( i You may want to just back up, and I don't l 18 19 think anybody's going to object if you do, and go through 20 those two or three questions again with the hope that we 21 can get the information and answers that are responsive ~ 22 and that you want. I 23 MR. ROISMAN: .I think the question that's k 24 waiting is the answer to the question: Why? l l 25 MR. DAVIDSON: I agree with you, Mr. Roisman, i l l
- a L77,344; 1
1 That's the question you'di ike tolgetfanswered. That's. l L 2 theLguestion I'd like to'get answered. ~ 3 MR.'ROISMAN: No, no,'no. I':mean, I-lj ust : .) '4 thought the record wa's unclear.- 5 MR. DAVIDSON: And that's the question'IL 6 thought Mr. Mizuno was; going to ask. 7 'But, apparently,' at1this point, he:doesn't 8 wish.to. .9 But if you do wish to and you want to'go {' 10 j back, Mr. Mizuno, I think Mr.-Roisman and I are bothLinviting 11 you to do so. 12 BY MR. MIZUNO: 13 Q Well,ldo you remember my original question, 14 where I asked you-- 15 A (Whereupon,.the witness shook his. head 16 negatively.) i' -[ 17 MR. MIZUNO: I don't know whether.he under-- l 18 stands if I asked him why now-- -what I'm asking why;about. i 19 MR.!DAVIDSON:,No,-I.think_that's right, 20 Mr. Mizuno. 21 I really do think you have to-- .unfortunately 22 you have to back up. - You 're going to have t o ask the ques-2 tion. And' frankly, you'll prefer: the. transcript that~way-24 because then the question and your answer will follow each' 2 other, and the reader will not have to remember a page or 4 'l 1__.__________._-.--_._-!i--------- ~ ~ ~ _._o
- 77;345; 11 two'back.
Let's put it that way. 2 BY MR. MIZUNO: 3: -Q Let's just start'with my. original questio'n 4 .which.was: Would anfinquiry through!NOTEPND'possibly result i 'in obtainingTinformation which will- . And I'm' changing; my 5 6- . question a'little bit. 7 36R. DAVIDSON:. Phrase ' itu any 'way you wish,- 8 Mr'. Mizuno, so-long7as;it is.not objectionable. 9-BY MR. MIZUNO: 10 Q Would an inquiry through. NOTEPAD help one obtain information on the operating history'offferro-resonant 11 12 transformers at other ' nuclear power plants? 13 . A. Yes. 14 Q Do you believe'that-- 15 .MR. DAVIDSON: Excuse.me. Did you wish'to 16 say something, Mr. Vogelsang? Were 'you finished with 'your - 17 answer? Oh, you wish.to consult with. counsel?. 18 All right. I 19 (Consultation betw'een the witness and counsel i 20 for Applicants.) 1 l l 21 MR. DAVIDSON: Off the recordi- ] 22 (Discussion off the. record.)' <t 23 MR. MIZUNO:. 'Okay. On the record., .l, 24-MR. DAVIDSON': I suggest, Mr.'Mizuno,-if I-25 may, since we just had a break, that the Reporter read. i .!1 ____________.______LE..
77,346 1 back the last question and the last answer so that we will 2 all be back on train. 3 MR. MIZUNO: I think that's acceptable. 4 Madam Reporter, could you read back the 5 last quest' ion and answer that we had before the break? 6 (Whereupon, the record was read.) 7 BY MR. MIZUNO: 8 Q Do you believe that the information that a 9 person would obtain through the NOTEPAD system after putting 10 an inquiry on ferro-resonant transformers into the NOTEPAD 11 system, that that information would be more or less complete 12 than the information that may have been known to Westinghouse' 13 MR. DAVIDSON: Object to the form of the 14 question, but I direct the witness to answer it. 15 A (By the witness) I believe that information 16 might or might not have been helpful. Westinghouse would 17 know the operating history of their inverters. l 18 Q What is your belief for that statement? 19 And the statement I'm referring to is that Westinghouse f 1 would know the operating history of their transformers. m 21 Inverters, I'm sorry. 22 A The Westingbause inverter is part of their 23 scope of supply at all plants. Any time there's a failure 24 with their equipment, they are involved. So, Westinghouse mi 1 would have accurate records of operating history of their
77,347; 1 equipment. ~ 2 -g-Well, let'me.ask you:' What do you mean by ~~ 3 "theyLare involved"?. 4-MR. DAVIDSON:- In other words, he's asking, 5 Mr. Vogelsang, when youLsay that within'the scope of 6 their' purchase-- purchasing' cycle or obligation >and they 7 are involved. What do'you mean by " Westinghouse.is involved"W 8 A' (By the witness) In the. repair /and-procure-9 ment cycles of the inverters, the ferro-resonant-transformers 10 or whatever component'has failed,Lthat procurementLcycle l's-11 back through Westinghouse.- 12 O Well, do you normally indicate,to a. supplier 13 .why you are' ordering another component?' 14 MR. DAVIDSON: I think the - testimonyfis that 3 15 we're talking about an involvement by ordering another 16 component. He's' talking also about repair and corrective. q 17 action for a failure. 18 MR. MIZUNO: No,. :I'think-I heard'the witness-j 19 say.that because he meant involvement to be the fact that 1 2 Westinghouse was the supplier of these inverters =and.that, 21 therefore, when one purchases the inverter that they;are i A l 22 involved. i l l i 23 MR. DAVIDSON: No, that's not what hesaid. j l. 24 He said " procurement cycle"..But you haven't asked him,to 25 define what he means by " procurement cycle". d ] i*- 4
77,348 1 And I think you'll find that he's more.than 2 just buying.the goods. But I.think_that'sfa question you ~3 have to'ask. 4 -MR. MIZUNO:' N5,'I'm not~goingito ask11t in 'S that fashion. 6 'MR.'DAVIDSON:~ Why don't;you.try it[again .7- .and ask him what'he means:by " involved"? 8 BY'MR. MIZUNO: 9= Q Okay.;.What doLyou~mean by Westinghouse'being to involved? 11 A' Since an inverter is'part of the Westinghouse 12 scope of suppl.y of the N-SSS, they'are always--- they are 13 aware-- When there's a failure with one of their pieces. 14 of equipment, they are aware because they are responsible 15 for the whole program.of the N-SSS system. That isla piece of their equipment that's installed in the plant. 16 17 Q Let me' direct your attention to-Camp 7', 18 Camp' Exhibit 7, and I will _ ask you txt review the sentence ^ 19 that beging-- that states. 20 "Because this same style of invertor is'in t 21 use at many plants with much smaller failure rates, it'is, di 22 our feeling that there is something unique in'the way the ] t TBX invertors have been operated causing.the transformer. 23 24 failuce." ~ 25 Do you see that? l
-77,349 1 A Yes, sir. 2' .Q First I'd 'like'to'ask;you: Was' this the Iparticular sentence that you relled'upon or that'you_. read . 3' which first notified you that these inverters-were being. 4 5 used atLother plants,; operating nuclear' powerplants? 6-A Yes,Esir. .7 Q' Now,-doesn't the-Okay. Is1the samerferro - 8
- resonant transformer type--
By:" type", I meanLmodel number.' 9 --used in all' inverters-- all Westinghouse' inverters.which' 10 .the'ones' that failed at Comanche Peak?- 11 MR. DAVIDSON: Do you. understand-that question, 12 Mr. Vogelsang? 13 THE WITNESS: No, sir. 14 BY MR. MIZUNO: 15 Q Okay.- An inverter is-- I. don't want to call j 16 it a component, but-it is"a--- - 17 The inverter'consistsLof.various' components; 18 one of which is a ferro-resonant transformer, and there was ) 150 a particular model ofEinverter'that was used'at Comanche' i 20 - Peak. -21 A Yes, sir.
