ML20136C167
| ML20136C167 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 11/06/1985 |
| From: | NRC - COMANCHE PEAK PROJECT (TECHNICAL REVIEW TEAM) |
| To: | |
| Shared Package | |
| ML20136C157 | List: |
| References | |
| NUDOCS 8601030167 | |
| Download: ML20136C167 (312) | |
Text
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9 1
TUGCO MEETING WITH NRC 2
CPRT Monthly Status 3
November 5-6, 1985 4 -
5 Wednesday, November 6, 1985-Granbury, Texas 6
This meeting" commenced at 8:30 a.m.
7 8
9 10 11 12 YOLIIME II C
14 15
, 16
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2 2 21 2
2 22 23 jIO)DO K 5 T
,. 24 25 Taken by: Carmen Gooden, CSR, _RPR November 5-6, 1985 Catmen @oode..
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1 PitOCEEDINGS
( 2 MR. BECK:
Mr. Noonan has asked for the opportunity 3
to make a few remarks before we started in today's 4 presentation. Vince?
5 MR. NOdNAN: I just want to briefly talk about 6 schedules. I don't see any members from CASE 7 organizations here this morning.
8 And what I'm looking at basically is a schedule that 9
I put together myself without benefit of the Utility or 10 the intervenors. After today's meeting I've asked Jack 11 to go back-and start preparation for the SER that we 12 would like to publish at the end of December here on the 13 program. Now, part of the things that are critical items
- 14 is on November 12th, the answers to all of the so-called 15 questions we had of the eleven programmatic, the two
, 16 hundred plus questions that are on the other issues.
l l $ 17 On the 19th and 20th, the Staff will sit with CASE, l .
!. ~18 represented by Tony Roisman, to discuss SER Nos. 7, 8, 9, 7
19 10 and 11. This is a public meeting. It will be 8
i 20 transcribed in Washington'. After this meeting, I have i.
f 21 asked the intervenors to supply me with any kind of !
22 comments they have by the first week in December. l 23 We're talking about another meeting that we have I t
l 21 already scheduled, which is the second and third meeting !
t
' f 25 to -- maybe at that point we can. start getting some Q_____.__ _,_..-., _ - , , . . - - - . . , , - , - . _ , - - - - _ - _ - _ , . - - , . , , , . _ , - , . , . , _ . _ , - - , , ,m'.m
- .- , .-,m ., - .
3 _
1 definitive comments from the intervenors, and also you
( 2 will be hearing that the Staff, at that point'in time, 3
pretty much that they've got their stuff-down on paper.
4 Upon receipt of the Program Plan, which I just put down 5
at 6 December -- John, I don't know 'if that's the right 6
date or no't.
7 MR. BECK: It's consistent with our planning, Vince.
! 8 MR. NOONAN: Also, I have requested that the -
9 intervenors have all their comments about the same time, 10 and I would purpose to do it around the end of December 11 when we would come out with our safety record. Last year 12 it didn't work because of the holidays, but I'll try it 13 again this year.
14 I guess the thing I would like to do is provide 15 Staff evaluation on the program, at least have that thing 16 done by that time.
! $ 17 Now, I unders'tand that maybe by next week sometime, j '
18 you will have answers to those questions to us. '
19 MR. BECK: We're doing everything we can to meet i
i 20 that November 12 deadline for having all the questions ~
21 answered in writing and in your hands.
22 j MR. NOONAN: I presented this to Bill Dircks on 23 Friday, and told him that it looked, it was possible, l 21 assuming it was all put together, that in December we 25 could do that. He was very receptive to that. Okay.
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4 _
1 MR. BECK: Yes, sir.
( 2' We'd like to have Howard Levin start with the Phase 3
3 scope, and we'll go through the Design Adequacy Plan 4 Imp 5ementation.
5 MR. LEVIN: My name is Howard L'evin. I'm the Review 6
Team Leader for the Design Adequacy Program.
4 7
This is an outline of my presentation today. First, 8
I'd like to review with you just a little bit about where 9
we have been and where we are going in the activities -
10 that we.see in front of us.
11 Next, we won't be going through the details of the i
12 scope from the standpoint of the specific designs views 13
{ that we'll be doing, but I want to give you an idea of 14 the number of design verifications to be completed in the 1
- 15 Program. I'll be addressing some of the qualifications
- 16 of the Staff that we put together from the standpoint of !
i 17 current staffing and what our future plans will be to i !
.! 18 augment our staff, to meet the Phase 3 scope additions. .
=
19 z I want to make you aware of the papers that we will i l'
! 20 be generating and the docv? Mtation that will exist at f 21 the end of the Desigr I 2tgr r:y. Program. I will review 22 the milestones that we have completed to date, and then I i 23 have selected two topics that I think are very important 1 23 to our program at this stage, the first being the i f 25 external source evaluation process,-just where we stand h 3 mr. - - -. - * .e--
1 in terms of the status of that activity, and last, an
( 2 overview of.the scope validation process and how we have 3 arrived at the Design Adequacy Program scope.
4 This is a simplified logic diagram of our program.
5 I want to note that we are approximately -- at this stage 6 of the process right now, we have completed the Phase 3 7 scope validation process and essentially completed the 8
development of the checklists that are required to 9
support the scope defined in Revision 2 of the Program 10 Plan.
11 Prior to this time, in terms of reviewing the past, 12 of course, we have developed a body of procedures.
{ 13 Currently there are 21 that will control execution of the 14 Plan. A few of those are still in process. I'll get to 15 that in a moment. We were involved early in the program I 16 in'an understanding of the Gibbs & Hill design process !
i j 17 and the documentation that exists from that source. We t
I i
18 ;
were involved in the review of various external source - '!
t 4 E
=
19 documents that give us some insight into the body of 1
- )
i 20 ; issues that are out there, particularly in the piping and i i l 5
j 21 i the cable trays area, and that, of course, fed into the 22 initial scope development.
t 23 We are currently in the process of developing .
l 21 additional checklists to support the scope that evolved j 25 out of Phase 3, and we will be talking about that right I i
1.
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1 now. We plan to do that a little bit differently than in
( 2 the past. In the past we had operated in a sequential 3.
mode where all the checklists were developed prior to 4 initiation of implementation. The Senior Review Team has 5
recently authorized implementation, and in that process 6 we will be following -- filling out the Phase 2 7
checklists, and at the same time, developing and 8
implementing the scope chat is part of Phase 3.
9 We have various systems that we have developed to
/
l 10 help us manage this program. We've discussed some of L
11 these in the past. They include issue tracking, 12 discrepancy tracking, corrective action tracking and some
{ 13 activity planning, and this tool helps us implement the 14 whole program. As you can see, during implementation 15 information is logged and flows into that system to l 8
16 insure that it's leak-tight and we have a complete ;
I 17 documentation trail. :
i i
18 In this process there are certain activities where !
i
- t 19 we're overviewing corrective action. The best examples I
i 20 of that to date are our overview of the typing program by .
! 21 Stone and Webster, as well as some of the cable tray.and.
22 conduit support work. Implementation, of course, feeds
{
23 into the development of DSAP's Results Reports which will t 21 be developed for each discipline, and we plan to take'a 25 step back and make a collective evaluation of what those
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7 1
reports mean and write a final DAP Collective Evaluation
( 2 Report.
3 This diagram is indicative of the nuimber of design 4 verifications that we plan. Currently in the Program, 5
reflecting Phase 3, we have approximately 75 design 6
topics that we are investigating. These convolute into 7 approximately 500 homogeneous design activities, and 8
we'll be talking about those a little bit later in our 9 presentation._ Homogeneous design activities are 10 evaluated by looking at attributes, and the number of 11 attributes that we have identified are approximately
< 12 6500. These attributes, as reflected on checklists, will 13 be evaluated multiple times by looking at groups of 14 calculations or drawings or specifications, and we 15 arrived at a final figure of approximately 51,000 16 attribute design verifications in the Program, i i 17 I think it might be useful to give an example -- the i j 18 terminology may not be clear.-- maybe starting at the
- 19 top. What I mean by design topic may be something as i
i 20 relatively broad and in the high plane -- for example, t l t 21 concrete design -- and if we get down to a homogeneous l !
(
l 22 design activity, at that stage we're talking about things 23 that are subordinate to concrete design. For example, 21 design slabs, tornado design considerations, block walls, 25 may be examples of homogeneous design activities.
i f
i 8 1
Attributes that may be reviewed-to look at thesu
( 2 homogeneous design activities could be parameters like !
3 concrete strength, modeling parameters, rebar 4 development, load combinations. Then, of course, as we 5 look at various calculations, multiple times for multiple 6 block walls or slab, then you kind of get higher up in 7 the number of verifications that actually are to be
, 8 completed. I just wanted to be sure that we had a 9
consistent idea of what these terms mean.
10 This is an overview of the qualifications of the 11 team that we put together to date, basically just 12 reflecting the personnel we have in the various 13 disciplines, not a lot of the support and management 14 personnel for the program. I want to indicate that this 15 profile shows the experience we have built into the 16 program. In order to implement Phase 3, there were i
i -
additional design areas that were added, and consistent g 33 with that, we have planned to augment the staff to be
- ig able to. support these design verification activities. I i
! 20 wanted to make it clear that this is the Phase 3 profile,.
S h 21 that there are a couple of points that I think are i
22 w rthwhile to make. Number one, on the average we're !
23 talking about a team of.having 15 years of engineering '
21 i experience, and for the scope that's being executed here, '
23 we think we have a -- we brought together~and assimilated
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I a team that can do this work, and we will be 1
( 2 supplementing this consistent with the needs of Phase 3 3 and the new design areas.
4 MR. SOFFELL: Howard, how do you read this table?
5 MR. LEVIN: I'm sorry. The large number is total-6 years of experience in that discipline.
- In this case 7
it's power plant design experience, which is primarily AE 8
type experience, or related experience, and this is just 9 an average number per man. So, for example, if you look
.10 at the whole program, we're talking about over a thousand 11 years of engineering experience when you include the 12 remainder of the personnel and an average of fifteen.
l 13 What I want to do here is to give some indication of 14 the types of paper that we'll be creating in the program 15 and the hierarchy of some of this paper. I have broken
, 16 it down into three categories. There is a series of i r7 documentation that governs the control of the program, i 18 starting out at the highest here with the Program Plan, ~
19 our Design Adequacy Plan, including the DSAP's, our QA 5 ,
i 20 program, our procedures, the DAP's, as well as discipline -
Ih" 21 instructions that will be generated by a discipline 22 coordinator to give specific technical instructions to ;
3;g their staff. -
3.; { As far as working documents, we have criteria lists, !
i 23 which are a tabulation of TUGCO commitments; checklists, !
l r
10 _
1 which provide the thread from criteria to attributes to i
( 2 documentation of where we reviewed it to the specific 3 line item or location in project documentation, how we 4 verified it and whether we found it satisfactory or 5
unsatisfactory. The bases for these sat or unsat 6 findings, though, do not occur on our checklists. They 7 occur in engineering evaluations which are a very 8
important element of our documentation process. A set of 9
engineering evaluations together provide input into our 3
10 Results Report in the discipline.
11 In terms of the end product, there is the Results 12 Report and the Corrective Evaluation Report. Supporting
{ 13 this Results Report will be a body of documentation which
- 14 will' include our completed checklists, any calculations 15 or special evaluations that we do, our engineering 16 evaluations, safety-significance evaluations as required, j 17 issue records and DIR's which I will be talking about in
[ 18 a few moments. An issue record is a documented record of
- 19 an external source issue, and DIR is an indication of a i i 20 discrepancy that we found in our program. There are
~
s
- 21 various miscellaneous documents that support it in terms of source documentation.
l 22 23 Right now, I'd like to just give you a quick 2 3 snapshot of the milestones that we have completed. I 23 indicate that we have 21; 17 procedures idJe been issued,
(
11 1
.3 are near completion. These procedures are not
( 2 currently required, or have not been required, to support 3 execution of the program. l That's why they're not l 4 complete right now. They're in the area of trending and 5
generic implications -- this is something that's going to 6
be particularly important as we get further along in the 7 activities -- overview of project activities and 8
correction actions and selection of review items are two 9
areas that have been out for comment within our 10 organization, and they'll be issued very shortly. The l
11 one procedure that we will issue, if necessary, is that 12 to control subcontractors, and right now there are no
, 13 subcontrac, tors involved in the DAP.
14 MR. NOONAN: Howard, is that all? You have 21 15 procedures total?
16 KR. LEVIN: That's correct. Seventeen have been i 17 issued to control distribution.
} 18 This is a tabulation of criteria lists and -
19
! checklists that we have developed, or are developing, i 20 . broken down by phase. Phases 1 and 2 really reflect the
. l l
21 i scope defining Revision 2 of the Program Plan, and Phase i 3 is that which fell out of the Phase 3 scope validation 22 #
process.
23 The criteria lists for all disciplines in ,
. 21 supporting the scope in Revision 2 are complete from the t
25 standpoint of capturing the criterion commitments. We l
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I still have various activities ongoing to confirm the
( 2 overall adequacy-of those criteria, but we believe we l 3 have captured the commitments that TUGCO has made.
4 In terms of checklists, there are a total of 97 i t
5 required to support that scope.
4 Eighty-eight have been 6 completed. Those that remain to be completed fall in 7
areas like walkdowns and things like that that we really 8
haven't required to date, but those will be complete very j 9 shortly.
10 Due to the addition of new review areas in Phase 3, a
11 there's'a need to supplement some of the criteria lists 12 to reflect those commitments. That process is ongoing.
13 In some areas it's very trivial. For example, in civil 14 we believe we have captured most of the commitments as
. 15 part of the Phase 2 effort. In other areas -- as an 16 example, in mechanical -- the addition of looking at i -
essential EVAC will require reflection of those types of i
j is criteria on these lists, and we're currently in that - '
a 19 process.
i We will need an additional 64 checklists to i i 20 .
support this scope, bringing the total to approximately l j gg 161. l
\
.I 33 MR. NOONAN: . Howard, I don't understand comething 23 there. You had mentioned a.new area. You said "HVAC"; I that's not a'new area.
3; r l 25 MR. LEVIN: It is a new area in the programs that l i ~
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1 were added as a result of Phase 3, and Doug Timmins will
( 2 be going'through what the new areas are and just give 3 some insight into the scope of review in'his 4 presentation.
I 5 MR. NOONAN: The top line reflects there's still 6 some checklists to be completed. You're saying those are 7 due a walkdown checklist?
8 MR. LEVIN: Some of them are walkdown checklists, 9 that's correct.
10 MR. NOONAN: What are the other ones?
-11 MR. LEVIN: I don't recall specifically, but they're 4
12 in areas of design review, a couple of areas. I could 13 get that information for you.
14 MR. NOONAN: When do you think they'll be complete?
, MR. LEVIN: Very shortly, within the next week
, -16 approximately, in terms of Phase 2. These 64, my ,
i i 17 comments don't apply to those.. We just kind of nailed j 18 those requirements recently, and these 64 will be ~
I 19 i l
completed in process, and you may not find the last one I
i 20 being completed until it's required to support that !
[ aspect of the implementation.
1 i
21 We're not going to have a 22 sequential process as we had in the past with Phase 2. ;
23 We will~ initiate immediately implementation of the 21 Phase 2 scope, and in parallel to that, we will implement ,
25 Phase 3 at the time that those checklists are available
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14 I and initiated by a discipline coordinator. ;
I
( 2 What I'd like to get into right now is an overview i
I 3 i of the external source issues evaluation process. This !
t 4
slide is very similar to one that you have seen before, !
5 but just a refresher. The purpose of this evaluation is !
6 to resolve all issues raised by persons or organizations 7
that are external to the CPRT relative to the safety- i 8 related design adequacy of Comanche Peak. I I want to make i 9
it clear as to what we're talking about when we mention !
i 10 an external source issue. It's a design-related concern i
(
11 from my point of view. I John Hansel has a similar
- 12 activity, but his are construction of QA/QC concern. It i
13 has to be a concern applicable to safety-related systems, !
14 structures or eomponents. It must be reflected and i
15 docketed information, and it is, of course, expressed i I
16 external to TUGCO, as well as CPRT. !
i
} 17 I don't plan to go through this methodology as to !'
i
[ Is how we deal with an issue once it gets into the hopper. i i
=
19 We've dealt with that before. We can answer some !
i 20 questions, but just in summary, there is a process to e [
l 21 i
! arrive at a complete disposition of an i.ssue, including !
I' the development of new action plans that are required if 22 i
23 there are currently insufficient activities gone on to !
(
j 34 cover that concern. And, of course, wherever that may
- i. (
i 25 lead in the way of corrective action, if that woul be l
I f
i
15 _
1 required. So an important part of this is that there is
( ~2 a process that captures the item and leads to the 3
ultimate disposition, whatever that requirement may be.
4 MR. CHANDLER: Howard, could you explain what you 5 mean by the word " docketed *?
6 MR. LEVIN Information available in the PDR.
7 What role does the external source issues evaluation 8
play in the DAP?. Number one, I think it's very important 9
that open issues as expressed by the originator -- that to is, he does not feel the issue is resolved -- will be 11 resolved in the context of the DAP program and Closed by 12 the DAP.
We are also interested in issues th<at have been 13 closed or considered closed by the external sources. We 14 believe that this information is very valuable as input 15 into our trending analysis. We do not plan to 16 specifically reopen issues that are considered closed by I j 1; the sources unless through the course of our evaluation l
l l 1s we arrive at a piece of information that would tend to -
I 19 contradict the closure by that party. In that case, we
! }i 20 would obviously have to reopen it and understand the
. I i
s 21 l basis for that closure. ;
22 This is a listing of sources of external source '
23 j issues. I think it's self-explanatory what the list is.
t 1 21 If issues become available from other sources in the 3.3 future, the system has the capability to accommodate this 1
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16
- t 1
in a systematic way. i
( 2 MR. CALVO Can you explain how this system has the 3
capability to accommodate both the external source issues 4 !
by the homogeneity design populations? You said l
- 5 something that the homogeneity of, the design would I 6
involve all the disciplines, all the processac and !
7 factors of external source issues. Suppose in the future !
I 8 a new external source is' sue comes up. What if in the i i
9- ;
methodology that he had they said, " Don't worry about !
i 10 this one because we already took care of it in thi's 11 particular design activity homogeneity," if you've got in j t
12 place thct kind of methodology that permits an i
! 13 independent party to assert that it was not.
[
t 14 MR. LEVIXJ Jose, you might recall that very busy ' I
_ 15 logic diagram that confused people sometime back where --
i t s
16 going back to that slide, that previous slide, Terry,the !
i 17 purpose slide -- this area right here is an l i
j is
,l identification of the key portions of that process, but i 19 t e
basically what happens is that an issue, we'are made '
I !
t aware of it, or we are seeking it out, and there's a i 20 I
. t' ;
! i 21 process of identification. In this next process of t ,
t l !
22 ;
i definition, we are doing what I think you are alluding !
+
< r ga to. We're t'rying to assess'what are the boundaries of ,
2., .this 1.scue, what does it mean, are we covering it
' 23 somewhere 61se, is it bounded by another evaluation?
i I
I - -
l
\ I
I ~
17 l
1 It's my expectation that as our program proceeds and we
( 2 get more intelligent about the design of the plan and we 3 have an inventory 02 design reviews that we have 4 completed, that as new issues come in, I think we w'ill be i
i 5 able to show that things are covered, are bounded. If 6
l they are not, though, we will then proceed further
, 7 through this process and develop action plans, if 8 necessary. I mean, it's conceivable that something will i
9 come up that is not covered or warrants some additional 10 investigation to verify that it is. This process is a
- 11 fairly complicated one, and we have discussed it j
22 previously, but I guess the most important thing is that 13 it's really intended to do exactly what you are alluding 14 to.
! 15 MR. CALVO: All right.
i 16 MR. LEVIN: We have not finished this process, and I f} 17 will be giving you some statistics in a moment on the i j is volume of documentation that exists.
i
- Because of that -
19 volume and our need to feed information into our program l
i 20 as soon as possible for the development of new action
- .l 2
21 l Plana on the front end, we had to assign some review
! l i
! 22 priority to how we went through this information, the 23 i idea being that we wanted to go to those sources where we 34 could get the greatest number of issues with the least 3,
amount of effort, and feed that into the program. We e
d 18 I
have started with recent documents before old documents,
( 2 primarily because we believe that the issues tend to be 3 more updated and summarized. We have selected key 4 documents -- for example, the original Walsh-Doyle 5 allegations, tte transcript from a meeting held with CASE 6 and Walsh and Doyle back in March of this year, the CYGNI.
l 7 review items list and the Staff's SSER's. It was our 8
1 view that through these documents we could get a high i
9 percentage of the issues. And there are other documents, for example, NRC and CASE-originated documents and TUGCO-i 10 11 originated documents and transcripts, where we believe 12 that we will find additional issues. However, in most 13 cases we believe that they will be covered here, and 14 we're going through this process as much for 15 completeness, to be sure that we have looked at 16 absolutely everything, although what I see, what I haie
} 17 observed is a process where things are asymptotically j 18 slowing down because, in fact, the vast majority of the 19 items came out of these sources. '
i i 20 ! HR. CHANDLER: Howard, of the CYGNA issues, what is
! l e 2 the universe that you're looking at there? Is it limited 22 in time, or how current'is it?
23 MR. LEVIN: We are looking at input, or output, from !
21 CYGNA in all four phases of the program, so it's not t 33 limited in time at all. I r
t
. _ _ . _ _ - . . _ _ . _ _ _ _ . _ . .._.. _ . _ _ . . . _ . . . _ _ _ _ _ _ . . . _ _-___ ~_ _ _ _ _ - . . _ , . . -.
19 1
What I want to do is go through a little bit of the
~
( 2 process that we go through in terms of capturing these 3 external source issues. First, we have a dedicated group 4
of people that is involved in first identifyi.ng the 5
information as opposed to having each of our disciplines 6
turching through the same 25,000 pages of documentation.
7 We happened to assign it to our piping discipline, 8
primarily because a significant portion of the issues is 9
in that area; however, they are not the sole source 10 involved. They will identify the location of an issue to
. 11 other disciplines, and it's at that point that the 17.
discipline group gets' involved, because we want to assure f3 that the technical aspects of that issue are 14 appropriately captured, and that certainly may not be 13 possible if we are having a group witt srecific technical 16 orientation do that. So they will identify and, of i 17 course, they will take care of issues within their own l
i j 18 areas of responsibility, transfer it to a discipline -
=
19 group who will go to that reference and characterize it '
5 90 and complete the issue record. An issue record is an j
i 21 item that is basically just a documentation of what is !
- t
. 22 ,
f o u n d i n t. h e e x t e r n a l s o u r c e d o c u m e n t .- It's as accurate i
23 a representation as we can make of the concern expressed l [
\
21 by that source, so it's an historical record.
25 The responsibility for execution or logging and
~
20 l 1 insuring the lead tightness of the system is with the
( 2 Generic Implication' staff. They will ultimately ~ play a l l
l l 3 big role in providing the assurance that we can close the 4 program and that every issue has been addressed. They 5 get the issue from the discipline groups, they assign a 6 control number. Onca that number is assigned, it i
7 cannot -- it's forever retrievable and it cannot be lost.
8 l We're utilizing a computer to help us in that regard, and 9 this is something that is available and updated once a 10 ~ week.
11 These are some considerations in the process. We 12 classify these issues to be consistent with our own DAP 13 classification system, primarily to assist us in eventual l 14 trending of this information, along with other information that we will generate in our program that i
13
[
, I 16 will primarily come from our self-initiated reviews. The i 17 other important thing to note is that occasionally we l [ 18 - will identify an item that has construction or QA/QC -
- 19 significance, and there is a process that develops from i*
i 20 us and to John and vice versa -- John Hansel -- that i i 21 disseminates this information to people who need to kriow '
I !. .
22 it. - '
23 This is just a quick overview of what is in the i
3g Design Adequacy Program tracking system. I mentioned 1.s earlier that we have the external source issues expressad !
l
^
~
21 I
as issue records, an historical record of' open and closed
( _
2 items expressed by the source. We have in there 3
discrepancies that are identified by the DAP, as well as 4
those itees that we have classified that were expressed 5 by'the external sources.
6 In terms of resolution, the system assists us in 7
tracking resolution of external sources, as well as our 8
own deficiencies that we may identify in our self-9 initiated Inview. The important thing is that this is a 10 l
tool that helps us provide a trail to insure complete 11 closure and nothing falls through the cracks.
12
]
t the data base of documents that we have identified,
{ 13 approximately 170, corresponds to approximately 25,000 14 pages of docnmentation. To date we have reviewed 74 l 13 documents. We have idencified 134 issues as-indicated in 16 those specific documents, but this warrants some 17
$ clarification. We go through this process on a document-13 by-Jocument basis in certain cases; for example, CYGNA -
19 and CASE may have identified exactly the same issue. So 20 i
) if we'ra looking at a CYGNA document and a CASE document,
! t ,
21 we may have some double counting in this number. After I
22 .
we have gone through the entire inventory of documents, I
we will aggregate those issues that are in fact common 13 21 and still retain. knowledge as to who expressed it, but l 25 this number can be somewhat misleading at this stage in i t
~
22 1 our program. The number of real issues is somewhat less
( 2 than this, but we won't be able to get a handle on this ~
3 until we have completed all the document reviews and the 4 aggregation process.
5 MR. SHAO: How does an external source issue develop 6 into a generic implication?
7 MR. LEVIN: The external source issue comes into the ,
8 hopper, Larry, for evaluation. It's in that process of 9
evaluation that we will get insight into the generic 10 implications, and we don't just look at it with that 11 Particular item in mind. We look at it with other items 12 that may be similar. Hence, you know, we needed a tool '
13 like a computer that would allow us to do some searches j
l 14 through -- and the information that would give us some 15 insight into commonality and implications elsewhere. So t
16 the process is really not that much different than the i 17 generic implications process that we articulated before, j 18 This i's just another source of data that is trended and ,
19 utilized in assessing generic implications.
I f i 20 I would like to introduce 'to you Doug Timmins. Doug i
=
. i
- 21 2
has had responsibility for directing our Phase 3 scope 22 validation process, and he has a presentation that will L t
l 23 Provide you an overview of the steps that we went i
t through, as well as the scope that we arrived at in this '
23 program. ;
~ ~ . - . . ~ , , . . . . _ ~ _ . . . . . _ _ . . . ._.--....-...,.-_._..__,-.__.-.._.,_-___.,.._.-.._,__-__..,_..,_,.,....L.
f l '
23 1
MR. TIMMINS: As Howard said, my name is Doug j( 2 Timmins, and I'm the Project Management Coordinator for 3 the Design Adequacy Program. I've been principally 4 involved in the scope validation process over the last 5 several months, particularly dealing with what we call '
i 6 Phase 3, which I will be discussing in a moment.
7 In my discussion I'm going to be talking about this i
8 validation process of the DAP scope, and the scope that 9 I'm referring to is that scope that we will review on the .
j 10 Comanche Peak design. I'm going to speak briefly to the 11 four phases of the scope validation process, and then I
- 12 will speak at length to what is called Phase 3, which has 13 been the process that we've used over the last few months 14 to assure ourselves that we have a fully comprehensive 15 scope for review, an6 that we are indeed going to review 3
16 the AE safety-related design scope of Comanche Peak.
i 17 Phases 1 and 2 have been discussed in Revision 2 of '
[ 18 the Program Plan, and basically the purpose of those two -
,i
} 19 phases was to assure that our original scope was ,
t i 20 comprehensive and representative. The way that we went i t 21 about doing that is to assure that the two systems, so to .
I !
l 22 speak, that we had originally decided to review, that is, ;
i 23 auxiliary feed water system and a vertical slice through l
3; the electrical power system, indeed were comprehensive f e
33 l and representative. !
l l
- I
. .._-_.-....__...,m_,, .. _._,m, , _ . ,_ _,, , . , , ~ . . . , _ ~ , - - . . _ _ ~ , , . . , _ _ _ _ _ _ . _ , _ _ . , _ . . _ ,
24 _
1 Phase 1 was a period of time in which we looked at a
( 2 number of independent design verification programs and 3
integrated design inspections performed elsewhere in the 4
industry and compared the scope and the depth of those 5
reviews against the type of attributes, systems, 6
components, et cetera, within the auxiliary feed water 7 and electrical power systems scope that we had decided 8 upon to review.
9 We also looked at a numbwr of the Comanche Peak 10 specific reviews that had been performed as another check 11 to insure that we had acceptable scope in our original l 12 DAP.
{ 13 After looking at a multitude of these IDVP's and 14 IDI's and looking at specific scopes that b.ad been 15 reviewed at Comanche Peak, it was our conclusion that the 16 auxiliary feed water and electrical power systems
! 17 vertical slice that we had chosen was indeed j 18 j representative of the types of reviews that had been -
- 19 performed elsewhere.
1 i i
!l 20 l MR. CHANDLER: Excuse me. Let me just stop you at l : !
! 21 : that point. What other past CPSES independent reviews 22 were performed? -
23 MR. TIMMINS: By that, I mean such as TRT, the 23 construction appraisal team reviews, the special i
25 inspection teams, the CYGNA reviews and so forth;
25 I
strictly for a comparison basis to say, "Look at the size
( 2 of these types of programs that had been performed j 3 elsewhere and at Comanche Peak," and "Are we at minimum 4 comparable?"
, 5 MR. CBANDLER:
I was just curious who other than i
6 CYGNA you ned ineladed in that phrase.
4 7 MR. TIMMINS: Phase 2 was another effort that we 8
went through to assure ourselves that auxiliary feed l
l 9 water and the electrical power system slice were -
1 l 10 representative of the safety-related systems in that i
11 nuclear power plant. We looked at the attributes 12 involved as related to equipment, system i
j 13 comprehensiveness, system complexities, organizations i
14 involved, design interfaces and so forth, to assure ,
)
15 ourselves that the attributes, both as related to '
i 16 hardware and the attributes as related to the manner in
! ! 17 which the systems were designed, the auxiliary feed water 1,
j l 18 and electrical power systems were representative of the 4
19 collection of safety-related systems that would be there.
i 20 our. conclusions, similar to Phase 1, were that the !
i .
21 auxiliary feed water and electrical power system vertical I I r
- o, slice that we had chosen indeed were representative along l
' r 2:1 l chose lines. '
i 24 So we' feel that Phases 1 and 2 which have been :
33 i accomplished in the past, did indeed confirm that we had I l
l
4 26 I
a sound and comprehensive original DAP scope.
( 2 Now, Phase 3, which I'll be discussing at length in 3 !
a moment -- the purpose of Phase 3 was to go from our 4
original DAP scope to a scope which we could say 5
4 encompasses the AE safety-related design scope of 6 Comanche Peak. I won't dwell on that at this time.
7 t
Phase 4 we call the Final Scope Determination, and 8
as we proceed through our' reviews of Comanche Peak i 9 i
design, we anticipate that we will have findings and we .
10 will be performing trends and generic implications, and 11 through the findings and the efforts that we apply to 12 them on determining the concerns, the breadth, the types 13 of problems that might be associated with those, ic may l 14 lead us to review some areas which are within our scope, 15 and in more depth. And that's what I mean by " final I
16 scope confirmed," is that after going through the trends
, j 17 and generic implications of the findings and pursuing !
[ IS some in varying depths, that will confirm and finalize ,
i 19 our scope of the program.
- 90 Phase 3. As I mentioned a moment ago, the purpose s
21 of Phase 3 was to use the auxille.ry feed water and C
22 electrical power systems slice as the original scope, and i 23 to supplement that as necessary in order to say that we l 24 , had captured for our review the AE safety-related design i 25 l scope. And that is the design scope which I will define i i
e t
. . _ - - - - - - - -* - - - - " ' ~ - - ' *
27 1
relative to AE on the next slide. However, I'd like to
( 2 point out that our review is focusing on nuclear safety-3 related components and structures and systems. We are 4 not going to go and review things such as emergency 5 planning relative to what happens in the community at 6 this point, or things abstract in a sensa relative to the 7 original citing issues. We are focusing on the AE scope 8 and on nuclear safety-related components, systems and 9 structures.
10 I spoke of the AE safety-related scope a moment ago.
11 I'm going to line up for you with this diagram that this 12 circle represents the entire safety-related scope, design
{ 13 scope, for Comanche Peak. It's broken up into three main 14 pieces. The NSSS scope, the equipment vendor design 15 scope and what I'm calling the architect / engineer scope.
16 our review is not going to go into the internal design of i 17 the NSSS. We have a standardized, pressurized water j 18 g reactor. Westinghouse has been reviewed numerous times -
! 19 by other utilities, by engineering firms. It has gone I
i 20 under various audits, and it is a standardized design.
j !
e t
n It is not the intent of the Design Adequacy Program to 22 review standardized designs. We will, however, be l
2:1 reviewing the interface between the NSSS and the t
g architect / engineer. We will be reviewing to assure that ,
3,, the !!SSS design requirements that apply to the
r 28 I architect / engineer are indeed properly executed in the
( 2 architect / engineer design scope.
l 3 And similarly, we will be reviewing to assure that 3 4 concarns that arose in the AE scope were considered by 5 the NSSS as appropriate at that interface.
t j 6 Equipment vendors. We do not intend to look into 7 the internal design of equipment vendors. For example, a 8 manufacturer of heat exchangers or a pump or a motor.
9 These equipment vendors, for the most part, have supplied 10 numerous types of equipment to various utilities and plants in the country. They, likewise to the' NSSS, have t
Il 12 undergone extensive reviews and audits of the program.
) 13 There are also history programs in place to consider 14 vendor problems such as IE bulletins, notices and
! 15 circulars and Part 21's and 50.55E's.
- 16 So under those types of considerations, we don't j -
intend to look within the internal design of the i is equipment vendor; however, as before, we will again look a -
- i. ;
19 at this interface both ways between the equipment vendor j!
l 20 and the architect / engineering scope to assure that the 21 ,
specified requirements of the architect / engineer were t
22 properly handled by the vendor, and we will do that 23 through a review of the vendor documentation coming back '
1 j
.; the other direction, which will allow us to come to a
. .a. lconclusionabouttheoveralladequacyofthedesignat i
(
l
~
29 1 that point.
( 2 MR. CALVO: I agree with you that the Comanche Peak -
3 I Westinghourse Plan being more or less identical to your l,
4 standard design of the other Westinghouse Program Plan, I 5
and most probably the same QA/QC procedures used by L j
, 6 Westinghouse was probably also agreed with down at 7
Comanche Peak, but I guess the question that I'm asking:
8
! Do you know for a fact that there is nothing there unique '
9 on the Comanche Peak Program Plan, something special, the [
10 introduction of computers for protection of systems, 11 single parameters; that Westinghouse created a QA/QC 12 program that is unique only for Comanche Peak? I want to
{ 13 know if you have searched or you have looked for 14 information so you can say, "No, those are the same 15 welds, the same things that they have done~with the other i
I 16 plan," and we can put it to bed.
} 17 MR. TIMMINS: Let me address that in a little bit i i IS different fashion. Our interest relative to '
' 19 Westinghouse, along the lines of your question, is i
i 30 that we are not interested from otte point of view t gi ; as to whether Westinghouse had manufactured some new
- I '
l 22 } widget that hadn't shown up elsewhere. Westinghouse i
2;g has demonstrated through years of experience in the 21 industry that they have accomplished design, multiple 23 different types of design. They have quality assurance ,
l
30 1
programs in place through the years which have been j
( 2 audited, surveilled, and whatever; and they have
~
3 demonstrated, as one of the front runners within the 4
i industry along with the other major suppliers, that they 5
i can perform nuclear safety-related design, and do have 6
the controls in place in order to do that and to have an 7 exceptional product. So our thinking along the lines of
- 8 Westinghouse in this regard is that they do have in place 9
controls, programs, experienced, qualified people, et 10 cetera, which are the main ingredients that go into designing a piece of equipment.
11 And with that in mind, 12 we do not feel that we have to go and look for some
{ .13 unique something that has been manufactured by i
14 Westinghouse. .
. i 15 MR. CALVO I know what you're saying, but keep I
\
16 in mind the objective of the program. The objective of f
! 17 the program is not whether Gibbs & Hill did a superb job.
j 18 It is whether there is reasonable assurance that it is !
19 design quality in the Comanche Peak steam electric I
i 20 station; not only what Gibbs & Hill has done, what l 21 Westinghouse has done, what everybody has done. What t
! [
i 22 I'm saying, that's what you heard, what people told you. !
23 I'm saying, I guess, if I'm to perform independent ;
l 24 evaluation of what you had heard, is there some 3
- 23 documentation that you have somewhere that I can look at ;
+
i
. . . . . , ..-.-,-.-. --.-.- - = - - . - --. . .-
31 m
I it and confirm that truly you are correct on this and no
( 2 need to pursue it further, so I'll be able to say with
. 3 reasonable assurance in this plan that all designs are 4 quality.
5 I can't read your mind. You say that all the things 6 are there. I just want to know what kind of 7 documentation do you have to help me to reach the 8' decision.
9 MR. TIMMINS: I understand your point, well taken; ,
10 and that brings me a little bit into the next piece of 11 this slide, which I would:like to address along the same 12 lines of what you were just mentioning.
13 By the way, we have documented our rationale for why 14 we are not looking at the NSSS. We have documented our 15 rationale of why we are not looking at equipment vendor.
16 These are contained in the engineering evaluation which l l 17 were one of the results from the Phase 3.
j 16 This little piece of the pie at this point, -
- 19 which I'm calling Potential " Unique" Vendors, there l
i 20 . might be some equipment vendors which have only
' l i 21 ! supplied nuclear safety related equipment to Comanche
! l i
! 22 Peak, not one of the typical vendors that have supplied 23 equipment to numercus utilities across the country that 33 , have had their equipment go through shop tests, 23 multiple performance tests, and then operating under i
32 1 operating conditions. If this is the case that we have a
(, 2 potential unique vendor that meets that type of 3 definition, then we can't really treat them similar to
~ -
4 the other equipment vendors that-would be contained 5 within this wedge of the pie.
6 For that reason, we have taken steps in Phase 3 to 7 identify potential unique vendors, and we have a list at 8 this point which we call preliminary. We call it 9
preliminary because we're still taking additional steps 10 to confirm, in fact, whether that list of preliminary 11 unique vendors is unique to Comanche Peak or whether they 12 have provided equipment to other plants around the 13 country. Right now, I don't know whether this wedge will -
14 exist or whether it will go to zero, but we are pursuing 15 that particular aspect. And that again is along the 16 lines of what I was talking about before, Jose, relative j 17 to our concern for looking at the QA program versus j is individual equipment. -
19 MR.'CALVO: So you say that today you have got in
}
i 20 place'an auditable trail that you actually, through the !
! j gi engineer'ing evaluation, that you have some basis and
! 22 rationale for why the computer system vendors are not to !
1 23 concede to other vendors for the Design Adequacy Plan, i 11 correct?
33 MR. TIMMINS:
We have the rationale that we .used in I
i 33 1
review of the equipment lists for Comanche Peak where we
( 2 used a screening function going down through the list of 3
vendors and equipment to identify this preliminary list, 4 and we'll be taking secondary steps going to the vendors 5
or other utilities or vendor files to confirm, indeed, 6 whether they are unique or not. That step remains to be 7 taken.
8 MR. CALVO: All right, so you cannot take that step.
9 Once you take that step, then as part of your engineering
.10 evaluation will be documentation to the fact that you had 11 done it to permit an independent evaluation by the 12 interested parties.
{ 13 MR. TIMMINS: That is correct. That additional step 14 in confirming them will be documented in engineering evaluations.
15 I6 MR. SHAO: Jose, I agree with you that the equipment i 17 vendor has made a lot of equipment in other areas and i
l 1
l Is they have done that before, why do you look at their
=
.19 specifications? They don't --
i
! 20 KR. TIMMINS: Are you referring to the NSSS l
a 21 specification? 1 l
22 MR. SHAO: No, I mean -- engineer also gives the :
l 2:1 specification to equipment vendor to do (inaudible) . Are ?
24 you going to review the specification of the equipment vendor?
25
. . , - . , ., , , , . . . . _.,-.----.-~4--.-- ,. ,-,- ,-, ,-._,.
t t
t
- i 34 :
1 MR. TIMMINS: Yes, in answer to your question,
(
i we will review the design internal to the ADE to 3 confirm that what he is requiring in the specification !
4 is supported by his internal design, and that what is 5 specified is correct, and we will also review 6
vendor documentation to assure that what was specified 1 7 was reflected in what was provided from the vendor. ji 8 MR. LANDERS: Don Landers from Teledyne. Following 9 up on the same question: What happens when you have a t
10 half a dozen suppliers with the same type of equipment i with a specification that may be confusing, and half of 12 the vendors are all in the category of acceptable f
{ 13 vendors, but you wouldn't be reviewing because of
[
u their experience, and half of them provide documentation !
I 15 and equipment that's acceptable, the other half r i
i i 16 provides documentation that may not be acceptable and i i
! 17 would have had to have been revised to comply with the !
i 33 FSAR?
. gg MR. TIMMINS: In my view, you have to handle that on I e j
, i 20 a case-by-case basis. You're posing a hypothetical i j 21 condition right now, and let me elaborate on that just a
.! l.
22 little bit. In ou'r review of what the architect / engineer i i
23 did, in order to develop the' parameters that go into a !
l t.
.g specification, it should come to light if the condition
- 25 , exists that we may have a confusing situation or a I
r _ _ .
. ._ - - - - . ~ . .
35 -
I specification that can cause concern. If that is the
( 2
. case, through our reviews that will be identified. At 3
that point we would lay out what further steps, if tnere 4
are any, that would be necessary to pursue the concerns 5
that were brought about because of the nature of that 6 specification.
But we have to deal with that on a case-7 by-case basis.
8
, MR. LANDERS: Can I follow that? Are there any 9
external issues to DAP that you're aware of now that fall 10 into that classification?
11 MR. TIMMINS: I am not personally aware, because I 12 have not reviewed all that information.
{ 13 MR. LEVIN: Don, there is one that I'm aware of.
14 That's the, quote, ASME valve issue. Is that the one you l
15 had in mind? I think one thing, a point of 16
- a clarification, the exclusion that Doug is talking about
!= 17 with equipment vendors does not apply to our review of i IS
' interfaces like that ASME valve question where there was '
19 i a specification promulgated by Gibbs & Hill. And I think j
20 l the question in that particular thing relates to the ;
3 i
e 21 : degree to which those requirements were reconciled i i 22 between the two parties. That type of consideration does 23 l . exist in the program and is not exempted by this unique l 23 .
vendor category. For example, we will be picking [
-' 1 23 j selected specifications for review independent of this i
t P
. - - - . - - - --....-m ,w. _r .- _- - _ . _,__,..-__.,,,,..v.,,,._,_...,-y. ,. .. _.., ,,,,_.,,-,_,ywe,_,,,.,_wy
,, 9y.,,.,w.
i 36 1
unique vendor category. What Doug is saying is what we
( 2 won't do is look into the internal process within the 3
vendor, but we will 1cok at how he complied with the 4 architect /engiceer's requirements.
5 MR. LANDERS: My concern there is that within ';he 6
internal process, is there something that triggered some 7
vendors to comply and others not to comply?
8 MR. COUNSIL: Bill Counsil. Don, we became aware of 9
this shortly after I came on the project in May. ile on 10 the project initiated an internal review of all valve'
, 11 vendors. In addition to that, I became concerned because 12 the very error that was made perhaps on the specification
( 13 of a valve vendor might have also been made on a pump 14 vendor. We did a total review of all valves, all pump 15 vendors, against the specifications. We have that --
16 i documented in-house as far as what we did. We made a
[. 17 presentation to the NRC after we alerted them to the j IS concern that we had under 50.55E in Washington some -
l months back.
1 19 That is all totally there, available right' l g 2o now, to third-party review. So I would hope that it will '
I j
t 21 be reviewed by a third party overall, and it is totally 22 documented on the project today.
23 l MR. LANDERS: I'm aware of that, Bill. I was 3 at the meeting when that presentation was made.- My 23 concern is that when you have a group of qualified I
i
- - _ - ~ _ _ _ _ _ _ _ _ _ __ __ . . . . .
37 1
vendors, all of them have been in the industry for a l
2 long time and subject to lots of review, and some of them 3
find the pitfalls in the specification and others don't; 4 how does that change your equipment vendor review?
'S That's my real question, and I'm just providing that as i
6 some input.
7 MR. TIMMINS: Any further questions at this point?
8 MR. CALVO: We are commanded by our fierce leader, 9 Vince Noonan -- and I say that with respect -- we have to 10 write an SER very soon into~the system. I highly agree 11 with him. Now, one of tha issues, the 11 programmatic 12 concerns, the main ones that we had, one had to do with
{ 13 external source issues, and also how we're going to 14 handle things like~new vendors, Westinghouse; and I guess
! 15 my question is: You say that you have reached the first i
16 level to ascertain that you don't have to review i 17 Westinghouse because it's just like the others and you.
j 18 ,still cannot (Inaudible) with the second level that I
l 19 you're going to confirm this so an auditable trail will
! i i 20 .be available to permit independent evaluation. I'd like 1 2
? 21 to know from you so we can complete our SER in the time i l 22 indicated by Noonan when you are going to have that 3;g information to us so we can write this thing up one way i
21 i or the other in the SER. We have to get the thing done h 25 l by December 27, will you have that information available !
, . , - - ~ . _ _ - . _ . . . _ . . . , _ . . . _ . . . .
38 I
to us by December 27 that an auditable trail that will
( 2 permit the staff or interested parties to perform an 3 independent evaluation, that you had done that?
4 I want to put that into the record. You think about 5
it, and before the day is over, tell me whether you're
'6 going to do it or not.
I 7 Another thing that I want to put into the record.
8 There is some allegations that we are currently 9
evaluating that have to do with SIT points, not .
10 especially with SIT points, but deal with the 11 Westinghouse design, the effects that we have for the 12 Protection systems. In those that surface up, have r 13 merit, that require further looking into, then we got l (
14 external source issues. Now, that puts you into a 15 position that you're going to have to look into the 16 Westinghouse or not. How are you going to handle those i
!. 17 things that does appear to be new allegations and new j 18 external source issues?~ They will be permitted to look -
19 into that-particular kind of design.
I
! 20 l MR. LEVIN: Not knowing the boundaries of that t
. {
i 21 l allegation, it's hard to answer that until we'see that, i
I i : i 22 l MR. NOONAN: Before we take that off, I have a i
23 1I question, two questions really. Who are the "others" on !
I
.,3 there? You listed "others".
l 33 { MR. TIMMINS: I was just coming back to that. This
(
f r
. . . - , ,--v.- - - - . ~ -a.~..--n--,---.n.-- ,-,-,-,-,,----,~n. ,~.,r--------- . -
I i
l 39 ..
I part of the pie is what I'm calling the " Big E" scope,
( 2 and I'm defining that basically as other than NSSS 3 equipment vendor. What I mean by "others" here is that 4 it's obvious the lion's share was performed by Gibbs &
5 Hill, but there have been other organizations, other 6
firms, that have performed the designs that are safety
- 7 related for Comanche Peak. You have TUGCO Nuclear 8
- Engineering that has been involved for the last couple of 9
years performing some aspects of design. We've had EES 10 Corporation. We've had Ebasco. So there have been 11 several firms that have performed pieces of the design 12 that we include under "others". So our scope of review 13 is the typical, if you will, AE scope, which includes 14 Gibo's & Hill, plus these others.
15 -_
MR. NOONAN: For the past two or three years -- I 16 i think since about the end of '82 -- there have been a s
l l
I. 17 number of I&E information notices that have gone out on 1
i is equipment vendors. I think the number is somewhere '
=
19
~i between 12 and 24, a couple of dozen maybe, more or less. ;
i 20 i They pointed out particular deficiencies in equipment i 21 l vendors. I can think of at least a co,uple of them that I
$ I 22 i considered fairly serious in the cable area. Normally r
2j those I&E information notices are the responsibility'of i l
l 21 the Utility to make sure they look at it and see how they 33 ; impact.. Are you going to look at that to make sure it
40 I was done?
( 2 MR. TIMMINS: We are considering those types of 3 things in our selection process for the specific items 4 that we will be reviewing. We are not going through on 5 an item-by-item-by-item basis through each information 6 notice. For example, on a specific programmatic basis, 7 where we will have more or less like a checklist, look at 8
this, then look at this; but the considerations of those 9
types of things which have been discovered as problems ,
10 within the industry or have been identified as specific 11 problems for Comanche Peak will be considered in that 12 selection of --
13 MR. NOONAN: I don't like that answer, because 14 there's not 1,000, it's only like 20 of them. Why
.can't you look at all 207 15 That's not a lot. We're not i
16 talking about hundreds of them, we're only talking i 17 about 20.
j 18 MR. COUNSIL: If I may, there's a document -
19 in-house, checklist, whatever you want to call it, that l ! 20 ha,s all information notices, bulletins, and circulars, f
21 and what action has been taken by us as licensee on each t t l 22 one of them; and those are in turn reviewed by Region 4, 23 and they have been with every one that has been done to 21 date.
25 MR. NOONAN: Information notices?
41 I
MR. COUNSIL: Yes. We have taken action on each and 2
every one of them, and I think that Tom can verify that 3 they --
4 MR. WESTERMAN: I know that we've closed out --
5 MR. COUNSIL: I'm not sure that we've closed them 6
all out at this point myself, but I know that Region 4 7 is, in fact, reviewing our actions on eli those, and that 8
also goes to info notices, IOER's, and SER's; and that 9 comes in through the nuclear network and our actions 10 taken on those, which are outside the scope of your 11 information notic'es and'so forth.
12 MR NOONAN: There are at least two on there, Bill,
{ 13 that are really design problems, vendor design, not AE
, 14 design.
15 MR. COUNSIL: Understood. Those are all followed on
, 16 project.
l
'i
~ 17 MR. LEVIN: Vince, I think you'll see later in I
i j 18 Doug's presentation where he' discusses some of the bases -
[ 19 i for selection of specific items for review, and a very i
1 .
i 20 important criterion is, in fact, being sensitive to '
2: either p;oblems that have existed here on this project 22 ) or within the industry as a criterion fer biasing a i 23 ! sample one way or the other; so while we have not 3; made a commitment to specifically look at every IE 23 , notice, we believe that we will pick up those important :
l i
. .. . . _ _ _ - _ _ _ . _ . . . .._ ._._. .J
l l
42 l
- 1 issues like, for example, the two you have mentioned. I
(. 2 would be particularly interested in those that you 3 believe are --
l ~
4 MR. NOONAN: Both in the cable area.
5 MR. COUNSIL: We have an internal review right now 6
on metal insulated cable. That came up several years 7 back. It's being revisited again today.
8 (A short break was taken.)
9 MR. TIMMINS: I believe we have a question on this 10 alidi.
11 MR. NEVSHEMAL: My name is Nevshemal, and I have a 12 question with respect to your statement about not looking 13 at the NSSS. It is my understanding that there are 14 certain systems in the plant that the NSSS remains 15 responsible for from a design standpoint, but the AE has 16 certain portions of the design process under their
! 17 responsibility, for example, pipe routing and things of
(
is this nature. So during the design process there is an -
t
- 19 l
interchange of information between the AE and the NSSS i 20 where the NSSS does both the design calculations. Have f 21 you documented whether or not there are systems of this I
22 nature that allow you to say that you will not be looking-at 23 that portion of the design process within the NSSS, or 3; i do you intend to document this?
1 '
25 MR. TIMMINS: We have not reviewed those types of
l l _. . . . .
l 43 I
areas to date, but those are the types of things that we
(, 2 would be looking for as part of the confirmatory work I 3
i that we would be looking at relative to issues c6 ming out
! 4 of the architect / engineer's house and resolution of I
5 l design at that interface, so we will be looking for those l
6 l
types of systems- if you will, or processes there that 7 would help us confirm that the interfaces at that point 8 have been properly handled.
9 Where we had left off is I had defined the scope of .
10 design review for DAP, and I want to take just a 11 moment -- and I'm going to come back to this slide later 12 on -- but I just want to take a moment and try to focus 13 your attention-a little bit on what one of our end 14 products. When we're talking about the DAP scope of i
15 review, we are looking both at breadth and at depth, and 16 the breadth of the program is reflected in what we call
! 17 the matrix. This happens to be an example of one of the i
18 i mechanical matrix sheets, and when we're looking at the -
i
' I
! 19'i design of Comanche Peak, we are looking at design i ! I l
i 20 ' activities, and design activities are on the left-hand e
2 l
21 side of.each one of these matricws. And there are many, l
22 many sheets which define what the design activities are.
l 23 Also on the matrix we're calling out what organizations, 21 performed the design, and we're also providing amplifying 25 ; comments over in the " Comments" column. All I wanted to 1
A
~ -
- l 44 I
do is just calibrate you for a moment that onc of the end
( 2 products that we're after -- and I'm going to be 3
discussing how we get to that end product in just a 4
moment - is a list of des'ign activities which reflect 5
the engineering tests that have to be performed, the 6
engineering safety-related design scope.
7 Now, how do we go about defining what those design 8
activities are? First of all, we've got seasoned 9
engineers performing the review that were icyolved in 10 Phase 3 who are familiar with 7.he architect / engineer'c 11 design process, and in the process of identifying these
(
12 design activities, we are looking at a wealth of data-
{ 13 coming in to what I have called a data base for review.
I4 The people involved in Phase 3 reviewed this data base as 15 a means of assuring that we had defined all of the design 16 activitiea that were required for the AE safety-relsted h 17 scope, 18 Now,'the bulk of the informatipn is coming in from 7
19 Gibbs & Hill, the architect / engineer, in the form of i 20 criteria and in the form of indices which list the 3
i 21
, different things such as specifications, calculations, 22 drawings, output drawings, intermediate drawings and so
~
u forth, that reflect the design for Comanche Peak. We're 21 also looking at data, similar data, from other design 3 j firms such as TUGCO Nuclear Engineering and other design i
45 I contractors.
( 2 Now; in the review of this information from the
- 3 data. base, we developtd a list of design activities 4 which through secondary reviees of regulatory 5
13formati0n provided a confirmatory check from looking at 6 this information that, indead, our original lists of 7 design activities were comprehensive. We also included 8 '
au part of the criteria the licensing commitments in 9 FSAR.
10 Earlier in the discussions, Mr. Calvo asked about i
11 caternal sources. The information, the external sources, 12 is also fed into this process; on this slide, through the
, r 13 word "other," has been incorporated. And as another part i
14 of this program, the comments from NRC that wera provided l
15 to us on Revision 2 of the Program Plan were also l
l 16 construed as one of these regulatory-related inputs in i 17 our confirmatory check.
)
t j 18 Now, this is a tather complicated chart, and I'm not -
j 19 going to go through it in detail, but just try to.
l i
20 calibrate you a little bit on how ons went through that
! 21 wealth of data that I just alluded to on the previous '
i 22 ,
111de to define our individual design activities. This 23 slide represents a decision process, if you will, that i
24 allowed one to go from all of the data associated with 25 the engineering scope of Comanche Peak down to individual l
46 I
design topics at the bottom.
2 For mechanical, you would have a sorting process 3
from all of the scope to that that is applicable to-4 mechanical. Some of it is associated with system design.
5 Some of it is associated with analyses. What I mean by 6
"some of it", I'm talking about that data that is being 7 reviewed. And the engineers, as they went through the 8
review of this material, mentally went through this type 9
of review process. At this point they would sort out 10 those that are non-s,afety related, and then they could 11 break it down further, the data, into that associated 12 with fluid systems, building services, process systems --
{ 13 for example, radiation monitoring -- snd then a further 14 breakdown to the component system level. And then once 15 one_gets down to the component system level, as far Gs 16 a sectioning this information, it can be further boxed, if l i 17 you will, into areas dealing, like -- for example, j 18 functional requirements, operating limits, operating -
19 modes and so forth. So this slide, let me emphasize, is i 20 associated with a mental process that engineers were 21 3
- going-through in order to get down to a level where you
! 22 had similar design activities, similar information, thac 23 was small enough that an engineer could deal with the i-24 ,
data ih a mancgeable fashion to Identify the individual l *' l 25 design activities. i 4
.. _=_ . . - .
47 1
) t. CHANDLER: Excuse me, but how is that mental
( 2 F process being documented?
3 MR. TIMMINS: The concept of this type of process is 4 documented in the engineering evaluations.
5 MR. CHANDLER: Could you elaborate a little more on '
6 that?
7 MR. TIMMINS: This is the type of process which any S
engineer that is seasoned in the design process of an 9 architect / engineer could go through in his mind from the .
10 world of data down to these types of boxes, as far as 11 topics review areas.' The fact that this type of decision 12 Process was used by the engineers to get down tc this 13 point, which is where we start to define our design 14 activities, is explained in a conceptual nature in the 1
15 engineering evaluations, but each cne of these decisions i
a 16 for each piece of data, which would be very voluminous, j 17 is not documt aed. The concept is documented.
i IS , MR. CHANDLER: In other words, it's sort of like a - -
i j 19 prototypical approach. .Thir is the way an engineer would 5
l I
, i 20 ,
go about doing it. If I were an engineer, hero's how I i
21 would do it.
z ,
22 MR. TIMMINE That is correct, and these diagrams i 73 l reflect the thinking of the Discipline Coordinators of I 21 each one of the disciplines that did that review.
i 33 MR. CHANDLER: Assumed thinking.
= _
t
.c .
_ . . . _ - , , - . . , _ , - , , , , . _ . , - _ - -____m__ .,_.,------,_..,.._.__,-,,,_.....,..__-,.,_e,. -
~
48 1 1
MR. TIMMINS: It! reflects their thinking as they're 2
documenting it in the figure related to their discipline 3 that they generated.
4 MR. CHANDLEP But it doesn't reflect what 5
necessarily occurred-in the process. It's what you 6
assume occurrad.
7 MR. TIMMINS: It's not my assumption. It's the 8
Discipline Coordinator who did the review, that 9
documented his mental process in the forza of one of these 10 figu5es. I'm not assuming that it's the Discipline 11 Coordinator.
12 MR. CHUlbLER: I understan6 it's not you per se r but 13 somecne is making an assumption that this is the way the 14 process occurred. It'.t not necessarily that the process 15 did occur.
16 MR. TIMMINS:
I understand your point. Let me put
! 17 it a little bit differently. When you're saying it's i IS something that we're assuming as far as the process " -
f 3
19 occurred, it is the process that that 2ndividual said I ?0 that he took in breaking down from a world of data down
- l I
4
?
21 to a manageable level that he can apply, that he can 22 define his design activities for. It's that individual 23 saying what the basic structure was of his mental process 2-1 that he went through, so he's saying what he did. It's i .
25 not his assumption, because he's the one that performed L- _ . - - - - . - - - - - - - - -. - - - - - - - - - - - - ~ ~ ~ ~ - - ' ~ ~ ~ ~ ' ~ ' -
49
, ~
! that review.
( 2 MR. CHANDLER: He's performing a review that 3 recreates the design process.
4 MR. TIMMINS: He's performing a review which allows 5 him to just go through various screens from thousands of 6 pieces of data down to a level of data that he can then 7 apply additional criterit to to get to his individual 8 design activities. It's merely a means of sorting data 9
in different boxes mentally, such that he can get to a 10 manageable group of things to apply some refined 11 criteria.
12 MR. CALVO: I'm not a mindreader. Neither are a lot 13 of people working for me. I guess the question I'm 14 pondering: Do you F1ve an auditable trail that will 15 permit an independent interested party to verify how that i
1 16 mental process went through? Is the information there 8
17 that an independent party can verify or ascertain how you
[ 18 did it? -
3 19 MR. TIMMINS:
Let me respond to that in a different i 20 way. I understand your point. '
l 21 MR, CALVO:. All I want is a yes or a no. That's all
! i !
22 I want. I don't want a lecture. I just want to get to t
23 the specifics. I want to know whether you have it or 34 .not. If you give me a maybe, I'm satisfied, and I won't ,
25 ask you for an explanation. !
, y - , _ _ , _ - , , - - , - . . - , . _ . - - -, ,,-.,,.,y
l
^
I 50 '
1 MR. TIMMINS: The concept is documented.
( 2 MR. CALVO: But the concept is not the auditable 3 trail. I want to know the documentation; the documents, 4 the drawings, everything that you used to reach it.
5 MR. TIMMINS: All of the source documents that were 6
4 used, starting up here, are documented in the engineering 7 evaluation, and one of these types of figures for each 8
discipline is documented in our engineering evaluation.
9 i
The concept of going from here to here is documented in 10 the engineering evaluation.
11 MR. CALVO: So with the engineering evaluation the i
12 only documentation I can recreate is mental process, and 13 presumably at the e'd n the minds will meet.
14 . MR. TIMMINS: I believe that on a discipline-by-15 discipline basis, engineers which have AE' design type of l
l ,
16 understanding of that process and that are seasoned
{. 17 engineers in their disciplines would not argue with this i j 18 type of breakdown.
~
e ,
19 MR. SOFFELL: At what level is your engineering I ;
i 20 evaluation written? Is there an engineering evaluation ;
a
- 21 written for each of these disciplines?
z' o 22 MR. TIMMINS: Yes. I 23 MR. SOFFELL: So in essence, there are six i
3; engineering evaluat.ons then? r
,u '
25 MR. TIMMINS: Let me back up here. We have four
(
1 b
51 _.
1 engineering evaluations. Keep in mind I'm speaking to
(, 2 the self-initiated review' principally. You have civil /
3 structural, instrumentation control, mechanical and 4 electrical. This is just kind of a restatement relative 5
to the NSSS and vendor design that we are not looking at 6
those internal designs. Piping and supports is being 7 handled separately.
8 Mypurposeforgoi$gthroughthisslidewasto
'. 9 briefly discuss that process that allowed us to get down -
10 to this level, which we considered to be a manageable 11 number of data which we could apply additional criteria 12 to define our individual design activities. That's on 13
{',
the next slide.
14 MR. NOONAN: I want to make one comment on the 15 documentation. It's okay for you people to sit there and l
16 tell us how you did it,.because that's exactly what you
$ 17 did. It's difficult for my staff to sit down and j IS articulate an SER or in front of a hearing board on how
\ ~
j 19 they determined the process-was done right. They can't i 20 ! go by what they hear. They have to go by what they see e i '
L 21 . on paper. That's where Jose is coming from. He has to ;
22 sit down and have it on paper so he can say, "I looked at !
23 1 !
the documentation and I am convinced it's there." Not I F !
23 that "I heard it," or "I listened to him and he told me ;
' i l {
25 l ,
how he did it." That's not gotng to hold water. That i
52 -
I will hold up my SER if that's not there. That's all.
( 2 MR. TIMMINS: Let re speak just a moment about 3 homogeneous activities before I get into this slide.
4 We had from Revision 2 of the Program Plan 5
< identified that we were going to look at auxiliary feed 6
water in a vertical slice through the electrical power 7 system, and our goal was to scpplement that scope with 8
what else was necessary in~ order to encompass the AE 9 safety-related design scope. So we had to have a means. .
10 One, crisply identifying the various engineering tests 4
11 associated with the overall scope, and secondly, insure
.12 ourselves that we had a comprehensive scope. So we -
j 13 chose, after going through the mental process on the 14 previous sheet as kind of a sectioning effort, to use l 15 what we call homogeneous design activities to further 16 this process.
i i !
j 17 Now, a homogeneous design activity is a design i
l
,t l 13 activity which is representative of a collection of l I
19 i individual tasks which one might perform which are very }
i i
20 similar in nature, similar in criteria, design
! t h 21 considerations and approach, similar in organizations, !
-22 similar to design control processes, including design 23 interfaces, i
t 21 Let me elaborate just briefly on that. If you have ,
i 33 two different organizations involved performing design, r
i f l
_ _ _ _ _ _ _ _ _ . . _ _ - . _ _ _ _ _ _..___ . _ _ _ ~ _ __ _ ,. . _ , ._
53 2
1
'and they perform design for a similar design activity,
( 2 that constitutes two separate homogeneous design 3 activities. Therefore, we would review a piece of design 4 that each organization was associated with. Similarly, i
5 we applied that down through the discipline levels within 6 the organizations, if you have -- if there would be a
-7 need in order for something to be considered a homogeneous
-8 design activity for similar design control processes to 9
have been applied to those design activities and that the .
10 design interfaces were the same. They would also have to 11 hree similar design considerations and approaches and 12 methodology, such that -- and when an engineer performs '
{ his tasks that he would have no meaningful differences 1
13 14 within that group that could influence the end product l -
15 that he was trying to generate in the design process.
16 So our means of getting at homogeneous design i 17 activities was a process which allowed us to define the
[ 18 discrete tasks associated with the engineering process, '
I*
1 19 and also to assure ourselves that we were comprehensive.
i 20 MR. SHAO: Let's talk about organization, ,
21 civil / structural department. Civil / structural department i i 1 22 there's concrete, there's structural steel, they have t
q supports. Do you consider that as one organization, or t
3.; do you consider it a separate organization?
25 MR. TIMMINS: We looked at the homogeneous design i
n ,- i
_, _a '-^^ '
54 _
1 activities down to the discipline level, like mechanical
(. 2 discipline, civil / structural discipline.
3 MR. SHAO: So you consider all civil one discipline?
4 MR. TIMMINS: We looked at, relative to the
- 5 discipline, Gibbs & Hill, which had additional 6
disciplines that had related activities to what one would 7 typically call civil / structural.
8 MR. SHAO: Can you give me an example of 9
civil / structural under one discipline, or do you consider -
10 separate discipline in the civil / structural?
11 4
MR. TIMMINS - Gibbs & Hill has a structural 12 discipline, a civil discipline arc a special analysis
, 13 discipline, also forming what one might call in other 14 organizations civil / structural. i 15 MR. CHANDLER: Doug, you used, I think, when you 16
,8 talked about design control process and some others, you '
! 17 used the word "similar". In design interfaces you used i j 18 the word "same". Did you mean --
i 19 f MR. TIMMINS: Am I trying to draw distinctions?
I i 20 MR. CHANDLER: Are you trying to draw distinctions, l i : '
I : 21 a or do you mean same or similar?
.i 22 MR. TIMMINS: I am not trying to' draw distinctions
[ 23 between the.two. What I mean here on design control 21 processes is that basically you would have, is that you 25 would have had the same design control procedures in the !'
- - - . .-- - .- --- . - - ~ . _ - - . . - - . _ . - . ...-. .
55 2
1 sense that there may have been some revisions to those
( 2 procedures, but the question becomes: Were those changes 3 meaningful or not to where it could have' influenced the 4 design process? You can have changes to procedures over 5 time which may ~not be meaningful in having an actual 6 impact on the design process, so when I say "similar," I 1
7 mean similar in that vein.
8 MR. CHANDLER: How about when you use the word i
9 "same"? Do you mean literally same?
10 MR. TIMMINS: I'm not trying to draw a distinction 4
11 between same and similar. I guess I should say in answer 12 to your specific question, similar design control
, 13 processes in that there is the flexibility to have 14 revisions within those design control processes, which 15 may not be meaningful, and in that case would not cause a i
16 separate design activity to be defined.
i 17 MR. SHAO: Back to my question. You say you have a i
IS civil, structural and special, right? -
\
s' 19 MR. TIMMINS: Special analysis.
l ! 20 MR. SHAO: And you're going to look at three 4
l 23 samples.
( 23 MR. TIMMINS: It depends upon the particular designs l
23 that those disciplines perform. If those three '
i 33 disciplines perform separate parts of the design, then we
( "
33 will be looking at those different disciplines, not 1
-____ _ _ _ _ _ _ _ _ _ .~ _....--.__ -_.- . ___ . ._._.,. ~ - . _ _ . . . . . , . . . . _ . . - . . . _ . . _ , . , _ - . . . - , _ . . . , , . _ . . , , . . _ .
56 -
I because you have three disciplines, but because you have
( 2__
three separate parts of design that you have to look at.
3 l If two of the disciplines perform the same type of design 4-over time, then we would need to go look at two pieces of 5
design .'ur that same type of activity, because two 6
different disciplines were involved.
7 MR. CALVO I know you would be the right guy to
- E8 answer this question.
Why homogeneous design activities?
! 9 ~
Why you elected to put them in the homogeneous -- what do 10 you hope to accomplish? What is the information you try j 11 to get_from them?
Give us for the record the importance 12 of that.
13 MR. TIMMINS: Two things: .One is that we had 1
14 i
identified a scope in Revlsion 2 of the Program Plan, and 15 one said if I'm going after the AE safety-related design, i
16
~
how do I define those engineering tasks such that I can
! 17 sort out Phase 2 from Phase 37 In other words, how do I g 18 determine what my delta is that I have to supplement '
19 Phase 2 scope with?
i So we chose to define what we call 20
- design activities, or homogeneous design activities in 21 3
i this case, as a means of defining those types of 22 engineering activities so that we could identify to a
23 ourselves what we needed to supplement the original scope 21 with.
. And secondly, by going through this type of 25 Process, which was on the upper part of the slide, in
57 2
1 allowing us to get a more comprehensive picture of what
( 2 was going on relative to the things that might influence 3 the design such that we could have a firmer conclusion 4 relative to our review of the design at Comanche Peak.
5 So it was for comprehensiveness and a means, or a 6 vehicle, if you will, to get to that delta. After using 7
the homogeneous design activity for those two purposes, 8 you actually go to the checklist level, which I'm sure 9 you're aware of. The review is performed to the
.10 checklist, so the homogeneous design. activity only serves 11 as a vehicle during that interim period. Prior to --
r t
12 MR. CALVO: But it becomes also the vehicle to i
{
12 prepare the checklist, correct? i 14 MR. TIMMINS: It becomes a breadth definition of the l 15 Program, which then drives the depth to the checklist, f l 16 MR. CALVO: Each homogeneous design activity would i
i 17 give me the depth,-but also as I'm going deep into the i 18 design, I'm also projecting it horizontal to tie with the - ,
/ :
19 other design activities that also are going deep into I
! 20 whether the design was done. So I guess -- it looks to i
! i 21 me, some kind of way it appears to me that the !
f- [
l 22 centerpiece of the whole Design Adequacy Program is the l
23 design activities homogeneity. Some kind of way you're 21 trying to put our arms around all the external source !
l 25 issues and come up with a good understanding of whether
1 58 _.
1 the design process was done and make inference to new
(~ 2 allegations.
Is that the purpose of the homogeneity?
3 That's the purpose as the staff sees it, what'your self-4 in'itiated review is going to accomplish through this 5
concept of homogeneity design activity. I guess the 6 question: I say, why do you call them homogeneous? Why 7 do you call them design activity? Why do you have to go j 8 through all this in here, how many yeu started with, how 9
'many you got right now? 'Was that a worthwhile effort to 10 summarize or -
MR..TIMMINS: I have to go back to what I said just
~
11 12 a moment ago, Jose, because it's what~is meaningful to me 13 in the homogeneity design activities. One key thing is 14 what vehicle to use to crisply define the design that's 15 within Phase 2 in order to get at that delta that you 16 have to get to to have the overall AE safety-related l j 17 design scope.
, i is The mental process prior to this, shown on the -
I l' ;
I 19 figure, and this process here, provides the vehicle to do E 20_ that.
i 2g e
- MR. CALVO: And pretty soon you want to do that 22 because you don't want to do any other activity. You 23 , want to only include those that are different from the l
i 23 ones you did before, because you don't want to have i
25 repetition with them, right?
l
~
59 I MR. TIMMINS: That is correct.
( 2 MR. CALVO: Next question. So if I'm going to 3 Bethesda next week and look for you, the mental process 4 that you had -- I'm not a mindreader -- but I want to go 5 back to the documentation, to the engineering-evaluation, 6 that you had. If I go there, is that information 7 available for audit at this time? Keep in mind that you
> 8 are developing checklists and everything else, so this 9 mental process some kind of way evolved to the checklist 10 level. I'm just wondering if it had developed that then 11 you had already established some design activity for 12 homogeneity, so the process that went from before to this 13 process, to the design activity homogeneity, there was '
14 some engineering evaluations, to permit an independent i 15 evaluation by an interested party. Is that information, [
i a
16 is that'auditable trail in place? !
i 17 MR. TIMMINS: The a.nswer is yes and no. !
1
_} 18 MR. CALVO: You give me a maybe, and I don't know -i
=
l 19 whether I want to-hear a lecture on the maybe, because [
l i t
! i 20 every time you lecture on a maybe, I always and up with a i .
! 21 yes or no --
I i 33 MR.'TIMMINS: May I amplify that, please? There is !
an auditable trail in your definition on the last three 23 '
33 bullets on organization design control process and design 25 interface on~how we got to that point, and that is I l
4 60 I documented in the Phase 3 Scope Validation Evaluation
( 2 Summary Report.
{
3 The first two bullets, dealing with similarities in 4
criteria or a criteria category, if you will, and design 5
. considerations, similarity in design considerations, 6
approach and methodology, is that piece that was carried 7
on on the individual discipline basis primarily by the 8
, Discipline Coordinator, based upon his understanding of 9
the design process and his personal knowledge and 10 experience.
11 MR. CALVO: Written down or in his mind? i 12 MR. TIMMINS: It's conceptually spoken to in the 13 engineering evaluations. You will not find on an item-14 by-item basis for each design activity an auditable trail for each design activity on these two points.
! 15 i
16 MR. CALVO: It is written down or not? Answer the
! 17 question. You bring me back again to the global, to the 18 conceptual thing. We're not there anymore. We're right
=
19 here with one month to approve the Program Plan. I want
'i
! 20 to know whether that thing is written down or not.
I
! 21 cannot read minds. You must say yes or no. Keep that in i
22 mind, and go to the next one. I just wanted to be sure 23 it's an auditable trail to permit an independent party to 7; perform an eva'uation so we can write an SER.
25 MR. LEVIN: What he said is that the Icst three l I
\
6 -
i 61 m I bullets are, in his opinion and in mine, and the first
( 2 two are not.
3 MR. SOFFELL: Will they be?
4 'MR. BECK: We're going to have to look at that. .It 5
is not a simple process, as you're we~ll aware, and the 6
effort required to go back and document that mental 7
checklist, if you will, or check-off process is not a 8
trivial task.
9 MR. NOONAN: I'm not sure that we're aware of that, 10 though.
11 MR. BECK: We need to address the issue clearly. We 12 have to address it, and we're going to have to take it
{ 13 under advisement. I understand what's needed. I I4 understand the reason you need an auditable piece here.
15 Let us retreat and consider how we can satisfy your 16 needs.
i
! 17 MR. NOONAN: I think part of the problem, at least IS
-I from my_ perspective in listening to my staff, maybe we're ~
19 not sure how complex that is. We have a certain i 20 perspective. We think it can be done.
You're saying
- ! 21 that you think it's more complex than that.
22 MR. BECK: Complex is probably the wrong word, 23 Vince. Large. The winnowing process is relatively l 2. simple. It's just that there are an awful lot of steps, 25 and there will be a tremendous amount of paper if you
62 I
documented each time this was done in those first two
( 2 categories, as I understand it. We need to go back and 3 see how we can satisfy your legitimate concern and 1 i
4 requests.
5 MR. CALVO: You're~ proceeding on the same basis 6 that, I guess, with the young Hansel. Sometime you move 7
ahead,' compare the checklists, you know, for the
~
8 implementation, and the centerpiece of the program.has 9
not been anchored yet, and here we are again making the 10 same mistakes we made before, we are making here again.
11 We are getting involved with implementation ~of the 12 program, and we have not approved the Program Plan.
r 13 MR. BECK:
( Anchored in the context that there is not 14 a piece of paper for each of one of those considerations 15 in the first two_sategories, you're right. It does not
(
16 exist.
- The answer that Doug and Howard gave was no.
! 17 Please let us go back and consider --
IS
! MR. HANSEL: John, I just want to say that it's more -
2 19 than our needs.
i 20 MR. BECK:
I'm personally satisfied that the process j 21 was one that was objectively exercised. It's been tested i
22 at the bottom line a number of times. That test, as I 23 understand it today, does not substitute for the paper, i
- 21 but we'll have to deal with it.
l -
33 MR. MILHOAN: John, I can take on the individual
,--wn,-c-v-e< -
,e-, - , - - ,-n.- n,--,---..~ ,,---v---- , , ---v--,N-
63 _ )
I homogeneous design activity, the last thr'ee bullets for
( 2 individual homogeneous design activities. Those three 3
items might be described on a global basis, but I don't 4
think you would find an item written down for individual 5
homogeneous design activity, so it is a complex process.
6 So when you're considering it I think you'll have to look 7
at the last three bullets also.
8 MR. NOONAN: I'll make one more comment, and then 9 I'll get off of it. I think part of the disconnect that 10 occurred here was when the Staff came down to the site 11 and they'went out to Bethesda and looked, we came down 12 here and we found that trail we were looking for. We 13 found the documentation, knew it was sort of in place.
14 We said, "That guy is there. We have it." On the other 15 side of the fence, we don't see it, it's not there, and 16 we don't understand fully why, the Staff doesn't. It
! !. 17
- could have been probably expected to be the other way 18 around. Right now, we've said we came on the site, we're 19 i pretty well -- we found just.about everything we were
! 20 looking for, I think, basically. It's not happening on e 21 the otber side. It's a slower process, let's put it that I
22 way.
23 MR. LANDERS: Doug, one of the concerns may be we I
21 define here today and in past meetings what you mean i 33 ,
about the last three bullets, but you don't define what I
4 64 1
you mean about the first two. Perhaps we all have
, ( 2 different ideas of what criteria or criteria category are 3 and design consideration. If you could define that, it 4 might help.
5 MR. TIMMINS: I will try to define that by the use 6 of some examples. I know some of you have heard this 7 example before. I will use it again. Relative to j 8 criteria, I will give you two examples. One is that of, 9
let's say, atmospheric storage tanks. There may be 10 f several atmospheric storage tanks associated with the 11 safety-related design at Comanche Peak. The type of 12 i
criteria associated with those tanks is very similar.
13 j{ There may be quantitative differences in some numbers 14 that are involved in the design of each one of those 15 tanks, but they're not meaningfully different in the 16 sense of what an engineer has to consider when he goes 17 about design..lg an atmospheric storage tank.
j 18 Another case night be that of centrifugal pumps. He
- i
=
19
- may have several centrifugal pumps in safety-related I i 20 systems. You have section considerations, NPSH
=
i corj si % cions, discharge considerations, et cetera.
i 21 The ;
22 types of considerations that an engineer would go through !
t 23 in c 2ar to specify the requirements for that pump and in 21 l . order to design the interfaces between the AE scope and ;
l-l 23 vendor scope luould be very similar, and you would be :
i i
I
+ .
65 I able to apply those types of design considerations to
( 2 various centrifugal pumps.
3 Again, I get-back to the word " meaningful". I have 4 to amphasize that, such that an engineer can perform a
- 5 similar type of design process, similar type of 6 engineering test, and is there something meaningfully 7 different in those tests that would cause hbn to do 8
something different. And'that's what I'mean by 9 similarity in criteria and in design considerations. You ,
10 may have different people with different opinions of the 11 thresholds that are involved here, and I think that's i
- 12 where some concern may come about, but if I have to go
, 13 back to the word " meaningful," it would affect that 14 engineer in performing his. design task. ,
15 MR. NOONAN: We're talking about this a. lot, but I ;
16 guess really from my perspective and the Staff's, we're ;
. 17 not talking about -- this is not a major glitch that we '
i 18 see here right now. We can see this is something that '
l ;
x*
19 takes time to put it down and get it here. I would guess ,
i 20 we're talking a matter of a week, week and a half, to j 21 satisfy the Staff.
i
- i MR. BECK: I would reiterate, Vinc6, that I just 22 l
23 made a statement a few minutes ago that I'm satisfied the [
21 bottom line we've reached with regard to the breadth of 23 design activities that are going to be investigated and l I
c._- _
66 2
1 the depth to which this prccess is going to take place is
( 2 sufficient, when implemented, to satisfy an extra expense 3 of this type. What we're talking about is one segment of 4
that that forms the basis, an important basis, on how 5
that process was accomplished and documented. We simply 6
need to go back and see what we can do.