- )
22 Q Would various-- ;WouldLthe same ferro" -1 23 resonant transformer model be used in every. inverter;that i 24 was produced by Westinghouse.of this: type of~in,verter?- l i. J 25 A I don't know. l '.( i .i i _ - - _ _ --_ : LQ
77,350 1 Q So, there's a possibility.that different 2 kinds of-- or different models of ferro-resonant transformers 3 could have been used. 4 A Yes. 5 MR. ROISMAN: Let me just note my objection. 6 I think the witness's first statement was "I don't know". 7 The second question asked for what was obviously speculation, 8 and the answer was "Yes". And I just want to note that I 9 don't think that's good evidence. 10 MR. MIZUNO: Okay. 11 MR. DAVIDSON: I don't think it called for 12 speculation. I think the question, actually, was for the witness to draw a conclusion based on his prior answer,-and. 13 14 I think his conclusion is one either you or I could have 15 drawn because it was a logical one. 16 But I don't believe, in a sense, that it was _) 17 a statement about a factual condition, but I don't think 18 it was speculation either. It was merely a conclusion drawn 19 from the stated fact that there were possibly other ferro-20 resonant transformers, i 21 MR. ROISMAN: I thought it was speculative 22 in the sense that, with a few rare exceotions, normally 23 known to be only death and taxes, everything is possible. 24 In that sense, everybody in the world would have been able 25 to answer that question, irrespective of knowledge. i e
77,351 1 MR. DAVIDSON: I agree with you. That's what 2 I said. You or I or Mr. Mizuno could have drawn the same 3 conclusion based on that answer. Therefore, it wasn't 4 necessary to secure the answer from the witness, but I didn't 5 think it was speculation. 6
- BY MR. MIZUNO:
7 Q Okay. Now, reading this sentence, do you 8 believe that the Westinghouse surmise or feeling about the 9 failure of these particular inverters was that the problem was'due to the way the inverter was being used or the fact to 11 that a component within the inverter may have a problem? 12 MR. DAVIDSON: May I have the question 13 repeated, Mr. Mizuno, or have the Reporter reread it? I 14 didn't quite hear it all. 15 MR. MIZUNO: Can we have the Reporter reread 16 the question? { (Whereupon, the record was read.) l 17 9 18 MR. MIZUNO: I want we should go on the f 1 I l 19 record. 20 I'm going to withdraw that question and 21 request of the reporter and ask Mr. Vogelsang a dif ferent 22 question. 23 BY MR. MIZUNO: l 24 Q Is it fair to read this memorandum as stating 25 - that Westinghouse believed that the failure' of the TBX l l l
77,352 1 inverters at Comanche Peak was due to-- was probably due 2 to the way in which the inverters were operated? 3 MR. DAVIDSON: Objection. I don't think that 's. 4 a proper question. You can ask him what he concluded from 5 having read that. You can't ask him what Westinghouse 6 intended, and you can't ask what other people might have 7 thought or whether it is a fair reading, but only what'his .8 reading is. 9 MR. MIZUNO: I think it's acceptable to ask 10 him if it's a fair reading. 11 MR. DAVIDSON: No, no. You can ask him what 12 is his opinion of what it meant. 13 MR. MIZUNO: Okay. 14 MR. DAVIDSON: That is something he knows 15 about because that's his personal knowledge. 16 MR. MIZUNO: Well, I think it's-- l 17 MR. DAVIDSON: Whether or not it is a '\\ 18 fair reading is for someone else to decide. In fact, for 19 parhaps all of us to decide whether that is reasonable or 20 not. But that is not a proper question for the witness. 21 That is my objection. But if you wish the 22 question to stand, ask it and the witness will answer it 23 as best he can. I just think it is an objectior able question. 24 That's all. 25 MR. MIZUNO: Fine. _____________-__--------J
t77,353: 1 BY MR.' MIZUNO: 2 Q. Mr. Vogelsang,3will you answer.the question?- 3 A-I don't understandithe question. 4-Q- Okay. How did you-- 'Do you believe-that,- 5 after: reading this sentence,-that; Westinghouse felt 1or.had-6 a. feeling that the way:in' which'.the TBX inverters were1 used 7 at Comanche Peak was-the reason for their failure?' For the-' 8 transformer failure,'I should.say. 9 A~ It was'my opinion!that something'that we were -doing with the inverters at Comanche Peak had caused the 10 11 failure. 12 MR. DAVIDSON: Mr. Vogelsang,.that wasn't 13 the question. Perhaps you didn't understand it. p 4 14 I understood Mr. Mizuno,'what he was asking 2 15 you was: Based on reading.that: sentence,-was it your l [ 16 understanding that Westinghouse was suggestingfthat there. a; 17 _ as something wrong with the way-that'theLinverters were w i 18 being operated at-Comanche : Peak? I 19 That's what he was asking. Is that'not- ) i j 20 right, Mr. Mizuno? j 21 MR. MIZUNO: 'Yes. 22 THE WITNESS: He said "used" and--. I don't l l l L 23 understand the question. I l i 24 MR. DAVIDSON: Well, he-- You know,.you .) s broke it'up in a couple of spots, and-it made it difficult' 25 i .-m _x:----__-_--------
l 77,354 l 1 to follow, i k 2 When he does that, Mr. Vogelsang, normally 3 I would object. But I'm trying to let Mr. Mizuno get 4 through with his examination. 5 But if you don't understand the question, 6 I think Mr. Roisman told you this last night, and I just 7 want to repeat it, you should not try to answer it because 8 you may not give a responsive answer or it may not be an 9 answer that's correct merely because you're answering 10 something entirely different from that which was asked. 11 So, you have to listen carefrily to the 12 question, and if, having listened to it, you still don't 13 understand it, then you should say: I don't understand the 14 question, Mr. Mizuno. 15 5 Mr. Mizuno, you want to try again? j 16 BY MR. MIZUNO: 0 17 Q i Do you believe that Westino-- i l 18 i i MR. DAVIDSON: I'm sorry. I didn't mean to E i 19 interrupt you, but I was going to suggest if you have the 'I i 3) question reread-- { 21 MR. MIZUNO: No, I don't want to have the l 1 5 22 question reread. l l I 23 BY MR. MIZUNO: 24 O After reading the last sentence in Camp l Exhibit 7, was it your belief thet Westinghouse had the 25 r. I
l l 77,355 i I feeling that the way in which TBX inverters were being used 2 or operated at Comanche Peak contributed to the failure of 3 the ferro-resonant transformers in the inverter unit? 1 4 A Yes, sir. 1 5 o Okay. Do you believe-- Do you have an opinion 6 as to whether-- I take that back. 7 Would an inquiry through the NOTEPAD system 8 help you in obtaining information about-- I take that back. 9 When you found out that as 10 considering or had used the NOTEPAD system in inquiring into 11 ferro-resonant transformers, was it your understanding that 12 .had inquired, or was about to inquire, into the 13 operating history of the transformer itself or of the 14 inverter? 15 MR. DAVIDSON: I'm going to object to the 3 ] 16 form of the question, Mr. Mizuno. It's a little complicated. e 17 It's got several compoured predicates. l 18 i BY MR. MIZUNO: E 19 Q Okay. At the time that you-- l j 20 MR. MIZUNO: I It's a very complex question. 21 I have to get into the right time frame. ,1 l 22 0 MR. DAVIDSON: I understand. But one way 23 you might do that, and I d3n't mean to suggest a question I 24 to you, but one way you might do that, you could say: At 25 the time you stated that you learned sometime in September 1.
l 77,356 1 that Mr. Walter was considering using NOTEPAD or had, in 2 fact, begun using NOTEPAD? Did you know what use he was 3 making of that? I 4 MR. MIZUNO: No, that's-- that's-- That 5 wouldn't be a-- 6 MR. DAVIDSON:' Oh, sure, it would.- Because 7 then you'd get an answer, saying: I didn't know he was 8 making an inquiry about this or I was told he was doing that. i 9 And you'll find out what information he 1 l 10 was seeking. 11 MR. MIZUNO: Well, I' would like to go Q l 12 specifically to whether Mr. Vogelsang understood that Mr. l 13 was obtaining information about the operating history about the inverters or the ferro-resonant transformers. 14 .i 15 MR. DAVISON: Well, see, the problem is that -i e* i [ 16 we've already established that he has no personal knowledge 17 of wha was doing because he was never given any. l 18 He didn't speak with about it. He wasn't i given any information or results by He doesn't 19 i 20 know. This is hearsay. I ~ l 21 MR. ROISMAN: But it's certainly possible i j 22 for him to ask him: What did you learn for the purpose 23 of then judging his later conduct, and I think he already 24 did a moment ago, stated the question very clearly. 25 That's when you said: No, no, but that. _m.-_____
j. 77,357. ] I would then be asking him to-- he didn't.have any. personal 2 knowledge of something.- l I 3 But the question Geary stated was crystal l 4 clear, which was: From the information you had, did1you i f know whether'he was seeking this or whether he was seeking f 5 6 that. 7 MR. DAVIDSON: I think in the way in this l 8 Mr. Roisman's explained it to me, it is crystal clear. 9 When you learned that he was using NOTEPAD, 10 or considering its use, did you learn whether he was inquiring about the inverters or the. transformers? 11 12 I think that's a clear question. 13 MR. MIZUNO: Fine. That's a very clear 14 question. i 15 BY MR. MIZUNO: $j 16 Q Mr. Vogelsang, can you answer that question? 17 A Yes, sir, I can answer that question. l 5 1 18 O Will you do so? fi l 19 A The answer is no. -I 20 Q Okay. 21 MR. MIZUNO: Well, I think we've-- I guess -I'll end my cross-examination at this point. 22 23 MR. ROISMAN: I have a-- 24 MR. DAVIDSON: Mr. Roisman, do I understand { 25 you to say that you'd like to have recross?