7 MR. NOONAN: I just got a little concerned when you 8 '
said, you kind of indicated, a complex situation. From 9
our standpoint we don't look at it as being something 10 complex. We think it's relatively simple --
11 MR. BECK: I agree with you, it's simple, but it I 12 happens many, many times. That's the question.
13 MS. GARDE: I would just like to comment on the 14 discussion that has just taken place, that CASE has asked '
15 for this material in the discovery in the licensing l 16 proceedings, and we're concerned about this, what we '
i i 17 refer to among ourselves as more of the eyeball approach, j i is and that things are'not being written down at this level -:
I 19 f and/or that. applicant is receiving advice or comments on
}l i
20 approaching methodology from a group of individuals who
('
l, t
21 have not yet been identified. That is, that even the i r i 22 People that are now working on this program for any one !
23 !
particular system in-the examples that you gave are not '
l 21 the only individuals who in the beginning, as you were !
b 23 developing your program, came on and gave you their i- - . - . . . - - _ . - _ _ - _.. . . - - - - . . - . .-. . - - _ _ . _ _ _ - - . - - . . . -_ . 2
67 i
1 opinions on what could and could not be done, or how it
( 2 should not be done or how'it should be approached, and 3 the different methodology.
4 I'm not asking for an answer, but I just want to 5
make it real clear at this point that this is the type of 6 material that we're seeking.
7 MR. TIMMINS: May we proceed?
I'll just briefly
- 8. retouch on this slide. ,
You've seen it before. The 9 design topics at the top are those bottom boxes of the ,
10 figure that you saw earlier in my presentation. The i 11 approximately 500 design activities are those that are on 12 the left-hand column of the matrix, and the attributes
{ 13 spoken to here are associated with the checklists that we 14 have spoken to. If you sum the individual attributes 15 that are going to be reviewed on the checklists, come up i
16 with approximately 6500, and then the number of times j 17 that a checklist reviews -- and that's taken into
- j 18 consideration -- then that's where approximately 51,000 19 comes about.
7 i 20 Now, the design actually takes place here -- not the i : '
design, but the design review -- and again, I just want
? 21 i
22 to reiterate that the homogeneous design activities is a !
23 ' vehicle to generate the checklists to be used in the 1 [
24 I'VI'W*
23 i Now, I'm going to take just a moment and speak to ,
I ,
. ___ . . _ . . ~ _ _ - - _ _ _ . - - , . - - - - - _ _ . . . - . , _ _ . . _ . . _ _ , _ . . _ - - , . . - _ . - - _ _ -
._-._..-...,2
l 68 -
I this, but not in depth. As I have mentioned, this is the j 2 left-hand column, or a list of homogeneous design 3 activities. The latter three column headings here refer 4 to organizations. GH refers to Gibbs &' Hill, TN is TUGCO 5
Nuclear Engineering, OC is other contractors, and that OC 6
is the others that were referred to in the pie chart as 1
7 performing some of the AE activities. And where we have 8
an *0ther," that is defined'over on the right-hand side.
9 I'm not going to go into this in the presentation, -
10 but for your information, in your packages it's defined 11 what these various acronyms mean. Here they are 12 ass 9ciated with general review areas associated with
{ 13 scope of the program. The X's indicate where particular 14-activities were included in Phase 2 or Revision 2 of the 15 Program Plan. When you come across from the left-hand 16 l side to the right-hand side up to the point where you i 17 have organizations listed and there are no X's, that's an j is indication of an addition based upon the Phase 3 scope '
a' i
19 effort.
i 20 I think that's all I'm going into on this slide.
i ,
! t t
l 3 21 Now,-within our program we have some design
(
i l 22 l activities which we are defining as givens, and at this <
t I
23 point we have actually two types of givens, what we call l 24 j generic givens and then what we call candidate givens. :
\
23 :
I'm going to speak to the definition of a given and the i
.- , _ - . _ , , , , . - . , , , - _ _ _ - , , , , . - - - - - . , , , , .c. . _ . . . , , , , , _ . . . ,_,.y.~~~_,,e._,. . . - .
69 1 generic givens first. A given is a design activity or
( 2 criteria or area of design which is considered correct 3
and will not be reviewed under the Design Adequacy 4 Program. A design activity might be looking at MPSH for 5 a pump. A design criteria might be that in an IEEE 6 standard or the ASME code. An aren of dasign might 7 seismic equipment qualification or fire protection.
8 Now, on generic givens, these are givens that we're 9 defining at the program level, and they are areas that we 10 are going to consider correct and will not review. The 11 requirements within industry codes, standards and 12 regulatory documents we will consider correct. We will 13 review how they were used and incorporated into the 14 design, but we will assume that the attribute within 15 these particular codes and standards is correct.
16 The typical postulated accidents and protective j 17 actions that are defined in the FSAR we are going to j is consider correct.
19 z.
As we have stated earlier, the NSSS design scope
, i 20 we're going to consider correct and will not review; t : >
! i 21 however, we will be reviewing the interface, and '
- 22 similarly for the equipment vendor as.we spoke to i
23 earlier. -
21 Also, for unresolved industry generic issues, we are 25 not in our program going to usurp the authority in the l !
l l
~
70 I resolution of those types of issues. We will review the
( 2 design up to the interface point of those generic issues, 3
but we will allow the resolution of those-to stay within 4 the industry and regulatory bodies.
5 And we are not going to review the attributes that l
6 are related to the original plant siting and site 7 suitability study.
8 Now we have what we call candidate givens. What ,
9 candidate means is that we have defined it as a .
10 candidate, to be later defined as a given at this point 11 in time. And that is to say that we will have to do some s
12 level review in our program to determine whether a l 13 candidate given actually meets the criteria which we are ,
l 14 going to use in order to allow that area not to have to 15 be reviewed any further in depth. The criteria we're
, 16 using for candidate givens is that'the area should have i 17 received an indopendent technical review. To our j j 18 knowledge there's no question about the review's quality -
i 19 or the independent results or the reviewer expertise that i 20 ,
was associated with that review, and-that the review was i ! l '
? 21 comparable in scope and in depth to what we would have '
i 22 l' done under the Design Adequacy Program. If some ,
23 i particular design activities we believe at this point may :
3.; ; have these qualities, then we have defined them as ;
I 33 J t
candidate givens, and we will, however, have to review i i
y
~
71
- I further the documentation that would back up these types
( 2 of assumptions in order to determine that, indeed, they 3
l were givens and therefore not review them any further in 4 the program.
5 MR. SOPPELL:
When you say " received an independent ,
l 6
l technical review," are you talking about internally or 7 externally or both?
8 MR. TIMMINS: I'm talking about independent relative 1
9 to third party, if'you will, other than TUGCO. CE, some 10 other architect engineering firm, could have performed a 11 review of an area for a particular reason. It may have 12 received other reviews by consultants.
J l r El MR. SOFFELL: CYGNA7
(
! 14 MR. TIMMINS: We're not taking credit for CYGNA. :
15 M3. SOFFELL: NRC7 i
, 16 MR. TIMMINS: NRC may be considered, depending upon l
8
- 17
-- the key to this is the scope of the review, the depth !
i is
(
- of the. review and how well it was documented. We have to i
19 go after those pieces to determine if.it's a given,
\ l i 20 independent of who that party was, !
i 2 21 MR. CALVO:
i I just hope you will have a good
(
22 auditable trail when you do that. I 33 MR.,TIMMINS: I hear you, Jose. !
24 MR. CALVO: I try to make my point, but I feel that I 23 I have not quite yet made it.- !
[
r I
~
72 1
MR. TIMMINS: This is our list of candidate givens.
(. 2 They are items which at this point in time we believe may 3 have the qualities to meet the definite criteria on the 4
previous slide, and that is benchmarking of computer 5
codes, containment sump design, high energy line break 6
analyses, seismic behavior criteria, dynamic soil J
7 properties, r, oil properties and analyses. And basically _
i 8
these are associated with independent reviews performed i 9 by other engineering firms, which we will have to look .
10 into and see if they meet that criteria. Let ce say also j 11 that several things may happen to these candidate givens.
12 We may decide after our review that it does not meet the ,
r 13 criteria, in which case it has to be reviewed in depth in '
l -
14 our program, or it may moderate one of our reviews.
l 15 Perhaps the review Of one of these creas was sufficient e i
I 16 in one area b not in the total scope associated with j 17 one of these items.
r
. i g is We may.also in our program, as we get further into -
19 l our reviews, identify areas based upon new knowledge that I
! l I
i 20 i would bring a current design activity up to a candidate
! [
i 21 ! + level, which would then' receive consideration and be i 1 : ! ;
! 22 l documented and justified at that time.
i
['
23 ! MS. GARDE: Two questions. Do you have a process by i I
21 which a document is processed'by which particular systems [
2; or parts of systems, such as these candidate give.ns, l :
?
73 1
bec me a candidate given?
-( 2 MR. TIMMINS: The candidate-givens are defined based 3 upon the judgment of the discipline coordinator at this 4 particular time.
i The auditable trail that, for example, 5
Jose was looking for and which is really crucial relative 6
to these items will be in the engineering evaluation that 1
7 will be generated as a function of performing a level of 8
review in each one of these to determine if it meets the 9 criteria.
1 1
10 MS. GARDE: Okay. That's part of my second l
11 question. But the criteria by which someone would
[
12 recommend a particular system or component or property or 13 whatever as a candidate given, that's just engineering 14 judgment right now?
15 MR. TIMMINS: No, it's engineering judgment in the .
16 sense that our people believe that there may be i
17 information there sufficient to meet the criteria that we 2
i i
18 find, but there are data and documents available that 19 i
provide us some insight to why we would have thought that i 20 there would be a potential for a candidate given to be i !
=
of defined. For example, we have information on containment z
22 sump design, as an example, that a firm by the name of-l !
23 l Western Canada has performed intensive modeling and l i i testing.
l ,
28 We haven't reviewed that modeling and testing !
data to date, and that's why it's still a candidate 23 I
b
-,,--+,----,----e,_.-,--..-- ---,-.,-n v.-,, - ---n, - -- - - -e.,, ..- ,, . - . - ~----.,--m,- , ,,v.-,.-,,---------,-,., ,,-r,--r-. , , ,
74 i I given.
We are aware that such testa and such modeling {
_(- 2 wel:e performed.
i 3 MS. GARDE: But there isn't a specific procedere 1 4 written up by which something gets sent up to be i 5 considered.
6 MR. TIMMINS: There is not a progedure.
7 MS. GARDE: All right. Thac's my quastion. Could 8
you please identify who did the reviews on these items 9 here? You named one already, Western Canada.
10 MR. TIMMINS:- The benchmarking of computer codes 11 being defined as a candidate given is based upon the 12 strict requirements imposed within the industry on 13 benchmarking the computer codes.
14 MS. GARDE: So this is just general industry 15 practice.
16 MR. TIMMINS: That's general industry practice, and i 17 it's very rigorous along those lines, j IS MS. GARDE: What about high energy line break -
i I 2
19 analysec7 l
i 20 MR. TIMMINS: High energy line break analyses is up i ?
t 1
21 I
there because of invulvement, that potential involvement, 22 that Ebasco had had for one of -- for Comanche 23 i Peak 2.
I 24 l MS. GARDE: For Unit 27
+
l MR. TIMMINS:
33 That's ccrrect.
=
r t __ ._ . _ _ _ _ _ _ _ _ . _ _ . . . _ . _ _ _ _ _ __ _ _ _ __ _ _ _. _.._. _ _ _
l 75 w _
I MS. GARDEr l A3d external flroding protectivC '
( 2 measures?
3 MR. TIMMINS: Based upon the location of the water
, 4 bodies to the site anc the elevation of the plant in our ] ,
5 looking at the designs at this point in time, L;sically 6 says that there may be -- or not may be -- but that there
- i. 7 are probably no design features that are considered based
- 8 upon this particular attribute of the plant siting. This
- 9 again will be further reviewed as we get into the details to of the design.
11 MS. GARDE 4 So this one is a little different than i 12 the other ones. This external flooding protective 13 measure is more of an execption.
14- MR. TIMMINS: That is correct, based upon the nature 15 -. of the site.
i 16 MS. GARDE: What about seismic behavior criteria?
I I
! 17 MR. TIMMINS: Seismic behavior criteria: What I 1
{ i8 mean by that is the deflection requirement associated 19 with seismic behavior, and that was externally reviewed ;
! i 20 by Ebasco, I believe, but I'm not sure. . ;
I 4 2 at MS. GARDE: For Unit 1 or Unit 17 i
i 22 MR. TIMMINS: I do not know the answer to that. .
23 MS. GARDE: Dynamic soil properties?
t 23 MR. TIMMINS: Dynamic soil properties and soil l
23 properties and analysis are areas which have had '
E i
I 76 1
extensive consultant reviews and involvement, both on the i-( 2 Utility's aide and the Regulatory side. This is a.
3 typical area in the industry that has this type of 4 treatment.
5 MS. GARDE: Thank you.
6 MR. CALV0: You may want to get -- 1 don't know --
7 NRC has performed eva.'.uation of these givens, the safety S evaluation. Has the NRC parformed evaluations of thase 9 evaluations? Has the NRC -- haa studies been su'o mitted 10 to the NRC for the Comanche Peak Project, has the NRC j 11 ev'aluated them, and they came out with a safety 12 evaluation? Would you happen to know that?
13 MR. TIMMINS: I do not have the answer to that,
! 14 Jose.
15 MR. CALV0: Okay, but it could very well be that we '
16 have gone through all the , Steps when we prepare
. 17 evaluatiene s.o that's another piece of dccumentation --
g' is MR. TIMMINS:
i .
That's possible, and that's something
- 19
- that will come about in our review. ,
i 20 MR. NEVSHEMAL:
r This is a question of understanding. -
j 21 In this area here, for example, if you take that one of 22 them which is the containment sump design, as I 23 understand it, what you're going to be doing is that j 24 you're going to be creating a set of criteria against 23 which the third party review is going to be adjudged.
77 1
For example, one of the criteria with respect to the
( 2 containment sump is velocity, screen submergence and that 3 sort of thing. If the third-party review did not take l 4 into account the screen submergence, then the candidate
. 5 given would only address the design activities associated 6 with velocity or whatever was covered, and it would be 7
your intention to then examine as a design activity those 3 missing areas.
9 MR. TIMMINS: That's correct, and that's what I was 10 referring to as a moderated or perhaps focused review.
11 MR. JENG: My name is David Jeng, NRC. Two 12 questions. These seven candidate givens: Are they quite i
13 exhaustive as far as you know, or could it have another 14 five or seven or ten? What do you know about this?
15 MR. TIMMINS: These are the candidate givens that we 16 can find at this point in the program.
{. 17 MR. JENG: Second part. What's the reason for j is separating dynamic soil properties and soil -
s 19 properties / stress analysis? '
i 20 MR. TIMMINS: I'm not a civil / structural engineer, .
5 21 but I believe based upon the input that I got from the 22 g people that identified these as candidate givens, it was ;
l 23 only meaning to make a distinction between dynamic and t
i 33 static soil properties. '
e :
33 MR. SHAO: Can you elaborate more on seismic i r
j.
78 _
I behavior criteria? What do you mean by that?
( 2 MR. TIMMINS:. Defining the deflections associated 3 with equipment under an acceleration.
4 MR. L3AO:
And this area is a given.because you 5
found -- because Ebasco had checked the Gibbs & Hill 6 analysis?
7 MR. TIMMINS: It's my understanding -- and, again, 8
I'm not the author, if you will -- but my understanding 9 of this is that the methodology used in order to define 10 the deflections and the calculations and the results were i
11 overviewed by Ebasco, and based on the nature of the 12 Ebasco review in scope and in depth, we would then make a
- - 13 determination at to whether we also did or did not need i-14 to review that area.
15 MR. SHAO: This is the original seismic system
, 16 analysis done by the -- is that what you mean? The s' t- seismic behavior criteria, including the soil, the r 18 buildings, and everything? Is that what you're talking a
19 about? '
i i
20 MR. TIMMINS: I think the scope is more narrow that 21 that, Larry, but I can't define it for you that
\ i [
22 specifically. I can get the information, but I don't i 23 have it with me here.
21 MR. SHAO: Is it the original system analysis? j !
i 25 MR. LEVIN: I don't believe it's that broad, Larry. j l
79 1
We'll have to give you specifics. I think it's down at I
(
2 the component level.
3 MR. TIMMINS: I think it's at the component floor 4 levels.
j . 5 MR. SHAO: You mean it's defining the floor is not o
6 threshold?
7 MR. TIMMINS: No, at the component level; a function 8
of the floor response spectrum being fed into the 9
console, components reaction to the floor response 10 spectrum, if you will.
11 MR. SHAO: The component dynamic analysis; is that 12 right? I don't understand.
< 13 MR. TIMMINS: The movement, the deflection of the u.
- k. .
14 movement of the component, I believe, is the specific 15 '
scope that we're referring to, but I think what we ought 16 to do is get back to the questions.
! 17 MR. SHAO: I don't know what you're talking about, j 18 MR. TIMMINS: Any more questions? -
p 19 i
MR. LANDERS: With respect to seismic behavior
,; i 20 criteria, I would assume that anything with a pipe 4 :
- , ! 21 attached to it is not a candidate given because of the bI j 22 ,
rework that's being done in the piping area.
I 23 MR. TIMMINS: The seismic behavior criteria, I 21 i believe, is ass ~ciated o with category two over one
{' l 1
>3 ; interaction.
\
80 1
MR. LANDERS: Thank you.
( ,
2 MR. JENG: In first item, when you say' computer 3
codes, do you mean to only include those computer codes 4
in the public domain, or are you also including the 5
computer codes in a proprietary sense? What's your 6 answer to that? Are you going to only address those 7
computer codes in the public domain as a candidate, or 8
are you meaning to include even those other codes which 9 are in the proprietary domain?
10 MR. TIMMINS: I would also include the codes that 11 are in the proprietary domain, assuming that they were 12 benchmarked in the same rigorous fashion.
(A 13 MR. JENG: There are some dif1'erences in the 14 reliability of the computer codes for the ones in the 15 public domain and those not in the public domain, so I 16 would ask you to consider this difference and take into
- 17 your consideration.
g IS MR. TIMMINS: I understand your comment. -
19 MR. SHAO:
i You just mentioned the seismic behavior
! 20 criteria, two over one.
- i t 21 .
MR. TIMMINS: I believe that's the area that it's i
1 22 ,
affiliated with.
2.1 .
MR. SHAO: Only two of those areas, two over one,
.q l and that'S Covered by another ISAP, the ISAP on two over i
23 ;
one. '
l
~
81 1
MR. TIMMINS: There is a relationship between that
( 2 ISAP and this particular candidate given that shows up on l
3 the mechanical matrix, that is correct. \
i 4 On the next several slides, I think you may find !
5 your package a little bit out of arrangement. It's the
. 6 third one back. These are the new review areas that i
7 Phase 3 identified. They are not review areas at the ,
8 design activity level on the left-hand side of the 9 matrix. They are broader and just here in this fashion r 10 for the purpose of presentation. Under Mechanical we've i.
I 11 got. HVAC, radiation protection and dose assessment, !
12 combustible gas control, containment isolation, welding '
i 13 engineering, containment /subcompartment accident 14 analyses, and looking at additional equipment relative to l 15 their functional requirements. !
i
- 16 Structural areas Through Phase 3 we will now be i g looking at the manner in which the loads were determined, j~ 33 We have additional areas in concrete design that we're -
i
- gg looking at.
i We have additional areas in steel design
, ! 20 that we're looking at, and other types of support had I
21 b.een included in our review scope.
22 MR. SHAO: Can you give us some logic why this scope 3 expanded? .
21 MR. TIMMINS: When you go back and look at the scope 25 that was within the auxiliary feed water, electrical
l i
1 82 I !
power systemc and specific civil / structural structures, j
( _ 2 chere were a number of design activities which were not 3
encompassed in that original scope, which one had to t
4 review to capture them in Phase 3 in order to say that we l 5 i were looking at the overall AE safety-related design j l 6 scope. So there are differences in the way that one 7
would go about performing design on embedmont plate and
- 1, 8
block walls versus the structures that were being looked !
9 i at in the Phase 2 scope. !
k 5
10 MR. SHAO: I would like for you to come up with a 11 logic. You have looked at these areas - you looked at 12 these areas and come up with the rest of the plan. Can [
13 you come up with some logic? r l
l i
14 MR. TIMMINS: I' don't understand your question. ;
15 MR SHAO: You increased your scope.
i I look at this f 16 copy. If I look at the copy here, I have looked at
] i 17 essentially the whole plant by a sample of this, a sample .
i 18 of that. Can you come up with.a logic why the scope is L
i
=
i 19 increased? i I
f i 20 MR. TIMMINS: It gets back to the definition of !
f 21 homogeneous design activity in that the discipline 22 coordinators have been looking at the Phase 2 scope, and I i
23 understanding what the criteria and what design !
3; considerations and methodology were used associated with i i
I }
25 the structures from Phase 2. We knew that from the work +
r
_ _ . _ _ _ . . _ _ _ . . . _ _ _ . . _ - . _ _ _ _ _ . . _ . . _ . . _ _ . - _ - . . _ . _ . . ~ . . _ _ _ _ . _ _ _ . _ _ _ _ . _
e 83
- I I on homogeneous design activities that there were other
( 2 considerations that were not being evaluated, and, 3
f therefore, in order to evaluate these other types of 4
design activities, we needed to expand the scope.
5 MR. LEVIN:
- Larry, that is not an exhaustive list.
- 6 That's the delta --
7 MR. TIMMINS: It's an overview.
l 8 i
MR. LEVIN: It's been basically added. You have to i
9 look at that in concert with what was previously defined
, 10 in Rev 2 of the Program Plan to see the full breadth; for 11 example --
4 12 MR. SHAO: I know, but for a true graph I want 4
13 justification for why you think you've covered the whole 14 spectrum.
c 15 MR. TIMMINS: That is contained within the
! i 16 i i civil / structural matrix which has been reviewed in last '
l 17 week's audit. I l t 18 MR. CALVO: The checklists, not the methodology to j
I
-!i 19 establish --
l t j ! 20 MR. SHAO: I still haven't heard a justification. ;
l t
- 2 2
~21 MR. TIMMINS: The matrix and the checklists were .
L l
reviewed, and this level here is more closely associated 22 I
23 with the matrix -- i l
24 MR. CALVO: You indicated _before that you don't have
[
23 in place the methodology that established homogeneity
[
r
[
I I
lo
i 84 1
design activities, so if you don't have that in place,
( 2 any checklist, any review, it doesn't mean nothing 3
because you have not made your point about having 4
documentation that justified that you had homogeneity in 5 design activities. I can't read your mind, you can 6 Laplement all you want, but if you don't have the 7
methodology, we just can't be able to agree or disagree 8 with you.
9 MR. GUIBERT: Jose, just to clarify, we understand .
4 10 what you're saying. It's not the issue of whether we 11 have tho' methodology. It's the issue of whether we have 12 other documentation, how it was applied.
13 MR. CALVO: I'm willing to be practical in this. I 3 14 want to have one single methodology. I want to 15 understand what the mental process, how you go from there 16 to put it on paper. That's what I want to know. I'm l 17 looking at it from a practical standpoint. That's all I l
j 18 vant. I want to write an SER -- whether I'm going to l
19 except or reject your Program Plan -- I want to write an I I
! i 20 SER who tells me at the end yes, with reasonable i 1
e s
21 assurance that the design of that plant was done adequate 22 or inadequate. But I cannot do that by reading your .
23 mind. I cannot do that. I'm sorry that I~ don't have 21 that ability to do that.
f 33 MR. FRENCB: Jose, didn't we have the same problem -
~. ._ -. . -.
! i
. i
! 85 !
i i
1 t
- in the'QA-QC Adequacy of Construction Homogeneity of i
( 2 population, and the solution to that was to come down, to
! 3 sit down, and go over item by item -in detail about
- 4 methodology? You're absolutely right, and I think if we
[
5 take that tack here, we'll solve that problem. We have ;
6 to. !
7 MR. CALVO: I don't know why we're arguing about !
) 8 this right now. !'
9 MR. COUNSIL: We're not. t
' We're going.to go back and l c
- 10 we're going to satisfy you. It's as simple as that, and i i
11 hopefully we'll do that within the time frame that Vince !
12 wants, a week to a week and a half.
i i 13 MR. CALVO All right.
1 14 MR. TIMMINS: This a list of other structures that
' i i ;
15 were picked up in Phase 3 and some areas that were !
16 included in the electrical and I&C disciplines. Again, 'I i 17 these are just broad categories.
]' [ 13 What I'd like to do now is spend a few moments -;
19 talking about how we're going about selecting what l
, I, i i 20 systems and components it is that we're going to review a
!h
+
1 -
21 that will represent or be reviewed from the checklists !
22 for .the design activities. 'I'm going to speak to it as !
l'
[
23 far as the selection of systems and structures, and then !
l l
[
21 I'm going to take a moment and discuss the selection of ,
33 specific items -- for example, components, the drawings l
f
- -- . _ _ - - . _ . - . . - - . . , - , , . . . - . . . . - - . - - . . , - - . . . - . - . . ~ . . . . , - . - . . . - - . . . . - - - , . . . . - - - . - - - - -
86 1
or the calculations -- that we will review.
( 2 Rev 2 of the. Program Plan presented auxiliary feed i
3 water system and vertical slice to the electrical power i 4 systems.
And that selection, as we discussed earlier,
- 5 was based upon importance to safety, if they are
- 6 comprehensive, and they are representative of the various 7
systems that are in a nuclear power plant. But more 8
Laportantly now, from Phase 3 we will make our selections 9
within the system or structure that was already 10 selected -- that is, auxiliary feed water and the 11 electrical power system's slice - .in order to maintain ,
12 that vertical slice and have the design be reviewed in a 13 more coherent form.
14 i
If the particular design activity that we need to 15 review is not within that vertical slice of auxiliary
(
, 16 3 feed water and electrical power systems, then we will try
$ 17 to pick an interfacing system or structure that is
~
g 18 related to auxiliary feed water or that electrical power 19 system slics.
!=
If the particular item that we're after --
20
! for example, combustible gas control -- is not within l 21
- either the vertical slice originally or in a interfacing 22 design aspect, then we will have the following design ,
23 considerations, or review considerations. That is, it's 21 relative importance to safety -- keep in mind the.*a are i 25 all safety-related systems, so we're talking about the
- . . , , . . - - . . - - - . - , - - . - - _ + , - - _ - . _ _ . - . - ~ - - . . - - - - - _ , . . - --_
~
87 1
relative importance of safety here. We will consider, as
( 2 we spoke earlier in the presentation, to those items 3
which have been identified as concerns within the 4 industry or concerns specific to comanche Peak. We will 5
be looking at the various interfaces that are involved.
6 We will insure ourselves that we're dealing -- that our 7
selections will consider diversity, design changes that
! 8 may have been involved and, if necessary, along with 9
these we will try to identify a new vertical slice for .
10 new systems that we need to review to capture the Phase 3 11 additional scope.
12 Now, below the system level we're dealing with
{ 13 individual components, the selection of drawings, the 14 selection of calculations that we'll be reviewing; and 15 again we have similar types of attributes that we'll 16 consider in that process. In addition, we'll also be i 17 looking at the ability to extrapolate the results from '
j 18 the design activities that are being reviewed. And what -
19 I mean by " ability to extrapolate the results" is l
- i 20 relative to the comprehensive nature and complexity of 2
i
! 21 the particular design activity that we're reviewing. We i
22 would want to assure ourselves that in the review of 23 i specific components, for. example, that the design 33 ;
complexities that were properly associated with that 23 design activity are properly reflected in the component
4 '
- 88 1
that we're reviewing so that extrapolation process would
(, 2 be appropriate. '
3 In addition,jlf during the process in our reviews, s 4 new design activities are identified, then additional 5 selections will be made.
j 6 At this point we have a minimum for each area that i
j 7 we're reviewing of looking at a single item. If the item 8
that we are looking at we determine to not be .
9 representative enough, again relative to complexity and 10 comprehensiveness, then we will need to step outside of 11 our vertical slices and choose an additional component.
12 And for review areas which do not lend themselves to
- 13 review of a single item, additional items will be 14 selected for review, and as an example to that, using ;
15 Pi pe supports, you may have a large number of people t S
16 performing various pipe support calculations. And you i 17 will,have various typical designs and then a lot of j is individual specific designs within pipe supports.
i In 'j
=
7 19
..those cases where it's not. practical or prudent to look !
- i 20 at one item, and again to make sure that we're !
t g 21 representative, we will look at additional items for ;
c' 22 review. We will select additional items for review in i 23 order to come to conclusions about that general area. :
24 That's the end of my presentation unless there are l
~
23 more questions.
l l
l
89 1
MR. CALVO: In our presentation yesterday, I think
( 2 we got the Construction Adequacy Review, I think we give 3 you our staff perception. Young Hansel has a program, i l
4 and how much we're going to use that program, how we're 5 going to use it, so the staff can come up with reasonable 6 assurance. I just want to say the same thing for the 7 Design Adequacy. It's our perception. You use it for 8
your purpose, the staff will use it for other purpose, 9 plus all the things the staff has to reach the reasonable
~
10 assurance. One thing we're having to accomplish in the i
11 program, to coin the phrase that young Hansel says, the 12 staff wants to put their arms around it. We want to be
(
13 sure when you establish the design homogeneous population 14 or activities, once -- for instance, you pick up a pump 15 in the auxiliary feed water system and you found out thac 16 Pump is okay, sizing and everything else, as a part of i 17 going deep with the checklist, that'any other pump in any
[ 18 other system, that they are charged, high pressure -
19 injection. All those systems, they also automatically l i 20 are taken care of. So later on, when.all the things is .
! 21 done and everything is finished -- and this is again the ,
. 1 22 staff perception -- a new allegation comes up, a new 23 i concern comes up, another pump. You know there's l
21 i something, you say yes, but you know that's.not going to 1 l 23 be good and you know that belongs to this particular i
_ _.-_..,_,_,..~.__..,..._--,s _ ... _ _ _ ... _ . _, . . _ ,._,_.
90 I homogeneous design activity. Then we know that it must
( 2 be an isolated case, if anything at' all, but we know that 3
that pump is not going to bring another generic 4
, implication because we did a good job establishing the 5 homogeneous design activity.
6 That's how the staff perceives the program and 7 that's how the staff is going to go, on that basis. I'm 8
asking you again, please, tell me if we are wrong with 9
i, that, because if you don't, our SER will not come up with 2
10 the conclusion we want to come up with. That's our 11 perception. . You can use it for whatever you want it, but 12 that's the way we're going to use it. So again, tell us 13 if we're wrong. To do that, I need to have an auditable 14 trail that tells me, to understand, what your mental '
15 process was so I can agree or disagree with you and a i i
16 reasonable compromise can be made.
i i t l } 17 MR. LEVIN: There's just one thing I'd like to add
\ '
j 18 to that. Part of the auditable trail is developed in the 19 instrumentation phase. For example, the attributes that i* :
i 20 Doug just had on his projector -- you might put them back 2
21 up -- our bases for selection of specific-items ,
22 consistent with the concept that you just elaborated upon ;
23 l will be documented. The profile of a specific selection !
{
24 versus.another with respect to attributes such as ,
25 lf importance to safety, whether or not the item has been a
.--..,_,,,...,p., , , ~ , + . , -
1
~
91 I
difficult design area, either internally to TUGCO or
( 2 externally by another environment diversity, to assure 3
ourselves that we're getting a good cross section of 4
function and items and things like that, interfaces where 5
we can test them through the selection of that. What 6
these items will be utilized for is to develop a basis 7
for picking this item versus that item, to be sure that 8
we are making a good test of that design activity.
9 There's a specific location where this will be 10 documented, and requirements for that documentation are 11 specified in one of the DAP's where the profile against 12 these attributes has to be provided. To me, that's the
{ 13 proof of the pudding. That is the proof that comes at a 14 time when you're infinitely more knowledgeable about the 15 process, because you're very familiar with the 16 populations that we're dealing with, it will be more i i 17 readily apparent to the reviewer just how similar the j is items are with respect to each other, and the validation, -
=
19 r if you wi1'1, or confirmations may be a better word, that j 20 i
those HTA's were appropriately selected, will be t 21 i :
validated again, and I think that' documentation is much 22 more important and more reliable than can be done on the i 23 1 front end. But there's something you can do on the front i
' l 24 end, and we're going to talk about that in the next week '
23 or ten days as Vince indicated, but the real proof of the !
92
- 1 pudding is in the pudding, and that's coming, and it's
( 2 defined, it's mandated in our staff. l 3 MR. BECK: Any further questions of Howard?
4 Now I'd like Ron Klause to give us an update on 5
4 one and Webster Piping System and support analytical 6 efforts.
7 l
MR. KLAUSE: My name is Ron Klause for Stone and 8 Webster.
I'd like to give you an update on the l 9 activities that Stone and Webster has been following .
10 since our last public meeting here a month ago.
11 The project has been quite active. We've 4
12 accomplished several noteworthy items in the month that 13 has expired. We've issued CPP5, which is the walkdown 14 report which addresses the as-built documentation on a
- 15 sampling basis, and we also issued the results of the t
16 . report from the walkdown.
~
i
[1 17 We've issued Project Procedures CPP6, which is the j is requalificatio'n procedure; CPP7, which is the design '
1 19 criteria for the requalification effort; and CPP8, which ,
i 20 is the walkdown procedure by the experienced engineers
! i 21 l-andanalysts.
i i
- I l
22 Now, as I stated last month, the analysis is Progressing.
23 i l
Currently at this time, approximately 50 24 percent of the large bore problems are in progress.
25 Pifty of those have been completed to the point of l
. 93 I i confirmation required, and what I mean by that is that
( 2 when the supports associated with those stress problems 3 are completed and when the nozzle loads have been sent 4 out and accepted and when the final resolutions of the 5 technical issues are resolved, those' confirmations 6
confirmed can be taken off of those calculations that
- 7. aren't affected.
8 Now, as far as the resolutions of the technical 9 issues are concerned, Project Procedure CPP6 and CPP7 .
10 have explicit criteria as to the proper treatment of the f 11 support and piping interdependence. i These procedures !
12 provide the criteria to be applied, the approach to be I i
13 taken and the extent of the review required.
14 Now, not all of the methods for~the technical i
15 issues, the resolution of the technical issues, arp in
} , 16 place at this time. I'd like to digress just a bit.
3 {
i 17 Howard indicated in his presentation that he had several i
[ 18 hundred items. These items in his review process are 19 really different aspects of the same issue, and what that'
? i 20 i
means to us is that we can take a look at the source of ,
! j 21 those that have been given to us by the CPRT and boil l l
22 ,
those down into what we consider generic technical
, I. t 23 issues. .
To date we have identified approximately 33 of 21 those that relate to piping and supports. !
So as I said, not.all of the resolution methods are l 25 i i j r 1
i l
A '
... .. . _ - - - _ - - = - - - - - - -
94 1 in place. Currently we're missing about three of the
( 2 areas, and that has to do with the cinched U-bolts, -
3 Richmond inserts, and some bolt distress issues.
4 Now, once we have developed the resolution methods 5
l
! for these, these will be incorporated into the project 6
procedures, and the procedures will then be reissued as 7 it affects the requalification effort.
8 Now, as Larry mentioned yesterday, the CPPA, which 9
is the procedure that governs the walkdown by the 10 experienced analyst, has been issued, and that walkdown 11 is scheduled to take place next Tuesday, which is 12 November the 12th. Essentially, there are two reasons r 13 for having this walkdown. Number one is to determine
(
14 whether or not any technical configuration issues other 15 than those that have previously been found through 16 previous reviews exist, and whether or not we need to j j 17 effect the criteria that has been developed to date for i [ 18 enhancement into the approach or methodology to determine -
i
=. 19 the functional behavior of the piping system.
[ i 20 Also, the second reason is that we want to .
[ ! l i
! 21 familiarize the Stone and Webster personnel .with the l i. ;
22 physical design aspects of the site and to determine I
23 whether or not the design input needs-to be modified or ,
i 24 th0 approach to the requalification effort or the i
~
- 23 i
! procedure needs to be enhanced to reflect anything, a l
l
?
i
l 95 i <
1 more specific finding that they have at the plant. 1
( 2 The engineers involved in this walkdown have been 3
selected on the basis of their qualifications. They are 4
being familiarized with Project Procedures 6 and 7, and 5
also they're being appraised of the technical issues that 6
have been found to date so they will have an 7 understanding of' these when they perform this walkdown.
8 In summary, the project has been very active. The 9
actual production of the reanalysis effort is well .
10 underway, and by the next month I believe T can report 11 more progress in that area.
l 2
12 Any questions?
< 13 MR. BECK: Thanks, Ron.
k 14 I'd like to make a few comments about the cable tray 15 area and give you an update on where we are with regard a
, 16 to the investigations that are underway in that regard,
- 17 the reverification and the walkdown.
[
IS .For the Unit 1 effort, there are 4527 supports that -
i 4
=
19 are being walked down, and that process is well underway,
) I i 20 with 719 of those supports having been evaluated to that
! 21 Point, i.e., the walkdown is complete.
t The designe v'rification effort utilizing the 1
22 23 walkdown information is only just beginning. There are 24 ,
two design -- or verifications -- that have been r
i 23 j completed with regard to these walkdowns.
i
-.- --.-,,-%- --,-----w- - y -.--,,--,-.--,-,,r.. - w +=, , - - , , ., . , , - - - . ... -, ,16,- yy- *=-e e- ---s--s -v g e--*m'w e - 'wi-
96 1
On the Unit 2 side, which, of course, started much
( 2 earlier, there are a total of 3851 supports, and in that 3 instance, the walkdowns completed are 3691. There are 4
160 hangars in that particular case, or supports rather, 5
that are of what we characterize as'new design; the 6
valkdown, the verification, was part of that design 7 process, so that would total up to a completed effort 8
through the walkdown aspect. '
9 The completed design verifications in that case were 1
10 2,951, and out of those 2,951, we have identified 845 -
11 supports that will require some modification.
12 We anticipate completion on the Unit 2 side of the.
13 walkdown and the design verification effort by the end of 14 December of this year.
15 Our schedule for design verification completion on 16 the Unit 1 side is March of next year; March of '86,
! $ 17 March 1.
g' 18 We have recently, in order to expedite the effort on >
4 ,
19 the Unit 1 side, in particular, added a new member to the i
i 20 team that's been assigned responsibility in the cable
. 21 tray and in the conduit support area -- cable tray i
22 primarily --- and that's IMPELL Corporation. They'll be 23 assisting in some of the analytical efforts associated 24 with-the design verification. The NRC staff has i 23 scheduled audits on site to deal with the nitty gritty of ;
i I
. l
~
i 97 I
_i the efforts in that regard, and those will be proceeding
( 2 this week and, I understand, perhaps next week, if
, 3 necessary, until there is adequate satisfaction.
4 If there are any questions in that regard, I would 5 entertain them in general, but the audit process is one v
6 where the details will be taking place. I woula add that the third-party review of this effort is still underway,
~
7 8
and that it's not been completed yet, nor has the SRT .
9 completed its review of the cable tray and conduit 10 support pieces..
11 MR. NOONAN: I have a couple of questions. Number i 12 one: There seems to be some lack of understanding on the
{ 13 part of the staff as to some of the details of both the 14 cable tray and the piping areas. There are some 15 questions that need to be answered. In our audits over 1
a 16 the past month, some questions came out of them, and j 17 there was some concern and some questions need to be j 18 resolved. I don't think the staff is fully knowledgeable 2 z
19 in these small bore areas. They don't have a complete I
i 20 picture. It's.something that we're working on. On the l
2 21 cable tray and conduit it's kind of the same thing, all i
22 the things that you're doing there. Let me ask this:
23 Where do you-stand on your judgment?
24 MR. BECK: Vince, what I'd like to do is break for lunch, and then immediately after lunch have Mr. Hansel 25 e
, , , . - - - . . . . - , , . - ~ . . ..,,-.,._...,,.g.,-,- , . . , _ , . - - , , _ , ,~ ,,,,, ,,
. ~
98 I
pick up with his status report on 7C, the reinspection
( 2 effort of the construction activity.
3 I would anticipate, John, that that presentation ,
4 is -- what? -- about an hour?
5 MR. HANSEL: At most, unless we get a lot of 6
interest on some of these.
7 MR. NOONAN: There's one thing that my management 8
has asked me to bring to the table. This is a question 9
as to all this process, the things that you're doing with 10 the SRT and CPRT. What happens when we have this 11 dissent, not the word dissent, but disagreement, between 12 the CPRT and the SRT?
, How is that process handled? What 13 I'm looking for is some kind of, maybe a chart, celling 14 me just exactly what's happening there.
15 MR. BECK: I think one point, Vince, that needs 16 clarification there is the SRT is part of our CPRT i 17 effort --
[ IS MR. NOONAN: I meant the third-party people. When 19 John Hansel or Howard Levin or whoever would have a i 20 recommendation to make to the SRT, that recommendation !
21 can be either accepted or rejected by the SRT. I think i
22 that could also happen with the project. I don't know.
23 I'm not sure yet. Maybe the project has some other way.
21 of doing things. Maybe they want to do it.some other i
{ 25 way, that kind of thing. I guess, how is that process
- - - r.w . -. .-.r.- y.-- .,-------.,,-.-------,-.rw --.---v.-
99 a
1 resolved? When is the NRC made aware of these things?
( 2 MR.~ BECK: The SRT, the deal with the third-party 3
side of the fence, if you will, is the governing body as 4
far as policy and as far as the final review point for 5
anything that is done within the CPRT umbrella by third 6 party, or project, for that mattee.
7 There is a bigger interaction that takes place in 8
this process between the Review Team Leaders, all of 9
which, as far as action plans or results reports, is 10 documented. In the end, should a Review Team Leader 11 adopt a position that is not agreed to by the Senior 12 Review Team, the Senior Review Team's consensus prevails.
13 That would be so indicated.
14 To date, I'm not aware of a single instance where 15 that's been the case, where there is any disagreementt 16 but if that ever happened to be the case, it would be
! 17 documented.
! 18 On the other side, if there is a process of =
f- 19 executing the CPRT Program, which includes project and i
i 20 third-party people, a disagreement of a fundamental
! 21 nature or between the project and the third party, the i
22 SRT process -- and I consider that third party, even 23 though as Chairman of that body, obviously I'm a TUGCO 24 employee and my colleagues on the SRT can out vote me at
~~
25 any point - ,that disagreement would go to Mr. Counsil, i
, . , . - - - .- - . - - - . . , ._m.----..
10G I
the Executive Vice President of TUGCO, formally
( 2 transmitted, fully documented, for his ultimate 3 resolutione You8ve got to keep in mind that the CPRT 4 process itself uns initially ret up by the president of
- 5 our company, Mr. Spence, to assist him. The charge is l
! 6 very clearly laid out in our documentation.
l We serve in l 7 that role in an advisory capacity today as Amended, and 8
Mr. Counsil, any decision at that point, it would be up 9 to him to make.
10 I would caution to add that there is yet to be an 11 instance where there has been a disagreement between the 12 project sine of the house and the third party in evolving l 13 project plans. As you well know,-we're in the initial 14 phases of evaluating results reports, and we'll simply 15 see what happens. ,
16 In any event, it's fully documented and it's i 17 available not only for audit, but it will certainly be j 18 produced in the discovery process. -
=
19 MR. NOONAN: Is this documented anywhere? Is that ,!
t i
i 20 part of your program? This thing that you just .
I 25 mentioned: Is that documented anywhere so I can show it i e <
22 to people, pick it up and say, "Here it is"? .
23 MR. BECK: It's in the organizational section of the 23 Frogram Plan. Mr. Guibert just pointed out to me that l I
25 th.ere are three different areas. First, the '
w I
1 101 I
organizational chart and responsibility flow is clear.
I
( 2 Second, we have a number of procedures internally that 3 dictate exactly how findings flow and the paper that l i I
l 4 documents those findings is maintained. .
Thirdly, as John l l
i l 5 1
Guibert points out, we have Appendix H that's coming out f
! 6 that identifies, among other things, precisely how l
f 7
corrective actions, for example, are monitored by third !
8 !
party; and included within that is additional information !
9 with regard to the visibility of the activities of the !
10 CPRT as~a whole. The combination of those three sources, . !
11 I think, should provide an adequate and clear picture of.
12 how the events proceed. !
13 MR. NOONAN: When do you think you will have~
14 Appendix H ready to go to print?
15 MR. BECK: It will be included in Revision 3.
16 MR. GUIBERT: Of course, I think it's possible that, I s' 17 since we have.a question on the record from y'all, -- I j is can't remember whether it was Book 1 or Book 2, in 2
19 Larry's lingo -- that dealt with this subject of ;
i 20 corrective action, that it may be opportune for us to
' {
2 1
21 provide you an advance copy of Appendix H as part of the :
i 22 response to that question. We'll be 1 coking at that !
t 23 later this afternoon.
l I 21 MR. NOONAN: The only concern I have right now is as 1 23 long as construction activities -- Tom here is part of a
m -- - -
,,---w
102 i u
I Region 4 and they keep me pretty much informed on that --
(. 2 I feel we get -- we get at least on a weekly basis, every 3
Monday Tom calls and pretty much gives us an indication 4 of what's going on. On the design activities or any l 1
5 other activities, it's not quite so well documented from 6 our standpoint. If something were to occur and there was 7
a disagreement, the only problem I would have, I'd like 8
to know about it early, not find out about it in the 9 hearing process. .
10 MR. BECK: I understand. I can illustrate better 11 how these things will happen. When a Results Report 12 comes to the SRT for review, as far as we're concerned,.
r 13 that's available for the public, period. That's the
(
M principal vehicle for all the findings of the CPRT, the 15 Results Report.
S. 16 Now, we also have available SRT minutes that, as far i 17 as the SRT meetings go, tells you what has transpired in IS that regard. Should there be changes in a Results Report 19 i as the end product of SRT review, any differences in what
[ 20 l
t the Review Team Leadars submitted to the SRT-and what the
? 21 SRT findings proved would be very clear. Both of those l' 22 doc'uments would be available.
23 MR. WESTERMANc- John, where are the SRT minutes 24 kept?
i 25 MR. EECK: In the Central File oh site.
i
_ _ _ _ __ ._.__ __.._ .- .- - - - - - - - - - - - - - - ~ ~ ~ - ~ ~ ~
103 .
1 s N
we 11 reconvene at 1:00 o' clock and pick up 7C. !
i
( 2 (A lunch break was taken.) f 3 ( !
MR. BECK: Ron Hansel is going to give us the status (
i 4 on 7.C.
5 . t MR. HANSEL: Most of us know the process that we l 6
identified in 7C, so I'm only going to give you the
{
7 status today and not back up to discuss the process.
f 8
This is our currbnt listing of formulations. There ,
9 are five changes in here that I still need to talk with -
i 10 the Senior Review Team about, yhich I will be doing 11 tomorrow, most likely. I'll point those'out.
12 We're proposing a new population for lighting (
r 13 q
circuits. The reason for that is we found the lightingf i 14 circuits were performed by a different Kraft and to'a i i
15 different set of procedures, so we're breaking that out t
, 16 s'eparately. !
t !
3 17 In mechanical areas, due to some other changes that !
t j 18 were made within those population descriptions, we're i
19 f combining large bore and small bore welds and materials. ,;
s I
i 20 That again has to do with the work process, !
f 21 ; We did not have coverage in any of our populations 1 i {
.i 22 from the work process standpoint to look at grouts, '
i i
e 23 either grouts or cement or epoxy grouts, and we're 24 proposing those. And we also found as.we go through thiu f'
- t 25 iteration process of looking at all the populations, all !
i i; !
~
i 104 -
I the work processes, to maks sure we have total
( 2 accountability, we did'not have an easy way of 3
identifying the equipment supports with any other 4
J populations, so we're proposing that.
5 I m now going to give you some' statistics that were 6
effective October 15 In the electrical area we needed 7 five checklists. Five of those, they've all been issued, ,
3 and are in the process, and inspections are ongoing. For 9
those populations, the packages that needed to be 10 prepared for those five populations, there will be a 11 total of 950; 678 of those are in the system.
12 In the reinspection documentation review area, we
{ 13 have completed ~303 reinspections and 252 doc reviews.
14 For a total to date for these inspections, we have 15 initiated 216 deviation r6 ports, and 60'of those have 16 been through the process of review by the safety !
~'
! 17 Significance Evaluation Group.
[ 18 In looking at the mechanical area, the same type of 1 19 data. Nine checklists requh ed.- These have not been t
i 20 updated for those new 5 populations, but they're agreed ,
i 21 'c o . There were 9 required, 9 issurd. We have 463 out of i
22 1470 packages prepared, and in the hands of Inspection.
21 We have completed 322 reinspections of hardware, and none 24 of the documentation reviews are completed there yet. I 25 Those inspections have resulted in 210 Deviation Reports, i i
=
105 I
and 13 of those have been through the process of review
( 2 for safety significance.
3 MR. CHANDLER: John, if I could stop you at that 4 point. On that slide there, you mentioned on the 5
Checklists, Package Preparation, et cetera, items have 6
been issued, inspections have been completed.
7 Documentation on the issued procedures and packages and 8 reinspection is available.
9 MR. HANSEL: Yes.
10 MR. CHANDLER: Where?
11 MR. HANSEL: At the site. You're talking our 12 checklists and --
i g- 13 MR. CHANDLER: Yes.
i %
14 MR. HANSEL: All of that material is available; the 15 working documents, they're moving all the time. These f
16 numbers change every day,
!. 17 MR. CHANDLER: Have any of these things made their j 18 way, or are they intended to make their way into the -- I -
19 think it was a public room that y'all were going to be
- i, i 20 establishing in the' Dallas area?
j .2) MR. HANSEL: When we complete, the plan is -- unless
)
. ) l r'
1<
22 somebody. !: nows something different than I do -- when we ti l 2
] 23 complete our inspections, we will write reports on a 23 population-by populacion basis, and also on each of the I 23 individual action plans. When that's produced and given ;
i
. I
l l
106 I
to the Senior Review Team, then it will be available.
( 2 In the structural area, we have all the checklists 3 produced. There will be a total of 2182 packages
~~~ 4 required; 895 of those'have been issued. 492 combin'ed 5
reinspections and document reviews have been completed,
, , 6 resulting in 559 DR's to date.
122 of those have been
. 7 through the review process.
i 8
Now, I'm going to give you some ideas to help 9
quantify this thing, of what the data looks like. These '
i 10 charts I had made up late last night, and they're not in 11 your handouts, but if you would like, I can get them to 12 you.
I -
13
- . In looking at the cable area, we're looking at 90 i
14 cables total. We've completed inspections on 82 of those
- . 15 cable packages. If you take the item, the attribute and l
t 16 subattribute, then you take the individual item, the t' 17 number of possibilities for inspection -- if you have a 18 cable that has three conductors, you'd have three times -!
' =
i*
19 the opportunity to look at,,say, terminations -- for ;
1 20 those packages, 8,438 inspection points have been ll i
! s 21 covered. Out of that activity we have identified 52 DR's -
- a j , 22 to date for about 0.6 percent deviations per inspection 23 Point. There are many other ways to cut that --
l 24 MR. CALVO: Can you quickly characterize the 23 . deviations, what kind of deviations those are?
l
107 1
MR. HANSEL: I'm going to talk about some of those
( 2 later, Jose. I'm going to give you a complete summary 3 through the SSEG of what we're finding.
4 In the HVAC area, there's the same kind of data, and 5 I'm not going-to go through these, but in that
- 6 particular, we're hitting ~about 2.2 percent.
7 MR. CALVO; Ubat is the estimated number? Do you 8
mean that this is the actual number or -
9 MR. HANSEL: To get some quick characterizations of 10 the points, we gathered up those packages, and we did a 11 quick count, and that's a very quick count. Those 12 numbers are very, very close. I'd say they're within the 13 noise level.
14 Large bore pipe supports-rigid, the same type of '
15 thing. You have a lot of opportunities here because you
,e
, 16 have a number of welds, joints, supports, different beam t i 17- structures and so forth, and there we're hitting about l 18 0.8 percent. .
'! -19 On large bore pipe configuration, again the same i,
i 20 type of data. a i
We've completed 73 of those, and just
,j 21 about.1 percent, 0.99.
E
.; 22 In the mechanical area, this is a different cut now.
23 I want to show you the DR's that-have been processed 21 through the Safety Signif.icance Evaluation Gr,oup and let 25 you see what that data looks-like. Here we have the "
~
l'08 u
I populations, the number of DR's that they have received,
~
( _. . _2 how many they have completed their evaluation on and how 3
many of those have resulted in a construction deficiency, 4
by our definition, that's in the Program Plan.
5 In the structural area, same type of data for 6
} .
concrete placement and liners.
B 7 MR. SOFFELL: John, what's SSE in this case?
i
- 8 MR. HANSEL: Safety Significance Evaluation. You'll 9
, hear SSE and SSEG.
10 In the electrical area, you have this number in i
11 these populations. None to date have been defined to be 12 safety significant or construction deficiency.
13 On the supports, we have one -- we're going to show
!) 14 that to you after a bit -- that we have declared to be a i
- 15 construction deficiency, and that was picked up on our i
i I 16 review of the pipe support problems in Room 77N that came
- e. . t q ..
! I7 out of the TRT issues.~
] [ IS MR. SOFFELL:- Did you say you were going to talk
[j =
19 about that more later?
1 i d ! 20 MR. HANSEL: We're going to show you what that is, J
21 the rationale,~how we're going through the evaluations.
l ! "
) 22 Large bore piping configuration. Now, I'm going to 23 show you for some populations the kinds of deviations l
21 that we're finding to date. These are our own 25 classifications from the DR's themselves. When I finish l 1 r
109 1
with these numbers, then Jim Adams is going to show you
( 2 some typical examples so you can understand the kinds of t
. 3 things that we're finding and how we go through our 4 evaluation.
5 Here you can see pipe and pipe clearance. We're 6 1 going to show you one of those. . Pipe sleeve clearance, 7
valve flow, those are the kinds of things that we're 8 finding on large bore piping.
9 The tank liner weld seam and the liner population .
10 undercut in 8 areas: 4 in the case of overlap and 11 ripples and grooves; excessive reinforcement, 3; rust,
- - 12 23; and right on down. Let's let them study that one for 13 a second.
i ,
14
! In the case of the weld seam, 15 overlap and, of 15 course, ripples and grooves; 20 on excessive i
16 reinforcement.
[. 17 In the concrete population'we have 11 where we have l
l l
i IS voids and/or honeycombing in the concrete enbedment 19 inserts facing violations.
i 8 20
,; i Instrumentation installation population, increased -
i 21 slope. We're going to show you one of those.
E Locations out of tolerance, incomplete or missing, to be 22 23 manufactured, reference sheets. Incorrect, missing 21 alphanumeric ID air gap, and then 25 of various types.
25 No real significant trend in those 25 I
t
- . , . - . , . . . . - - -,,.,_,-------,---,,.-.,,----__,n.-,,,-----..,-nn -- - - - - - , - - _ _ - . -
--e.- - -e ---
, m -.au - -, A ,m, sa 110 i
1 In our large bore supports-rigid -- again I'll let
(
j 2 you scan that -- 4 where we have insufficient or
. e 1 3 incorrect enbedment length, 4 dimensions out of 4 tolerance, 6 undersized welds, 3 incorrect clearances, 5 and the rest are single items.
6 Large bore pipe supports-rigid continued; single 7 items in these particular areas.
8 f
MR. SHAO: Who evaluates significant or non-9 significant? You or the engineer?
10 MR. HANSEL: I have Jim Adams who works for me, 1
11 who's the coordinator, and a supervisor of the Safety 12 Significance Evaluation folks. They take the DR's and 13 they do the evaluations to determine if they're safety 14 significant.
15 MR. SHAO: Let me give you an example. Is it t
16 possible you say they're not significant and then Stone i . .
l 3 17 and Webster later say they are significant?
j IS j MR. HANSEL: From a construction adequacy -
- 19 standpoint, we're making that evaluation. They get .
.=
i 20 copies of all those and have access to them. I don't '
s
- 7 t 21 4
5 conceive of an issue where we'd.have a difference of '
opinion, but I guess it's possible.
22 I don't know of any. ;
23 We haven't had any disagreements yet, e l
93 MR. SOFFELL: I think a point that needs to be
!- g ,
25 . clearly recognized is the criteria that we use for sample i i
._-.__.___j
111 1
expansion purposes ~and which we have labeled safety !
( 2 significant.
If you recall, our Program Plan originally 3 laid that criteria out. What are we going to use to 4
decide whether or hot to expand the sample? And we 5
purposely set it at a higher level of rigor than one 6
would normally use in evaluating, say, a potential 50.55E 7 occurrence. These would be safety significant where you 8
would take credit, perhaps, for component redundancy;
~
9 you're interested in whether or not a system will perform 10 its intended function. For purposes of sample expansion 11 in the Construction Adequacy Program, we are not taking 12 any credit for component redundancy at all. So it is a 13 much more severe test in that context.
14 For example, in the case of this cotter pin, the 15 component that conceivably might not perform its I
i 16 function, if you did a -- and, in fact, the Project per j 17 our rules is going to be evaluating under an NCR whether g is or not that is indeed safety significant from a i i
19 reportability standpoint, and it may not be, but for
! 20 purposes of sample expansion, it meets the criteria, it l 2
s 21 meets the threshold for expanding the sample, t
22 And-I think that's a key point to recognize, is that I z;
we've got a much more severe judgment at'this juncture i
,, ; for sample expansion purposes than is normally required 2-
\
in what you would call safety significant deficiencies or l
l _ _ _ , . . . _ , , _ . _ . _ . . _ . _ . _ - . _ _ _ _ _ _ _ _ . _ . _ . _ _ _ . _ , , _ . . _
112 .
1 deviations or defects.
( 2 I just wanted to interject that point.
3 MR. BANSEL: I think another point to help Larry and 4
others is that when we finish our evaluation, copias of 5
those are in our files and will be addressed in our final 6 report. Copies of those go to Howard Levin's Design 7 Adequacy Group for their information. Copies go to the 8
Project, and in all cases an NCR is written for the DR, 9 and' copies of those go to Stone and Webster. So there's 10 broad distribution of our data to all those who have need 11 for.it. If there are any questions on those judgments or 12 decisions, it's an auditable trail. We~can back up and
, 13 show you how we arrived at those conclusions on a case-14 by-case basis.
15 MR. SHAO: What worries me most is: .Is it possible 16 you'd find something that may affect the analysis, l !. 17 invalidate the analysis?
l 18 MR. HANSEL: Stone and Webster gets that information -
l 19 and takes that into account.
i
$ 20 MR. BECK: I guess to carry it a little further, 2 21 Stone and Webster will consider all that input as far as i
22 it might have an effect on the analysis, or validity of 23 the analysis.
24 l MR. SHAO: I'm thinking beyond Stone and Webster.
l Is there some area you.look at which you don't have a 25 i l
~
113 1
reanalysis effort that may invalidate the original
( 2 analysis?
3 MR. HANSEL: As I said, I can't conceive of that 4 happening. They have the data and have access to it, and 5' believe me, if we see one that we're concerned about, 6
we're going to let the world know about it through the 7
Senior Review Team and after the Stone and Webster folks.
8 Bernie, did you want to back up one chart?
9 MR. SOFFELL: Yeah. When I look at that -- and I 10 don't' know whether it involves more than one support-or 11 not -- but if you add up that column and what's on the 12 next pr.ge, you come up with a fair number of, albeit not r 13 safety significant, but a fair number of deviations.
( Are 14 you taking a look at - well, you obviously are on an 15 individual basis -- are you taking a look at them on an i 16 overall basis aus a group to say -- s i 17 MR. HANSEL: We're looking at them individually j 18 first.
Then we are also charged with the responsibility i
i
.- 19 to do an adverse trend, if we see a trend in there that I
, 1 i 20 would cause us to go look furth'er at other supports or 1
- 21 other pipes, so we do that adverse trend analysis and i
.- i 22 weld. That will come downstream when we get sufficient -
23 data. !
MR. JENG:
3.g In your information on DR's, in deciding !
3- the safety significance, you mentioned one assistant is i
t t
- t. _ _ _ _ _
i 114 -
1 going to perform this one. Now, his performance, is he
( 2 guided by more specific acticn or evaluation or just,'
3 quote, safety significant, and quote? Is there any 4 guidance?
5 MR. HANSEL: We have a procedure covering that, and 6 they're reviewing the drawings, the specs, and if it's 7 appropriate, the vendor criteria. In some cases they're 8 redoing calculations. They're taking into consideration 9
the loads, and I think when you see -- after he goes 10 through fou,r or five examples and he'll talk about how he 11 did the analysis, let's see if you have a comfort factor 12 at that time as to the level of detail. Everything that
, 13 we do in tu' at evaluation process is documented and in j k 14 some cases -- I don't know what percentage -- we actually i 15 redo calculations.
)
~
l 16 MR. JENG:
5 The details of the evaluation, of each of
$ 17 the factors which constitutes safety significance?
j IS MR. HANSEL: Yes, sir. In most of these cases, c z
19 there are two, three, four pages; in some cases quite I s
i 20 thick documentation backing it up as to how we declared .I 21 that it was not safety significant. These are all very i
22 senior level folks doing this through our own contract to I i
23 us from Stone and Webster. i 3.g MR. JENG: One person or more than one person doing I
l 25 ; this?
l
115 1
MR. HANSEL: Right now, Jim, you've got -- ?
( 2 MR. ADAMS: Close to-40 people.
3 MR. HANSEL: Close to 40 people doing that.
4 .MR. JENG: So 40 people should be guided by same 5 standards of evaluation; otherwise, there would be --
6 MR. HANSEL: We have procedures. We have guidelines 7 as to how to go about that. We have forms; it's all 8
documented; a very rigorous process. That's probably the 9 most important piece of work that we do.
t 10 MR. SEAO:
~
What are the qualifications of these 40 11 people? Do they have extensive design analysis 12 experience?
13 MR. HANSEL: We picked -- and I had the criteria put 14 on me by Mr. Counsil that he wanted to personally agree 15 with the supervisor, Jim Adams, and he also wanted to 16 approve each of the leads in that group that were going i 17 to report to Jim. Then he let us go get the rest of j 15 them. But he wanted to be certain that he had senior 4
=
19 -
level people with extensive design experience, i
j 20 l Analytical experience. They are all well qualified.
3 21 MR. SHAO: Mostly from Stone and Webster?
t
. I 23 , MR. HANSEL: Yes, all but about two or three.
I 23 MR. SHAO: In all disciplines?
l-21 ! MR. HAJSEL: Yes, we picked very carefully the best people we could get from all the various Stone and 23 '
l l
e
^
~
116
< =
I 3.
Webster facilities.
( 2 Large bore supports-nonrigid: No' locking devices on 3
clamps, dimensions out of tolerance, excessive spherical 4 bearing gaps, painted spherical bearings, pins used 5 instead of clamp bolts, U-bolts clearance violations.
6 These are not unlike other defects or deficiencies you'll
- 7. find in any plant.
8 some additional ones: Welds undersized or missing, 9 welds undercut.
10 Now, this is the TRT issue, Room 77N, and the 11 results of that -- they're about 75 or 80 percent 12 complete in terms of the inspections. Pipe clamp halves 13 out of parallel, not being parallel; again, spherical l 14 bearing gaps, cotter pin missing. ,
Let me talk about that 1,5 for a second. Jim will talk about it later. Almost
, 16 within a day or two of when we identified that; problem,
$ 17 we had an immediate response from the Project to go to a 18 100 percent inspection and replace those as required.
19 They jumped right on it. They're going to go fix them i
i 20 all.
i 21 With that, I'm going to ask Jim Adams -- he's the 22 supervisor of the Safety Significance Group, and h'e's '
11 going to go through some typical examples. We can run these out, we can stop whenever you think you've had-24 i ;
23 enough. We're not going to give you too many, just five '
I t
1 117 .)
1 or six.
( 2 Jim, it's all'yours. We're also going to show you 3 some pictures so you can relate to a sketch and the ,
4 picture of the items we found and get a better feel for 5 it.
6 MR. ADAMS: The first example is the construction
. deficiency with the missing cotter pin.
7 This is a sketch 8 'of the support as the deviation exists. The problem is, 9 in this support, the pin that holds the strut has a 10 cotter pin on the bottom, but it has no cotter pin on the 11 top. The support is a horizontal support with a vertical 12 pin. It's in place right now due to the friction, the
{ 13 tightness of the line. In the analysis we would look at 14 frictional effects and we would look at loads and so 15 forth on different components, but in this case, the 16 seismic event, there is n> way that we could justify this i 17 pin ~not falling out through gravity. So we declared this
(
j is an item that was unable to perform its intended function !
19 in this case. We declared it'a construction deficiency, i i.
I 20 The line itself that we're dealing with is a four-i s inch line, which on the next vu graph, from the flow
! ! 21 I.
- ,.i f 22 diagram, if you start at the other end, its manifold, 23 which picks up a bunch of release valves, three-quarter ,
21 inch release valves primarily off of the safety injection j t
[
25 i system downstream of our ER pumps and the safety I
t
I 118 1
injection pumps.
( 2 It's continued on the next slide. The support in 3 question is part way down that manifold. It continues on 4
and it picks up some other safety valves. The largest 5
one is a four-inch safety valve off the blind control 6
tank, and it discharges those safety valve release to the 7 Boron recycle tanks.
8
~ This gives you a vivid illustration of the line as 9 it sits in the plant. It goes through a wall, and it 10 goes through Room 77N and then discharges eventually 150 11 feet or so into the recycle tank. The support that did 4
12 not form its intended function, if that pin were to fall 13 out, is a horizontal restraint located there.
14 MR. SOFFELL: Is that supported at the wall, or does 15 it have clearance?
16 I MR. ADAMS: It's a strut to a frame.
$ 17 MR. SOFFELL: No, I mean where it goes through the i
IS wall. ,
19 MR. ADAMS: It's an anchor at the wall, yes.
i ;
i 20 We're in the process of looking at the effect of the s ;
21 line, the effect of taking out this support on the entire 22 line just to see what would happen. But all of the 23 release valves that dumped into it.down here, until you 24 get up into.this area, are small. release. It's a minor 25 : energy line'used less than 2 percent of the time.
i t
119 2
1 So where we stand right now is that we have
( 2 completed our evaluation of the item, the item being.the 3 affected item which was the support, and the attribute :
that we looked at -- well, the attribute that was written 4
5 up as a deviation was the missing cotter pin. There 6 wasn't too much that we could do in an analysis under a 7 seismic event so that it would stay there, so the item 8 itself is a construction deficiency. I don't have any 9 Photographs of this one --
10 MR. BECK: You have a question, Jose?
11 MR. CALVO: You say that if you have a seismic 12 event, because of this cotter pin, that whole pipe will r 13 fall about --
(
14 MR. ADAMS: No. All we're saying - put back the 15 first one, Terry -- the way we're establishing whether we 16 have a safety significance evaluation and a construction l 5 17 deficiency is whether the item that's inspected -- which j 18 are these. clamps, the nuts and so forth, the strut and
,'* 19 the attachment into the structure -- works, whether it's c :
! built in a way that it will perform. Even though it may 20
! . [
l' l 21 have deviations, it still may perform under the .
r' l 22 conditions that it's going to see. So all we're saying -
e 23 in this case is under an earthquake this pin is going to
- j. fall down and this strut is going to be loose. It will l 33 no longer be able~to take the horizontal motion and stop f i
1
?* .,__ . , , , . . _ _ . . . _ . _ - _ , _ , _ _ . . . . _ , . _ - . _ . _ . _
120 1
the horizontal motion of this line.
( 2 MR. CALVO: You have not analyzed the consequences?
3 MR. ADAMS: No, that's not part of the 4 determination, if there's a construction deficiency. The 5 item itself is the inspected item. In that case, it 6 doesn't.
7 MR. COUNSIL: As part of the criteria here, for 8
sample expansion they're calling it a safety significance i 9 evaluation. This will, in fact, generate an NCR. I'm
~
10 quite certain when we go back with the NCR and evaluate 11 this through the Project, we will find that it would have 12 had no effect whatsoever under seismic events as to 13 damaging that pipe whatsoever. In my experience, I have 14 never seen any one single support that could take out a 15 whole system. And in this case, I'm quite certain that's l
16 what we'll find. This is cause for a sample expansion, j 17 and I think we ought to clarify that.
g 18 MR. HANSEL:
_ hat gets back to John Beck's -- .
19 MR. CALVO: How many~ deviations do you have all I
! 20 together? How many deviations?
~
3 21 MR. HANSEL: I'd have to dig that number out --
1
~ t
[ 33 MR. ADAMS: The deviations totalled up to the 15th,
! 23 we have around 520 -- l i
24 MR. HANSEL: That's into his area. There are others
,. )
33 that were written that are not there yet.
121 1
MR. CALVO: How many have you evaluated all
( 2 together?
3 MR. BANSEL: At that point, the 15th, around 215 or 4 16. -
5 MR. CALVO: You only found this one, the missing 6 cotter pin?
7 MR. HANSEL: That's correct.
8 MR. JENG: Earlier, after visiting a couple of 9
slides showing the deficiencies, you may have implied .
10 that these are the type one would perhaps see at other 11 Plants. Is this an opinion based on your super 12 experience or it's a documented fact?
13 MR. HANSEL: It's my experience from two plants.
14 MR. JENG: Could you name them, please? .
I 15 MR. HANSEL: Bryon and Braidwood.
i 16 MR. JENG: So you're implying this is no worse i
17 than -- !
j 1s MR. BANSEL: I'm just saying that these kinds of ;
a' I
19 deficiencies are not unlike what I might expect to find j 20 in other facilities, based on my experience with two 2 21 plants, plus reports that_I have read from other plants, i
23 MR. JENG: Thank you.
23 MR. HANSEL: And the numbers and the percentages 21 that we're finding are about on target also. I might say-23 at this time ~that the number of deficiencies per '
122 _
1 inspected item is running at a lower rate on Comanche
( 2 Peak than my experiences on two other plants.
3 MR. JENG: John, just to put this in perspective, do 4 you know if the effects of the evaluations of these two 5 other plants are similar to the ones you have done so we 6 can compare on essential basis?
7 MR. HANSEL: No. I'm not going to get to that point 8
without additional data correlation. I'm just saying -the 9
kind of deficiencies that we have detected here I've seen 10 in other plants, and the numbers are close. If anything, 11 they're a little less here than what I've seen at two 12 other plants, personal experience.
r 13 - MR. CALVO: He made a promise that he'was never
(
14 going to bring Braidwood as a basis for the argument.
15 You may have broke that promise.
16 MR. ADAMS: If there are no more questions on the I 17' cotter pin, the next example is one on the large bore
[ 18 configuration sample. The example that was inspected was s
. 19 a line that you see running this direction. There's a 2
- i e
20 six-inch auxiliary feed water line inside the reactor ,
l h 21 containment. On top of that line, going across the line
, s' l
22 perpendicula r, there's a' one-inch air line, and' it's 33 located closer than one inch to the auxiliary feed water l 33 line. There is also a support for a ventilation duct.
33 Underneath thet line there's another interference 9
. ., . - . - . - , - n,.-,. ---------.--v. , . . , , - - . . .-n . , _ , . . , , , , , , , , - . . , - , , , . . . . - , - . . . , - - - . , . . , . . - . , , . ,
123 1
potentially where the clearance is less than one inch.
( 2 The inspection attribute for the configuration evaluation 3
is that clearance be an inch or more, so we get a 4
Deviation Report to evaluate anything with a clearance of 5 less.
6 These are the three points shown on the sketch where 7
the clearance is less than an inch. To evaluate-this, 8
the engineers go back to all of the existing calculations 9
that relate to this with respect to pipe stress, pipe 10 movement, for the feed water bypass line, for the 11 auxiliary feed water line and for any of the other 12 -interferences. In the case of these two lines, there are 13 very well documented calculations that we can use to show 14 how much they deflect under all conditions; seismic, 15 variable, water hammer, all the different loading __
I 16 conditions.
i 17 For the movement.of the ventilation duct and for the j 1s movement of the one-inch air line, we relied on field -
i 19 examination of the coniition, the location of these items i 20 to the concrete structure to which they were originally
- g. 21 attached, and used an estimated deflection for those E-22 systems. When we do that, wa then compare what the t
23 motion is of these lines and we see that there is plenty !
l 21 of clearance between them; and we say that its intended 23 ,
function is met and there's no problem. It's a non-I
> - - ->-m-, , - - -- - ,- e -r- 7--,,,-,,-,,w -
--w----+- ,--,--w -,w,, ,,,----e- , - , +
124 i m l I safety significant deviation.
]( 2 MR. SHAO: Is it possible this thing occurs 3 somewhere else, you may have problem? Could this 4 particular --
5 MR. ADAMS: We have other cases where we have i 6 clearance problems. We have not had any that have proven 7 to be safety significant, as you have seen from the 8 numbers and from the ongoing work beyond the 15th.
9 MR. SHAO: But you say you can't approach an
, 10 integrated (Inaudible) .
11 MR. ADAMS: We have not tried to do that. There are 12 so many different cases that you could have. It would be r 13 difficult to do it; different size lines, different
(
1 14 thickness lines. We have evaluated cases where the lines
. 15 are touching each othec, One is Cat 1, one is non-Cat 1.
8 16 We looked at the stresses and so forth and found that i
}. 17 they are acceptable.
t g 18 MR. SHAO: My point is you didn't inspect every -
19 case. ygu inspected a case and you analyzed it; this z
! 20 Particular area I have no problem with. But the same
! ! 21 kind of problem maybe occurred somewhere else.
t :
22 MR. HANSEL: We think that in our sample we will 23 have looked at enough cases that we will find the issue.
y
,; Now, when we're finished with these inspections, if we 25 see some that are very close or on the ragged edge, we
\
e
~
I 125 t
l' may have to back up and take a look and maybe go look for
( 2 some others or get back with the design folks to see if 3
they found anything that would lead us to any areas. We 4
think so far through this sample process that we have the ,
5 problems bounded. We'll look at a fair number of these. ,
6 If we don't find anything that is considered to be a 7
construction deficiency, then we would probably - !
8 MR. SHAO: You look at one problem, or you look at 9
quite a few problem areas? ,
10 MR. HANSEL: We have this opportunity - and I don't 11 know how many is in that population - but approximately ;
I 12 100 opportunities and maybe as much as 110, plus what we ;
P 13 did in Room 77N, so we're probably looking at a sample of 14 about 200 items through our total inspection program. .
15 MR. JENG: Okay. Suppose you have identified 16 deficiencies and.you would use this information as a ?
i 17 basis for expanding. You are sampling population to look j IS further. Now, based upon this approach, just on a -
19 judgmental basis, as to how many more you are looking
.i ~ ,
20 i
into or you are incurring considerable statistics to see, 21 even such occurrence of how I'm going to define that next ;
expanded population.
22 What's your philosophy at this 23 ! point?
I '
24 MR. HANSEL: I really had a hard time undccstanding. ;
25 Let me address what I think I heard. .
i
1 l
126
- o 1
MR. JENG: Let me make it clearer. I understand
_( 2 earlier'this confirmation, the schedule with the 3 deficiencies. They will be used solely for the purpose 4
of looking into whether expanding the population of
, 5 examination.
6 MR. HANSEL: Yes.
7 MR. JENG: Now, I'm asking what documented o 8 philosophy governs that activity when such a need arises.
9 Are you basing on experience ~or judgmental basis, based 10 on that experience, or are you-tying up usable, some 11 quantitative statistical approach to define how many more 12 you are looking into?
13 MR. HANSEL: Our expansion is based on statistics.
14 If we end up with one construction deficiency in the u5 _first sample, then we will expand. I think that number l
I 16 is'30 or 35 We could expand to go look at another 35.
! 17 MR. JENG:
Again, you are assuming homogeneity of j us that population.
19 MR. HANSEL:
z Yes.
i i 20 MR. JENG:
i To start with.
MR. HANSEL:
21
' On the work process, yes. '
22 MR GUIBERT:
' I'd like to clarify that just a little >
.23 bit.
The answer to your question is a litt1e bit of yes i
~
i 21 on both sides. First of all, from a statistical point of !
23 view, a statistically based expansion, more or less as '
t
Y 127 i 1
John indicated, another 35, if it's a safety significant
)
( 2 deficiency separate and independent from that, we also
- 3 take a look at what the root cause is of that individual l
4 item. So there's a statistically based expansion and 5 there's potential for expansion based upon what we find 6 the root cause to be of the safety significant l
7 deficiency.
}
J
- 8 MR. SHAO: My question is different now.
l This is 9 deviations. You just proved the deviation. How do you 10 know the deviation occurs somewhere other than the 11 deficiency?
1 12 MR. HANSEL: Again, I'm didn't understand i
i
! '13 you.
14 MR. SHAO: This is a deviation he just proved, 15 analyzed and everything. I say if the same problem 4
16 occurs somewhere else, can it be a deficiency because l 1 37 different geometry --
i j 18 KR. HANSEL: That's possible, but we feel again -
l 19 through our samples and all the various inspections thr.t i
i 20 we're covering that we will have done enough to evaluate gg that plant in that population. We think that we will 4
22 have bounded the issue, t
23 Now, as John pointed out, we look at each one
.1 !
i individually, and we'll look for trends. If I saw a i
t 33 I number of these, then I would probably ask myself, is the l ,
1
_ .- -~ -
128 1
opportunity there that could be, as you say, a deficiency
( 2 in another place. But if we have one that we do not get 3 adequate-clearance and we do declare it to be a i
4 construction deficiency, we're going to go through a very 5
laborious process to determine the root cause, whether 6
7 caused by design, whether by construction, what actually 7 caused that to occur. We'll also look for the generic i 8
implications, if it could be in other places. So this 9
process, until we're finished - to get back to Dave's 10 concern, I think - we're going to have to go through it 11 to see what that data tells us on a population-by-12 population basis.
13 MR. GUIBERT: Larry, maybe I can help you here.
14 MR. SHAO: Mayae we can resolve it.here, but I would 15 like to have maybe in the future another meeting with my 16 staff and your people to look into these deficiencies.
! 17 MR. GUIBERT: I think when you see Appendix E as '
[ 18 revised, sor.e of the ocastions will possibly be answered.
=
19 MR. LANDERS:
i One of the concerns that.I have is
! 20 that you're evaluating the sample you showed with respect 21 to clearance based on analysis of piping systems that are '
i 22 being redone, reanalyzed, by Stone and Webster. Is there 23 something in the system that when Stone and Webster is i
24 through that we can be assured that this deficiency is !
23 going to be revisited by Stone and Webster or by John r i
1
_ _ _ _ _ , . _ . . _ _ _ . - - - - - - - - - - - - -'~ ~ - - ~ ~ ~ ~ ' ~ ~ ~ ~ ~ '~ ~ ~ ~ ~
i 129 _
1 Hansel's group?
( 2 MR. BECK: Don, I'm sorry. I'm not sure I 3
understood what you said.
4 MR. LANDERS: Okay. We have a deficiency and you 5
have evaluated it for safety significance, and you said 6
it's acceptable because you've looked at the relative 7
displacement based on the correct analysis. That 8
analysis is being redone. We may end up with different 9
results in that analysis, and this deficiency has to be 10 revisited.
11 MR. GUIBERT: It will.
12 MR. LANDERS: Is there something in the system that 13 assures that?
14 MR. GUIBERT: We discussed that at last month's 15 meeting, Don, and basically the way that's handled is 2
16 i I each one of these items gets an NCR associated with them, i 17 and it's through that process that Stone and Webster is 3
[ 18 advised of the situation, of the current status. '
19
, MR. HANSEL: And they have in their scope the
' 1 i 20 visiting of all NCR's. I
. i .
j 21 MR. COUNSIL: They have, as far as piping 22 interferences, whether it's through a sleeve in the wall i 23 or whatever, and they're also doing it, Don, through 9
24 their engineering walkdowns. They're going to revisit 25 these things. They're going to do 100 percent of these.
i l
__. _ _ _ _ _ _ _ _.___ ,__ _ ~ _ _ _ _ _ _ . _ _ . , _ _ - , . - - _ _ _ _ _ _ _ _ . . _ , _ _ . .
'~
130 1
It will be revisited.
( 2 MR. NEVSHEMAL: With respect to that one that was 3 safety significant, was that the one in sixty that caused 4 you to take another thirty more?
'h 5 MR. BANSEL: No, the 30 extra are part of the two
'6 samples, the random sample and then the samples required 7 for safe shutdown. That particular one came about in 8 Moom 77N. Had it happened in the 7C issue, we would have 9
expanded that sample, but the Project jumped on it right 10 away and said, "We're going to go fix them all .100 11 percent."