77,358 1 MR. ROISMAN: I have a couple-- Well, I 2 don't know what you'd call it. It's cross based upon the 1 L 3 information elicited by Mr. Mizuno. I'm not sure what the 4 label for that is since we are tripartite. 5 But I understand you want to do-- if you 6 do redirect, it will be after Mr. Mizuno and I finish what 7 we are doing; is that right? 8 MR. DAVIDSON: Well, actually, I was going 9 to raise a question because I am less than familiar with 10 NRC procedure. 11 My understanding of procedure from other 12 tribunals before which I've appeared is that cross is 13 limited by the scope of the direct, and thet questions, therefore, suggested by someone else's cross are not proper 14 ,j 15 subjects of any further examination. And, thus, there 4 f 16 wouldn't be any recross or cross in seriatim. ) 1 17 In other words, the reason I think you i 1g were searching for a label is the same reason I would not ] 19 be able to supply, because I do not understand that to be I i I k, 20 appropriate procedure. i .r 21 But if I am advised that that is the way i 22 it is done at the NRC, I am perfectly prepared to go forward 23 with it. 24 MR. ROISMAN: It is. I think the problem 25 that we have is that the Staff is not either a part plaintift 4
E77,359 r-1 ' or a party defendant, necessarily. So that, we can't tell-2 whether what we'veljust heard was redirect orJrecross:or-3 a mixture. -4 I think Mr. Mizuno considers his responsibility t-5 to be " complete thelrecord" to get what he believes is1 the 6 full'information. 7 So, it-falls-Half of:it'could be. called 8 recross.by him'and; half of.itLeould be called redirect. 9 }UR..DAVIDSON: I-was, really,'merely raising-10 a question. And I don't have any objection.to.your doing. 11 it. I was really asking for some direction as to what'the ~ 12 proper procedure is. 1 13 Please go ahead, Mr. Roisman, and'then-I' l will wait for the end, and we'll take care-of the matters 14 15 that you and I discussed as. housekeeping details.' J g 16 MR. ROISMAN: ' Fine. 1 5 3 17 1 i ? FURTHER CROSS-EXAMINATION-l- i 7 l 18 BY MR. ROISMAN: ti g 19 Q Mr. Vogelsang, looking at Camp Exhibit 4, I -.c 20 .is it your reading of this document that Gibb's & i t. Hill. 3 is asserting that the portion of ES-100 that is in contro ' .I 21 22 versy is explicity authorized by Reg Guide 1.75 Lor.that il it; l \\ l-23 is not explicitly prohibited by. Reg Guide 1.75?' 1 24 MR. DAVIDSON: Mr. Roisman, wousld you, permit i i .i the witness to review the three-page letter that is-- 25 i .i j i I 4
77,360 1 MR. ROISMAN: Oh, absolutely. Yes. 2 MR. DAVIDSON: --the Gibbs & Hill response 3 before responding to your question? 4 MR. ROISMAN: -Yes, I certainly would want him 5 to. 6 (Review of documentation by the witness.) 7 A (By the witness) I don't understand that 8 question. 9 Q (By Mr. Roisman) The question is whether it to is your reading, or your understanding, of Camp Exhibit 4 11 that Gibbs & Hill is saying that ES-100's treatment of the 12 issue in controversy is explicity authorized by Reg Guide 13 1.75 or that it is saying that it is not explicitly pro-14 hibited by Regulatory Guide 1.75? j 15 A It's not explicity prohibited by the Reg 2 16 Guide 1.75 l 17 i j Q Thank you. I I a 18 i Just one other question on he document. I I i 19 on the bottom of page two of the' document, 5 [ M paragraph number 2, the concern expressed there about cables I { 21 which are air-dropped, and I believe the third to the last } 22 sentence says: l' 23 "When cables are air-dropped, there is no I i 24 assurance that cable separation or orientation will be 25 maintained." J e
77,361 1 Do you have that sentence in mind? 2 A Yes, sir. 3 Q Is it your understanding, either of ES-100 4 or Reg Guide 1.75, that one of the cures for that problem 5 when it exists is to increase the amount of separation 6 between the air-dropped cable and the conduit? 7 A Yes, sir. 8 Q Is it true that, depending upon the amount 9 of slack in the cable, one cannot say with certainty that to a given amount of separation will automatically. assure that 11 the cable cannot come in contact with the conduit? 12 A I don't understand the question. 13 0 Well, if the cable-- That, depending upon 14 how much slack, in other words, how much movement the air-15 dropped cable has, you'd have to know that factor before 2j 16 you could know what the definite separation distance was e 17 that would assure that the cable and the conduit could not i 18 come in contact with each other. t:j 19 A Yes, sir, i j 20 Q You indicated to Mr. Mizuno that you had, { 21 shortly after the 16th of January, had the hi-pot test run 22 on the ferro-resonant transformers. 23 My question is: Did you have them run at 24 the voltages that were recommended in the letter, which is l 25 the second page of Vogelsang Exhibit 3 in the last paragraph?
77,362 1 Particularly the next'to the'last. sentence ~ 1 2 A Yes, sir. 3 0 Why did you decide to-have the test run? 4 What did you. hope'to learn'from it? .5 A I1 felt that possibly-by reviewinggthe 6 insulation resistance of the. transformers that we might have 7 some'of them that.might have a: low insulation resistance, 8 or, in fact,..I. expected that we would see a low! insulation i ~ 9 resistance in-some of the transformers that we checked. 10 0 Please bear with me. :It is not automatically' 11 obvious to me what the relevance of low insulation:: resistance 12 meant. 13 Can you translate.it to the concern about 14 the failure? Does that mean that it would-be more likely. 15 or'less likely to fail?
- .j 16 A
By monitoring the leak rate current.during' 17 a hi-pot test, you can determine what the resistance between i l 18 the conductor and the transformer and ground'is. The i a i 19 higher the resistance, the smaller the leak l rate current,. i 2 the more insulation or.the better' insulating capability ~ 21 the insulator has. 22 So, by monitoring low hi-pot value, that 23 tells me that I don't have the insulation that I think-I' 24 have. 25 Q So, in other words, it might have been a-way ~ 8
__,-,,-----,----v-m 77,363] 1 for you to _ find out whether the ferro-resonant ' transformers 2 that were being ready to be put in-use'were defective.or.not, il in that respect. 4 A Yes, sir. .5 Q ' Excuse me. When it'gets-technical, if.it-6 appears that the question is obvious, it isn't always obvious 7 to the lawyer..And I1just want'to make sure that;I under- ~ 8 stand it. That's why sometimes I ask you what must seem 9 like a very simple question. 10 You indicated'that you factored in:the 11 results of those tests in writing the memorandum, which'I-12 believe we have marked as Vogelsang Exhibit 4. 13 Will you tell me first, what wereithe-14 results of the. test and, secondly, in what way did you1put 15 it into a memorandum? } 16 A The results of the test were that the 17 transformers were good. The ones that had beenLin operation,. i i plus the ones we had that' had been in operation showed 18 I 19 favorable test results. ? 20 So,.in my knowledge of what the' failure mode i 21 of the transformers had been, it was a time mechanical type 5 22 failure. d 23 So, that's why-in the draft that.is Vogelsang 24 Exhibit No. 4 on page 3 when I say that the deficiency i 25 appears to be of a generic nature L,because.the electrical 4 s _._..--1--
l 77,364 1 testing that Westinghouse had requested us to do gave 2 conclusive evidence that at that time those transformers 3 were good. 4 Q So, in conclusion, then, running the - hi-pot 5 test had a useful value-- was of use to you in being able 6 to better focus on the nature of the cause of the failure 7 of the ferro-resonant transformer. 8 A No, sir. 9 Q Well, let's go back over.it. 10 One of the things you were trying to determine 11 was whether or not the nature of the failure of the ferro-12 resonant transformers was time dependent or not; is that 13 not correct? 14 A No, sir. i 15 Q I'm sorry. I thought that you had just { 1 l [ 16 testified that in Vogelsang Exhibit 4, one of the factors j 17 you put in there and it was important was whether or not l 1 l l 18 the failure was a time dependent failure. { i ) 19 i Did I misunderstand what you'd said before? =. 20 MR. DAVIDSON: I thought he said time 1 21 mechanical. But I would have assumed that it would also 22 have been time dependent. So, you and I are at the same l i 23 disadvantage, Mr. Roisman.. But I think he said time 24 mechanical. i 25 //
l -77,365: 1 BY.MR. ROISMAN: q 2 O If I were to change my question toisay: 3 Was the running of the hi-pot test useful:in helping'you 4 determineLwhether or not thecnature of the failure of.the 5 ferro-resonant transformer was' time mechanical, what would- '6 your answer be: Yes,Jor no?' f 7 'A .Yes. .8 Q Finally, Mr. Mizuno asked you about'your -9 understanding of Westinghouse's--. the1 nature of the record that Westinghouse would have of failures of-ferro-resonant. ] 10 q 11 transformers at other wites. i 12 A Uh-huh. 13 Q. Do you remember that exchange with him? j 14 A Yes, sir. 0 15 0 I'd like forlyou to look, if'you-would, at-4 l 16 Camp Exhibit 5. And, in particular, at the test' deficiency j a-a 17 reports which are attached thereto. 's }i j 18 And I'd like to direct your attention:to the } ) 19 first and the second one. I, j 20 Now, in-looking atithat test' deficiency. ~ 1 21 report, are you able.to indicate to me, in general, when' l 1 i 22 those first two failures occurred? i I 23 MR.LDAVIDSON: I believe that was-asked- .I 4 24 and answered by me. _ I mean, not answered by me. But I l J 25 asked that in his direct. l ] l
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_____..__________________1_u____O __.1______. _._____________1____..______...