12 MR. NEVSHEMAL: So that was not part of your 60 from 13 a sample --
, 14 MR. HANSEL: No, it came out of the evaluation of a
~
15 T2T issue .where they fottnd pipe support problems in t
j , 16 Room 77N.
l 17 MR. SHAO: Are you going to give 9s any examples?
ti 11
[ 18 MR. HANSEL: We haven't had any to date.
l ',
f 19 MR. SHAO: You dot.'t-have any to date.
!}
Li' ! 20 MR. HANSEL: Not yet. l t
s on MR. CALVO: The way your program is, you take 60, i
,: 22 random select, you fit that 60 and you go back to the ;
23 same ser of 60, and you use another random 60, but if '
21 some of those 60 you do within the first sample, then you i
23 only do what you have left over. So you only got 30, !
, - - - - - - , - - - - - , , , - . - - . - , -e .-- , ,, - , - -- ,
l l
l 131 1
because you did 30 before. I'm still looking at 60.
l
, ( 2 MR. HANSEL: No. I draw my first sample and I get l
)
i 3 60 And that's totally random. 1 4 MR. CALVO: When you did.60, you took care of 30, 5 for the one shut-down system. So I only got left 30 6 more.
i So you say in the second random sample, within ,
7 those 30 that you took that you didn't find nothing with 8 it, and the next 30 that remained is what you found 9 wrong.
4 10 MR. HANSEL: No. In this issue r in the cotter pin i 11 . issue, that was separate from 7C, from the self-initiated 12 program. We got at that through Room 77N, which was
, ( 13 identified to us --
\
14 MR. CALVO: You nnswered it.
15 MR. LANDERS: I have to go back tc what I missed at
, , 16 the last meeting. One of the points that was brought r s l 17 up -- but there was another one, the two over one where
, i 18 the pipes were touching -- they get to'the NCR and they -
I I 19 evaluate it and they say, "Oh, gee, that one is a problem l i i
i i 20 now with the new analysis." Is that situation going to
- 3 21 force you to go back and expand your sample?
i!
22 MR. HANSEL: (Mr. Hansel nods.) i 23 MR. LANDERS: What's tile basis for that si this 34 point?
2 "> MR. HANSEL: Because the only NCR you're dealing l .
1
132 I
with now is that one, and this is kind of a follow up of
- ( 2 the quwstion that Larry asked with respect to where do we 3 get to the point that we can say comfortably we have '
4 looked at all the NCR's and nont of them create a 5 problem, so we're okay. But what beppens whr.n one of 6 them, or three of them, create a problem now? How many 7 more out there are there that we didn't look at?' They 8 didn't create a problem an this case?
i 9 MR. LANDERS:
You don't have the final answer. .
10 Stone and Webstcr has the final answer, and now they 11 will -- assume they come up and say, " Gee, that has 12 safety significance."
(
13 MR. GUIBERT: Don, you have to remember what the 14 purpose of John Hansel's program is. His program purpose i
15 is to test the adequacy of construction, and that is, l
. I 16 taking whatecer the design and construction
! i 17 specifications were, was this thing constructed I'
is satisfactorily? So if subsequently the design changes ---
l i
19 MR. LANDERS: But the design is not changing. What
! 20 you have done in your process of evaluation is, "I'm 1 '
21 tearing up these computer sheets, and I'm generating new i
22 ones." The evaluation.that's done is based on torn-up 23 computer sheets; therefore, it's not complete in my r
21 li opinion. Stone and Webster is going to have to complete '
23 fth3t. If they find that this situation did have safety
, _ , % - - - - _ . - m - ~ _ ..,_,_.--.,-e-- --w-_ . - - - - ,
i 133 u.
I significance, I'm wondering what that does to your
( 2 construction sample.
3 MR. TYLER: Don, the only way that could happen 4 .would be if they physically changed the deflection which 5
- . says the original basis for building- the plant is no 6 longe.c valid.
7 MRe LANDERS: No, it says the original computer 8
output may not have been good, which is one of the i
9 3
reasons you may be redoing the analysis. I don't know. .
10 You have elected to do that. The data you're dealing 11 with to a degree is non-existent, is my point, and it 12 bothers me that you're making it, judging --
- r 13 MR. COUNSIL
- If we can go back and cover some of
(.
14 the stuff that you didn't read from the last meeting 15 either. Stone and Webster did an as-built walkdown of 16 all Category 1, 2 and 3 samplings. We talked in detail i 17 about the 7914 determination and so forth. This is i 18 already -- part of this is already documented as far as <
i 19 the other walkdown of the as-built systems, where there .
I 20 are interferences. This is just another piece of that l
! 21 whole thing. Stone and Webster is. reanalyzing all of l i l 22 this information. You understand --
23 MR. LANDERS: I understand. What I'm saying is in 21 my opinion the Safety Significanca Evaluation may well be 23 based on data that's going to be different in two months.
w_
i 134 2
I When Stone and Webster reanalyzes those two auxiliary
( 2 feed water pipes, they may end up with displacements that 3
are totally different and there had"'t been any design 4
changes; therefore, the Safety Significance Evaluation 5 may change.
6 MR. HANSEL: I suspect the thing that's going to 7
have to happen is when Stone and Webster completes their 8
analysis, if they, in fact, find something that has 9
changed, then I would suspect that there may have to be 10 some more reanalysis, a
11 MR. LANDERS: What I would suspect is that there may 12 have to be some more QA/QC.
13 MR. HANSEL: Which could result in it, but I think 14 we have to take that --
15 MR. LANDERS: I'm not arguing with you. All I want i 16 to know is, is the system in place to do that?
!. 17 MR. COUNSIL: Yeah.
Ib MR. HANSEL: Mr. Counsil just said yes.
19 I
j i
MR. JENG: I'd like to finish my earlier points, the !
i ! 20 i response given by John Guibert. The answer, I thought, i
t j
21 was that yes, they would use statistical approach in j !
l 22 l deciding.how to expand the population fo'r examination. l I I j j 23 ! My question is, then, is there enough consensus in l
24 j existence among the TUGCO people and its consultants that 23 such approach which incurs or embraces the homogeneity e
t
. - . - _ - _ - , - - , . ~ . _ _ . . - _ - - . _ ~-.,_..,~.z._.- _ ,_ .. . . , ,,, , , , , - . _ _ . . _
l 135 l 1
- l i I concept, 95-5, are you prepared to feel that that's
( 2 enough consensus that you can go ahead on this basis, 3 despite there are some concerns expressed by other 4 parties about the homogeneity and the statistical l
!. 5 approach? And the second part of the question: Do you o still consider the use of a reasonable assurance judgment 7 as overall approach in supporting your arguments? Is i
)
8 that another factor in your bag, or-are you going all the 9 way through your statistical approach? ,
10 MR. HANSEL: Let me answer both of them. The first t
11 Point is yes, we feel within the CPRT, including the SRT 12 and ourselves, that we certainly have agreement within i < 13 TUGCO and the Comanche-Peak Response Team. In our k.
14 discussions with Staff, I cannot address that. Most of 15 those discussions have been between the Senior Review 16 Team and them. It's my understanding that we have i
!. 17 general agreement. We have had people on site looking at
! i 18 our work processes and our records and Jose's audit -
19 trail, and I think that they're satisfied, at least'with i
i 20 the methodology and the approach we have taken and the .
j 21 documentation to back that up. It says yes, we are 22 " reasonably homogeneous,' and we have a good foundation.
23 We have the cornerstone in~ place.
33 The second piece, yes, I think when we finish with l
33 the program that we-have that we'll have reasonable
l l
136 I
assurance that we will have covered the plant, based on
( 2 two things. One is that we're going at a very meticulous 3
step-by-step process to be sure that we cover everything i 4 in our work processes and we've really tested the 5 construction. Secondly, we have a very disciplined 6 approach to the inspection and the evaluation of the 7 deviations that come out of that. We still have to go 8
through yet the analysis of the data and completion of 9 inspection, but when we're finished, we will have done a 10 very thorough review of that facility, the kinds of 11 deviations th'at we found, evaluate on a case-by-case 12 basis. We'll also look for any trends that might cause r
(
13 us any concerns, that could cause us to go elseuhere. If i
14 we do have a construction deficiency, by our definition 15 safety 'significant, we're going to_ expand and go beyond 16 that.
i
! 17 I think our program is well founded and well based, j is and it's' being very carefully Laplemented.
If: 19 MR. JENG: So you answered my question yes, you are
! 20 looking at a two prong approach in providing a basis for 21 your evaluation. One is the statistical approach.
s The I
__ other is (Inaudible); am I correct? i 23 MR. BECK: Let me amplify a little bit on the l
24 statistical approach aspect of it. The only reason we 25 chose to use a statistical basis for a sample selection .
I
137 1
process was to establish, help us establish, methodology
( 2 and a trigger, if you will, to assure that we're 3
consistently applying the same methodology across the 4 board. We're not saying that the use of statistics in 5 this context stands alone by itself, and we sink or swim 6 on the basis of 95-5. It's an aid to give us a rigorous 7 framework within which to operate and to select the 8
sample to be sure that we're doing.it consistently and to 9
give us that touchstone, that touch point, if you will, 10 to increase the likelihood of our reaching reasonable 11 assurance. All the other facets of the program are 12 certainly of importance as well, and the breadth and 13 depth of it, as. John Hansel indicated, the depth of 14 reviews, when we evaluate deviations, are critically
! 15 important to the process. Statistics is only that e
16 methodology, or gives us the ability to use the -
i 17 methodology on a sampling basis.
j is Anybody else is free to add. We have had many, many -
19 hours of discussion on this point and other facets of the i
i 20 Program, and I can certainly speak for myself as Chairman
? 21 of the Senior Review Team, and have been interrupted a l i 22 few times in our sessions by other members when they 23 didn't agree with me. So if that's the case now, I'd 3; sure welcome hearing so.
23 MR. CALVO I believe the subject came up in our i
l
~ - - .,,- ,,-,m w-,,.m ,,, ,-w,w-4 >g ,g---nw,r.e. ,we- p op- y m,- - , - om m,- ww,m,ey-
138 1
Presentation the first dcy, and I think we presented a
( 2 Staff perception what we were going to use for the 3
construction -- for the self-initiated construction
, 4 adequacy review. And I think that out of that context 5 arose the concept of the 95-5 when we say that it's 6
supposed to provide the Staff with the mechanism so you 7 can proceed in an orderly fashion and also set forth the
! 8 criteria for knowing what to do when you find something 9 wrong with the first sample. Therefore, the overall i
10 criteria, what do you want to do to review the whole l gg thing in case you found something. So that's the way 12 we're proceeding. That's our perception, and until we
, r 13 have something different, the Staff will continue with t
\.
y this perception, and we'll use that as the basis with so I
15 many other inspections that can be done to reach the i
16 overall reasonable assurance. So it is not -- they've
! 17 got to bite the bullet, we've got to bite the bullet, but g gg at the end we're going to reach an overall reasonable - ;
39 assurance, based on that and whatever else we,have.
' I i 20 We're setting up the mechanism to proceed in an
.; orderly fashion.
.y g I think that's the important part of 22 it. That's the way we.look at it. s I
23 MR. HANSEL: That's a good way to go. i MS. GARDE:
3 Taking this cotter pin example one step '
. ,5 further, am I correct'in my assumption that Region 4 has >
139
~
1 been looking over your shoulder on this whole effort of
( 2 the cotter pin?
! 3 MR. HANSEL: Region IV has been with us on 4 inspections. They have come after us on inspections.
i 5 They have reviewed a number of our checklists. They have 6 watched us draw samples. They have observed, I 7 believe -
8 MS. GARDE: I want to use just this one example, not i 9 generic. In their efforts at reviewing your work on
)
10 this, would they typically look at the same sample that 11 you did? Would they look at the same 60 or 307 12- MR. HANSEL: I'll have to let Tom Westerman answer
~
13 that.
14 MR. WESTERMAN: There are two things we do. One, we "
{
1 15 witness the inspection that they perform, and we do deal 16 in the same samples that they work in because that's the j i 17 one hiere we're essentially validating their samples, and j is satisfying ourselves that we're doing a proper job in 19 looking at the samples.
l i i 20 Secondly, we independently come in -- in fact, s 21 they're doing it on Saturdays -- we take their checklists
! i 22 and we go behind them and look at a different one than l i 23 we've looked at before, still within their population, 24 and then we make a comparison to what we find when we do 23 that to what they found. L v
i
140 1
MS. GARDE: That's different than the population of
( 2 60 thry've selected?
3 MR. WESTERMAN: No, it's the same 60 4 MS. GARDE: So you're still saying within the same i 5 60 '-
{ '
t 6 MR. WESTERMAN: That's right.
7 MS. GARDE: So you're not looking at anything 8 outside of that.
9 MR. WESTERMAN: Not as far as this program here is 10 concerned. We still have a 2512 Program for construction
! 11 that's ongoing on Unit 2. We have had some independent 12 folks come in, like Region 1, and look at something completely separate.
{ 13 For example, we looked at pipe 14 supports. They did an as-built look at pipe supports.
15 They also looked at skewed welds.
, 16 MS. GARDE: You're going further than what I want to i 17 ask.
j 18 MR. WESTERMAN: It's much further than what their 19 program is. We're not trying to take their sample and
}
i 20 pick up 60 more. We're looking at their -- ~
1 t
t 21 MS. GARDE: Mr. Hansel, what would happen if i i
22 Region 4 found another missing cotter pin that you hadn't !
23 found?
3: MR. HANSEL: I would take a very hard look at that. !
t l
25 That tells me that I've got an. inspector maybe who didn't l l
i
141 I
do his job right, or maybe I had a procedura -
2 MS. GARDE: But not of the 60.
3 MR. HANSEL: Let me go ahead and address the issue.
4 y,,re still in the' sample of 60. I inspected it. They 5
came along and found something different than I found. I 6
need to understand that.
7 Now, did they make a mi.itake? Did we make a 8
mistake? Was the procedure not clear? I need to 9
investigate that. If it ends up it's a procedural .
10 problem, I immediately get it clarified and go back and 11 reinspect what we'd already inspected,-if that's 12 necessary.
13 MS. GARDE: Is that written up in one of your f_
14 internal NCR's?
15 MR. HANSEL: I have a card in place right now where 16 i
- we had an incident where they had found something that we l ! 17 did not find..
! IS I
MS. GARDE: Using your procedures, iooking at your 19 procedures?
s 20 MR. HANSEL: Exactly. And we're retraining j 2I inspectors. I met with all the inspectors yesterday i e 22 myself, and we're backing up and looking at the l 23 procedures. We're reinspecting the work that that man 21 has done, and we're looking at some other samples to see 25 if it had been missed. So we take that very seriously.
l
I 142 I MS. GARDE: Okay, and that's within your internal QA
.( 2 Program?
3 MR. HANSEL: Yes.
l
~
4 MS. GARDE: What if they find a cotter pin 5
outside -- a missing cotter pin outside of the sample of 6 60 that everyone is dealing with?
7 MR. HANSEL: We'd have to take a look at that, where 8 it was.
9 MS. GARDE: Would you consider that in expanding 10 your samples?
11 MR. HANSEL: Probably not. Probably not, based on 12 our program. We'd look very hard at.it in conjunction (3 13 with the project.
14 MS, GARDE: What do you mean, you'd "look very hard i 15 at it"?
i 16 MR. HANSEL: Well, from a sample expansion we would
{ 17 not expand our samples, because it was outside our j 18 sample, but we'd certainly be aware of it. We'd talk to -
19 l
the project, and they may well choose to say, " expand i 20 your sample," but'that would be their cost since it's j s' 21 outside of our program.
t i .
l I
22 MS. GARDE: So if other people that are on site, 23 I i
whether it's the llRC or other third-party folks, look at
.;,3 another part of -- look at something beyond your sample ,
i 25 } size, that is not going to be automatically factored into I I.
\
e *,
I .
143 l 1
either sample size or consideration for expanding the '
( 2 sample by you?
3 MR. HANSEL: That's correct.
4 MR. NOONAN: Let me talk that a little bit. The 5 question you are asking, if I interpret it right, I think 6 what*you're saying -- let's say the NRC Staff goes out, 7 the Staff force itself, goes out there and finds 8 something that's outside of John Hansel's sample. We 9 find something. The question is, what happens next?
10 MS. GARDE: Right.
11 MR. NOONAN: Let me answer from my perspective. If 12 something like that were to be identified, then I think e
( 13 we'd come back and find out what it is. Then we'd look 14 close at what that means as far as this whole sampling 15 Program. Are we mit. sing things? This is strictly an i
16 audit. That's what it is. And what he's doing is i 17 strictly a sampling basis. He is not looking at 100
[ 18 percent. I would have to look at it and decide what we 19 wanted to do about it. I don't have an answer.
i
! j 20 MR. CALVO: The answer, we're almost going to find 5
that isolated case. I don't care if you do 100 percent, 21 b
22 we're alwr.ys going to fic4 it, so the answer is the first 23 thing is, like I said yesterday, the way the Staff 21 perceives the program in hopes that a homogeneous
( 23 ; Population was done in such a manner that the effort !
L r I L
^
i
= \
144 1
resulting from that, it will result, we will brush out
( 2 all the generic implications, so when this cotter pin is 3
found by whoever finds it, walking through there at 4
morning or at night, then you say the test of the program 5
and anyrhing else that w'e come up with, it is a fact that 6
that one did not reveal by itself a generic implication.
7 Keep in mind that you need a cotter pin somewhere else 8
that is missing, because you've got a redundant built
- l. 9 into this plant. You must consider that when you're .
10 analyzing that isolated case. But if we find a cotter 11 Pin, it indicates that we had missed the generic l
12 implication, and then that part of the program is 13 suspect, and you're going to be in trouble and we're 14 going to be in trouble.
15 MR. HANSEL: That's why I indicated awhile ago we're 16 going to look at'this very hard. We'll factor it into an i 17 adverse trend. We're not just going to ignore it. If it j 18 happens, we certainly want to know about it, and we'll -
take it into our evaluation. I would not expand the 19 i
! 20 sample for that unless we saw some reason.
t j 3: MR. GUIBERT: It might be worthwhile just to revisit i
22 this specific case, which, as I said, by our definition, l 23 18.the only safety significant issue we found today.
34- If you look at what our action plan and our program 23 would require John Hansel to do, as a minimum, is the l
, . - - = - - - - - - - ,.,- , .-- - - ,-.,,,-,m,.
--v , - , , -,.r----- . , , ., , - --,---s-,.--my-- m,,., - - , - .--,-,,,rv
I .
145 1 next step. Having found that, what I think is
( 2 constructive is what the Project elected to do of its own 3 volition, as far as assessing what we necessarily were t
4 headed toward. Maybe Counsil or somebody from Project l 5 can talk about it.
6 MR. COUNSIL: I'll take it.
7 What we basically did, John, with one safety 8
- significant deficiency would, in fact, expand his sample.
9 We have other issues on some supports in the plant ,
10 itself. What I elected to do, when I learned of this, is i
11 we're going.back and do 100 percent reinspection for '
12 cotter pins along with a few other attributes that we on :
i 13 the project are doing. !
14 Any missing cotter pins that are found are being fed i i
15 back -- if we find any -- are being fed back to John for 16 generic implications. So I elected to expand it myself 3 !
i 17 to 100 percent. i
! j 13 MR. CALVO: So if somebody come back and find one -
t I
L .
z 19 more cotter pin missing, it must be an isolated case !
s -
r i 20 because you have done enough of it that it take care of
' l
. . a 2 21 all generic implications. So there's going to be a lot
' i 22 of those and the question is, what are the consequences !
23 of finding those, and hope to God that they'll be no 21 generic implications?
23 MR. HANSEL: Let's look at some other samples. i l !
- ?
~
146 1
MR. ADAMS: This is a view of Unit 2. The reason I l
{
( 2 wanted to show this view, the population is the liner, 3
and the location of the sample that we received the DR on 4 is somewhere up in here, inside, on Unit 1. But I wanted 5
to show you from the outside so you could get an idea of 6 where it was.
7 This is a view of the spray piping that is supported 8
on the liner on Unit 1. If you follow it up, there's a 9 spray header that runs around the dome of the 10 containment. One of the plates that those spray headers 11 are held on had a welding DR written against it.
12 This shows you the spray header and the spray 13 nozzle. This is the support for the spray header. The 14 plate in the containment liner that has the weld on it is 15 shown here, and the next view you'll see where the defect i
16- was, the deviation was written.
! 17 The type of deviation that was written here was a n;
l i
- weld undercut deviation. It appears down in this region, -
i '
19 down here along the weld seam. This is between the half-i 20 i
inch plate and the thickened plate of the support. The
- 2 21 evaluation, the sketch, I guess, will show a lot clearer 22 what we're talking about as far as the welds. The 23 inspection would be -- one of the weld samplec would be a '
l 24 weld seam between the plates in the liner, in this case 23 the weld around this reinforced plate. The evaluation of I
+
,- _.:,, - , - - - , - - - - . ., , ,-.,,,e- _< ---,,m,,
1 .
147 I the undercut was made by first determining how deep the
( 2 undercut was. That was then checked against the l 3 reduction in cross sectional thickness of the plate. The 4 material test reports for that particular plate were then
- 5 reviewed and a comparison was made against the specific 6
4 material properties of that plate, the design allowables,
_ L
, 7 the allowables used in the design of the containment, and t 8 the reduction in -- the percentage of reduction in the '
I :
l 9 thickness. And in almost all of the undercut cases that -
- 10 we have evaluated, including this one, the material 11 properties were in' excess of the 60,000 psi yield that
, 12 was used in the. design, so that you would have maybe 15, 13 16 percent, or maybe 20 percent, design margin in the 14 actual material properties over what you needed for that 15 steel.
16 The thinning caused by the undercut was in the order
! 17 of 5 to 10 percent, so it was of no concern.
j is 'Now, all this is doing is looking at actual material
' (
! ; t 19 properties. We did not look at design margins. We did i : !
! .20
.not have to look at the actual loads of that containment I
- 21 spray header on that to see what the actual load was ,
22 against the design load that was used for the support.
23 ! So that's generally how we have looked at all these !
,i 21 undercut problems in the containment liner. This is our !
25 sample. There were a few of them listed. That was one '
r
148 _
I of the more prominent deviations that was written.
( 2 MR. SHAO: I have a problem with this. This liner 3 is supposed to meet ASME Code Section 3262.
4 MR. ADAMS: Yes.
5 MR. SHAO: Now, you say you want to use the so-6 called specified yield strength which is more than a 7 minimum yield strength. Does that mean you don't need an
- 8 ASME code?
9 MR. ADAMS: No, because we haven't looked at the ,
10 actual stresses. All we've looked at is - we have 11 sufficient -
12 MR. SHAO: Whatever is the alignment, this is my (s 13 yield strength. The excess in yield strength may be 14 higher than this minimum yield strength, but that's the .
15 yield strength you have to use.
16 MR. ADAMS: Well, in our evaluation we are not the i 17 ones that are checking against the codes. We use codes,
[ IS but' the project, when they go through the NRC's, they '
,'* 19 have to check against the codes, but in this case'we did l i 20 not go back to get the Gibbs & Hill calculations. -
c
! 21 MR'. SHAO: I realize you didn't do any calculations. f I
i 22 All you do is, you just say, "My yield strength is higher l l 23 ) than the minimum yield strength specified, so I don't i !
l l 21 have to do anything further," but my point is the miaute 1 f
! 25 you.do this you violate the code.
1 -
i !
i 1.
149 1
MR. ADAMS: I'm just looking to see if the liner is
( 2 going to work. It is.
3 MR. SHAO: I know it will work, but the code i
4 specified minimum yield strength. You are using higher 5 than the code --
6 MR. ADAMS: We haven't used a yield strength in any 7 calculations'.
8 MR. SHAO: Whatever the strength, tensile strength, 9 whatever strength you use.
10 MR. ADAMS: No, but the ASME calculation, the 11 calculation that you_would do for the liner,-you would 12 Put the actual loads from that support to figure out what 13 is required.
14 MR. SHAO: Let me understand what you say. You say
, 15 the weld may be 5 percent undersized --
16 MR. ADAMS: That's the --
i
$ 17 MR. SHAO: Let me finish what I hear,'what I j 13 understand I hear. The weld may be 5 percent undersized
- 19 or 10 percent. undersized, but now you compare the i
! 20 strengths of the liner material. It's more than, f -
{ 21 - 15 percent higher than minimum specified. Okay. And i
33 that's why you say there's no problem. 1 j
gy MR. ADAMS: Yes. l l
3; MR, SHAO: But according to the code, even though I 23 you are 15 percent higher, you should use this code-h
150 u
I specified minimum yield strength.
( 2 MR. ADAMS: If we were going to put the loads and 3
calculate the thickness required for the plate, using the 4 code yield strength, we might come up with a thinner 5 plate. We didn't go back and check the actual loads.
6 MR. SHAO: Using the code-specified strengths or 7 your actual strength?
8 MR. ADAMS: Well, tti2 Project would look at it from 9 the code strength.
10 MR. HANSEL: .The point is, we're determining is it 11 safe and will it perform its function. Those all go to 12 the project, and they're looking at them for two other r 13 reasons, at least two. One is --
\
14 MR. SBAO: I-say did you meet the codes?
15 MR. HANSEL: That's what I'm going to answer. All 16 those projects, for at least three things: One is i 17 correction, if they think it's necessary; two, to j IS determine if they violated the code; and three, to -
=
19 determine if it's reportable under 50.55E. We're making 1 I i 20 a determination: Is it safe.and will it perform its 31 function? They all go to the Project, all of them. They i
22 will make a determination if, in fact, there's been a 23 code violation, and is it reportable.
21 MR. LANDERS:
For example, is a fatigue evaluation 25 of that required by the code?
.' 7
l l
151 1
MR. ADAMS: The Project has done a fatigue. I don't i I
( 2 know if it is -- 1
- 3 l
MR. LANDERS: Well, my point is that in determining 4
the safety significance, if that is required there, then 5
what appears with respect to the weld undercut is going 6
to have an impact on that because of the stress 7
concentration factors that are generated.
8 MR. ADAMS: We addressed the stress concentration ,
9 factor in our evaluation from the point of view of 10 configuration of the undercut, but the fatigue evaluation 11 was done in the calculations by Gibbs & Hill, and it was 12 not limiting.
r 13 MR. SHAO: And your last comment is because of
\
14 undercut your stress concentration ~ factor changed, maybe 15 originally only have 1.5, maybe now 3, and it may change 16 your fatigue factor.
l I 17 MR. LANDERS:
And again, my cor,eern is with respect l j 18 to retracing the sample size. And if you're not going to a
19 i do it and now we go to the project again they do it, and 20 i
they find out that the things are of concern, then we go (
ti I h 21 back and revisit this, i c' ?
,; 22 MR. BECK: Yes, '
J' ;
23 MR. ADAMS: Another example that we have in the f
21 concrete area; a number of the deviation reports were 25 written on voids in honeycombing, as you saw on the [
t h
. , , . -e,- -. . - - ,
152 1
statistical -- or on the status report. This deviation
( 2 report involved a blocked-out area in the pouring of a 3
floor slab, which is shown, primarily outlined by all 4 these reinforcing bars. What we did was we went and 5
observed the underside of the area which had the 6 deviation written against it. In this case the i
7 honeycombing was in the corners of the later poured slab, 8
the blockout was poured later, and determined the extent 9 of the honeycombing. Then we looked at the effect of the 10 steel that's built into the slab and its capability 11 against the loads and the required steel that's in the 12 slab under the tension loading condition.
13 Assuming that there is no concrete in this area, the 14 floor slab has still got sufficient strength to carry any 15 loads in the area. We also went and looked at the 16
! surrounding area from the poiht of view of potential
! 17 falling or something like that. In the case of a bolt on j
~
18 the slab, there is no high energy system or anything like -
19 that.
i There's nothing of safety concern underneath this, s 20 anyway. Generally, the --
21 .MR.-SHAO: The same' question: Suppose that 22 honeycombing area appears somewhere else?
23 MR. ADAMS: .
That's the whole basis for the sampling. b I
^
24 That's why we're doing the sampling and the trending and !
25 so forth.
153 1
But our observations on these types of deviations,
( 2 as we do our analysis, is that a lot of these are showing f 3
- i up as having no structural or functional problem.
4 Theytre on'y aesthetic-type problems. Even though 5
they're written up, they are no problem. But that's what 6
you would look at when you get into the trending. My 7
group does not do the full responsibility for the
-8 trending. That's done by the population sample 9
- engineers. They would read our evaluations and factor 10 that into it.
11 The next example is in the electrical area. The 12 population is instrumentation installation. The i
13 deviation that was. written on this evaluation, on this 14 inspection, was a slope to an instrumentation sensing 15 line. This is off of Loop 2, reactor coolant loop; these 16 were sensing lines that are used for low flow signals for i 17 the recctor coolant system.
j IS The line in question were these lines -- this line
- l 19 l :. that goes over, exits the reactor coolant cubicle through l
20 the wall, through a sleeve in the wall. There are s
2 21 various degrees of slope in the line. At some points t
i !
22 it's a quarter of an inch.
l The criteria is for a full i 23 one inch of slope every foot. I i
24 ; There's another slide on the other side of the wall, j i
l 25 when it comes out of penetration. There's one line that
. - . . . . . . . . . . , _ , - . _ . , . . _ _ . . _ . , _ _ _ _ _ . , _ . i_
154 1
has the one-inch-per-foot slope, and then there's another
( 2 line that's more or less horizontal coming through the 3 same sleeve. This type of evaluation was a qualitative 4 type of evaluation where our instrument specialists went 5
out into the plant and reviewed the slope of the line for 6
air pockets, for high points and so forth, and found that 7
there were no places along the line where there were any 8 problems of that nature. So it was a non-safety 9 significant item.
10 MR. J3NG: What were the deviations?
11 MR. ADAMS: The lack of slope to the line. In other 12 words, the line is supposed to run downhill from the 13 point of sensing on the reactor coolants load. The angle 14 at which it runs is different from what was required in 15 the installation specification; however, in the t
16 construction it didn't make any difference as far as i 17 functioning properly of the instruments that it ran to.
j is The attribute that was being checked, or the requirement -
19 i that was being checked against, was one inch per foot,
! ! 20 but Brown and Root had the option, if there were i 21 arrangement problems, of using a quarter of an inch per.
i 22 foot; and I think most everything that's written up is 23 written up against the one-inch criteria, so there are l 24 some that_are a little bit, they are a quarter of an 25 inch, that are still acceptable. And'there are some that '
P
_ _ _ , _ ,~-..r-- - - - - " ' " * ^*T-* * - ' " ' ' ' '
e .. ..-
l i \
l 155 _
1 are actually level that are still acceptable, as long as
( 2 we don't trap air and get erroneous readings in the line.
1 3
MR. CALVO: This is something having to do with the 4
reactor coolant loop, the elbow ducts --' slope, right --
5 i so it will be a typical Westingho~seu plant. There will 6
be a level that will be maybe a different story where the 7
slope may have a little more significance than it would 8
'have if it went to the floor. But again, you went by 9
these specifications, anyway.
10 MR. ADAMS: Yes.
11 MR. CALVO: So you say the slope was not there, you 12 went back and inspected this line, you followed through, 13 found out there was no point for air bubbles to be 14 dropping there, that kind of thing.
l 15 MR. ADAMS: That's right.
16 MR. CALVO:
How do you check for air bubbles?
! 17 MR. ADAMS: We didn't check for air bubbles. We 1
j 18 just checked'that there wasn't any point for them to be.
19 MR. CALVO: Do you have venting in those lines?
i 20 MR. ADAMS: Yes.
- 21 MR. CALVO: So any type of maintenance, you must 22 probably have the same problem, anyway.
23 MR. ADAMS: The n3xt illustrations are support i
21 j inspections. The support that was written -- this was a l I l 25 I large bore rigid restraint, rigid support, where the l
' i
~
156 1 i _
i I deviation was written against the embedment of the
( 2 Richmond insert anchor where th'e amount of thread 3 extending above the concrete was greater than wac called 4 for in the drawing. In evaluating this type of 5 deviation, what we do is we look at the actual thread 6 that is embedded into the concrete, we reduce the 7 capability that this embedment, this anchor, has 8 proportionately to the amount of embedment that it's ,
9 supposed to have. then we compare that with the actual 10 loads that are imposed on it by the support. In most 11 cases we see that we increase the design margin from 50 -
12 percent to 65 percent of the capability of the embedments are being used up.
{ 13 In other words, there's still a 14 margin of 35 percent oves what it's actually seeing from 15 the support.
, 16 We've seen p~ipes, we've looked at hilti bolts, we've
$ 17 looked at these Richmond inserts. In each case the j IS embedments and the anchors are capable of taking a much -
z 19 higher load than they're actually seeing from the i 20 supports that are attached to them. We go through and we ,
l !
= '
21 look at that. We compare shear, we compare the tensile
, 5 22 stresses and we compare the total capability of combined 23 loads.
23 The next one is a support out of Unit 2.- This is 23 one'that was written up as.a dimensional problem.
> . , . , . _ _ _ _ - . _ _ , _ . _ _ _ _ . _ - - . _ - _ . - _ _ . - . - _ _ . _ _ _ . - . _ _ . - _ . _ ~ _ .
157 1
There's a single pipe that is supported off of the wall
( 2 in Unit 2 by two snubbers, non-rigid supports. The 3 dimension that was checked in the inspection was the 4 diuce. ace C to C dimension between the pins for the 5
anubber, and they were different from top to bottom, o waie , shows up in the overhead. They were different by a 7 quarter of an inch. In this type of evaluation we again 8
look at the allowable tolerances in the extension of the 9
'anubber item based on the vendor requirements to see if 10 the actual extension in the plant is within the plus and 11 minus dtritsions given by the vendor. We look at the 12 pipe stress calculations to see what the pipe movements 13 are, to show that in extended or shortened configuration 14 that it will still have sufficient, excess room to 15 travel', given the deflections. That's a typical type of an evaluation for that.
16 I
i 17 There's one more example. I don't know if we need j 18 to go through it. The last example was a type of example
{ 19 from a support where we've had a weld deviation written I i i i 20 up. .In the deviation, in the corner here, that channel 3
g 21 steel member is welded all the way around the sides and i
22 in one of'the welds, the thickness of the welds to show 23 the weld is too thin. The evaluation approach used in 21 this case was to ignore all the welds inside on this 23 piece -- just look at the welds on the outsides of the
158 _
1 channel and look at the loads on the support. We found
( 2 that even doing that the weld was probably twice sa tbick 3
as-it needed to be for the load it received. Again, we 4
have a much lower load than the support was designed for.
5 MR. CALVO: Going back to one about the 6
instrumentation of the slope, how did you conclude that ~
7 that was an isolated case?
8 MR. ADAMS: We didn't make that conclusion yet.
9 There are a number of slope deviations that we have 10 looked at, and after we go through them all --
11 MR. CALVO: But that particular case there was no 12 safety significance,
{
e 13 MR. HANSEL: We showed these examples to give you a 14 feel for the kinds of things we're finding and the 15 analytical approach we're going through to avaluate es:h l 16 and every one. Each time we meet we'll give you some new l
$ 17 examples just to let you get a feel for-what we're doing.
1 j 18 MR. NOONAN: I have a question to ask you on the -- -
4 :
19 back a few slides on that embedment- . How do you check to 1
i i 20 !
see how much is embedded? How do you determine that? -
21 MR. ADAMS:
~
In some casec we have UT reports we use.
. I 22 Other cases we have drawing dimensions that we use. And '
23 if we see a need to, we'll go to UT.
j 21 MR. NOONAN: Well, UT gives you a pretty good :
I :
25 indication. I guess I'llogo the other way. How do you
?. -- . , . _ , . . _ . - - - . - - - - , , - . - - - , , - - - .
159 1
know random rebar chopped it off and you don't have what
( 2 you'think you have?
3 MR. HANSEL: The results of those surveys for those 4
kinds of instances in the plant have not indicated that 5 to be a problem. There are allegations in that area, 6 that, yes, we have looked at. We have gone back and 7
looked at all the results of the hilti sweeps that were 8
done by the Project, and there have been a number of 9
inspections in this plant on hiltis, embedments, et .
10 cetera.
11 MR. NOONAN: Do you have the actual number of UT 12 examinations done?
13 MR. HANSEL: That were done by the Project?
14 MR. NOONAN: Yes.
15 MR. HANSEL: We don't plan to do any; howevar, if we
=
16 see a need to, where we can't get enough data, we'll go
\
-s 17 do it.
MR. ADAMS: That completes our presentation.
1 18 i
- 19 MR. CALVO
- One more question. This thing on
'I l' 20 October 17 when we had the audit, and I think we've
! 21 reached an agreement that you were going to go through !
i 22 the old populations and come up with some narrative 23 justifying th'e homogeneity of it. And it became ! !
23 something -- last week we came and reviewed some of them -
and we are ready to come back again if you have finished.
i 25 ,
I
~
160 _
1 But again, we offer that challenge to the Senior Review '
( 2 Team. I want them to look at it. I want to get the 3
Senior Review Team agreement before I commit my resources 4 to do it for the Review Team.
5 MR. HANSEL: Al Patterson, would we be ready next 6
week for Jose and some of these folks to come back in and 7
look at more backup documentation of our populations?
8 MR. PATTERSON: Yes.
9 MR. EANSEL: About how many would you have ready 10 next week?
11 MR. PATTERSON: I would say we'd have anothe. half a 12 dozen, probably in the middle of the week.
13 MR. HANSEL: And then we would have the remainder 14 all ready for the following Monday.
15 MR. CALVO: Keep in mind I want the blessing by the 16 Senior Review Team. I want them to agree with you so l 17 it'd make my job easier when I come in here. Will I have i
18' thtt blessing, Phat stamp of approval?
i l ;
19 MR. HANSEL:
i My records are available to them, as i
! 20 well.
l 2
3 21 MR. CALVO: I just want you to call me and say we've i.
22 got the CPRT all the way to the Senior Review. Team, 23 they've looked at it, they're happy with it, then the 33 stamp will come.
23 . MR. HANSEL:
l ! We'll work that with the Senior Review
161 _!,
1 Team and get a schedule, and John can get back with you
( 2 and let you know what that looks like.
3 MR. CALVO: Get back with Annette Vietti. j 4
MR. HANSEL: Those are in work, Jose,.and they're 5
looking very good, t 6
MR. CALVO Next week is leasible,'or do you know? l 7
MR. HANSEL: If I can get these fellows to look at !
8 them.
i 9
MR. BECK: The reason I'm shaking my head no is i 10 because of the workload associated with getting all the
~
11 questions out by next week; week after next, maybe.
12 :
MR. CALVO: It's up to you. We are ready. We are '
(s 13 almost there.
14 MR. HANSEL: Let me make sure I understood. I think 15 all you're requesting is that the Senior Review Team look r 16 at what we have done and that they're satisfied with the !
i 17 process. i IS g MR. CALVO:
Only that part that we feel is missing, '
19 f
the justification for the homogeneous population. The s 20
- i r.arrative that you prepare I want the stamp of approval -
! 21 by the Senior Review Team. When that is finished, then L 22 we come over and we verify, and I hope this is the last i 23 time as far as auditing. We can start writing the SER's. r 2;
We will start writing the SCR's regardless, but we want f l
25 to make sure that.we finish this part.
i v
~
l 162 -
i I MR. HANSEL: I believe we're in good shape. We can
( 2 coordinate schedules, and then John --
3 MR. CALVO: You say as o* now, two weeks from today 4 you will be ready?
5 MR. HANSEL: Right.
6 MR. CALVO: Let me know if it's different. We have 7 planning on our part.
8 MR. SEAO: Also, I'd like to have an audit meeting 9 relating to deficiencies and deviations. I'd like to 10 understand more. And I want Landers to come down to talk 11 to audit meeting on this.
12 MR. LANDERS: All right.
13 MR. CALVO: This is a combined effort both on your 14 part and my part. When they're ready and approved by the
-U5 Senior Review Team, we come and we prop one up, one way
, 16 or the other, good or bad.
-s
, l 17 MR. SHAO: Are we going to have the homogeneous 18 population meeting and also the deviation?
- =
19 . MR. HANSEL: Sure. It's easy for us, because it's i !
! 20 two different groups of people. You may have the 21 ! resource problem.
22 MR. CALVO: Please, in your agenda, the Appendix P 23 of this SER 11. We'd like to put that to bed, if we can.
,yg MR. HANSEL: We're ready for that also.
l 25 MR. NOONAN: I want to repeat mysel'f a couple of 1
! 163 _
! I 1
times from October because I think some people have not ,
i \
(} - 2 read the transcript, at least not very well. In October 3
we said that the Staff would be out in a number of places 4 doing what we call audits. We were going to document 5
those audits in the monthly inspection reports that were 6 put out by Region IV.
I have asked the Staff to prepare 7
what they did on these audits, a description of what they 8
did on these audits, so we can get it to Tom Westerman 9 for his next inspection report. And I think, by the way, 10 I haven't gotten any of those yet. I don't think.
11 The reason for doing this this way is, number one, 12 so we can have a clear record of what the Staff has been r 13 doing and so on. I also stated in October that I put out
(
14 another piece of paper talking about what constituted 15 meetings and what constituted audits. Any time we're 16 going to discuss results, conclusions, it's going to be i
17 done in a public meeting. If you're out there looking at j U; inspections, records, you want to get more data for '
19 yourself, et cetera, that's fine.
i The minute you're i 20 going to start presenting conclusions, recommendations or .
t j 21 whatever, that will be done in a public meeting. Annette Vietti will take the proper courses to make sure that is ,
23 noticed properly. .I notice a lot of times today the I '
23 words being interchanged about meetings.. I want to make .
25 it very clear that that procedure is in existence, and I 1
1
164 I want it adhered to by the Staff. An audit is an audit.
(- 2 A meeting is a meeting. Make sure we keep it that way.
3 I guess I'm going to ask Billie to comment on the 4 schedule. I think she's going to advise me on the 5 schedtle.
6 MS. GARDE: My comments on the schedule also kind of 7 coincide with my overview comments to the Applicants. I 8
learned a lot mo're at this meeting an'd it was very 9 helpful to me above and beyond the revision of the .
10 Program Plan. But it also confirms the concern that I 11 have been raising from the beginning of this whole 12 process, which is that in order for CASE to take any kind 13
{ of position for, against, or articulate what our
- 14 objections are to the Program Plan, solving many of the 15 Problems that we see at the site, we've got to be able to f-t 16 see the checklists and the basis for the methodology and
! 17 scope. And I can't emphasize that enough, because j 18 otherwise the Staff or the Applicant are both putting us I
19 in a position where they're charging us with delay or '
I .
i 20 making unreasonable conclusions when we'have not had the 2
e 21 benafit of seeing~what the Staff has seen doing the 22 audits, what is being make available in explanations, 21 diagrams, objectives, from the Applicant to the Staff. !
21 And if you were in our position, I'm.sure that you l 25 could understand there is no way we can just look at the .
'~
165 1
Program Plan as we now have it and say, "This is great," .
( 2 because the whole thing is based on the quality of the 3 . checklists. And I assume that the checklists are very 4
good and they're very comprehensive, that we're not going 5 to be taking dispute if they are thorough. On the ones 6
that are not thorough or that there is a problem thet we
- 7. think is not being dealt with by the checklists, we know 8
the allegation and the allegation came from us, or we're 9
working with the source of that. allegation, and we see a 10 loophole, I really believe that both the Staff and 11 Applicant want us to tell you at the earliest possible 12 time. We can't do that until we see the checklists.
13 It's just impossible for us to do that. I want to be 14 very clear that until we see those documents and have 15 time to evaluate them, that we just can't take a position 16 on the Program Plan. It's impossible.
5 17 And so, Vince, that feeds into my comments on your l
j 18 . schedule. We are never going'to be able to take a -
e' 19 i
position on the Program Plan'until we see the checklists; L
i 20 you know, put a little sign, "No position on Program Plan <
i e 21 until we see'the checklists." We can't do it. It would
,t .
be a foolish -- it would be an unwise move for us to 22 i
23 make. !
21 To the extent that we have been able to comment on 25 the process, we have done so, we will continue to do so; i I i
_ . _ _ _ _ _ _.__.__---,~,- -.~ , e e. , , , . . ._w~.% ,.,e..--., , , - . . . . , . . .. -.w.-, . . . , _ . . , . . - . . - _ , , ,w,. ,.,,,%,. ,__,.,.,,---._,.~,-,y.
166 "
I t but until we see the basis of it, we can't take a final
{
(
d 2
position. I would think that would be helpful to you, 3
that we would be.able to put to bed a lot of the concerns 4
that we have by seeing that that was okay, that looks 5
i like it's going to find everything, and whittle it down 6
to a number that we may never agree on, but at least it's 7.
a more manageable number than 1500 allegations, you know, j 8 a large number of ISAP's.
9 Vince, I think, as I told you over the break, that 10 you're mixing up apples and oranges here on this November t
11 19th and 20th meeting. I want to say for the record that 12 we are not going to be giving you comments at that 13 meeting on this, on the CPRT, on the Program Plan or 14 anything else.
We, CASE, are going to be asking you, the 15 Staff, questions on the basis for the position ynu took i
16 in the SSER.
s' 17 You've got on your schedule a public meeting for the j
18 NRC Staff to receive any intervenor comments resulting
,' 19 from the 19th-20th meeting. There may be some, but I l I
.i 20 t
don't think it's what you meant when you wrote this up. l
! 21 I think what'you mean - and correct me if I'm wrong --
i 22
.is that at some point you are expecting CASE to tell you 2:1 the flaws that we see in the SSER on the individual '
2.t }
allegations and conclusions that'you may. reach. That's !
25 t I
true. -That is something that CASE owes you, and I' don't i i
i 167 -
I know if we can meet that 2nd or 3rd. I think we can try.
( 2 The second thing is to provide feedback to TUGCO on 3
it's responsive Program Plan. That we can't do until we 4
! see the checklists and until we see Revision 3.- You're
, 5 putting us in a position of, you're asking us to sign off
- 6 something that isn't even final. We won't even see, 7
according to your schedule, Revision 3 until three days 8
after the public meeting when you want our comments on 9 the Program Plan. We just can't do that.
t 10 MR. NOONAN:
I will clarify one statcment. It's my
- 11 understanding that when Revision 3 comes out, it will be 12 conservatively done.
, What I mean by that~is the
{ 13 questions, the answers next week, all those questions 14 plus, from our perspective, the Staff audits, everything 15 that we've seen today, is going to be put into that a
16 document. I agree, I don't expect you to see the s' 17 document after a certain date and not give you time to
~
18 comment. My goal is to try to get the Program finished '
19 I from my standpoint, the NRC standpoint.
- i. ! -
a 20 We mentioned in October about implementations 2
21
. i going on right now, and Bill Counsil now is proceeding at 22 l risk -- and that's true -- he is proceeding at risk, and q so are we. 1 We are proceeding at risk right now, too, i i
21 ;
i because we might find things we don't like. Right now we '
3$ : haven't found any. I need to get the Program Plan put to i
I>
t
1'68 I bed.
We need to do that, so I need -- if you tell me
( 2 that the only thing missing out of here so far is the l 3
checklists, then I'll work with the Utility and see what 4
we can do to make those available.
5 MS. GARDE: It seems to me that from~ CASE's 6
perspective, we still have to evaluate the answers to 7
questions that you have raised in your two letters, which 8
encompass almost all the questions that we've asked.
9 See, all of the questions that we've asked are asked 10 again in some form by the NRC, so when you receive those 11 answers, we'll receive those answers. Those were 12 programmatic.
13 As to the rest of the product that you've been 14 looking at in audits, I don't think on this schedule that 15 I'm going to see the things on the inspection report, 16 I'm going to see the results of your audit by December i r7 2nd or 3rd, given the schedule of the delay that you're
[ 18 talking about in terms of how long it's taking you to get l
19 the inspection record on the street. And I want to see l :
i '20 the checklists. I won't have any idea what's going on on - e 21 the specific level, and I won't be in a position to i
22 comment. I don't think I can do that until you and/or 23 the Applicant make arrangements for us to have access to 3.; that kind of information.
23 As I said, we will work with you in any way i
. . _ _ . , . . , . , .. , .v..y___ y ,. -. ,.ry- , _ , , __ _ , , , , - . _ , ~ , , , , . .
r-169 I
possible, that's reasonable, to be able to digest that 2
material in a fairly quick manner.
3 MR. NOONAN: I'll work with John Beck about the 4
checklists and see where we stand on that.
5 The only reason'for putting that date of the 19th 6
and 20th on my schedule is that there are things we need 7
to get done before we issue the Program.. I do understand 8
we're not going to discuss the Program Plan at that 9
meeting. But I really -- I guess I keep repeating 10 myself -- but I really need to get this Program' Plan, 11 final evaluation, accomplished.
12 MS. GARDE: I understand that. I'm not disputing
{ 13 your need to do that, nor am I disputing that it looks e 14 like things are getting pretty close. I'm just saying 15 that we can't take an intelligent position. We would 16 l
like to be able to get to the point where we can say, "We
! 17 looked at all the checklists; we disagree that there's 18 not enough categories or that the homogeneity -- or we -
19 i
think that those categories, that there should be two or i 20 three more, that some of them should be subdivided, or i
i ! 21 that the checklists in several discrece areas are not i
22 detailed.enough." I would like to be able to have.our -
2j disputes to be'at that level. L 3; MR. BECK: You're telling me that agreement with the 25 t
Program Plan by virtue of getting deeply enough into it l
L
- ,, - - ,--- ,-. w-e,---e - - , - - - - , - --w--,----,v,,--,~,,,-,,--,,e.-e.- -,-,,r,w-r,-- --,
-4 i
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170 I and examining all the details that Svolve from the
(
2 Program Plan and checklists - 'ev'01ve from it -- they're 3
sot prt of it -- would put you lit a position where you 4 could agree with what we're going at Comaitche Peak. I'm 5 ready to open the door wide open. -That will end the 6 litigations. '
'" 7 ' MS. GARDE: Nowe you're putting another eleAent in y n 8 there. We're talking about the Program Plan. "
I mean, 9 you want to talk about -- '
/
y y u'~ .
10 MR. BECK: You're talking' about ou'r' evidence. \
s s 11 That's what you're talking about. '
\ .'(
i 12 '- MS. GARDE: Well, if that's the'dispbits, John, then
~3
{ 1 ,
we should get the lawyers involved and we should a'.1 sit :
14 down and talk about this. I am right now participating
. 15, in what I yiew as the Staff process on making sure that Il I6 - ;
there's' reasonable assurance that the plant is going,to \
- 17 eperate safely. I separate that, at least in my mind, i j IS 'from'the hearing process. 'I maybe do that so I can -
' conceptually deal with the two different trackF as I see 19 i (
! 20 them. I'm not disputing that they do interre et and they
- s. %
5 s
.I 21 do relate at a certain point, but right now in ofder'to l r
22 answyr Vincb's question, " CASE, wdat is your pdsition on ^i s
23 the CPRT?" I have-to say that I can't take a position \~
S 34 unt.11[wehaveaccesstothekindofl.fatathatwould t i 25 enable us to take an intelligent positicn. And without j
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171 p I having seen that data, we have to say we reject it. I
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don't think we would if we would see a lot of this 3 material. I think we would get down to say we disagree 4
z on some points and what those points are.
t 5
t MR. NOONAN: I guess I don't have any further -
6 comments.
t Billie, do you have any?
7 MS. GARDE: No. Thank you very much. And, John, 8
thank you for giving me the opportunity of clarifying the
'. 9' questions.
\
10 MR., BECK: It's always a pleasure.
11 12 ' i,
{ 13 14
( (The meeting was completed
., 15
-at 3:00 o' clock p.m.)
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CERTIFICATE OF PROCEEDINGS 2
This is to certify that the attached proceedings 3 '
before the Nuclear Regulatory Commis' ion and Texas 4 Utilities Generating Company 5 In the Matter of: NRC Staff Progress in Review of 6
the Program Plan and Applicant 7
Activities on the Program Plan 8 Date of Proceedings: November 5 and 6, 1985 9 Place of Proceedings: Granbury, Texas 10 were held as herein appears, and that this is the original 11 transcript for the file of Texas Utilities Generating 12 Company.
13 14 Carmen Gooden '
15 Certified Shorthand Reporter i 16 g r. ,/ '
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AAUNGTON. TEXAS F4014
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OCT 3 0 585 Docket Nos.: 50-445 and 50-446 MEMORANDUM FOR: Vincent S. Noonan, Director Comanche Peak Project Division of Licensing FROM:
Annette Viatti-Cook, Project Manager Comanche Peak Project Division of Licensing
SUBJECT:
FORTHCOMING MEETINGS WITH TEXAS UTILITIES DATES AND TIMES: Tuesday, November 5, 1985 1:30 p.m. - 6:00 p.m.
Wednesday, November 6,1985 8:30 a.m. - 5:00 p.m.
LOCATION: Plantation Inn
( 1451 E. Pearl Granbury, Texas 76048 PURPOSE:
November 5, 1.985: To discuss the NRC staff's progress in review of the Program Plan. See agenda.
November 6, 1985: To discuss the Applicant's activities on the Program Plan. See agenda.
This is the beginning of monthly status meetings of activities described in the Applicants' Program Plan.
Two similar status meetings are planned to be held on '
December 2-3, 1985~and January 13-14, 1986 at the same location and times. i t
a l
9 l
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Participants:
( NRC: Apolicant:
V. Noonan W. Counsil A. Vietti-Cook J. Beck, et. al.
C. Early l L. Shao J. Calvo J. Milhoan T. Westerman, RIV /^\
/ i l -
. W %od_ J Annette Vietti-Cook, Project Managei-Comanche Peak Project Division of Licensing
Enclosure:
Agenda
- These meetings will be trar. scribed I
l l . . - - . . . . . - . . - . .. . .. . . . . - . ...
W. G. Counsfl Texas Utilities Generating Company Comanche Units 1 and 2Peak Steam Electric Station cc:
Nicholas S. Reynolds Es Bishop, Libennan, Cook, q. - Resident Inspector / Comanche Peak Purcell & Reynolds Nuclear Power Station 1200 Seventeenth Street, NW c/o U.S. Nuclear Regulatory Comission Washington, D.C. 20036 P. O. Box 38 Glen Rose, Texas 76043 Robert A. Wooldridge, Esq.
' Worsham, Forsythe, Sampels & Regional Administrator, Region IV Wooldridge U.S. Nuclear Regulatory Comission *
- 2001.Br Dallas,yan Tower, Suite 2500 611 Ryan Plaza Drive, Suite 1000 Texas 75201 Arlington, Texas 76011 Mr. Homer C. Schmidt Manager - Nuclear Services Larry A. Sinkin Texas Utilities Generating Company 3022 Porter Street, NW #304 Skyway Tower Washington, D.C. 20008 .
400 North Olive Street, L.B. 81 Dallas, Texas 75201 Mr. Robert E. Ballard, Jr.
Director of Projects Ms. Billie Pirner Garde Gibbs and Hill, Inc. Citizens Clinic Director
( ' 11 Pen Plaza New York,-Ne,< York 10001 Government Accountability Project 1901 Que Street, NW Washington, D.C. 20009 Mr. A. T. Parker David R. Pigott, Esq.
Westinghouse Electric Corporation Orrick, Herrington & Sutcliffe P. O. Box 355 600 Montgomery Street -
Pittsburgh, Pennsylvania 15230 San Francisco, California g4111 1 Renea Hicks, Esq. Anthony Z. Roisman, Esq. '
! Assistant Attorney General Trial Lawyers for Public _ Justice '
Environmental Protection Civision 2000 P. Street, NW P. O. Box'12548 Capitol Station Suite 611 Austin, Texas 78711 Washington, D.C. 20036 '
4 i
Mrs. Juanita Ellis, President Nancy E. Wiegers Citizens Association for Sound Energy Spiegel & McDiarmed :
1426 South Folk 1350 New York Avenue, NW -
Dallas, Texas 75224 Washington. 0.C. 20005-4798 Ms. Nancy H. Williams i CYGNA 101 California Street I
San Francisco, Califon.f a 94111
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Texas Utilities Electric Company ({. Comanche Peak Electric Station Units 1 and 2 cc:
Resident Inspector - Comanche Peak c/o U.S. Nuclear Regulatory Commission P. O. Box 1029 Granbury, Texas 76048 Mr. John.W. Beck .
Manager - Licensing Texas Utilities Electric Company Skyway Tower 400 N. Olive Street, LBf81 '
Dallas, Texas 75201 Mr. Jack Redding Licensing Texas Utilities Generating Company
- 4901 Fairmont Avenue Bethesda, Maryland 20814 William A. Burchette. Esq. *
' Heron, Burchette, Ruckert & Rothwell Suite 700 i :
( 1025 Thomas Je~fferson Street, NW Washington, D.C. 20007 Mr. James McGaughy Southern Engineering Company of Georgia 1800 Peachtree Street, NW -
Atlanta, Georgia 30367-8301
' Administrative Judge Peter B. Bloch i U.S. Nuclear Regulatory Commission ,
Washington, DC 20555 !
, Herbert Crossman Alternate Chairman ASLB Panel .
U.S. Nuclear Regulatory Commission Washington, DC 20555 '
i Dr. Kenneth A. McCollom, Dean Division of Engineering, Architecture and Technology -
Oklahoma State University Stillwater, Oklahoma. 74074 -
Dr. Walter H. Jordan l i
881 W. Outer Drive !
Oak Ridge Tennessee 37830 e
I.
- - - - - - ~~
Agenda
(- November 5, 1985 Presenter
- 1. Status of Construction Adequacy J. Calvo #
review i
- 2. . Status of Construction Adequacy inspection activities T. Westerman
i i
- 3. Status of Design Adequacy review J. Milhoan /
- 4. Status of review ~of Stone and Webster activities- L. Shao
! 5. Status of review of 'basco E
activities L.-Shao November 6, 1985 O N.,
1.
Status of the Technical Review J. Beck
\
Team (TRT) issues \
\
- 2. Status of Quality of Construction p
Inspaction Program J. Hansel \,
i
- 3. i-Status of Design Adequacy Program I'
H. Levin
- 4. Status of pipe and pipe support activities by Stone and Webster E. Siskin -
i'
- 5. Status of activities by Ebasco on cable tray and conduit support. R. Iotti
, in Unit I and Unit 2, and testing /
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{- TUGC0 Meeting with NRC CPRT Monthly Status November 5 and 6. 1985 Plantation Inn /Granbury, Texas November 5, 1985 - 1:30 P.M.
I. -
NRC Remarks 3
II. Public Comments III. CPRT Status A. Introduction New CPRT Members B. Electrical ISAPs.
C. Testing ISAPs.
D. Civil, Structural, Mechanical, Miscellaneous ISAPs Novecber 6, 1985 - 8: 30 - A.M.
III. CPRT Status (Continued) \
I E.
, Design Adequacy Program \
j -
Phase 3 Scope DAP Implementation
- ^ -
Piping / Pipe Supports '
Cable Tray / Conduit Supports ]
F. Quality of Construction ISAP Status j -
ISAP VII.c Status ,
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IV. /
Closing Remarks
'l I
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I CPRT-104 l
. - - - - - . - - . - - - ~~~e ~ . ~ . - - - ~ ~ -
~~-- ~ ~ , - - ,- --~ +~ -
NRC PROPOSED
(. CPHI FHUbHAM PLAN HbVlhW SLHEDULt DATE ACTIVITY
' NOV. 5 TUGC0 PROVIDES ANSWERS TO MOST PROGRAM PLAN QUESTIONS AT PUBLIC MEETING TN GRANBURY, (ANSWERS WILL BE BOUND INTO TRANSCRIPT AT NOV, 5 MEETING, BUT NO DISCUSSION OF THEM AT MEETING),
NOV. 12 THE REMAINING ANSWERS TO PROGRAM PLAN QUESTIONS, NOV. 19, 20 TRT GROUP LEADERS MEET WITH CASE /ROISMAN IN BETHESD (THIS PROVIDES CASE WITH 2 WEEKS FOR ANY COMMENTS ON TUGC0 RESPONSES OR TRT ACTIONS ON ALLEGATIONS)
DEC 2, 3 PUBLIC MEETING, GRANBURY. NRC STAFF TO RECEIVE ANY INTERVENOR COMMENTS RESULTING FROM NOV. -19, 20 MEETING, AND PROVIDE FEEDBACK TO TUGC0 ON ITS
, RESPONSES TO PROGRAM PLAN QUESTIONS, DEC. 6 TUGC0 SUBMITS REV. 3 TO PROGRAM PLAN (CONFORMING PRIOR RESPONSES OR AS MODIFIED AT DEC, 2/3 MEETING).
DEC. 27-NRC STAFF ISSUES SER ON PROGRAM PLAN.
AGENDA OVERVIEW OF STAFF REVIEW OF CPRT PROGRAM - J. CALVO STATUS OF THE CONSTRUCTION ADEQUACY REVIEW - J. CALVO STATUS OF CONSTRUCTION INSPECTION ACTIV! TIES - T. WESTERMAN STATUS OF THE DESIGN ADEQUACY REVIEW - J. MILHOAN -
STATUS OF REVIEW OF STONE AND WEBSTER ACTIVITIES - L. SHA0 s
STATUS OF REVIEW OF EEASCO ACTIVITIES - L. SHA0 i
I
- j. .
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_ , , , _ . _ _ . , _ _ , _ . . . _ , . . - - , . - - - - - - ~
~
OVERVIEW OF STAFF REVIEW 0F CPRT PROGRAM
. STAFF SUPNARY EVALUATION i
- 11 MAJOR CONCERNS IDENTIFIED 1
. STAFF DETAILED EVALUATION COMMENTS
- ev 151 DESIGN
- ~ 117 CONSTRUCTIOPi
- N 5 TESTING
. CASE AND GAP COMMENTS
- N 83 PROGRAPNATIC
- 1 VOLUMINOUS COMMENT ON WELDING .
. ASLB COPRENTS
- N 11 FROGRAPNATIC
. CYGNA COMMENTS l : N 184 SIGNIFICANT CONCERNS-HOMOGENEOUS. CONSTRUCTION ACTIVITIES
- HOMOGENEOUS DESIGN ACTIVITIES
- AUDITABLE TRAIL '
. PENDING INITIAL REVIEWS
- UMBRELLA QA/QC S
l -
CONSTRUCTION ADEQUACY REVIEW PROGRAM
. RESOURCES
- 6 NRC STAFF
- 13 CONSULTANTS
-LAWRENCE LIVERMORE NATIONAL LABORATORY
-EG&G IDAHO, INC.
-BATTELLE COLUMBUS LABORATORIES
-TELEDYNE ENGINEERING SERVICES
-ENGINEEP.ING ANALYSIS SERVICES INC.
-WESTEC SERVICES, INC.
-ZYTOR, INC.
-PRIVATE
(
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STAFF PERCEPTION CONSTRUCTION ADEOUACY REVIEW PROGRAM
. EXTERNAL SOURCES ISSUES
. SELF-INITIATED REVIEW
- GENERIC ASSESSMENT
- HARDWARE POPULATIONS HOMOGENEOUS CONSTRUCTION ACTIVITIES (WORK PROCESSES)
( :
EVALUATIONS SUPPORTING THE HOMOGENEITY OF CONSTRUCTION ACTIVITIES (AUDI2LE TRAIL) -
- SELECTION OF EQUIPMENT ITEMS FOR INSPECTION OTHER CONSTRUCTION AND OPERATIONAL ACTIVITIES
4 .,
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- S N I IR N L P O T CI EEL ETE C C A UV NEE GFV RI ENV S LX U
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CPSES CONSTRUCTION INSPECTIONS AND OPERATIONAL ACTIVITIES
- 1. SITE INSPECTION TEAM (SIT)
- 2. CONSTRUCTION ASSESSMENT TEAM (CAT)
- 3. SPECIAL~REVIEWTEAM(SRT) 4s RESIDENT INSPECTOR
- 5. REGION IV
- 6. NDE MOBILE VAN (ANALYSES)
- 7. TECHNICAL REVIEW TEAM (TRT)
- 8. FSAR REVIEW RELATED SITE VISITS
- 9. CYGNA PHASE 1, 2, 3 AND 4 WALXDOWNS
- 10. CPRT CES!GN ADEQUACY REVIEW WALKDOWNS
- 11. CPRT ISAPS (VARIOUS SELECTED RANDCM AND BIAS SAMPLES) i 12. CABLE TRAY AND CONDUIT SUPPORTS - 100% REINSPECTION
- 13. LARGE BORE PIPES / SUPPORTS - 100% REINSPECTION
- 14. SMALL BORE PIPES / SUPPORTS
- 15. CPRT SELF-INITIATED CONSTRUCTION A0EQUAGY REVIEW
- 16. PREOPERATIONAL TESTING
- 17. NORMAL OPERATION l
l 18. TECHNICAL SPECIFICATION SURVEILLANCE AND TESTING l ~
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CONSTRUCTION ADEOUACY REVIEW PROGRAM STAFF REVIEW STATUS
. AUDITS
- OCTOBER 9 AND 10, 1985
- OCTOBER 16 AND 17, 1985
- OCTOBER 28 - 31' , 1985 SCOPE OF AUDITS: EVALUATION OF HOMOGENEITY CONSTRUCTION ACTIVITIES
- ELECTRICAL -
E. TCHLINSON
- HECHANICAL -
- 8. SAFFELL
! : CIVIL / STRUCTURAL - M.' RIVARD i
SUMMARY
/ PRELIMINARY FINDINGS HARDWARE POPULATIONS CATEGORIES EVALUATION ALMOST COMPLETE EVALUATION OF H0110GENEITY OF CONSTRUCTION ACTIVITIES NOT YET COMPLETED
( -
INCREASE IN CONSTRUCTION ACTIVITIES ESTABLISHING BETTER AUDITABLE TRAIL FUTURE ACTIVITIES l :
POSSIBLE ONE MORE AUDIT AFTER AUDITABLE TRAIL IS ESTABLISHED FOR I
ALL H0t40GENEOUS CONSTRUCTION ACTIVITIES
- PREPARATION OF AUDIT REPORT REVIEW OF RESPONSES TO STAFF QUESTIONS
. PREPARATION OF SER ON THE CPRT CUNSTRUCTION ADEQUACY PROGRAM PLAN 4
l .
,,%-. , ,g.,.. . , , , , . . ,, ._ , , , , ~ _ . ,
~
ELECTRICAL AND INSTRUMENTATION
( ALLEGATIONS
. CATEGORY 1, ELECTRICAL' CABLE TERMINATIONS
- 2 NEW ALLEGATIONS
- WIRE UNDERSIZE - UNDER EVALUATION
- BUTT SPLICES - NO FURTHER ACTION REQUIRED CATEGORY 5, ELECTRICAL NONCONFORMANCE REPORT ACTIVITIES
- 1 NEW ALLEGATION
- CLASS 1E METERS - UNDER EVALUATION
- 3 PREVIOUS ALLEGATIONS NEW INFORMATION
- CABLE PENETRATION SEAL - NO ACTION REQUIRED l
- TRACEABILITY OF "Q" ITEMS - NO ACTION REQUIRED
- REWORK ON TERMINAL BLOCK - UNDER EVALUATION
, (
. CATEGORY 7, ELECTRICAL CABLE INSTALLATION
- 1 PREVIOUS ALLEGATION NEW INFORMATION
- IMPROPER TRAINING OF CABLES. .NO ACTION REQUIRED CATEGORY 9, ELECTRICAL INSPECTION REPORTS, INSPECTION REMOVAL NOTICES j AND IN-PROCESS INSPECTIONS
- 1 NEW ALLEGATION
- ELECTRICAL INSPECTION REPORTS WERE INCOMPLETE AND IMPROFERLY FILED IN THE VAULT - NO ACTION REQUIRED l
i
_$ ,_. . , ~ . - , . . , , . . , , , , , . - . . , . _ _ , , , y ,,. y _- , , .,-.
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STAFF AUDIT REVIEW 0F CONSTRUCTION ADEQUACY PLAN DOCUMENTATION l
j POPULATION B0llNDARY il o INCLUDES ALL SAFETY RELATED SYSTEMS AND COMP 0NENTS (UNIT 1, UNIT 2, AND COMMON) FOR WilICll INSTALLATION IS COMPLETE SOURCES FOR POPULATION SAMPLING LIST TUGC0 AND CONTRACTOR MANAGEMENT SYSTEM FOR:
o SPECIFICATIONS i o DRAWINGS o EQUIPMENT SCllEDULES
~
i 7 A q
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- i ,
WORK ACTIVITY (PROCESS) Il0M0GENEITY H
U CONTRACTOR o ERECTION SPECIFICATIONS i o INSTALLATION PROCEDURES U- o INDUSTRY CODES AND STANDARDS o VEND 0R INSTRUCTIONS TUGC0 o QUALIFICATION OF INSPECTION AND TEST PERSONNEL 5
li .
ATTRIBUTE APPLICABILITY ii '
- j o DESCRIPTIOy 0F ATTRIBUTES
- j. o ACCESSIBILITY OF ATTRIBUTES o VERIFICATION OF Tile FREQUENCY OF ATTRIBUTES o JUSTIFICATION FOR ATTRIBUTE EXCLUSION i
i j
1 i
i
- l
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- 1 I
I it li QUALITY INSTRUCTIONS
- < o RElliSPECTION CHECKLIST i
j o DOCUMENTATION REVIEW CHECKLIST O o ACCEPT / REJECT. CRITERIA i-REINSPECTION / DOCUMENT REVIEW PACKAGE j o QUALITY INSTRUCTIONS
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COMANCHE PEAK RESPONSE TEAM DESIGN ADEQUACY PROGRAM THREE FUNCTIONAL ELEMENTS EXTERNAL SOURCE ISSUES EVALUATION AND RESOLUTION SELF-INITIATED EVALUATION ROOT CAUSE AND GENERIC IMPLICATIONS EVALUATIONS THIRD PARTY REVIEW BY DESIGN ADEQUACY REVIEW TEAM PROJECT RESPONSIBLE FOR EXECUTION OF DESIGN BASES ANALYSES AND DESIGNS
-COLLECTION OF HISTORICAL INFORMATION FOR USE BY DESIGN ADEQUACY REVIE' TEAM IMPLEMENTATION OF CORRECTIVE ACTION DESIGN ADEQUACY REVIEW TEAM STRUCTURE
, CIVIL / STRUCTURAL PIPING / SUPPORTS MECHANICAL SYSTEMS / COMPONENTS
, ELECTRICAL /I&C l
l PROGRAMMATIC / GENERIC IMPLICATIONS ,
IE RESPONSIBLE FOR EVALUATION OF IMPLEMENTATION OF DESIGN ADEQ'JACY PROGRAM IE INTERFACES WITH DIRECTOR OF NRC COMANCHE PEAK TASK FORCE I
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IE RESPONSIBLE FOR EVALUATION OF IMPLEMENTATION OF DAP REVIEW DISCIPLINE SPECIFIC ACTION PLANS (05AP)
. CONOUCT INSPECTION COVERING DAP REVIEWER (TERA PERSONNEL) QUALIFICATIONS, SCOPE SELECTION PROCESS, AND INSPECTION CHECKLISTS CONDUCT INSPECTION OF TERA (DSAP) IMPLEMENTATION. ASSESS DEPTH OF REVIEWS, E.G. BY REVIEWING THE SAME CALCULATIONS REVIEWED BY TERA REVIEW DAP REPORTS TO ASSESS RESOLUTION OF IDENTIFIED DISCREPANCIES VERIFY' IMPLEMENTATION OF CORRECTIVE ACTIONS PREPARE SSER INPUT
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. STAFF RESOURCES TEAM OF FOUR NRC PERSONNEL AND EIGHT CONSULTANTS IN THE FOUR DAP OISCIPLINES 2-3 SENIOR ENGINEERS IN EACH DISCIPLINE DISCIPLINE LEADERS ALL HAVE COMMERCIAL NUCLEAR DESIGN EXPERIENCE AT AN AE NINE TEAM MEMBERS HAVE BEEN ON IDI TEAM OR IDVP EVALUATION TEAM TEAM WILL BE AUGMENTED AS NECESSARY 6 ( -
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NRC STAFF ORGANIZATION STRUCTURE FOR EVALUATION OF DAP i
DIRECTOR IE MANAGEMENT COMANCHE PEAK J. TAYLOR, DIRECTOR, IE TASK FORCE R. .VOLU1ER, DEPUTY DIRECTOR, IE
- : D. GRIMES,DTRECTOR, DQAVT
- V. NOONAN T. ANKRUM;'CITIEF, QAB J. MILtiOAN.3 CHIEF, LICENSING SECTION, ',qAB t
NRR COMANCHE- TEAM LEADER PEAK TASK FORCE D. NORKIN, IE L. SHA0 - - . .
J. CALVO E. MARINOS C
CIVIL / STRUCTURAL PIPING / SUPPORTS MECHANICAL ELECTRICAL /I&C
- R. SHEWMAKER, IE* D. TERA 0, NRR* SYSTEMS / COMPONENTS G. MORRIS, WESTEC*
K. BUCHERT, WESTEC P. CHEN, ETEC S. KLIEN, WESTEC* L. STANLEY, ZYTOR J. BLACXMAN, J. NEVSHEMAL, WESTEC J. KN0X, NRR WESTEC** S.V. ATHAVALE IE DIRECT REPORTING'
- - - INTERFACES DISCIPLINE LEAD"R J. BLACXMAN WILL ALSO BE ASSISTING PIPING / SUPPORTS AND MECHANICAL SYSTEMS / COMPONENTS DISCIPLINE TEAMS
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i RESULTS OF TEAM INSPECTION WILL BE PROVIDED-IN INSPECTION REPORT
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! o LINERS o LARGE BORE PIPE SUPPORTS (NON-RIGID) o FUEL P0OL LIN R o SMALL BORE PIPE SUPPORTS
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1 o REVIEWED WORK PROCESS BREAKDOWN FOR EACil POPULATION o REVIEWED SAMPLE INSPECTION PACKAGES AND INSTALLATION PROCEDURES TO ASSESS WORK PROCESS HOMOGENEITY o REVIEWED ATTRIBUTES FOR APPLICABILITY TO WORK PROCESS
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- i REGION IV CPSES INSPECTION PROGRAM INSPECTIONS BEING PERFORMED INCLUDE:
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' IE MC-2513 PREOPERATIONAL TESTING IE MC-2514 STARTUP TESTING IE BULLETINS, CIRCULARS, INFORMATION NOTICES NRR GENERIC LETTERS OPEN PREVIOUS INSPECTION ISSUES IMPLEMENTATION OF THE CPRT PROGRAM ACTION PLAN
- ALLEGATIONS l CDMANCHE PEAK REGION IV MANPOWER ASSIGNED l
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0FFICE Of INSPECTION ---__m.e .e - O DIRECTOR DIVISION OF - - - - - - -
i & ENFORCEMENT DIRECTOR. COMANCilE PEAK REACIOR SAFETY & PROJECTS PROJECT CillEF, COMANCilE PEAK REGION IV GROUP l:
ALLEGATIONS /SAFETEAM ' PROJEC1 STATUS L
GROUP LEADER I
i I I I r I OPERATIONS CONSTRUCTION QA/QC ISSUES CIVIL /HECllANICAL ELECTRICAL SENIOR RESIDENT SENIOR RESIDENT TEAM LEADER TEAM LEADER TEAM LEADER INSPECTOR INSPECTOR eeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeemeeeeeeeeeeeeeemeeeeeeeeeeeeeeee CONTRACTOR PERSONNEL ASSIGNED AS REQUIRED 1 .
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t INSPECTION OF CPRT PROGRAM IMPLEMENTATION OA/0C PROGRAM REVIEW & AUDIT CPRT PROGRAM i
ISAP's INSPECT IMPLEMENTATION OF ISAP WITNESS INSPECTIONS OF HARDWARE f VERIFY RESOLUTIONS & CORRECTIVE ACTIONS REGARDING DEVIATIONS I
VERIFY RESULTS REPORTS .
t ISAP VII.C OA/0C AND CONSTRUCTION ADE0VACY WITNESS OF HARDWARE INSPECTIONS INDEPENDENTLY INSPECT HARDWARE 1
INSPECT DOCUMENTATION REVIEWS
( VERIFY RESOLUTION & CORRECTIVE ACTIONS REGARDING DEVIATIONS i
VERIFY RESULTS REPORTS I
SITE MCDIFICATIONS --
1 INSPECT MODIFICATIONS TO
, CABLE TRAY SUPPORTS 4 -
CONDUIT SUPPORTS 4 -
PIPE SUPPORTS '
i OSAP's ASSIST IN ONSITE ENGINEERING WALK 00WNS AS REQUESTED 4 -
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INSPECTION REPORTS
_ J90NTHLY REPORTS ARE TO BE ISSUED WHICH COMSINE ALL INSPECTION EFFORTS BY THE REGION IV GROUP INSPECTIONS NOT PERFORMED UNDER THE DIRECTION OF THE CPSES REGION IV GROUP WILL BE ISSUED SEPARATELY ENFORCEMENT ACTIONS WILL BE TAKEN ON AN INSPECTION-BY-INSPECTION BASIS THE INSPECTION REPORT FOR AUGUST HAS BEEN ISSUED
~ FINDINGS INCLUDE THE FOLLOWING:
1 VIOLATION 4
2 DEVIATIONS 2 UNRESOLVED ITEMS 36 OPEN ITEMS THE INSPECTION REPORT FOR SEPTEMBER IS BEING TYPED AND THE OCTOBER INSPECTION IS IN PREPARATION O
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G-( !!RC STAFF PIPil!G AIG PIPE SUPPORT REVIEW EFFORT PROBLEi STATBiENT:
o 1%NY C0!!CERNS IDEllTIFIED li: TliE DESIGli AIS ANALYSIS OF PIPING AIG PIPE SUPPORTS
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REARALYSIS AfD REQUALIFICATION EFFORT o ST0iG & WEBSTER EiXilNEERIllG CORPORATION C0liTPACTED FOR PIPING AfD PIPE SUPPORT REA;MLYSIS AND REQUALIFICAT10ll
( o TERA RESPONSIBLE FOR TillRD PARTY OVERVIEW -
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' PERSONf'EL o NRC STAFF MEfBERS o CONSULTANTS
- TELEDYllE ENGINEERING SERVICES ETEC EAS
- ( OBJECTIVES o TO ENSURE THE ADEQUACY OF THE SCOPE AIO IMPLEY.9!TATION OF THE PIPlHG AIS PIPE SUPPORT
] RE00AllFICATION EFFORT l .
PLAf' i
o TO PERFORM REGUI.AR AUDITS OF THE SWEC EFFORT SCOPE PROCEDURE AtG PITHODOLOGY REVIEWS WALKDOWN REVIBIS DESIGN REVIEWS
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STAFF REVIENS COMPLETED o REVIEW AND CO.T.ENT ON CPRT PROGRAM PLAN o REVIEW OF CPPP 5 (DRAFT) " FIELD WALK PROCEDURE" o AUDIT OF SWEC AS-BUILT VERIFICATION WALKDOWi!
PER CPPP-5 (NEEP. OF SEPTEl'3ED 23,1985) o AUDIT OF PROCEDURE CPPP-8 (DRAFT) FOR
. ENGINEERING WALKDOWN
( o AUDIT OF PIPING AND PIPE SUPPORT STATUS AT SWEC (NY) AID AT COMANCHE PEAK SITES 1
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( _ STAFF EFFORT AUDIT OF SrtC AS-BUILT VERIFICATION WALKD0'.M o THE HRC STAFF AIC ITS C0!!SULTANTS PERFORP.ED AN AUDIT
'0F SWEC AS-BUILT VERIFICATION WALKDOWN o THE STAFF SELECTED A SA..PLE OF APPROX 1PATELY 10% OF THE SWEC AS-BUILT WALKDOWR PACKAGES FOR EACH OF THE FOUR ATTRIBUTES .