77,366 4 1 MR. ROISMAN: I know. I.just-- I want to i 2 have the predicate in front of me. I don't want to try to 3 summarize what he said, and I don't think we ever got an 4 exact date. And I just want to make sure we're in the i 1 5 right time frame. 6 A (By the witness) -Yes, sir. 7 Q (By Mr. Roisman) And when, either the exact i 8 date or roughly around when, did those two failures occur? 9 A February the 15th, 1983. 10 Q Now, was it your understanding of the way in 11 which Westinghouse relates to the Comanche Peak site that 12 those two failures would have been brought to the attention 13 of Westinghouse? 14 A I don't understand that question, h 15 0 Would Westinghouse have been made aware that bj 16 there had been these two failures at that time, and on or 17 about the 15th of February 1983? { 3 l 18 MR. DAVIDSON: Shouldn't the question be: i i i 2 i 19 Were they made aware of it? 3 20 MR. ROISMAN: Well, he may not know that. I 21 But I want -- I 22 MR. DAVIDSON: Well, that's true. 23 MR. ROISMAN: --to get an understanding of 1 1 24 the procedure. Would they have been. In other words, was the 25 nature of the procedure such that they arould have been, t }
1 77,367 I or'should have been, made aware. 2 MR. DAVIDSON: In other words, do you under-3 stand Mr. Roisman's question? His question is a question 4 about the procedure. 5 Would the procedure have required, on the-6 basis of these two failures, that Westinghouse be notified 7 of those conditions? 8 THE WITNESS: No, sir. 9 BY MR. ROISMAN: 10 Q Under normal procedures, would Westinghouse 11 have been made aware of the failures of the ferro-resonant 12 transformers if the procedure by which-- the procedure 13 initiated by Mr. Camp's memorandum, which is dated May 31, 14 1983, and it's Camp Exhibit 5, had not been initiated' a_ 15 MR. DAVIDSON: I don't think I understood l [ 16 the question, Mr. Roisman. h 17 MR. ROISMAN: Okay. 5 l 18 BY MR. ROISMAN: rI i 19 O The question is: Would Westinghouse, i 20 following procedures, have been made aware of these failures 21 of ferro-resonant transformers by any mechanism other than e 22 the mechanism which was triggered by the sending of the l 23 memorandum marked as Camp Exhibit 57 i 24 MR. DAVIDSON: Well, I think my difficulty 25 is that I think the testimony is this is the procedure i I
l I 77,368 j 1 .i I for noting a possible trend. 1 l 2 s MR. ROISMAN: I understand that, but-- 1 3 MR. DAVIDSON: So, therefore, you're asking: 4 Other than the procedure, would they have notified it. l 5 And I think the point is: This is part of 6 the procedure. 7 MR. ROISMAN: But the question is important 8 to find out whether there are other procedures by which-- 9 there are other established procedures by which Westinghouse to is made known of the failure.of a transformer, even if the l l 11 people who owned the transformer don't think it's a trend. 12 This is a way of reporting a trending 13 problem. 14 MR. DAVIDSON: This is a procedure-- ~ 15 BY MR. ROISMAN: e. ~ 16 Q Is there another procedure, a normal procedure 17 that would be used to advise Westinghouse that two of their i \\ j 18 transformers failed when there was not a thought that it f a f 19 i was a trend? l l j Zi MR. ROISMAN: That's rea.11y the question. } 21 MR. DAVIDSON: I think in that form, it's i 22 a proper question, f 23 5 A (By the witness) No, sir. 24 Q (By Mr. Roisman) In your judgment, had the I 25 l I i .------------------------a
77,369 1 first two ferro-resonant transformer failures occurred and the third one not occurred, do you believe that Westinghouse 2 would have ever been made aware of the failure of the ferro-3 4-resonant transformers at this site? 5 MR. DAVIDSON: I'll object to that-question 6 as purely hypothetical and asking for speculation. 7 BY MR. ROISMAN: 8 Q You may answer it, Mr. Vogelsang. 9 A Yes, sir. 10 Q How do you think they would become aware of 11 it, if it had not been put into the trending procedures? 12 A .The replacement transformers that we used 13 to repair the Unit 1 failures were taken from the inverters that were supplied for Unit 2. 14 15 0 Okay. I { 16 A So, when the procurement cycle would have been in progress to replace the transformers that we took 17 i la from Unit 2, Westinghouse would have become aware that we i 2 were replacing some ferro-resonant transformers in their 19 i ~ m inverters. So, they would have become aware that we had some failures in them and that we were replacing them. 21 1 22 Q But, in reality, unless they decided to 23 make inquiries, they wouldn't know whether the failure 24 was caused by some accident totally unrelated to the compo-25 nent itself, the thing got dropped while being loaded,
l ,77,370 1 or whether the failure was a functional failure related to 2 some defect in the transformer; isn't that true? 3 A Yes, sir. 4 MR. ROISMAN: That's it. 5 REDIRECT EXAMINATION 6 BY MR. DAVIDSON: 7 Q Mr. Vogelsang, I want to clear up one 8 question, a matter that Mr. Roisman raised with me earlier 9 off the record. 1 10 I want you to look at Vogelsang Exhibit No. 3, 11 and you will remember that this is a cover memorandum 12 accompanying attachments that you received, I believe you 13 testified, on January 16th, 1984. l 14 That was the manner in which you received ~ 15 the Westinghouse letter and the GE report under cover ] 16 memorandum from Mr. Moller, Westinghouse Site Manager; is 17 that correct? 5 l 18 A Yes, sir, is; 19 Q Mr. Roisman pointed to me that the date on 5 2 this document is January 12th, 1983, although this receipt 21 stamp does indicate it was received January 16th, 1984 l i 22 To the best of yoe recollection-- Or, 23 better yet, do you believe this is a mistake? 24 A Yes, sir. 25 O That this is merely a typographical error or I l i
77,371 1 someone forgetting to change the year. 2 It would have to be because the documents 3 attached are 1984 documents that the letter is a January 4 1984 letter. 5-A Before the transformers failed. 6 O That's right. So, it's obvious that that's 7 a typographical error. 8 A Yes, sir. 9 Q Mr. Roisman wanted to make sure. the recntd 10 was clear. 11 MR. ROISMAN: I wanted to be sure that he 12 wasn't so angry at Mr. Moller because he had waited over 13 a year. 14 (Laughter.)
- j 15 BY MR. DAVIDSON:
2 l 16 Q Mr. Vogelsang, ~.st night Mr. Roisman asked 17 you a question regarding Camp Exhibit 9, which was a i 5 18 i memorandum addressed to you dated July 28 over Mr. Camp's u j 19 signature. 20 Do you have that document in front of you s r 21 now? i 22 A Yes, sir. } 23 Q And I believe your testimony was that this 24 was the operating history of the inverters at Comanche 25 Peak that you had requested so that you could forward it 4 e
,e. ~ 77,372 1 to Westinghouse lper their request. 2 A Yes, slr. 3 -Q Mr. Roisman asked you.whether, having ,4-received thatLdocument, you formed the opinion that the 5. problem that had been perceived of the ferro-resonant. 6 transformer might be generic. 7 And your testimony,was: No.. 8 Str question 11s:. Was there.anything in'there that would have'given'you'any factual'information'to permit 9 you to. form that opinion-one.way or the other, whether it-- 10 1 11 was likely to be generic or not?. 12 .A No, sir. 13 Q So, that, this document couldn't have changed an opinion or couldn't have had an opinion in-helping-you 14 15 form an. opinion. I { 16 A Yes, sir. 17 Q Because it only gave'information.with respect 1 18 to the operation at Comanche' Peak'for those'ferro-resonant. ti 1 19 transformers, bj m A Yes, sir. 21 MR. ROISMAN:. Mr..Davidson, can I aski ou y i 22 to be just a'little careful.on the leading? 23 MR. DAVIDSON: You certainly can,:and I'll' L L 24 .try to avoid that. 25 // i f
- 77,373 1
BY MR.. DAVIDSON: 2 .Q Last' night, Mr. : Roisman' asked - you1 in connec-3 tion.with your evaluation'of-the SDAR, that-is, Significant-4~ . Deficiency Analysis Report,-- Strike that.- Let me.estab'lish ~ 5 the predicate. 6 Last night,1you testified (that you1were-7 assigned'the responsibility to prepare.an evaluation of 8 the SDAR.so as to determine whether,Lin fact,~ that possible 9 50.55 (e) was,=in fact, a reportable def'iciency;under.that to particular regulatory section. 11 A Yes, you're correct. ) 12 MR. ROISMAN:Mr. Davidson, I'm= going ~to ; object to the form of your giving a summary of hisitestimony 13 last night and then getting him'to. testify.yes or:no'this 14 5 15 morning. H j 16 That is the equivalent of a leading;que'stion. 17 MR. DAVIDSON: I know'it is. All right. 5 l l 18 I just really wanted.tolget.to'the' question ~ 1 i: .i 19 because-- -{ 20 BY MR. DAVIDSON: d t. 't 1 21 Q-Mr.iRoisman asked you--' Well, was. it. not: a-I 'i 22 i fact that when you were assigned that project you.were l!3 given a deadline to complete your evaluation? 'i 24 A Yes, sir. I 25 Q Do you remember what that deadline.was? 'i e i
_a 4 77,374 1
- A
. February the 2nd.. 2 Q' Mr. Roisman asked you;whether, despite'the 3 ~ fact that you had until. February: the 2nd ' to complete ' the 4-project, that you would have attempted to complete.'it sooner. 5- ~ Do you remember-that? 6 b. Yes, sir. 7 Q And you said, "Not necessarily." 8 A: Yes, sir. 9: Q What:I want.to-know is: -Did you~ complete-10 .that project as fast as. you 'possibly could? 11 A. Yes. 12 MR.';DAVIDSON: That?sfall'of my redirect. 13 ' RECROSS / EXAMINATION 14 BY MR. ROISMAN: 2 15 Q Mr. Vogelsang,.the very last. question that !j 16 Mr. Davidson asked you was: -DidLyou completeithe project: 17 as fast as you couldC k-2' l 18 And your answer was: Yes,cyou did.. I j 19 i Is the work product thatl forms the' result j i a I j 20 of that project what has been marked as Vogelsang' Exhibit: 21 4 and Camp Exhibit 14? Is ttat the work product of the L k 22 completion.of the project? 23 MR. DAVIDSON: In other words, your_evalua-tion of the SDAR,.whether it's the reportable ~ deficiency, 24 25 these two documents, Mr. Vogelsang. ] ^l i 'J l
'77,375 1 A (By theLwitness) :Yes,' sir. 2 Q (:By-Mr. Roisman): And t is ' the material ~ 3-that you needed to review in orderfto prepare those documents 4 what is contained in Vogelsang Exhibit'3? f 5 This is the letter from Westinghouse--:Lthe 6 internal Westinghouse letter and the GE report. 7 JL Yes, sir. 8 Q .And it's your testimony that the fastest 9 that you could possibly have prepared - the Vogelsang ' Exhibit - 10 4, Camp Exhibit 4, and.reviewedLVogelsang Exhibit 3 was to 11 do it by February 2nd, 1984; is that correct? 12 MR. DAVIDSON: I'm going.to object, only 13 because your question doesn't'incluce--all-of the information 14 necessary to complete'the project 1in vogelsang Exhibitc3 h 15 Obviously, some-information:would, but we [ 16 haven't determined ~that all of the-information was-- 17 MR ' ROISMAN:- I'm sorry. .I thought I'd s 18 asked him that. rij 19 BY MR. ROISMAN: Ij 3) Q Was all of the information that you needed .j 21 to review in order to complete your project' contained'in-f 22 .vogelsang Exhibit 3? 23 A No, sir. 24 Q What other information-did you.have to 25 review? 4
l 77,376 i 1 A The hi-pot information. i i 2 O And other than that, was there'other informa- .3 tion? 4 A' .No, sir. 5 Q Do you recollect, what was the number.of 6 pages that constituted the hi-pot information? ' 7 A Two or three pages. l l 8 0 .All right. 'Now, adding.in the hi-pot'informa-9 tion, my question is: Is.it your testimony ~that the soonest to you could have completed the review of the.hi-pot informa-11 tion, Vogelsang Exhibit 3, and compared Vogelsang Exhibit 4 12 and Camp Exhibit 14, was February 2nd, 1984?' 13 A No, sir. 14 Q How much sooner could you have done that? j ~ 15 A The date on my Vogelsang Exhibit 4 indicates ij 16 that this was pre sred on the 1st of February.. So, the 1st-- r 17 0 If I had said "the 1st", would your answer l 1 1 have been, yes, that was the soonest you could have done it?,! 18 f 19 A Yes, sir. ? 20 Q Is that because to do this material it took i [ 21 you that long to do the review and writeup or because'there i 22 i were other responsibilities you were tring to do at the I 23 same time? 24 A I don't understand the question. 25 0 I was trying to find out whether the reason i l
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- 77,377.
1 -that there was a' passage of time.from- - if;I remember-2 correctly, it was on the 25th of: January that.you.receivedi 3 back,from Mr. Tolson his'information that told you byc 4 February 2nd, ; get me somethingsf isn't that correct? 5 LMR. DAVIDSON: I~ don't think he'said: Get 6 me something.. I think he said: i Prepare an evaluation. 7 MR. ROISMAN:-.That's correct. I'm'sorry. 8 'That's right.- 9 z I.only.used'that.to avoid mischaracterizing-10 what it'was. 11 MR. DAVIDSON:. Right, 12 BY MR. ROISMAN: 13 0 Andlis the reason.that February _ist was1the-soonest that'you would get that because'it?took'you all the' 14 ~ 15 intervening time between when you.got theLnote1from Mr..
- j 16 Tolson and February 1 to prepare--
to read andiprepare 17 the material, or because youLhad other' things that you were i 18 doing at'the same time and you.couldn't?spendfalllof your= }1 -t ? - 19 time on this item? ? j 20 A No, sir. I 21 0 . What was the reason, then, nth at : it: took you - 1 22 1 from the 25th of January until the 1st.of February'to 23 complete the project? 24 A The time that wasfrequired:tofrun the'hi-pot 25 on the ferro-resonant transformers'.'