. A. VALVE LOCATION C
B. PIPE SUPPORT LOCATI0li .
C. PIPE SUPPORT FUNCTION D. VALVE AIG SUPPDF.i ORIENTATION t
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STAFF EFFORT (C0!! Tit!UED) o THE STApF FOUND NO SIGNIFICANT DEVIATIONS WITH RESPECT TO VALVE LOCATION,' SUPPORT TYPE AIO SUPPORT LOCAT10ffl o FOR SUPPORT AND VALVE ORIENTATION, THE STAFF WALKD0i!N C0t!FIRME SIEC'S FINDING THAT SEVERAL SUPPORT AND VALVE
, ORIENTATIONS EXCEEDED THEIR TOLERANCE. .
o THE STAFF FOUND CORRECTIVE ACTION INIT!ATED BY TUGC0 ADDRESSING THE CONCERN IDENTIFIED BY SWEC WALKDOWN I ADEQUATE
( o THE STAFF COMENTED THAT WITH RESPECT TO OTHER ATTRIBUTES (ilil~,'PIPERUNGE0liETRY, CLEARANCE','ETC)
THE S'.EC WALKDONN t;UST BE SUPPLEMEllTED BY A TUGCO',' OR CPRT AS-BUILT WALKD095 T0 t!AKE SURE ATTRIBUTES EULLETIN79-14AREADDRESSED'l e
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STAFF EFFORT REVIElf DRAFT OF Sk'EC ENGil!EERING WALKD0k'N PROCEDURE CPPP-8 o THE STAFF HAD AN AUDIT OF DRAFT OF CPPP-8, SCHEDULER TO BE FORMALLY ISSUED EARLY F.0VEEER'.'
o CPPP-8 ENG1EEERING WA!.KDOWN IS TO IDENTIFY POTENTIAL INTEFACTI0liS BETEEN PIPING AND PIPING SUPPORTS, o CPPP-8 WALKD0h5 SCHEDULEL TO BEGil: ON E0VEi3ER 14,1985 4 ( o THE STAFF FOUND CPPP-8 EN31NEERING WALKDOWN PROCEDURE PROVIDES AN ADEQUATE PITHODOLOGY FOR IDENTIFYING 1 'TER-ACTIONS BET'EEN PIPE AMD PIPE SUPPORTS IIHICH COULD P0 TERT! ALLY ItPACT THE DESI6C AND ANALYSIS o AS A PART OF THE AUDIT illE STAFF PLANS TO PARTICIPATE IN APORTIONOFTHESWECVALKDOWNSTARTlHGONNOVEMBERIf6 1985 o THE STAFF PLAf!S TO EVIEL' THE FINAL SUEC REPORT COVERii!G THE ENTIPI RESULTS OF THE CPPP-8 K'ALKD0'B' AND VEP.lFY At!Y ADDITIONAL OBSERVATIONS AS DEEMED flECESSARi.'
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PIPING AND PIPE SUPPORT An'ALYSIS AUDIT o THE STAFF HAS FOUND THAT SWEC HAS COMPLETED A SUBSTAf'TIAL 4
Ali3UNT OF WORK IN LAYING THE FOUNDATION F0P. THE REA!'ALYSIS AND REQUAllFICATION EFFORT
- o THE CONCERNS OF THE INTEP.VE?!0RS, ASLB,' CYGNA AND THE NRC
! STAFF ARE BEING SERIOUSLY EVALUATED BY SilEC IN THEIR TECHNICAL
( PROCEDURES .
o BASED ON THE STAFF REVIEW SO FAR', THE SWEC PIPING add PIPE ;
l SUPPORT EFFORT APPEARS TO BE A MAJOR STEP IN THE RIGHT .
" DIRECTION TO RESOLVE THE TECHNICAL CONCERNS RELATED TO PIPE A!G PIPE SUPPOP.TS, -
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o THE STAFF WILL CONTlHUE TO CLOSELY F10NITOR THE SWEC EFFORT TO ENSURE ADEQUATE !!1PLEMENTAT10N OF THE PROGRAM. ;
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C NEAR TERM STAFF REVIEWS o REVIEW 0F PIPING AND PIPE SUPPORT DESIGN PROCEDURES CPPP - 6 " PIPE STRESS ANALYSIS FOR AS-BUILT ASME C1. ASS 2 AND 3 pipit!G SYSTEMS" (10/30/85)
CPPP - 7 " DESIGN CRITERIA FOR PIPE STRESS AND PIPE SUPPORTS' (NOVEM3ER 1985)
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CPPP - 9 "SMALL BORE PIPING" (NOVEI'3ER 1985) ,
o PARTICIPATE IN CPPP-8 WALKDOWN o AUDIT PIPIT!G STRESS ANALYSIS WORK (li!PUT DATA MODELING, A% LYSIS PISULTS) -
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ERC STAFF CABLE TRAY AND C0!!DUIT SUPPORT REVIEW EFFORT i
PROBLEM STATEMENT:
o PANY CONCERNS IPENTIFIED IN THE DESIGN Af!D ANALYSIS OF CABLE TRAY AND CONDUlT SUPPORTS REAMALYSIS.AND REQUALIFICATION EFFORT -
o EBASCO CONTRACTED FOR CABLE TRAY AND CONDUIT SI!PPORT
( REANALYSIS AND PIQUALIFICATION o TERA RESPONSIBLE FOR THIRD PARTY OVERVIEW 6
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NRC CABLE TRAY A?.D CONDUIT- SUPPORT P.EVIEW TEAM PERSONNEL o NRC STAFF MEFEERS o 00tlSULTANTS I
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BATTELLE 03JECTIVES o TO ENSURE THE ADEOUACY OF THE SCOPE AND IMPLEMENTATION OF THE CABLE TRAY AND CONDUIT SUPPORT PIQUAllFICAT10?! EFFORT .
PLAN o TO PERF0PJ' REGULAR AUDITS OF THE TUGC0 EFFORT l SCOPE i
PROCEEURE AND METHODOLOGY REVIEWS WALKDOW!: REVIEWS TESTit:GS DESIGN REVIEWS
' HARDWARE MODIFICAT10?!S L
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( STAFF REVIEVS C0FPLETED o REVIEWED AND C0t7.ENTED 0.k'. CABLE TRAY APID COIDUlT SUPPOP.T PROGPhti AS DESCRIBED I!! CPP.T PP0 GRAM PLAN o HELD TWO SITE INSPECTION At:D AUDIT DISCUSSIONS WITH CPRT PROJECT STAFF AND CONSULTANTS
,o OBSERVED ON-SITE CONDUIT SUPPORT TESTS o HELD AUDIT DISCUSSION WITH TUGC0 AND EBASCO LESIGN VERIFICATION STAFF IN EBASCO DESIGN OFFICE o REVIEW OF C0tIDUli AND CABLE TRAY TEST SPECIFICATIONS UNDERWAY '
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.- OBSERVATION OF ON-SITE C0flDUIT SUPPORT TESTS o TWO ON-SITE TESTS k'ERE OBSERVED <
o TEST NO. 1: SINGLE COEDUIT WITH A SINGLE STRAP TEST NO, 2: -JUNCTION BOX -
, o IN SOTH TESTS THE FAILURE LOADS EXCEEDED THE P.INitiUM I SPECIFIED DESIGN LOADS l t
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STAFF EFFORT ON-SITE INSPECTION AND AUDIT DISCUSSION o PARTICIPATED IN TWO PLANT It'SPECTION TRIPS TO OBSERVE l CABLE TRAY AND C0tTUIT SUPPORTS l
o PERFORPID TWO AUDIT DISCUSSIONS WITH TUGC0 PROJECT STAFF i
ANDITSCONSULTANTS0l1CABLETRAYAfTCONdUITSUPPORTS REQUALIFICATION !1ETHODOLOGY',' ACCEPTANCE CRITERIA, BASIS FOR SAMPLING AND TESTS o PROVIDED STAFF COMtENTS ABOUT THE ADE00ACY OF SCOPE.'
ANALYSIS DETAILS AfD SAMPLING BASIS
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o DISCUSSED WITH TUCC0 STAFF CABLE TRAY SYSTB1 DYNAMIC ANALYSIS fiETHODOLOGY (DAMPING, MODELING, LOAD C0F31 NATION ETC.).
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( STAFF EFFORT REVIEW OF CABLE TPAY RELATED SPECIFICATIOMS o ARE REVIE41fG THE FOLLONI?:G SPECIFICATI0.5:S CABLE TPAY HA!!GER DESIGN ADE00ACY VERIFICATION UNIT # 1 (CP-El-4.0-75)
CABLE TPAY HANGER "AS-BUILT" INSPECT 10!!/
VERIFICATION (QI-QP-11','10-9 REV.1)
U'{lT NO. 2 CABLE TPAY HANGER ENGINEERIMG
( WALKDOWN (CP-El-45-23)
CABLE TRAY HANGER AS-BUILT " BOLT HOLE VERIFICATION" UNIT NO. 2 (CP-El-4.0-71)
CABLE TPAY HA!!GER "AS-BUILT" DRAWil!G DEVELOPf'.ENT UNIT NO. 2 (CP-El-4.0-58)
SPECIFICATION FOR DYNAMIC TEST OF CABLE TRo.Y llANGER SYSTEM FOR CPSES UillT 1
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REVIEW OF CONDUIT SOPPdRT RELATED SPECIFICATIONS o ARE REVIEWING THE FOLLOWING CONDUIT SUPPORT REi.ATED i SPECIFICATIONS:
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" COMANCHE PEAK STEAM ELECTRIC STATION SEISMIC QUALIFICATION TEST PROCEDURE OF CONDUIT SUPPORT SYSTEMl"(P.O.'No.CPF-11167-SSUPP.27)
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TEST PROCEDURES AND TEST FIXTURE DESIGN FOR AN l ELECTRICAL CONDUIT CLAMP TEST PROGRAM 4 1 i
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~o REVIEW AS-BUILTIt!G PROCEDURES o SAliPLE OF AS-BUILT DPAUINGS WILL BE SELECTED AND VERIFIED BY COP. PARING AGAIMST THE SUPPORT C0!!FIGUPAT10N IM THE FIA D (0N-SITE AUDIT PLA!!!!En I!! DECE".3ER 1985) o REVIEW DESIG!! VEP.lFICAT10% PROCEDURES
( o SAliPLE OF At!ALYSIS PACKAGES WILL BE P.EVIEHED A!9 CHECKED AGAINST THE PROCEDURES USED 4
o SAMPLE OF P.0DIFICATIONS WILL BE REVIEWED AND A FIELD MALKDOU:1 PERFORMED TO VERIFY IMPLEME!!TATIO!!
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.. AND CHECKED ~AGAINST THE PROCEDURES 'USED
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o SAMPLE OF MODIFICATIONS WILL 3E REVIEWED AND -
FIELD VERIFIED.
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o I QC INSPECTOR QUALIFICATIONS ISAP I.D.1 -
ISSUES: LACK OF SUPPORTIVE DOCUMENTATION REGARDING PERSONNEL QUALIFICATION IN THE TRAINING AND CERTIFICATION FILES FOR ALL ELECTRICAL INSPECTORS AND ALL OTHER CURRENT INSPECTORS.
APPROACH: EVALUATION ACTION PLANNED PHASE I - REVIEW DOCUMENTATION OF INSPECTORS QUALIFICATIONS AGAINST REQUIREMENTS AND ANSI STANDARDS IN PLACE AT TIME OF CERTIFICATION.
PHASE II - EVALUATE QUALIFICATIONS THAT COULD NOT BE VERIFIED IN PHASE I.
PHASE III - -EVALUATE A SAMPLE OF WORK OF THOSE INSPECTORS NOT RECONCILED IN PHASE II TO DETERMINE:
IF INSPECTOR WAS ABLE TO CONDUCT INSPECTIONS DESPITE WEAKNESSES IN QUALIFICATION DOCUMENTATION.
IF INSPECTIONS RESULTED IN SAFETY
(-
SIGNIFICANT DEFICIENCIES REMAINING IN THE HARDWARE AFTER INSPECTION.
STATUS: 0CTOBER 15, 1985 PHASE I - COMPLETE PHASE II - RECONCILIATION OF ALL EVALUATIONS IN PROCESS
,. PHASE III - REINSPECTIONS ARE BEING COMPLETED AS THEY APE IDENTIFIED IN PHASE II PRELIMINARY FINDINGS:-
IN SOME CASES INSPECTOR QUALIFICATIONS WERE NOT IN ACCORDANCE WITH PROCEDURAL REQUIREMENTS AT TIME OF CERTIFICATION. -
l
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0478/ SLIDES
-__ y--- , .
GUIDELINES FOR ADMINISTRATION OF OC INSPECTOR TEST ISAP I.D.2 -
ISSUE:
LACK OF GUIDELINES ~AND PROCEDURAL REQUIREMENTS FO '
THE TESTING AND CERTIFYING OF ELECTRICAL INSPECTORS, APPROACH: EVALUATION ACTION PLANNED
' PHASE I - REVIEW OF PROCEDURES AND RECOMMENDED IMPROVEMENTS PHASE II - RECONCILIATION AND CONCURRENCE OF f... PROCEDURAL RECOMMENDATIONS PHASE III - REVIEW OF SYSTEM STATUS: OCTOBER 15, 1985 PHASE I - COMPLETE PHASE II - MAIN PROGRAM - COMPL TE PHASE III - IMPLEMENTATION IS BEING MONITORED PRELIMINARY FINDINGS:
WRITTEN PROGRAM DID,NOT PROVIDE ADEOUATE CONTROL FOR EXAMINING INSPECTION PERSONNEL k
(m 0478/ SLIDES
. ?
BATERIAL TRACEABILITY , ISAP VII.A.1
([) ISSUE: IS THE SYSTEM FOR llATERIAL IRACEABILITY ADEQUATE AND PROPERLY It1PLEMENTED?
- i WAS MATERIAL IDENTIFICATION AND
. TRACEABILITY MAINTAINED FOR ONSITE AND FIELD
.. FABRICATED COMPONENT'AND PIPE SUPPORTS 7
, , DID B&R FAILURE TO PASS A 19,81 ASME SURVEY RESULT-FROM A FAILURE TO MAINTAIN MATERIAL. TRACEABILITY?
APPROACH: EVALUATIO!1 07: SYSTEM AND PROCEDURAL BASIS AND IMPLEMENTATION.
- ~ '
} _
BY: PROCEDURE AND DOCUMENT REVIEW, INTERVIEWS,
- INPUT FROM RELATED ISAPS
- VII.B.1, VII.B.3, VII.C.
(1 -'
3 STATUS: OCTOBER 15, 1985:
1981 ASME SURVEY REVIEW COMPLETED.
PROCEDURE REv!EW APPROXIMATELY 757. COMPLETE.
OTHER ISAP RESULTS ARE NOT AVAILABLE YET.
i PRELIMIllARY FIllDI!!GS:
B&R PRACTICES DID NOT CONSTITUTE A " LOSS OF MATERIAL TRACEABILITY" Ill VIOLATION OF THE ASilE !
B&PV CODE. ,
BASED Oil THIS, THE ISSUE WAS NOT REPORTABLE (50:55E).
s.
' 0%8/111SC1
= = m m m* * = * " * -*' ~" * * " * * ~ ~ ' ~ * * * * ' **
}, 'll0!!-C0tiFORMAllCE AIID CORRECTIVE ACTI0tt SYSTEMS ISAP VII.A.2
~
ISSUE: ARE THE SYSTEMS FOR fl0NCONFORMANCE CONTROL,
{;.gy CORRECTIVE ACTION', AND 10 CFR 50.55 (e)
EE
~g . REPORTABILITY ADEQUATE AND PROPERLY !MPLEMENTED?
ee , .
h M'.;
DID LARGE NUMBER OF FORMS ALLOW FOR PROPER CONTROL OF N0tiCONFORMANCE7 ,
M;
- IS THERE AN ADEQUATE TREND PROGRAM IN PLACE?
We
- ARE THE TUEC AND BROWN AND ROOT CORRECTIVE ACTION 2$.: .
~
SYSTEMS PROPERLY IMPLEMENTED? ~
ARE ALL.10 CFR 50.55 (E) REPORTABLE ITEMS BEING
'k
=w
. REPORTED?
h APPROACH: EVALUATION D' '.
X
- 0F: SYSTEM AN
D. PROCEDURE
S, IMPLEMENTATIO!!.
.T.
- BY: DOCUMENT REVIEW, INTERVIEW, AND OBSERVATION 7.1 . OF CURRENT SYSTEMS.
STATUS: OCTOBER 15, 1985:
!!CR'S REVIEW APPROXIMATELY 75% COMPLETE (THIS INCLUDES llCR'S AND OTHER FORMS).
CORRECT!vE ACTIOri SYSTEM (INCLUDIllG TRENDING) 207.
'd COMPLETE. 4
?% *
,X. ' 10 CFR 50.55(E) REPORTABILITY SYSTEM 107. COMPLETE .
PRELI!11tlARY FillDitlGS:
~~
-5 I
THE CONTROL OF DISPOSITION / CORRECTION OF NONCONFORMING ITEMS IS ACCEPTABLE: HOWEVER, MINOR U IMPROVEMENTS CAN BE MADE TO PROCEDURES.
/.t CORRECTIVE ACTION (!!ON-ASME) PROCEDURES REVISED R'. AUGUST, 1985. IMPROVEMENTS WERE MADE, WE WILL ASSESS IMPLEMENTA7!ON.
g{. CORRECTIVE ACTION (ASME) PROCEDURES ADECUATE.
7 0440/MISCl
.., .. .. . ,. ..-..-*e = * * * * * ' ' * " * * ' " *
. - - - . - - . _ _ _ = _ . . . .
. . -~
DOCUMENT CONTROL ISAP VII.A.3
([
~
ISSUE:
WHAT EFFECT DID INADEQUACIES IN THE DOCUMENT t
CONTROL PROGRAM PRIOR TO JULY 1984 HAVE ON THE PLAN cr--
APPROACH: EVALUATION 1
?: INSTALLED HARDWARE: PREREQUISITE AND -
l
. . . PREOPERATIONAL TEST PROCEDURES j BY: EVALUATION OF RESULTS REPORTS l
FOLLOWING IMPLEMENTATION OF ISAPS III.D AND VII.C.
STATUS: OCTOBER 15, 1985 -
EVALUATION OF ISAP III.D RESULTS PRELIMINARY FINDINGS:-
PRELIMINARY ~RESULTS FOR ISAP I'll.D INDICATES THAT DOCUMENT CONTROL INADEQUACIES HAD NO ADVERSE
~
EFFECT ON TESTING PROGRAMS.
1 l
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s 0473/ SLIDES I
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e b AUDIT PROGRAM AND AUDITOR QUALIFICATIONS ISAP VII.A,4
([
ISSUE:
THE TUGC0 QA AUDIT PROGRAM (PROCEDURE CONTENT AND PROCEDURE IMPLEMENTATION) WAS INADEQUATE: AUDIT PERSONNEL STAFFING (NUMBER AND QUALIFICATIONS) WAS INADEQUATE.
APPROACH: EVALUATION .
. OF: SYSTEM AND PROCEDURESJ IMPLEMENTATION BY: DOCUMENT REVIEW, INTERVIEW, AND OBSERVATION OF CURRENT SYSTEMS
. STATUS: OCTOBER 15, 1985 PROGRAM DOCUMENT REVIEW COMPLETE (INCLUDES PSAR/FSAR, TUGC0 QA PROGRAM, CPSES 0A PLAN, AND IMPLEMENTING PROCEDURES).
{ *
~
RECORD FILES REVIEW APPROXIMATELY 75% COMPLETE (INCLUDES AUDIT FILES, AUDIT PERSONNEL QUALIFICATIONS, _TC.)
2.c PRELIMINARY FINDINGS:
c Di ;
5- *
.E' WRITTEN PROGRAM NOT COMPLETELY IN ACCOPDANCE WITH -
, APPLICABLE REQUIREMENTS (ANSI 45.2.12)
OVERALL PROGRAM IMPLEMENTATION ADEOUACY HAS NOT-
, BEEN DETERMINED AT THIS TIME,
(-s 0473/ SLIDES
.;-- --- - ;3 3_-;_
. - ----b+ -
MANAGEMENT ASSESSMENT ISAP VII.A,5
( ISSUE:
TUEC MANAGEMENT FAILFD TO PERIODICALLY REVIEW THE STATUS AND ADEQUACY OF THEIR OA PROGPAM.
? . .
APPROACH:
.*.e; _
,...REVIEhIN-PLACEMANAGEMENTASSESSMENTPROGRAMSIN
- T ' 'OTHER ORGANIZATIONS
-m . .
.. ". .. . - DEVELOP CRITERIA FOR PROGRAM ASSESS CURRENT CPSES PROGRAM STATUS: OCTOBER 15, 1985 0BTAINED SOME OUTSIDE SOURCE MATERIAL (INF0)
( PRELIMINARY FINDINGS:
NONE AT THIS TIME
.g
.r..-
4
(
0473/ SLIDES
EXIT INTERVIEWS ISAP VII.A,6
([ ISSUE:
EMPLOYEE EXIT INTERVIEW SYSTEM INEFFECTIVI i
LACK OF EMPLOYEE CONFIDENCE
- LIMITED IMPLEMENTATION ACTIVITIES UNDOCUMENTED INCOMPLETE CORRECTIVE ACTIONS APPROACH
- EVALUATE OF: OMBUDSMAN /SAFETEAM PROGRAMS BY: PROGRAM / IMPLEMENTATION REVIEW & COMPARISON j TO INDUSTRY EXAMPLES TO EVALUATE HANDLING OF !
PAST CONCERNS STATUS: OCTOBER 15, 1985
(
- OMBUDSMAN INTEP. VIEWS COMPLETE
- * ~
OBTAINING INDUSTRY INPUT ON OTHER PP0 GRAMS PRELIMINARY FINDINGS: NONE TO DATE 4
i -
l r
i
< l
's 0473/ SLIDES
HOUSEKEEPII!G Aia SYSTEl CLEAILIIESS ISAPVll.A.7 -
ISSUE: ARE SYSTEMS ADEQUATE TO MAINTAIN DESIGil CLEANLINESS AND PROTECT EQUIPMENT AND MATERIAL FROM DAMAGE OR DETER 10RATI0tt?
WERE THE PROCEDURAL REQUIREMEllTS FOR RV CLEANING ADEQUATE?
WAS EQUIPMENT PROTECTED FROM CONSTRUCTIOtt ACTIVITY?
. WAS CONTROL OF CONSTRUCTION DEBRIS ADEQUATE TO MAINTAIN REQUIRED SEPARATIONS Ill " CRITICAL SPACES"?
APPROACH: EVALUATIOM-OF: SYSTEM AND PROCEDURAL BASIS ATID IMPLEMENTATION.
BY: PROCEDURE AND DOCUMENT REVIEW, INTERVIEWS, OBSERVATIOtt OF TUGC0 SuRvEILLAtlCE, INPUT FROM RELATED ISAPS: II.C, VI.A.
( STATUS:
OCT0aER 15, 1985:
REACTOR VESSEL CLEANLINESS REV!EW COMPLETED.
PROCEDURE reviews COMPLETE.
OBSERVATI0tt OF SURVEILLANCE ACTIVITY APPROXIt1ATELY 80% COMPLETE.
PREllni!!ARY FIllDil!GS:
RV CLEAtiLillESS VERIFICATION ADECUATE.
PAST AllD CURREllT PROCEDURAL REQUIREMENTS FOR HOUSEKEEPIllG AllD CLEAtiLINESS ADECUATE. .
PAST PROCEDURAL REQUIREMEllTS FOR SURVEILLANCE OF HOUSEKEEPING , CLEAllLIflESS AtlD STORAGE WERE IllADECUATE.
W Ot48/ MISC 1
FUEL POOL LIl!ER DOCUMElTATI0ll ISAF Vll.A.8
(
ISSUE:
MAS THE ERECTION AND IllSPECTIOri 0F THE FUEL POOL l!NERS PROPERLY CONTROLLED At4D DOCUMENTED?
MERE FUEL POOL TRAVELERS CHANGED AFTER THE FACT WITH INSUFFICIENT JUSTIFICATION?
MERE THE FUEL POOL TRAVELERS COMPLETED BY QUALIFIED AND CERTIFIED PERSONNEL AT THE TIME THE INSPECTIONS OR EXAMINATIOf1S WERE PERFORMED?
APPROACH: EVALUATION OF: FUEL POOL LINER DOCUMENTATI0ft ADECUACY, CORRECTiiESS, AND COMPLETE!1ESS BY: PROCEDURE AtlD DOCUMENT REVIEW.
STATUS: OCTOsER 15, 1985:
1ST 60 (OF 300) TRAVELERS REVIEWED: P REL IM !!! AR Y REVIEW OF RELATED WELD MATERIAL ISSUE RECORDS, PRELIMit!ARY FillDl!!GS:
li0tlE TO DATE.
G68AllSC1
._A
0!! SITE FABRICAT10tl ISAP VII.B.1 ISSUE: UERE THE FABRICATION CONTROLS FOR P!P!!iG (7
SUBASSEMBLIES AtID COMP 0flElli SUPPORTS ADEGUATE TO ASSURE USE OF QUALIFIED PROCESS PROCEDURES AtD MAINTENANCE OF MATERIAL IDENTIFICATION?
WERE SHOP MATERIAL STORAGE AREAS PROPERLY MAltiTAINED At4D MATERIAL SEGREGATED?-
WAS SHOP FABRICATION WORK D0flE TO APPROPRIATE REQUIREMENTS AND '
PROPERLY DOCUMENTED?
APPROACH: EVALUATION 0F: SHOP FABRICATION PRACTICES, DOCUMEtlTATION, AtlD STORAGE.
DY: PROCEDURE APID DOCUME!!T REVIEW, INTERVIEW, RE!!1SPECT!0ft IF WE FIND COCUMENTATI0tt DISCREPAllCIES.
STATUS: OCTOBER 15, 1985: .
~
PROCEDURE REVIEW APPROX!!1ATELY 75T.
COMPLE'E. .
PREllr.lilARY FillDil!GS:
IlotlE TO DATE.
fs 0%8AllSC1
=
o VALVE DISASSEMBLY ISAP VII.e.2 ISSUE:
CONTROL OF DISASSEMBLED VALVE PARTS WAS INADECUATE CREATING POTENTIAL FOR INTERCHANGING VALVE BONNETS
- AND INTERNAL PARTS HAVING DIFFERENT PRES. & TEMP, RATINGS.
APPROACH: *
- REVIEW SPEC / PROCEDURE REQUIREMENTS
, IDENTIFY VALVES WHICH HAVE BEEN
- DISASSEMBLED 4
- SELECT SAMPLE AND PERFORM INSPECTIONS
- EVALUATE RESULTS/ ROOT CAUSES REPORT / ADVISE TUGC0 STATUS:
- OCTOBER 15, 1985 ALL INSPECTIONS COMPLETE PRELIMINARY
- FINDINGS:
NO CONSTPUCTION DEFICI.ENCIES FOUND
(
i .
J l,
4
?
1 0449 SLIDES
l
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\
PIPE SUPPORT IDSPECTIOUS ISAP VII.s.3 -
ISSUE:
(7 8
~*
HARDWARE DEVIATIONS Or OC ACCEPTED AND INSTALLED P!PE SUPPORTS.
DEVIATIONS FOR WELDS, SUPPORT IDENTIFICATION, LOCKING DEVICES, MATERIAL IDENTIFICATION, AS-BUILT DRAWINGS.
EVALUATI0llAPPROACH: VERIFICATION ACTION PLANNED REINSPECT THE TRT PIPE SUPPORT SAMPLE TO VERIFY PIPE SUPPORT DEVIATIONS AND ANALYZE FOR SIGNIFICANCE.
UTILIZE THE ACTIOri PLAN Vll.C INSPECTION RESULTS TO ACHIEVE BROAD AND MEANINGFUL RESULTS.
DETERMINE ROOT CAUSE OF EACH VALID CONSTRUCT!0ft DEFICIEllC AND ADVERSE TRE!4D.
EVALUATE FOR PROGRAftMATIC AND GENERIC IMPLICATIONS.
- { CURREf!T STATUS
- (10/15/85)
RE!r:SPECTIONS 907. COMPLETE. .
PRELIMIl!ARY FII DI!!GS:
EEVIATI0t:S FOUllD !!! ROOM 770 AGREE WITH TYPES ICE!!TIFIED TRT.
t ONe C0!:STRUCTIOfi CEFICIEllCY WAS ISSUED FOR MISS!!!G PIPE SUPPORT COTTER P!ft !!1 ROOM 770.
O e
9 0441/ MISC 1 9
- ~ . , .. . .
d . * -
HILTI ANCHOR BOLT INSTALLATION ISAP VII.B,0-ISSUE:
INVESTIGATE' ALLEGATIONS OF HILTI INSTALLATION DEVIATIONS MINIMUM EMBEDMENT
' VERIFICATION OF TORQUE MINIMUM EDGE DISTANCE SKEWED BOLTS EVALUATION APPROACH:
REVIEW SPEC / PROCEDURE REQUIREMENTS IDENTIFY ATTRIBUTES 8. SAMPLE INITIATE INSPECTION UNDER VII,C INITIATE TORQUE VERIFICATION PROGRAM EVALUATE RESULTS/ ROOT CAUSES/GENEPIC IMPLICATIONS CURRENT STATUS: OCT'BER 0 15, 1985 1
VII.C INSPECTIONS APPROXIMATELY 65% COMPLETE PROCEDURE AND SAMPLING FOR TOROUE VERIFICATION PROGRAM BEING PREPARED PRELIMINARY FINDINGS:
NO ADVERSE TRENDS IDENTIFIED TO DATE V
0475/ SLIDES
e 6 ELECTRICAL RACEWAY SUPPORT INSPECTIONS ISAP VII.B.5 -
ISSUE:
C UNDERSIZE WELDS, MISPLACED WELDS UNAUTHORIZED CONFIGURATION CHANGES
- UNDERSIZE NUTS i
- y HILTI ANCHOR BOLT INSTALLATION DEFICIENCIES APPROACH: '
J!
'~
', CABLE TRAY SUPPORTS ARE BEING COVERED BY THE TUGC0 CABLE TRAY HANGER DESIGN ADEQUACY UNIT #1 PROGRAM (CP-EI-4.0-75).
I FOR CONDUIT THE FOLLOWING APPROACH WILL BE USED:
REVIEW SPECIFICATIONS, DRAWINGS AND BOTH l
INSTALLATION AND INSPECTION PROCEDURES.
4 IDENTIFY POPULATION.
lj
- SELECT SAMPLES AND PERFORM INSPECTIONS.
,j
- PERFORM DOCUMENT REVIEW.
4 i
- EVALUATE RESULTS/ ROOT CAUSES AND GENEPIC
{
IMPLICATIONS.
l
- i STATUS: OCTOBER 15, 1985 1
33% OF INSPECTION COMPLETE.
PRELIMINARY FINDING: -
NO CONSTRUCTION DEFICIENCIES FOUND TO DATE
/
'0670/ SLIDES
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ww. - -
- * ~ - *- ***
.__m _ , _ _ _ _ - _ . - . , . _ ._ , _ _ _ - . ..
N TESTItlG PROGRAM ISAP t
III.A,1 Q-HOT FUNCTIONAL TESTING (HFT) DATA PACKAGE
(
t
)
ISSUES: PREOPERATIONAL TEST OBJECTIVES NOT ALL MET.
i STATUS:
8 .
s;
- i DATA PACKAGE RE-EVALUATIONS AS SPECIFIED IN ACTION PLAN COMPLETED.
' INCORPORATED RE-EVALUATION CRITERIA INTO STARTUP ADMINISTRATIVE PROCEDURE NUMBER 11. *
-~
INVESTIGATED PPEOPERATIONAL TEST ICP-PT-02-02, "r i
"118 VAC RPS INVERTERS," QUESTIONED BY THE ASLB. '
CONDUCTING SAFETY-SIGNIFICANCE EVALUATION OF
(, ICP-PT-02-02.
PREPARING RESULTS REPOPT.
I.
1 I'
PRELIMINARY FINDINGS:
RE-EVALUATED PACKAGES AND ATTRIBUTES MET ACCEPTANCE CRITERIA.
r
- 1CP-PT-02-02 DETERMINED TO CONTAIN A DEVIATION.
i t
1 5
. 11/04/85 0489/ SLIDES
-- .. - . . = _. . - . - . _.
e TESTING PROGRAM ISAP o .
III.A.2 JTG APPROVAL OF TEST DATA C
ISSUE:
FSAR NOT CLEAR REGARDING REVIEW AND APPROVAL OF DEFERRED PREOPERATIONAL TEST DATA.
STATUS:
' AMENDED FSAR TO PROVIDE CLARIFICATION THAT STATION OPERATION REVIEW COMMITTEE (SORC) IS RESPONSIBLE FOR REVIEW AND APPROVAL.
i EVALUATED ADMINISTRATIVE PROCEDURES.
l RESULTS REPORT SUBMITTED TO SRT.
w -
4 PRELIMINARY FINDINGS: .
j
(
- ADMIff!STRATIVE PROCEDURES PROVIDED FOR SORC REVIEW AND AFPROVAL OF DEFERRED PREOP TEST DATA. l ISSUE NOT CONSIDERED A DEVIATION.
i
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~
11i04/85 !
0489/ SLIDES
- s. _t.. -
TESTING PROGRAM ISAP c
Ill.A.3 TECHNICAL SPECIFICATION FOR DEFERRED TESTS ISSUES: PLANT CONDITIONS REQUIRED FOR SOME DEFERRED
' PREOPERATIONAL TESTS MIGHT NOT BE COMPATIBLE WITH TECHNICAL SPECIFICATION LIMITING CONDITIONS.
4 STATUS:
CLARIFYING INFORMATION INCLUDED IN REVISIONS 0 AND 1 0F ACTION PLAN. .
, SSER NUMBER 7 STATED THAT ISSUE "!S NO LONGER OF CONCERN."
. ,.e -
REVISION 2 0F ACTION PLAN REPORTED ITEM COMPLETE.
NO COMMENTS ON ACTION PLAN IN SEPTEMBER 30, 1985,
([ NRC EVALUATION.
~
~*
ISSUE CONSIDERED POTENT!' ALLY CLOSED.
5 i
- NO RESULTS REPORT TO BE PREPARED.
O 4
5 11/04/85 0489/ SLIDES
4 TESTING PROGRAM ISAP .
l III.A.4 TRACEABILITY OF TEST EQUIPMENT ISSUE: MdASUREMENT INSTRUMENTS (M&TE)
, NOT TRACEABLE TO MONITORED LOCATIONS STATtiS:
EVALUATED COMMITMENTS AND TESTING ADMINISTRATIVE REQUIREMENTS FOR M&TE TRACEABILITY.
' EVALUATED TEST DATA PACKAGE IN QUESTION.
EVALUATED OTHER S,TARTUP TEST PROCEDURES AND DATA PACKAGES.
EVALUATED REPRESENTATIVE PLANT OPERATIONS ADMINISTRATIVE AND TEST PROCEDURES.
PREPARING RESULT REPORT. '
x PRELIMINARY FINDINGS:
TRACEABILITY TO MONITORED LOCATIONS NOT AN ACTUAL
( REQUIREMENT.
DATA PACKAGE IN QUESTION CONTAINED M&TE DATA WHICH FULFILLED STARTUP ADMINISTRATIVE RECUIREMENT.
j DATA SUBSTITUTION HAD NOT BEEN PROCESSED IN ACCORDANCE WITH STARTUP ADMINISTRATIVE I
PEQUIREMENT. !
- J; OTHEP PROCEDURES AND DATA PACKAGES FOUND 4
ACCEPTABLE. '
4 i,
o i
1 11/04/85 0489/ SLIDES
n a
TESTING PROGRAM ISAP -
s III.a CONDUCT OF CILRT 9
ISSUES:
i
- TEST PERFORMED WITH PENETRATIONS ISOLATED AND PRIOR NRC APPROVAL NOT OBTAINED.
LEAK RATE CALCULATIONS PERFORMED USING ANSI /ANS 56.8-1981. FSAR SPECIFIED ANSI N45.4-1972.
POTENTIAL FOR OTHER DEVIATIONS FROM FSAR COMMITMENTS.
, STATUS:
NRC-NRR EVALUATED ISSUES AND REPORTED AGREEMENT
- WITH TEST METHODS IN SSER NUMBER 6 AND 7.
FSAR AMENDED TO ELIMINATE DISCREPANCY.
OTHER TEST PACKAGES EVALUATED FOR DEVIATIONS FROM FSAR COMMITMENTS AS PART OF ISAP III.A.1 INVESTIGATION.
([
- STARTUP ADMINISTRATIVE CONTROLS EVALUATED.
OTHER PPOJECT GROUPS ADMINISTRATIVE CONTROLS AND PROCEDURES EVALUATED.
PREPARING RESULTS REPORT.
PREllMINARY FINDINGS:
- CILRT TEST PACKAGE CONTAINED NO OTHER DEVIATIONS.
~
- OTHEP TEST PACKAGES DID NOT CONTAIN DEV!ATIONS.
STARTUP ADMINISTRATIVE PROCEDURES DEFICIENT REGARDING SPECIFIC REQUIREMENTS FOR MAINTAINING FSAR CURRENT. PROCEDURE CP-SAP-14 UPGRADED.
OTHER PROJECT GPOUPS ADMINISTRATIVE CONTROLS AND PROCEDURES ADEQUATE.
~
11/04/85
. 0489/ SLIDES m ..
. ~ . _ . _ -
- TESTING PROGRAM ISAP III.C PREREQUISITE TESTING
. f(
ISSUES:
TEST SUPPORT PERSONNEL (CRAFT) SIGNING TO VERIFY INITIAL CONDITIONS FOR PREREQUISITE TESTS.
- MANAGEMENT MEMORANDUM ISSUED TO CLARIFY PROCEDURAL REQUIREMENTS AND PROCEDURE (CP-SAP-21) NOT SUBSEQUENTLY REVISED.
STATUS:
MEMORANDUM IN QUESTION RESCINDED.
ALL OTHER CURRENT MEMO REVIEWED.
i PREREQUISITE TEST RESULTS EVALUATED TO DETERMINE l
IMPACT ON SUBSEQUENT TESTING.
INTERVIEWS CONDUCTED WITH TESTING PERSONNEL.
4 STARTUP PROCEDURES REVISED TO CLARIFY
! REQUIREMENTS.
RESULTS REPORT BEING PREPARED.
PRELIMINARY FINDINGS:
NO OTHER SIMILAR MEMOS WERE IN EFFECT.
PREREQUISITE TESTS WITH INITIAL CONDITIONS VERIFIED BY TEST SUPPORT PERSONNEL HAD NO ADVERSE IMPACT ON SUBSECUENT TESTING.
IEST SUPPORT PERSONNEL ARE QUALIFIED TO VEPIFY INITIAL CONDITIONS FOR SOME TYPES OF PREREQUISITE i TESTS.
TEST SUPPORT PERSONNEL WERE NOT ALLOWED TO VERIFY INITIAL CONDITIONS ON TESTS WHICH NEEDED SYSTEM i
IEST ENGINEER (STE) VERIFICATION.
t
- 11/04/85 0489/ SLIDES i
I - . - .. ... . _ . , , _ . _ .
- j. ~
TESTING PROGRAM ISAP III.D PREOPERATIONAL TESTING C
ISSUES:
SYSTEM TEST ENGINEERS (STES) WERE REQUIRED TO OBTAIN DESIGN CHANGE INFORMATION ON THEIR OWN INITIATIVE.
POTENTIAL FOR ADVERSE IMPACTS ON TESTING DUE TO DOCUMENT CONTROL SYSTEM PROBLEMS.
STATUS:
t
- EVALUATED ADMINISTRATIVE PROCEDURES AND METHODS FOR HANDLING DESIGN CHANGE INFORMATION FOR STARTUP TESTING. '
INTERVIEWED STARTUP AND DOCUMENT CONTROL PERSONNEL. ' ' " '
REVISED STARTUP ADMINISTRATIVE PROCEDURES CP-SAP-7 AND CPP-SAP-21 TO PROVIDE ADDITIONAL GUIDANCE AND DOCUMENTATION ON HANDLING OF DESIGff CHAflGE
( INFOPMATION.
SAMPLED AND EVALUATED IMPACT OF DESIGN CHAf!GES Off PREREQUISITE AND PR60PEPATIOflAL TESTIf4G.
PREPARING RESULT REPORT.
PREL IMINAPY Fit 3Dir!Gs:
ADMINISTRATIVE PROCEDURES AND METHODS FOR HAflDL DESIGN CHANGE IflFORMATION FOR STARTUP USE WAS -
SATISFACTORY.