l 77,373 I 1 1 Q I believe that your testimony was this j 2 morning that you received that information on either 3-January 31 or February 2nd. I believe that was your f 4 earlier testimony; is that correct? 5 A Yes, sir. 6 Q I assume that, based upon your other testimeny 7 it must now be the case that you couldn't have received it 8 on February 2nd, because I believe you testified you used 9 it in preparing the document that:you prepared on February 10 1st; is that right? 11 A Yes, sir. 12 O And that the-- So, the date you must have received it must have been January 31, then, Assuming that 13 14 l you've correctly blocked out the two options. 15 A The date should have been January the 31st i [ 16 or February the 1st. 17 Q That's what your testimony should have said. l 18 A That's what my testimony should have said. 19 Q Okay. 20 Now, _ you had requested that the hi-pot test i i 21 be run, I believe you said, about two days after the 16th i 22 of January;-- 1 l l 23 A Yes, sir. i l 24 0 --is that correct? ( 25 And-- 1 a
i ~ i L7 7.,3 79 - -1 MR. DAVIDSON: .No,.I don't know if that 2 was correct. 3' I was under'thefimpression th'at-- I'may-be misrecollecting, but'I thoughtLthat his testimony'was 4-5 that he did it two days after.he receivedjthe-assignment 6 to evaluate the SDAR, but maybe :I'm mistaken. 7 MR. ROISMAN:: Well, I thought-theftestimony,. .8 and, in fact, this was one place where'Mr.lMizuno was= 9 asked to clarify,-- 10 MR. DAVIDSON:.You may be right. 11 MR. ROISMAN: --what's the'date,rwhich'docu-12 ment are you talking about.- I think' he said--~~ But let's-13 just ask the witness again so there's no confusion. 14 MR. DAVIDSON: I'm with.you. 15-BY MR. ROISMAN: $j 16 Q Was it a couple of' days after the 16th of-3; 17 January that you asked to have the'hi-pot test run? i 5 l 18 A Yes, sir. I h 19 Q Do you know why it was nbt possible to getr 5 _j 20 the.hi-pot test results any sooner than;the 31st.of January 21 or the 1st of February? .j 22 A Yes,; sir. 23 Q What was that reason? 24 A The. equipment was energized, and the-engineer 25 that I had assigned the work tx) help gather the'information I
5 1.t 77,380T I had-to work with-
- to getithe: equipment de-2
-energized' so that they ; could; determinate the ferro- ~ ~ 3: resonant transformer so 'that ' they/could run the hi-pot on 4 it. 5-Q ' Excuse my simplicity, 'but = it sounds like 6 'de-energizing'means turning it off; is that' correct? 7-A De-energizing means turning offIthe1 inverters, 8 -yes, sir. 9 Q_ Is'that a lengthy.-process? ~ f you-wanted I l 10 to. turn them off,Dif you det' ermined'you wanted to-turn them 11 'off at noon today, how.long would it take you to turn them-J 12 off? E 13 A I don't think you understand.your question. 14 Q' That's quite'possible, but I-- i i 15 MR. DAVIDSON: What Mr. Vogelsang is saying-- } j 16 I don't think it's that Mr. RoismanLdoesn't1 understand his 17 question. He may very well understand it. ? 18 I think he.and I both share a disadvantage.. I 19 Neither one of us is an electrical engineer. So,,I don't i 20 know about Mr. Roisman, but 2Lcan'tell you.that/I'would have 21 probably' asked a very similar question. k 22 I don't know what you mean by de-er#rgizing,. 23 and I don't really know what you mean by.determinating-24 either-l- a 25 MR. ROISMAN: Let me try it a different way. I- = - -..
L77;381 1 BY MR. ROISMAN: As' Nar 'as you know,: was the test, run' on the 2 Q 3 ferro-resonant transformer as fast as it could.possibly be-4 run? 5 A- .Yes,fsir. 6 Q And\\there was nobodyfwhoLstood in'the'way-7 and said: I'm busy doing another test, and you can't' turn: 8 those inverters off right now. 9 A No,. sir. 10 0 And that if,you wanted.to run those ferro = 11 resonant transformer tests'at anyftime before the plant was 12 in operation, you would ' expect : that: it would - take-:in : the.-- 13 nature of a week, ten-days to.two. weeks to actually'get the. 14 test run; is that correct? 15 MR.'DAVIDSON: Well,'now, is it;a. week, ten }
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j 16 days, or two weeks? f 17 MR. ROISMAN: Well, I'm unless asEto'how-- c 18 BY MR. ROISMAN: b 19 Q Well, let's, just for.the' moment, assume that t j m the 18th was the day you said: -Get those tests run. q r 21 And that the 31st was the-day thatLyouigotithe result's.: .i 79 So, that's thirteen' days. 1 23 Is it your testimony thatayou'would expect ,) it to take thirteen days to get-the hi-pot test runion 24 ferr-resonant transformers regardless of when.that request 25 .i 9 i I -____--_ - - _____-_ __ -. 2 -
j, )77,382: I was made,.otherlthan:if.the plant were in operating condition L ? 2 L A 'I don't understand'that-question. 3 Q. Does it alwaysitake thirteen. days-to run;the 4 hi-pot test?. Is-that'the normal' time to'get"that run? 5 A. .The hi-pot test can be run in a' matter of.a
- 6 few minutes,1the actual test.
7 Q Okay. 8' .A So, iti doesn' t' take three weeks,' two: weeks, 9 or five days to'run'aLhi-pot test. 10 Q What is'it.that takes.the time?- 11 A The item that takes lthe time is beingfable 12 .to, first of all, get the equipment;in'the~ position.that1 13 it can be de-energized. You just can't go to'lt and turn 14 the switch off like you'd turn the light off:.when you'd ~ 15 leave a room. s { 16 Q What is it that you have to do?' 17 A You have to'make sure that other systems that 18 aredependingontheirsupplyfromtheinvertersystemshavej 1 g' 19 another supply. You can't-- I j N In this case, the pre-op testing that was-21 going on, we had testing that was happening at the. time i i 22 that you can't interrupt the test 'O run the hi-pot. test. 23 0 What do!.you mean "you can't"?.Do.you mean 24 it would be disruptive of the test, or do you mean that 25 it's physically impossible? a-__-___ _ _ _ _ _ _ _ _ _ =. _ _ _..
=i i 77,383 y 1 'l A-It would invalidateLthe pre'-opLtesting.. i j 2 O But it wouldn't have been!a. physical i 3' impossibility. It would have simply been.that that' pre-op1 4 4 Ltesting, whatever was in midstream.would have'been wasted. 5 .A Yes, sir. 6 MR. ROISMAN:. Thank.you. That's.al'. 7 MR. DAVIDSON: Arelyou-finished? 8 MR. ROISMAN: I'm'done unless there is some 9 more direct. 10 MR. DAVIDSON:< Why don't'we at least.go off' 11 the record so that_you can confer with Mr. Downey, if'that's 12 a problem. 13 Go off the record. 14 (Discussion'off the record.)- 2 15 MR. DAVIDSON:-.I have but one or.two 8, j 16 clarifying questions. oj 17 FURTHER REDIRECT EXAMINATION i l 18 BY MR. DAVIDSON: t 1 4 19 Q 'l Mr. Vogelsang, we have been discussing here j 20 this last few minutes the _ period of l time. that it ' took' to 21. comple'te the hi-pot testing on the ferro-resonant.trans-l 22 formers ~, and.you indicated that one of the~ reasons that 23 it took thirteen days was that it was not a simple' matter I l 24 of turning off the. inverters but thatJthey had to be 25 de-energized and determinate and put into'a position where i 4
- i 77,384
,d cs .: \\ L .I "l .1 they could beEtested and that,- likewise, that hadito be' 2-scheduled so as not totavoid- < so as.to? avoid wasting? '3 .certain=prekoperational testing onLthat system-- l 4 'MR.JROISMAN: Objection. :I did not"want 5- 'the witness-- ' ~ I' don't want you to.. summarize his testimony
- l.
.i 'and then have him give a-yes orino-- .{ 6 7 MR.-lDAVIDSON:--LI haven't askdd'him whether- '8. the said that. 9 _MR..ROISMAN: That's why_I stopped you. because we already have his yes on(this.- 10 t 11 Can we. agree that you're-not trying.to give 12 that summary of his answer as "yes" asihis testimony; but.- ~ 13 that his testimony'is wha'ever-it was;thatihe-gave- - t 14 You were summarizing.to get a predicate:to 15 ask a question, not to get the testimony.in. l l 16 MR. DAVIDSON: It so happens that:you are 17 right, Mr. i Roisman, but I was merely. summarizing so: that. l 18 I could establish the predicate for my nextLquestion. 3; 19 However, his testimony is' what ' it is. I N' s MR. ROISMAN: That's. correct. 'I': just 21 wanted to make sure that it wasn't.both of:them. LThat it 3 22 was just what it was. 23 MR. DAVIDSON: Excuse me. .I see that my i 24 colleague, Mr. Downey, is here. And'apparently he1hasian-25-urgent question for you, Mr. Roisman, so I willsaccede tct i l a
77,385 1 a break, even though it may be a little bit interruptive 2 of this questioning. i 3 (Whereupon, there was a brief recess in the 4 proceedings.) 5 MR. DAVIDSON: Let's go back on the record. 6 Let me just ask the witness: j 7 BY MR. DAVIDSON: l 8 9 Do you have the predicate for my questioning i \\ 9 still in mind? 10 A Yes, sir. 11 Q Who was responsible for scheduling the timing 12 for the hi-pot tests? ggg 13 A Since the inverters were energized and pre-op 14 testing was going on the startu ngineer who was assigned to that system, was the person who had to 15 I 16 schedule the outage of inverters. 17 O And whose desire was it that the tests be 18 I done at a time that would avoid the possibility of wasting 19 or otherwise invalidating prerequisite or pre-operational
- I i
20 tests? 3 21 A That was a schedule that ~ 1 22 developed. That was his desire to hold off and wait until i l such time as he could de-energize inverters. 23 24 O Would an SWA be required to conduct the O 25 tests to which you just referred, the hi-pot tests?