DOCUMENT CONTROL SYSTEM PROBLEMS RESULTED If1 fl0 ADVERSE IMPACTS ON STARTUP TESTIflG.
i .
f i
6 11/04/85 0489/ SLIDES
TESTING PROGRAM ISAP STATUS
([ III.A.1 HOT FUNCTIONAL TESTING (HFT) DATA PACKAGES INVESTIGATION SPECIFIED IN ISAP COMPLETED.
SAFETY-SIGNIFICANT EVALUATION 0F CP-PT-02-02, "118 VAC RPS INVERTER", IN PROCESS.
2
- RESULT REPORT BEING PREPARED.
III.A.2 JTG APPROVAL OF TEST DATA l
AMENDED FSAR TO CLARIFY THAT STATION OPERATION REVIEW COMMITTEE (SORC) REVIEWS AND APPROVES '
~~
DEFERRED PREOP TEST RESULTS. *
APPLICABLE ADMINISTRATIVE PROCEDURES SATISFACTORY
([ III.A.3 TECHNICAL SPECIFICATION FOR DEFEPRED TEST i
CLAPIFYING INFORMATION P'ROVIDED IN ACTION PLANS j .
' SSER NUMBER 7~ STATED ISSUE "!S NO LONGER OF CONCEP.N" i
4
- ISSUE CONSIDERED POTENTIALLY CLOSED.
NO RESULTS REPORT TO BE PREPARED.
t i
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V 11/04/85 !
0489/SL! DES l
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' TESTING PROGRAM ISAP STATUS (CONT'D) -
(I , III.A.4 TRACEABILITY OF TE5T EQUIPMENT ISSUE FOUND TO NOT BE ACTUAL REQUIREMENT.
TEST. DATA. PACKAGES FULFILLED. REQUIREMENTS.
s
+ '
- TEST PROCEDURE DEVIATION (TPD) HAD NOT BEEN PROCESSED FOR SUBSTITUTED DATA.
PLANT OPERATIONS ADMINISTRATIVE AND TEST PROCEDURES ADEQUATE.
r PREPARING RESULTS REPORT.'
~
x-III.B CONDUCT OF CILRT i.
TEST METHODS EVALUATED BY NRC-NRR AND FOUND
( ACCEPTABLE.-
NO OTHER DEVIATIONS FOUND. ' -
s.
FSAR AMENDED TO ELIMI,'iATE DISCPEPANCY.
STARTUP ADMINISTRATIVE CONTROLS IMPPOVED.
OTHER CONTROLS FOUND SATISFACTORY.
2 RESULTS REPORT BEING PREPARED.
1 4
)
1 1
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11/04/86
, 0489/ SLIDES n._ ._ _ . _. . . _ _ . . __- _
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' TESTING PROGRAM ISAP STATUS (CONT'D) ~
( III.C PREREQUISITE TESTING NO OTHER SIMILAR MEMOS IN EFFECT.
INITIAL CONDITION VERIFICATION BY TEST SUPPORT PERSONNEL (CRAFT) FOUND NOT TO ADVERSELY IMPACT ON SUBSEQUENT TESTING.
STARTUP PROCEDURES REVISED TO CLARIFY REQUIREMENT.
PREPARING RESULTS REPORT III.D PREOPEPATIONAL TESTING "'""
CURRENT ADMINISTRATIVE PROCEDURES AND METHODS FOUND TO BE ADEQUATE FOR HANDING DESIGN
( INFORMATION FOP STARTUP.
- SAMPLING AND EVALUATION OF DESIGN CHANGES DETERMINED DCC PROBLEMS RESULTED IN NO ADVERSE !
IMPACTS ON STARTUP TESTING.
RESULTS REPORT BEING PREPARED. -
I I
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ADDED TEST PROGRAM a . i r - s- i- .i r. s .u;:. r, vr. ..
. i e r9r. , r. -.
ON-GotNG ACTIVITIES INTERACTION EVALUATIONr e.r. .. .. .: cn t.r.
. DAMAGE SSESSMENT
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4 TRT ISSUE:
C.. II.A - REINFORCING STEEL IN THE REACTOR CAVITY COMPLETED MILESTONES e
- . . : : t. r: t . er . c.wn ANALYSIS OF AS-BUILT CONDITION c r .3: . .
P NCR REVIEWS FOR MISSING REBAR AND EMBEDMENTS POUR CARD REVIEWS
~.._.s.. f.y.'. .
PROCEDURE REVIEW 9
PROGRAM CHANGES
. : .:r 4. . ..; !.
NONE " '
i
! On-going ACTIVITIES i
(-
- FINAL EVALUATION 1
b t
i 0481/ MISC 2
'**"*J . _ . .:.**. l+ _ . _ , _ , ,_ _. , _ , . _,,y._, , , - _ , . , . . , _ _ _ _ . . . . , . . , , , _ ,. . . . . _ . , .
- s. . . . . _ . . .
\ _
TRT ISSUE II,8 - CONCRETE COMPRESSION STRENGTH COMPLETED MILESTONES Q l. l.1. " 6 I 4 , , , ..' '.4 SCHMIDT HAMMER TESTS FOR CONCRETE AT ISSUE
. i~u.h .. n . L L.
- 1. CONTROL CONCRETE ANALYSES OF RESULTS
- a;.: e .~.. , ':
PROGRAM CHANGES r, .
NONE ON-going ACTIVITIES
- FINAL EVALUATION 1
F 5
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II.C -'"MAINTENANCE OF AIR GAP BETWEEN CONCRETE STRUCTURES .
( ,
COMPLETED MILESTONES
, . . . : . Ji :
.. .i.,.
AS-BUILT INSPECTION OF BLDG.-TO-BLDG.' GAPS
. ;! t s :s. .. .- . ,,. .. .,
RRCCEDURE REVIEW.f-
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- . DEBRIS ~. REMOVAL FROM SINGLE WALL GAPS PROGRAM CHANGES . .. .
. "! M o .
'- - ;* 5 - > <-
ADDED GAP BETWEEN CONTAINMENT AND INTERNAL STRUCTURE ,
' - w-- -
ON-GOIRG ACTIVITIES DEBRIS REMOVAL FROM DOUBLE WALL GAPS
- WIDENING GAP WHERE LESS THAN PEQUIRED FINAL INSPECTION i -
i I
L 0481/ MISC 2
-- r__ _ _ - - - - - - - -
k -
TRT ISSUE: II.D-SEISMICDESIGNOFCONTROLROOMCEILINGILEMENT t
COMPLETED MILESTONES REMOVAL OF EXISTING CEILING -
DESIGN OF NEW CEIEING ' 4-1 PROGRAM CHANGES . . . . ie i r, gis, f.,3 NONE- ~
l ON-GOING ACTIviTTES f
. .. ,=- 1 3RD PARTY REVIEW OF NEW CEILING DESIGN i DAMAGE STUDY VERIFICATION I
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' ~' '
PROCEDURE' REVIEW *i? '
r REVIEW OF Att" REBAR CUT: REQUESTS' FOR' HILTI' BOLT '
INSTILL ATION F. * "' t "N C ' .
- h ' ' *
- . INSPECTION OF CASES WHERE POTENTIAL EXISTED TO CUT 2ND REBAR
,. .n ANALYSES OF CASES WHERE 2ND BAR MAY HAVE BEEN CUT n
PROGRAM CHANGES SHEAR LUG REVIEW
(
- REVIEW OF CMCS/DCAS PRIOR TO 1/81 FOR REBAR CUTTING.
ON-GotNG AcTivtTTES SHEAR LUG REVIEW CMC /DCA REVIEW
(
s 0481/ MISC 2
~ .
TRT ISSUE: V.A - INSPECTION OF CERTAIN TYPES OF SKEWED WELDS IN NF
- .;., . SUPPORTS COMPLETED MILESTONES WELD REINSPECTION OF. SAMPLE .
4
- PROCEDURE REVIEW PROGRAM CHANGES NONE
. ON-GoTNG ACTIVITIES
~
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EVALUATION OF RESULTS
(
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i 0481/ MISC 2
_ ..~..:.- . . . :. - - - - . . . - _ . _ . - - _ - - - . .
,9 -
( TRT ISSUE:.V,8 - IMPROPER SHORTENING 0F ANCHOR BOLTS IN STEAM GENERATOR UPPER LATERAL SUPPORTS
,w .
. . . a . , . .]: . .. :.
COMPLETED MILESTONES INSPECTION OF 120 BOLTS
.y.: >.-
PROGRAM CHANGES Pt ;p; y..;. . 4.. e NONE ON-GOING ACTivtTIES S. t . . ... . .~.,
REANALYSES OF UPPER AND LOWER LATERAL SUPPORTS (DAP) _
INSPECTION OF OTHER BOLTED CONNECTION SAMPLES RECORDS REVIEW PROCEDURE REVIEW (w
0481/ MISC 2
l .
( TRT ISSUE:
V.C - DESIGN CONSIDERATIONS FOR PIPING SYSTEMS BETWEEN SEISMIC CATEGORY I AND NON-SEISMIC CATEGORY I BUlt. DINGS
. i : :, . . , . i ,;:( .
COMPLETED MILESTONES -
alDENTIFICATION OF ALL LINES WHICH HAVE A SEISMIC ANALYSIS TRANSITION '
....r.. ..
ON-GOING ACTIVITIES i
-. .. a.. .. .1.3 C; .
THIS ISSUE WILL BE COVERED BY THE PROJECT PIPING AND SUPPORTS REANALYSES PROGRAM
~
THIRD PARTY OVERVIEW UNDER DAP (DSAP IX)
(
(-
(
k 0481/ MISC 2
= - =-_:,-- -
9 . .
i TRT ISSUE: V.D - PLUG WELDS
' COMPLETED MILESTONES INSPECTION OF CABLE' TRAY' SUPPORTS INSPECTION OF'ASME' PIPE SUPP' ORTS '
EVALUATION OF PLUG WELD DCA PROGRAM CHANGES -
.lRi-#:'.*r u NONE.
ON-GOING ACTIVITIES v i
1 EVALUATION OF RESULTS
( .
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! l C TRT ISSUE: V.E - INSTALLATION OF MAIN STEAM PIPES COMPLETED MILESTONES-ANALYSES '0F-UNIT'l?' LOOP 1 AND LOOP 4, MAIN STEAM P! PES REVIEW CONSTRUCTION PRACTICES RELATED TO THE USE OF TEMPORARY P!PE SUPPORTS' c .... : l PROGRAM CHANGES '
NONE
- r , r t.
- ., .;
ON-GOING ACTIVITIES EVALUATION OF RESULTS l
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0481/ MISC 2
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4 TRT ISSUE: VI.A - GAP BETWEEN REACTOR PRESSURE VESSEL REFLECTIVE INSULATION AND THE BIOLOGICAL SHIELD WALL i 4 COMPLETED MILESTONES
{ REYTEW 0F; COOLING' FLOW FOR BOTH UN!TS *
, r PROCEDURE. REVIEW i
.* l' PROGRAM CHANGES-r F.*...,i.NONE.;
i ON-GOING ACTIVITIES '* '
)
-v ;
REVIEW OF A SAMPLE OF NON-SAFETY DESIGN CHANGES !
i
, CRITICAL SPACES REVIEW AND REINSPECTION .
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TRT ISSUE: VI,s - P01.AR CRANE SHIMMING ,
COMPLETED MILESTONES REC 6RDS REVIEW: - -
RAtt. MOTION ~ TESTS -
PnospAM CHANGES NONE ON-GOING ACTIVITIES GIRDER SEl.T INSPECTION GENERAL INSPECTION
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- REVIEW OF DESIGN MODIFICATION TO ELIMINATE RA!L MOTION 4
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. DESIGN ADEQUACY PROGRAM i
j STATUS BRIEFING '
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- NOVEMBER 5-6,1985 f
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o QUALIFICATIONS o DOCUMENTATION o COMPLETED MILESTONES
'o EXTERNAL SOURCE ISSUES EVALUATION
- PURPOSE
- SOURCES :
- PROCESS l
- TRACKING !
C - STATUS o OVERVIEW OF SCOPE VALIDATION PROCESS
- OVERVIEW OF FOUR PHASES
- PURPOSE AND SCOPE OF PHASE 3 :
- DATA BASE l
- APPROACH ,
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DESlCN ACTIVITY MATRICES l" - GIVENS l -
AREAS OF SCOPE INCREASE i
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_ _ _ _ _ - - - - _ _ _ _ - _ - . _ - _ - . _ _ _ _ _ _ _ - _ _ _ _ ~ _ - - _ - - - _ _ _ . _ _ - - _ _ - - _ _ _ - _..- . - - _ _ _ _ _ _ _ _ _ _ _
[' O O
A CPRT DESIGN ADEOUACY PROGRAM LOGIC -
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DAP FHOGDuttES 4 I
i PRELIMt4ARY PtIA5E 3 i ACTIVITIES INITIAL SCON LOPMENT 1 P SCON e C&H DE5tCN FftOCE55 + " T vK'D# TION Y c, ggg$ $
StEV. 2 M ME
, e DOCUMEt4T A10N L i J L 1 r DAP IMPLEMENTATION
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4 DEVELOPMENT DAP DEVELOPMENT e EXTERNAL SOURCE 855UES OF D5AP COLLECTIVE l'
8
+ OF REV. 2 + e SELF.paTIATED Y RESULTS + EVALUATION CtECKLISTS EVALUATION REPORT REPORT e EtERIC IMFLICATIONS J L J L l
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- i II EX1ERt4AL SOURG OVERVIEW OF 155uE5 7 CORRECTIVE ACTION DEN 11FICAllON i 1 r 1 P DEVELOPMItai OF DAP mat 4AGuttil $YSTEMS ? DAP TRACMPC -
e 155UE THACKRC I
e DISCRIPAtJCY .
1HACKWC 1 e CORRECTIVE ACTIOti 1RACKRC e ACTlVITY It.At# AFC e
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DAP SCOPE 75 DESIGN TOPICS 500
- HOMOGENEOUS -
DESIGN ACTIVITIES -
4
(
6500 ATTRIBUTES <
l 51,000 ATTRIBUTES REVIEWED 4
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- DAP EXPERIENCE
SUMMARY
MATRIX Other Navy, Reg.,
Power Plant Commerical Non-Comrner. Other Totcl Design Nuclear Nuclear Design Engineering Discipline Experience Experience Experience Experience Experience i
Civil / Structural 176/7.3 16/0.7 3/0.1 147/6.1 342/14.2 Piping / Supports 105/9.5 19/l,7 6/0.5 68/6.2 198/18
.i 1
Mechanical 130/11.8 11/1 8/0.7 5/0.5 154/14 1 Electrical /l&C 141/9.4 67/4.5 38/2.5 7/0.5 253/16.9 Tctal 552/9 113/l.8 55/l.1 227/3.7 947/15.5 ,
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i- l i DAP DOCUMENTATION ,
i h CONTROL OF DAP [
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- CPRT PROGRAM PLAN 5 DESIGN ADEQUACY PLAN DESIGN ADEQUACY QA PROGRAM 47
.; DESIGN ADEQUACY PROCEDURES CAPS) t l DISCIPLINE INSTRUCTIONS ;
J ,
? *
- , WORKING COCUMENTS ;
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? CRITERIA LISTS i t
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CHECKLISTS SOURG DOCUMENTS
!(
I DAP-PRODUGD CALCULATIONS, SPECIAL EVALUATIONS f L
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END PRODUCTS RESULTS REPORTS i i'
DAP RECORDS i - COMPLETED CHECKLISTS i i
l - DAP-PRODUGD CALCULATIONS, SPECIAL EVALUATIONS l
- DAP-PRODUGD ENGINEERING EVALUATlONS (
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- SAFETY SIGNIFICANCE EVALUATIONS i ISSUE RECORDS /DIRs j OTHER DAP DOCUMENTS !
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t DAP PROCEDURES 17 PROCEDURES ISSUED w
- 3 EAR COMPLETION I
- TRDOING APO GEMRIC lMPLICATIONS EVALUATIONS
- OVERVIEW OF PROECT ACTIVITIES / CORRECTIVE ACTIONS l; - SELECTION OF REVIEW ITEMS I TO BE ISSUED IF NECESSARY
- CONTROL OF SUBCONTRACTORS G
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( CRITERIA lists AND CMCKLISTS n
- e PHASES I ANO 2 i
j CRITERIA CHECKLISTS QllCLPLINE Ll5TS (COMPLETE / TOTAL)
CIVIL / STRUCTURAL COMPLETE 26/30 PIPINC/ SUPPORTS COMPLETE , I/3 MECHANICAL COMPLETE 24/26 ELECTRICAL ,
COMPLETE 27/27 .
I&C COMPLETE 8/9 .
, 88/97 e PHASE 3 t
- CRITERIA ,
CHECKLISTS j OlSCIPLINE 4
LISTS (EST.) ._
CIVIL / STRUCTURAL UNDER DEVELOPMENT 25
', PIPING / SUPPORTS UNDER DEVELOPMENT --
l MECHANICAL I
UNDER DEVELOPMENT 20 ELECTRICAL UNDER DEVELOPMENT 15 l&C UNDER DEVELOPMENT 4 1
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{;
,- EXTERNAL SOURCE ISSUES EVALUATION i 1
>, i l PURPQ$E ii o RESOLUTION OF ALL ISSUES RAISED BY PERSONS OR
) ORGANIZATIONS OUTSIDE THE CPRT RELEVANT TO THE SAFETY RELATED DESIGN ADEQUACY OF CPSES !
l I
o EXTERNAL SOURCE ISSUES ARE: '
DESICN.RELATED CONCERNS i-APPLICABLE TO SAFETY-RELATED SYSTEMS, STRUCTURES, COMPONENTS
) - DOCKETED 1 EXTERNAL TO TUCCO AND CPRT !
o A SIX STEP METHODOLOGY r l .
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IDENTIFICATION OF ISSUES CEFINITION OF ISSUES S DEVELOPMENT OF ACTION PLANS 1 -
IMPLEMENTATION OF ACTION PLANS {
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CORRECTIVE ACTION l
REPORTING I
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t1 USE IN DAP r
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. OPEN ISSUES NOT RESOLVED BY ORIGINATOR) WILL BE RESOLVED AND CLOSED BY DAP t o OPEN AND CLOSED ISSUES INPUT TO TRENDING ANALYSIS i
( SOURCES OF' EXTERNAL SOURCE ISSUES li
- ] o NRC SER/55ERs i I
'1 l o TRT, SIT, CAT, irs, ETC.
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- EVALUATION
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o RECENT DOCUMENTS BEFORE OLD DOCUMENTS -
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o SELECTED DOCUMENTS KNOWN TO CONTAIN KEY ISSUES:
ORIGINAL WALSH-DOYLE ALLEGATIONS f
, TRANSCRIPT 03/23/85 (WALSH-DOYLE) !
IAP (CYCNA) REVIEW ITEMS LISTS
- l. - $$ERs l l l o i RC- AND CASE-ORIGINATED DOCUMENTS !
( BEFORE TUCCO-ORICINATED DOCUMENTS AND TRANSCRIPTS [
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\
REVIEW SOURCE DOCUMENTS .
i RECORD ISSUE /OTHER DATA ON ISSUE RECORD o DISCIPLINE CROUP
( -
REVIEW ISSUE RECORD COMPLETE ISSUE RECORD o
CENERIC IMPLICATIONS STAFF ASSIGN CONTROL NUMBER LOAD INTO COMPUTER OlSTRIBUTE DATA BASE WEEKLY
(~
m___.________ _ - - - - - - - - - - - - - - - _ _
____r_1_______________________;
._ _ .. .._m.._. -
(
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EXTERflAL SOURCE ISSUES EVALUATI0fl PROCESS (C0llTIllbG1 i o OTHER C0ftSIDERATI0lls .
OPEll EXTERflAL SOURCE ISSOES~ REQUIRE CLASSIFICATI0fl, AFTER CLASSIFICATI0fl 0PEll EXTERil'AL SOURCE ISSUES ARE
{ TRACKED WITil DAP-IDEllTIFIED DISCREPAllCIES IF EXTERIlAL SOURCE ISSUE IS C0flSTRUCTI0fi/0A/0C RELATED, n' RESP 0fiSIBILITY IS TRAllSFERRED T0 QUALITY OF C0llSTRUCTI0ll PROGRAfl <
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N
., o ) 0490/ SLIDES
-- -.-- - 3 ,
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.DAP MANAEMENT AND QUALITY ASSURANCE
, TRACKING SYSTEM EXTERNAL SOURCE ISSUES (HISTORICAL RECORD) o OPEN
- o. CLOSED
. DlSCREPANCIES
~
o ITEMS IDENTIFIED BY DAP
( o ITEMS IDENTIFIED BY EXTERNAL SOURCES A.ND CLASSIFIED BY DAP RESOLUTION '
o RESOLUTION OF OPEN EXTERNAL SOURCE ISSUES o RESOLUTION OF DAP-IDENTIFIED DISCREPANCIES (i.E.
DISCREPANCIES, DEVIATIONS, DEFICIENCIES) !
L PROVIDES TRAll FROM IDENTIFICATION TO FINAL CLOSURE !
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EXTERilAL SOURCE ISSUES REVIEW STATUS (AS OF 10/31/85) o 170 DOCUllEllTS IDEllTIFIED FOR REVIEW o APPR0XIfiATELY 25,000 PAGES
{
o ,74 DOCUtlEllTS REVIEWED
^
o 834 EXTERilAL SOURCE ISSUES IDEllTIFIED o
EACH REFEREi!CE IS SEPARATE ISSUE o ~
IllDIVIDUAL ISSUES I0T YET C0flSOLIDATED 9
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0490/ SLIDES
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OVERVIEW OF DAP SCOPE VALIDATION PROCESS
/
=
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DESIGN ADEGUCY PROGRAM SCOPE DEVELOPMENT OVERVIEW OF FOUR PHASES A*.
PHASE I INITIAL SCOPE DETERMINATION o PAST IDVP/IDI SCOPES o PAST CPSES INDEPENDENT REVIEW SCOPES o SCOPE (BREADTH) OF SELI -INITIATED - REVIEWS IN MECHANICAL, ELECTRICAL, AND CIVIL / STRUCTURAL DISCIPLINES IS EQUIVALENT TO OTHER INDEPENDENT DESIGN REVIEWS PHASE 2 SYSTEM VALIDATION
{
o DESIGN ATTRIBUTES / CHARACTERISTICS o SAFETY-RELATED SYSTEMS COMPARISON o AFW AND EPS REPRESENTATIVE OF OTHERS PHASE 3 DAP SCOPE VALIDATION o HOMOGENEOUS DESIGN ACTIVITIES o DAP SCOPE VALIDATED
/
( .,
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_ _ _ _ __ ,y
__ y __ __
i DESIGN ADEQUCY PROGRAM
(, SCOPE DEVELOPMENT OVERVIEW OF FOUR PHASES (continued)
PHASE 4 FINAL' SCOPE DETERMINATION o DAP FINDINGS e TRENDS / GENERIC IMPLICATIONS - f o FINAL SCOPE CONFIRMED 1
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C PHASE 3 DAP SCOPE VALIDATION PURPOSE DEFINE A REVIEW SCOPG FOR THE DAP SELF-INITIATED EVALUATION THAT ENCOMPASSES THE AE SAFETY-RELATED SCOPE OF DESIGN FOR CPSES (WHETHER EXECUTED BY CIB85 & HILL, TUCCO OR CONTRACTORS).
IDENTIFY, DESIGN - ACTIVITIES FOR REVIEW WHICH SUPPLEMENT THE INITIAL SCOPE OF AFW AND ELECTRIC POWER SYSTEMS. ESTABLISH JUSTlFICATION WHICH WILL ALLOW THE DAP RESULTS TO BE EXTRAPOLATED TO THE' SAFETY-RELATED DESIGN ASPECTS OF CPSES, EXCLUDING THE NSSSNENDOR INTERNAL SCOPE OF DESIGN.
( THE SCOPE OF DESIGN UNDER CONSIDERATION IS NUCLEAR SAFETY.
RELATED COMPONENTS, STRUCTURES AND SYSTEMS AND NONSAFETY INTERACTIONS HAVING THE POTENTIAL FOR IMPACTING SUCH COMPONENTS, STRUCTURES, OR SYSTEMS.
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VENDOR NSSS
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fEVEW TASMS V5 DE5804 ACTIVffE5 t
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- s. C , nt Stevelurelinte,ity a l ang co vein fiano, erstem operating tranelents & system Emile OOOO XXX SWEC IPiping Reeelysisk hier le Piping ed Sagoerte, DSAPIX k deele ed instellation of presswo
- reliei volves X X $WEC fPiping Reeolyist Refor le Piping ed 5,poree, DSAPIX
- c. component apperte- X X l EDS FCore,anent Tdiingt hier to Civil Matrin item {
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, e. pe erskens X l b. steam ersterne X X . X
- c. fluid ersteme X X .X
- 3. Pipe Wall Thidneesee X X
- 4. FluidVelocleles
- o. piping systeme X X X
- b. any Intake X X WC ICentoinment sure, Mortel Testingt Cmedote Civen j 1. Heet Removal ed Rejectlan
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C&H INDICES /
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HOMOCEbEOUS DESIGN ACTIVITIES A HOMOCENEOUS DESlCN ACTIVITY (HDA) HAS COMMONALITY IN:
o CRITERIA : CRITERIA CATEGORY e DESIGN CONSIDERATIONS, APPROACH & METHODOLOGY e ORGANIZATION e DESIGN CONTROL PROCESS e DESIGN INTERFACES IPOlVIDUAL DESIGN ACTIVITIES I 2 3 4 5 6 7 8 9 10 ll .....
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I DAP SCOPE 75 DESIGN TOPICS 500 HOMOCENEOUS ,
DESIGN ACTIVITIES
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6500 ATTRIBUTES -
.. i S i,000 ATTRIBUTES REVIEWED .
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- DSAPIX
- h. dreap ed baseltetten of pressee toilei volwe X X 5%EC Mping Reenslytet Refer to Pipby ed Supports, 4 DSAPIX
{l c. eengeone agparto X X EDS # Component Tdenet Refer to CMI Meerla item (
! L Srotem Pvesswo Drop s
a pe ersterne X .
, A steem ere'*ve X X . X j, c. fluid ersteme X X X jj. 1 Pipe Weg TMctaisesse X '
X
- 4. FWdVelocities a piping erstens X X X A may Intase X X i WC (Cantainment Sump MeArt Testinet. Ceididate Clwn
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- 5. Hrot Reasovet ed Njecisen 1, .
a apen erstem X X X j k closed erstem X X W freel Peel Heet, far thit 11 l DC-05 77 i I
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i Table I
{ (Continued)
PHASE Ill MECHANICAL MATRIX LEGEND A*.
SM SYSTEM OPERATING MODES NP NPSH MM MAX., MIN. CONDITIONS OP OVERPRESSURE PROTECTION ST STEAM FLOW REQUIREMENTS HT HEAT REMOVAL REQUIREMENTS WS WATER SUPPLIES PD PUMPS AND DRIVERS l VO VALVES AND OPERATORS TK TANKS
{ Pi SF PIPING AND FITTINGS SINGLE FAILURE /FMEA SS SUPPORT SYSTEM REQUIREME,NTS CL CLASS S PIPING HE HELB FL FLOODING FP FIRE PROTECTION MS MISSILE PROTECTION EO ENVIRONMENTAL QUALIFICATION -
50 SEISMIC QUALIFICATION RM RADIATION MONITORING AS BOP ACTIVE VALVES AND PUMPS STRESS LEVELS s
i s.,
6 h
DC-85-79
- _r -- -,- g ~ -
- 8 . %,. ea=e* ,kr4.-++>w e IDENTIFICATION OF GIVENS A "GIVEN"IS A DESIGN ACTIVITY, DESIGN CRITERIA OR AREA OF DESIGN WHICH IS CONSIDERED CORRECT AND WILL NOT BE REVIEWED UNDER THE DAP.
GEtERIC GIVENS o REQUIREMENTS WITHIN INDUSTRY CODES, STANDARDS AND REGULATORY DOCUMENTS
( o POSTULATED ACCIDENTS AND PROTECTIVE ACTIONS DEFINED IN THE CPSES FSAR o NSSS DESIGN SCOPE o EQUIPMENT VENDOR DESIGN SCOPE (EXCLUDINC " UNIQUE" VENDORS) o UNRESOLVED INDUSTRY GENERIC ISSUES o
ATTRIBUTES RELATED TO PLANT SITING AND SITE SUITABILITY
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s IDENTIFICATION OF GIVENS THE FOLLOWING ATTRIBUTES ARE USED TO IDENTIFY A " CANDIDATE -
CIVEN":
o RECEIVED AN INDEPENDENT TECHNICAL REV:EW, o NO QUESTION, TO' OUR KNOWLEDGE, ABOUT THE REVIEWS QUALITY, INDEPENDENCE, RESULTS OR REVIEWER EXPERTISE.
( o REVIEW WAS COMPARABLE IN SCOPE AND DEPTH TO THAT i
ENVISIONED THAT WOULD BE PERFORMED IF EXECUTED UNDER
, THE DAP.
1 9
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CAbOIDATE GIVENS BENCHMARKING OF COMPUTER CODES CONTAINMENT SUMP DESIGN HIGH ENERGY LINE BREAK ANALYSES EXTERNAL FLOODING PROTECTIVE MEASURES SEISMIC BEHAVIOR CRITERIA
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DYNAMIC SOIL PROPERTIES
' SOIL PROPERTIES / ANALYSIS
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( DAP PHASE 3 AREAS OF SCOPE INCREASE (A) i (Continued)
STRUCTURAL:
o DETERMINATION OF LOADS ~ (E.G., SEISMIC, PIPING, WIND AND TORNADO) o CONCRETE DESIGN RE: -
- LOCAL LOADS (E.G., PIPE SUPPORTS)
BLOCK WALLS EMBEDMENT PLATE .
. ANCHOR BOLTS RADIATION SHIELDING CONTAINMENT STRUCTURAL INTEGRITY TEST CONTAINMENT MAT MISSILE BARRIER o STEEL DESIGN RE:
CONTAINMENT LINER FUEL POOL RE-RACKS i
PtPE WHIP RESTRAINTS INTERNAL MISSILE PROTECTION REFUELING POOL IMPACT LIMITING MATERIAL HATCHES / AIR LOCKS o OTHER SUPPORTS '
FUEL TRANSFER TUBE g
TUBING SUPPORTS s
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' .{ DAP PHASE 3 AREAS OF SCOPE INCREASE (A)
(Continued) e.
, o OTHER STRUCTURES CATEGORY I TANKS UNDERGROUND STRUCTURES SAFE-SHUTDOWN IMPOUND DAM
- o PROGRAMMATIC ISSUES (E.G., HEAVY LOADS, IEB 79-02) o DEVELOPMENT OF SPECIFICATIONS (E.G., CONCRETE, EMBEDMENTS, ETC.) .
,' o TESTING
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ELECTRICAL 2
t o
EMERGENCY LIGHTING (RE: SAFE SHUTDOWN) !
i i o GROUNDING SYSTEM (RE: D/Gs) -
INSTRUMENTATION AND CONTROL o MICROPROCESSOR INTERFACE DESIGN o HYDROGEN MONITORING INSTRUMENTATION <
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o INSTRUMENT TUBING DESIGN
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~i o '
FUNCTIONAL REQUIREMENTS FOR ADDITIONAL IdC COMPONENTS
~ ~T ~: - - . .:r .:, . _ - :: : . . . . ~ . . - -- =. - _. - : . . , - . .
DAP PHASE 3
(
AREAS OF SCOPE INCREASE (A)
MECHANICAL:
ESSENTIAL HVAC (INCLUDES CONTROL ROOM HABITABILITY)
- RADIATION PROTECTION AND DOSE ASSESSMENT
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COMBUSTIBLE GAS CONTROL CONTAINMENT ISOLATION WELDING ENGINEERING i
CONTAINMENT /SUBCOMPARTMENT ACCIDEf!T ANALYSES
, w FUNCTIONAL REQUIREMENTS FOR ADDITIOflAL E00!PMENT b
(A) OTHER DESIGN ORGAflIZATIONS - TYPICAL !
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0494/ SLIDES
.._ . , .. _. . -_. _ _ .. . . . _._ __. . -- - ~
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- SELECTION OF DAP 4
REVIEW ITEMS 1
3
-i
.i SELECTION OF SYSTEMS APO STRUCTURES
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BASIS FOR C SELECTION OF SYSTEMS ABD STRUCTURES SCOPE'PER REV. 2 PROGRAM PLAN
, SELECTION MADE ON BASIS OF IMPORTANCE TO SAFETY, j PROJECT / INDUSTRY EXPERIENCE, INTERFACES, ABILITY TO
., EXTRAPOLATE RESULTS DETAILED COMPARISON FOR AFW AND EPS FOR
-COMPARABILITY TO OTHEN SAFETY SYSTEMS PHASE 3 ADDITIONS MAKE SELECTIONS WITHIN SYSTEM OR STRUCTURE ALPEADY SELECTED TO RETAIN " VERTICAL SLICE" IF NOT, PICK INTERFACitIG SYSTEM OR STRUCTURE IF NEITHER APPLIES, THE FOLLOWit!G C0flSIDERATIOt!S 3 APPLY:
IMPORTAt!CE TO SAFETY INDUSTPY/CPSES EXPERIENCE INTERFACES 1
, DIVERSITY DESIGN CHANGES
~
CREATION OF NEW VERTICAL SLICE
(%
0494/ SLIDES '
. - . . ~ _ . _ .
SELECTION OF SPECIFIC ITEMS
[- (DRAWINGS, CALCULATIONS, COMPONENTS, ETC.)
FACTORS USED TO MAKE SELECTION: e i
j IMPORTANCE TO SAFETY
[{ INDUSTRY /CPSES EXPERIENCE e
DIVERSITY
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DESIGN CHANGES INTERFACES ABILITY TO EXTRAPOLATE RESULTS i
ADDITIONAL SELECTIONS:
IF DURING THE REVIEW PROCESS NEW DESIGN ACTIVITIES ARE IDENTIFIED, ADDITIONAL' SELECTIONS WILL BE MADE.
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> A*e SPECIAL CONSIDEPATION RELATIVE To Aa!LITY TO EXTRAPOLATE RESULTS
! VERTICAL SLICE EXAMPLE NOT REPRESENTATIVE:
r i
4 SELECT ITEMS FROM OUTSIDE VERTICAL SLICE REVIEW AREA DOES NOT LEND ITSELF TO PEVIEW-OF A
- SINGLE ITEM, ADDITIONAL ITEMS WILL BE SELECTED J
(E.G. PIPING SUPPORTS).
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---_-__-___ _ _3 _
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- POPULATION LIST
- ELECTRICAL (E) j . .-
i *
- CONDUIT (CDUT)
+ CABLE (CABL) *
- CABLE TRAY (CATY)
- ELECTRICAL ECUIPMENT (EEIN)
INSTRUMENTATION ECUIPMENT (ININ) '
- LIGHTING (LITG)
- e
.
- MECHANICAL (M) e
+
HVAC CUCTS & PLENUMS (DUPL)
+
HVAC ECUIPMENT INSTALLATION (HVIN)
FIELD FABRICATED TANKS (FFTA) -
MECHANICAL ECUIPMENT INSTALLATION (MEIN)
++ LARGE BCRE PIPING CCNFIGURATION (LBCC)
C SMALL ECRE PIPING CCNFIGURATION (SBCC) t
+
P!PE - WELDS & MATERIAL (PIWM)
PIPING SYSTEM ECLTED JOINTS / MATERIAL ( BCM) 1 4
j +
. . STRUCTURAL (S) 3 . __________
4
+
CCNCRETE PLACEMENT (CCNC)
STRUCTURAL STEEL (STEL) '
LINERS (LINR)
FUEL FCCL LINER (FPLR)
+
- FILL & BACKFILL PLACEMENT (FILL) -
DCCLMENT PEVIEW CNLY GRCUT - CEMENT (GRTC)
GROUT - EPCXY (GRTE) 4 i
- LARGE ECRE PIPE SUCPCRTS - RIGID (LBSR)
!
- LARGE ECRE PIPE SUPPORTS - NON RIGID (LBSN)
SMALL ECRE PIPE SUPPCRTS (SBPS) t
- LARGE ECRE PIPE WHIP RESTRAINTS (PWRE)
+ INSTRUMENT PIPE / TUBE SUPPORTS (INSP)
CAT 1 CCNDUIT SUPPCRTS (CCSP)
HVAC DUCT SUPPORTS (HVDS)
- ECUIPMENT SUPPORTS (ECSP) f .
. INDICATES NEW PCPULATIONS OR CHANGES l
.44444494444,9#e999996.e#e9444444444ee....eee... 44.eeeeeeee4 4 9. 44.....**
- }
MECHANICAL
(.
CHECKLISTS TOTAL REQUIRED 9 TOTALISSUED 9 PACKAGE PREPARATION TOTAL REQUIRED -
1470
.TOTALISSUED 463
( REINSPECTIONS VISUAL INSFECTIONS COMPLETED 322 l 4 , DOCUMENT REVIE'WS COMPLETED 0.
l TOTAL INSPECTIONS COMPLETED 322 i -
\
DEVIATION REPORTS ISSUED . 210 REVIEWED BY SSEG 13
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mL - ---- - - - - - -- - - - --
Q .&>A>M Mmm STRUCTURAL -
- (
CHECKLISTS TOTAL REQUIRED 12 TOTALISSUED 12 PACKAGE PREPARATION TOTAL' REQUIRED 2182 TOTALISSUED 895 L L 4
REINSPECTIONS '
VISUAL INSPECTIONS COMPLETED 370 DOCUMENT REVIEWS COMPLETED 122 l
TOTAL INSPECTIONS COMPLETED 492 - I I
DEVIATION REPORTS ISSUED 559 REVIEWED BY SSEG 122 I
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ELECTRICAL -
A CHECKLISTS
. TOTAL. R EQUIRED 5 T.OTAL ISSUED 5
U PACKAGE PREPARATION '
,s TOTAL REQUIRED 950
, TOTAL 1 ISSUED 678
- i
, s
( REINSPECTION.S s. ,,
VISUAL INSPECTIONS COMPLETED 303 DOCUMENT REVIEWS COMPLETED 252 l
TOTAL INSPECTIONS COMPLETED 555 DEVIATION REPORTS ISSUED 216 REVIEWED BY SSEG -
60 ;
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i SAFETY SIGNIFICANCE EVALUATIONS STATUS I
MECHANICAL. !
t
SUMMARY
THROUGH 10-15-85 l NUMBER NUMBER NUMBER i POPULATION DRs SSES CDs !
RECEIVED COMPLETED f HVAC ducts 8 ~
i
( PLENUMS DUPL 21 1 0 I I
LARGE BORE I
PIP!flG CONFIGURATION- LBC0 15 6 0 j SMALL BORE PIPING COMFIGURATION SBC0 23 4 0 !
PIPING SYSTEM !
BOLTED JOIMTS/ !
MATERIAL PBOM 7 2 0 i VALVE DISASSEMBLY VALV 4 4 0 :
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1 5
SAFETY SIGNIFICANCE EVALUATIONS STATUS STRUCTURAL
SUMMARY
THROUGH 10-15-85 NUMBER NUMBER NUMBER POPULATION DRs SSEs CDs RECEIVED COMPLETED C0flCRETE PLACEMENT CONC 1(4 5 0 l!NERs LINR 80 6f2 0 t
i
! (~ -
i 0479/St. IDES i
.,. , - _ _ _ - _ _ . _ _ . - - - - - - - , - - - - - - - - - - - - - - ~ - - - - - - - - ~ - - - - - - -- --- -
( '
SAFETY SIGNIFICANCE EVALUATIONS STATUS ELECTRICAL
SUMMARY
THROUGH 10-15-85 NUMBER NUMBER NUMBER i
POPULATION DRs SSEs CDs RECEIV'ED COMPLETED
( CONDUIT CDUT 20 10 0 i
CABLE CABL I43 2f4 __ 0
.; CABLE IRAY CATY 31 20 0 ELECTRICAL EcutPMENT EEIN 20 6 0 IrisTRUMEllTATION ECUIPMENT ININ 56 0 -
e
(
s 0479/ SLIDES
_ . . . ..