__mc,_ _ - - _ - - - - - 77,386 1 A Yes, sir. i t { 2 Q And who would have to sign that SWA in order ( l 3 for them to be conduct _[ a as. 1 4 A + - 9 c 3 5 Q Because he was the STE? 6 A He was the startup engineer that was assigned 7 to that system, yes, sir. 8 MR. DAVIDSON: Those are the questions that 9 I wanted to ask on redirect. 10 MR. ROISMAN: I have no further questions 11 of Mr. Vogelsang. 12 MR. MIZUNO: The Staff does not have any j (~ 13 questions. %) 14 MR. DAVIDSON: Mr. Vogelsang, I believe i 15 that we have now concluded your examination and appre- [ 16 ciate very much your patience and your indulgence with j e [, 17 us. 3 l 18 i I think that I express the sentiments of 2; 19 Mr. Roisman and Mr. Mizuno in saying that you were a I 20 helpful witness. 21 And certainly, you were very willing to stay i 22 late last night and' complete your examination. 23 Mr. Vogelsang, we appreciate your having 24 come back today. 'Q) 25 And we thank you again. ________-_--__-_-_-J
i \\ 77,387 I 1 I think that concludes these proceedings. 2 (Whereupon, at 11:18 a.m., the deposition 3 in the above-entitled matter was concluded.) 4 5 6 7 W. Iven Vogelsang, Deponent' 8 9 10 11 12 13 14 15 t> l 16 1 i 17 i l 18 I I ? 19 1 20 i 2 21 i 22 i 23 3 24 i 25 l
l CERTIFICATE OF PROCEEDINGS I This is to certify that the attached proceedings before tne ! NRC COMMISSION 3l l In_the matter of: . TEXAS UTILITIES ELECTRIC COMPANY, et al ai Date of Proceeding: August 3, 1984 5 Place of Proceeding: Glen Rose, Texas i 6 i were held as herein appears, and that this is the original ~ 7 transcript for the file of the Commission. 8 4' l l Sandra Harden 10 4 Official Reporter - Typed 11 13 Official Reportet Signature 14 15 16 17 IB l l 20 i 21 l 22 23 1 24 25 TAYLOL ASSOCIATES REGISTERED PROFESSIONAL REPORTERS NORFOLK, VIRGINIA 4 w_______-__-__
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Gibba S M111.Inc. 11 Pem Paz2 New n:k. '!*w %rx ~CCC1 2t2 sa-4432 -e'ex: Ocmestic:127636/954534 Intematienst 2:3813/234475 A :tava Cwcst'y .,,e......r,..,, 3_. ,a.:. . --.n _ s.>.2 :. _ '..a a /_J3-(C January 23, 1934 GTN-68375 Texas Utilities Generating Company Post Office Sex 1002 Glen Rose, Texas 76043 Attention: Mr. J. 3. George
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a Gentlemen: TEXAS UTI'ITIES GENERATING COMP.UI'l-COMANCHE PI'4X. STEAM.II.ICTRIC STATION G Qt n,,,. .,JJJ Y..Vw f b. J. -.w/. 4. Cs.'.t.-'. ~ a-.>.",2.*s*. _ C'.<' d.e _r C.r C.s. 0 w7 .3. a.,. 3 _ _r.s _,.3 0 REF: SU-33963 D"'D 12/19/83 In response to the questiens raised in the. referenced memorandu=, we would lika to point out the following: _1 - -... > 3 4, .3 9 i 4 a..d '..=, u ' a _..~~: Gu.d d a. _'. "i.:..- v_d'= ".=_-;' a : e _d _" _" -_ c _ _d * =. r _d _= '+ _ -__ se a..=...d...
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_ e. s = =... _ t,... o =,en.aa.m-w_ _s u,_.a a t _ _ _ v a.a. a _a _. .r s e a _.,. __ _; o.. _= r.. between conduits and cab.le trays. f In.develeping he separation details currently in IS-100, i: was reccgnized that c=nduit crovides a.racewav. medium which effecti'.elv. l isolates internal events from the external surround 1ngs.. In this regard, a conduit system provides enclosure .d.. =_, _ _d. v..'.=._ s u e .4. ~.. o.."..=.~_ c ' =..~.c l e s a.d .. _= v. w _d..'. , v a. =- _=.. d / ~ ~ = o _' _i d '.'. e..... =..d.-'_'.=.'a..=.s..=...=.=.1. l 2 e.-. 4,. s. '..w.= _- = _" c - =_, c.'. a. s =..e .d. =.~ d a _- =_ <-- 3, d a _-' _=.".."..=. ".T.= *., _- v ' G u 4 d. e ' _ _- -_ _= v =, ~.~.=y _' _- = d.' v. :..'-. =.. .=d '.w= 4 ) n M- ....3 2 X H 1317 d cr { snoo Ora vo i .c m._.N._. h. ekh . h. J. __-__L___-_--
t' Gin & S l-lill. Inc. GTN-63 3 75 January 23, 1984 arbitrarily applied to conduits. The separation require-uents in E5-100 caly pertain to those cases where potential hazards are limited to aloctrically initiated fires. Thus, in nany instances, conduits satisfy the Standard's requirements for a barrier *. Cn this basis, a conduit has been considered to be an effsetive barrier whenever it at least 1-inch away fr:m circuits er raceway of a dissimilar s train and: It contains no Class 12 or associated circuits, a. or, b. It does not traverse directly abcve or in front / behind a hori: ental cr vertical trav., res ectivelv., of di,ssimilar train. All separation details provided in 25-100 follcw the abcve c a.e-;a.
- IEEE 384 defines a barrior as -
"A device'o interposed between Class 12 equipment or circuits and r s: rue:ure a potential source of damage to limit damage to Class II systems to an acceptable level." 2. We find no inconsistency between 25-100 and Regula: Guide 1.75 for the reascns stated above. Ory Circuits in trays located abcVe. conduits pose no hazard in the conduit to cir:uits by virtue of their Orientati:n (i.e., =-cve t.h.e cc dud t). c
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a a na.m. a, g-,..-: 1.75 is therefere considered to be satisfied when these
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^ Gibbs & Mill. Inc. GT'M8374 - January 23, 1933 If we can-'he of any additiena1Lassis:ance, please contact this c :::.c a.
- ery truly'ycurs, G:333 L'5ILL, nc.-
.. + Robert'E. 3allard, Jr. Project Manager f W-RZ3a-?NL-5?$:1e 1 ~.e:ter CO: A?;I5 (3s2 'sita). OL .,...t.t e,.. a.f. ( m. **.O. *. .s _4. m. ) _1
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. h.I.Vogelsang (TUS: ' Site) IL.(telecopied)~ L.?cpplewell (TUSI Site)'lL s G) ',' ;. ,.,I t i '. .~ o', 'a r-rt3 o ::*, i i 2 Uo1 ELEC.ENG. l l l l Cravo
I I su-83392 TEXAS UTILITIES GENERATING COMPANY ^ 0FFICEMEMORANDUM y Ta M R Mc3*7 a.iao r May 31. 19e3 I subs: Continuous Failure of Westinghouse I D r D U TTTED 7.3 KVA, 60 Hz, 1 Phase Instrument Power Supply' ' W V " ' Ferro Resonance IFar's N 3.4 jeg) ) Texas Utilities Services. Inc. { CPSES Const. Office It is noted that a possible trend of Class lE failures is occurring in the Westinghouse Inverters which supply the reactor protection systems with 118 VAC power. Over the past four months, three (3) failures of Westinghouse inverters have occurred, involving the output transformers. Reasons for failures a the transformers are that the secondary side of transformers become grounded. The actual cause for the failures is unknown. Attached are copies of TDR's 629, 630.and 1217 which identify the failures. Possible reasons for failures might be that the vendor has wound the transformer winding too close to the case and that with changes in temperature and vibration causes grounding of the windings to the casing. Determination of this possibility is difficult due to the transformers being sealed in an spory/ sand mixture. Please evaluate these failures and provide,a description of corrective actions that should be taken to mitigate or reduce reoccurrence.
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J. C. Kuykendall _ M 'E' R. A. Jones Merrrtt sen C. H. Welch i i
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i i A!!ACEF.E"! A CP-SAP-16 Revision 6 TIST DEFICTINCY REPORT Page 8 of 8 System Name: v'.s. A 11 ? D 4, O w S._ & [ 'w.,.) TDR No.: (., 7 9 A \\ Component Tag No: ~~~3X-JC<J2/v-CI Page / of / Safety ] Non-Safety { Startup System Jo.:o 2 M Test Instruction / Procedure No.: d'/* I i DESCRIPTION OF DEFICIENCT: T~ - 4 b w "T t/ t @C t
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m o'. L J e k e b de e.s v., ' I [ \\ c c. s'k.; ~L.,a._ b. I _. u ovu./4:Le is v.n a. i ( l Ccmpenent Operation _M.ay EMzy Not centinue until Corrective Action is complete: CORRECTI7E ACTION: 7c.d. a o,, [ h. A _..Sm - e..,ee.'.). I c _ n S ( '. e Cao e. 1,. C.,, L..L,. ,2..' h /. _ Co .bd, i C e.As L. 9 f.T I C.A m_ L ? ~ l l l Rtqu:2rD azTts!: c' c - it _, : L'. s.lL. ').., .L A L
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ngineering Evaluation of Deficiency Required: _er g Tes ]No Reference Documents for Engineering,Evalnation: /.N. Y Corrective Action / Recast Approved By: Date: O' /5 '/.[ -t-Correct 1se Acti n Cenpletad: c S.. p Ing.neer Date: "':.< ' - ' M Q 1atest Satisfactorily Cenplaced: U Oste- ~ ' - / ;- > te r' Test ?:g:.naer Scrap 7er_fied 3 :7 Data: CGCQ 4A startup, Tarnover su: re:._;;nce Jupv. 314tributi:n: Originni to *.og -'"SI Ingineer:.ng : tanager Initiating 5'"I ""CCO CA Jearts:/!arn: ter fu: reillance Super 71scr
v ' Al""ACL..C:T A C7-SAF-16 Revision 6 TEST DEFICIDICT REPORT Page 3 of 8 ,.
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L IC c System Name: ie s %a+ Page / of I Component Tag No: --h.ciLiv-C:7 Safety Non-Sa:ecyj i Startup System.No. : c 2,'5 Test Inse:ue: ion / Procedure No.: ~/m DESCRIP* ION OF DE7!CIINCT: -"",- 1._ T V i R l' O.'
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? E. T d E. _ L 2 ~ REQU!1I3 RITIST: 66-/1 v.il : JM. e(e.c C "., '.f,_ - k- /ed !~ i _r t c,,C< 5 Initiated 3y: Date: -/, 5-/? ; t Engineeri.sg Evaluatics of Deficiency Required: n ] No I' Yes Reference Doct=ents for Ingi:eering Ivaluacisn: . !}. 7 Corree:.ve Ac:1:n/Katast Apprev 3y: /$- - Ja::: d' -// ~ /./ Correct:ve A.::1:n C:=cle:ed: --h S c::gp Eng:.neer n , ~.. - Daga: 2.. 't., d Recast Sa:.sisc::rii? ~:::la:ed: Dace: ?' -/ 6 s:r !ast I:g:.6 sf Icrap ?er_i:ad Sy:
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,.. 3A scartup, Tar:cver sur te n e.ca Sucv. u -ww, Oiatribuc:.:n: Ori;;. a1 := Lag TOI: Ingi vering Manager !a:.::.st:.n; S*2 -- ::: 0A 3 ea::::/ ar..= rar Su-e:.;*.:nes iupe:.-isc
=. ATTACEME ! CP-SAP-16 J Revision 6 TEST DEFICIENCY REPORT Page 8 of 8 -3 System Name: U.4 l "I'ci. 3 118 d'. d - S A*.o Ccaponent Tag No: " Tit x - 6 S / L #v - 0 7. Page i of I Safety ~ Startup System No.: c2 A8v Test Instruction / Procedure No.:. W Non-Safety "'"~ t \\ \\ rd/- 1 DESCRIPTION OF DEFICIENCT: "l~, s., e.b '3~ d i FC 2 (,[ cl l_ w,] mbo 9.U C. _ h., L..M ' w, A_ d.L. af 4 L2 e w wth'.a & @~< ~ u e.l co-o N w N.,a Component Operation _May,g,,May Not continue until Corrective Action is complace: CORRECTIVE ACTICN: M ed e2 0,a ./ve,sh a s e,. ', / e s~L Ca ec.o e. A.,, l. :. - L. L... b+.: c.,~.%,3 O e :. Ee h, 4. Q b 6. 'I'."e.es k ,2. N 4 * %.,d., d ee-,ec.,b b, L I >%/:, '.13:{C 1.d eO_/.LC i c.L % C.-0 3:- m $.u a,L,m L g s e' ~
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-..O \\ d REQUIRED ETEST: F [ - /f s." y e f r., reuh.'2 LA,,,.,I #/- /. J b (r wD 1 s-v m t, l i Initiated 3y: - 5-b [ p. 4 N'- Date: f j Engineering Evaluation of Deficiency Required: Yes )( No i ReferenceDocumentsforEngineeringkvaluation: Corrective Action /Retast Appt ./ Date:$ ~ N " 83 ~~ Corrective Action Ccapleted: ~ isaa Stert!yp Engtneer /.f i ~~\\_ Da t e : b_/ 20/ l".'T Recast Satisfactorily Ccmpleted: l'~ Date: 5' 20!? ? Scrap 7erified By: s, sten !ast E g eer Date: UGCO QA ScartupiTurnover Survet;1ance supv. 1 Distribution: Original to *.og "'CSI Engineering Manager Initiating i'"I ""!CCO QA itartup/Tarnover Suc-re111ance Supervisor i, ves.t ..... c.. .. r 4..
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~ ~ a:. u re i l ... an -- 7.5 K7A IW IR"' IRS i s REF: S.0. T3X-386 / \\ // } C??A - 31,653 / y'.A. , /. (.[.. I }}. ...l, .[jjw.f 1 1 In order to cemply with your request in chi referenced let:ar i to evaluace the :hree transfor::er f.tilures,1: is requestad that
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t 1.) A purchase order :o c=ver the ces:s of a si:e visi: { by a farrice Engineer. I I ~ ~ ~~ 2.) Accass ti the~ failed ::ansfor:er. ~~ ~^ . _. 3.).,etailed in. n verter operating. istory (incluc.ing,cac.s, s . ltages, sch.eduled maintenance, etc.) prior to vo ) i 1 3ecause this same style of inverter is in use ac =any plancs vi:h much smaller failure races, ic is our feeling that there is so=echi::g unique in the way the !3X invert:rs have been :perated causing ~ ~ ~he ::ansfor=er failures. i .i R.__L.. Mo..ll er Y - Site Manager C.?SES.._-... _. r RECEIVED ~ cc: M R..dc3ay JUL 15 G33 J. T. Merri:t L. M. Popplewell
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~_s r1 -..,.., C??A 31,635 Raference:.C??A 32,053 T3%-M-10!.7 ?ar your requese, we have compilad i for=acies which indicacas. :hs: :he aheve testioned 1:verters were operated for short periods of time fres.'aly 1931 to - Nove bar 128,2. In November 392, a preoperational cast of :he inverters was perfor=ed. Af ter co=pletion of. the preoperational :est, che inter:ers vere placed is s. rice supplying power to tornal planc equi;eene. Nor=al cperacing asparage required from che inverters was approx 1= scaly 20 :o 35 a:ps (30. :o 35: full lead). Vol:ases applied :s the inver:ars were vichin specified 11=1:2." D.a 130 vol: input vill. vary vich grid vol:sge, b'ac dua co che high vol:sge rslay, internal'DC. bus vol:sg2 cannoc exceed 142 vde vi:houc crippiss :he 440 rel: 1:put brenar. Eac:ary vol: age on fics: 1.s nain: sized at appron':scely '22 id: : d en equalize t.c
- sc 3 aattr chan 140 vde. D.arefers, in:a: a1 C bus vol:sge is main: sited be:.:een 122 vde :o 112 vde during cor:21 operstics.
Reucine cleaning and inspectica as required, has been perfor=ed :n :he i=ver:ers. If any addicienal info:. acion is required ~ cepcerning the inver:ars, please f ael f.e4
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