ML20149M455
| ML20149M455 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 12/29/1987 |
| From: | NRC COMMISSION (OCM) |
| To: | |
| Shared Package | |
| ML20149M429 | List: |
| References | |
| NUDOCS 8802260055 | |
| Download: ML20149M455 (293) | |
Text
_ _ _ _ _ _
ENCLOSURE 3 r-l b t
NUCLEAR REGULATORY COMMISSION ,
~- q i
k " (!1 -
, e
,s MEETING BETWEEN THE EMPLOYEE'S LEGAL PROJECT aND THE NUCLEAR REGULATORY CGMMISSION
- h. -
- l King of Prussia, Penna., Tuesday, December 29, 1987 i
t i A Meeting was held between the Employee's l Legal Proj ec t and the Nuclear Regulatory Commission at 631 Park Avenue, at 9:00 A.M., on the above date, I
before Norma Carr, Court Reporter - Notary Public.
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4 2
i i 1 APPEARANCES:
Lj 2 JACQUE P. DURR, Acting Deputy Director, DRS '
3 DONALD HAVERKAMP, 4 Project Section Chief 5 JAMES KAUCHER, Project Engineer 6
JAMES WIGGINS, 7 Section Chief, Region I 8 DAVID RUSCITTO, Resident Inspector, NRC 9
ANTONE C. CERNE, 10 Senior Resident Insp'ector, NRC 11 KAMAL MANOLY, Engineering Technical Assistant, 12 NRR, NRC i,
LJ 13 E. HAROLD GRAY, Senior Reactor Engineer, NRC, Region I 14 SHARON TRACY, I 15 Director, Employees Legal Project i
16 DOUGLAS E. RICHARDSON, Researcher, Employee's Legal Project 17 g MICHAEL GREENSTEIN, 18 District Director, U.S. Rept. Nicholas Mavroules 19 MARY BETH GENTLEMAN, ESQ.
20 Assistant Secretary for Policy I Executive Office of Energy Resources 21 Commonwealth of Massachusetts 22 E X H I B I T S I 23 - --
NUMBER DESCRIPTION PAGE MARKED
[] 24 A Proposed agenda. . . . . . . . 155 i
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g i g '. _
2 MR. DURR: Let's open the record. I 3 guess for the benefit of the record I would ask g
4 everybody to state their name, their. title and 5 address, and who they represent.
6 I'm Jack Durr. I'm Acting Deputy 0
7 Director of the Division of Reactor Safety for Region 8 I for the NRC.
9 MR. HAVERKAMP: Don Haverkamp, Project i
10 Section Chief of the Seabrook Plant, NRC.
11 MR. KAUCHER: James Kaucher. I'm the
,__ 12 Pro]ect Engineer for Section 3C of which Seabrook is 13 a part.
14 MR. GREENSTEIN: Mike Greenstein, i 15 District Director for United States Representative l l
16 Nicholas Mavroules. The Congressman represents the 17 6th Congressional District of Massachusetts.. .
6 1
18 communities within the District lie within the 19 10-mile EPZ, and that's why we've come here today l 20 representing the Congressman.
21 'I R . RICHARDSON: Douglas Richardson.
22 I'm doing research work for the Employee's Legal 1 23 Project.
l 24 MS. TRACY: Sharon Tracy, Director of AREA-WIDE PEDERAL REPORTING, INC. (215) 925-5777
4 4
- 1 Employee's Legal Project.
I 2 MR. GRAY: Harold Gray, Senior Reactor 3 Engineer, Region I, NRC.
g 4 MR. MANOLY: Kamal Manoly, Engineeling 5 Technical Assistant, Division of Engineering and 6 System Technology, Office of Nuclear Reactor 1 7 Regulation, NRC.
8 MR. CERNE: Tony Cerne, Senior 9 Resident Inspector at Seabrook for Region I, NRC. ,
i 10 MR. RUSCITTO: Dave Ruscitto, Resident 11 Inspector for Seabrook for the NRC.
12 MR. WIGGINS: Jim Wiggins. I'm the s
13 Project Branch Chief here at Region I for NRC for the 14 Branch at Seabrook. I'll only be here for part of the f 15 time. I have other things I need co do.
16 MR. DURR: With that, I guess I would l 1
like to restate the purpose of the meeting, and it l g 17l ~
18 was at partially your request that we have a post-19 inspection meeting to deal with the issues of 20 inspection report 86-52 and 87-07, which dealt with 21 the allegations presented by Employee's Legal Project 22 to the NRC back in November of 1986 and April of I 23 1987, and the purpose of this meeting is to address
( 24 some additional questions that came from those 2 AREA-WIDE FEDERAL REPORTING, INC. (215) 925-5777 j
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fIt 1 reports, and this meeting ~will deal with those issues g lJ 2 and those issues only that-are in those 2 reports.
3 MS. TRACY: Could I add something to
, 4 that?
5 MR. DURR: Certainly.
6 MS._TRACY: To that end, I agree with I 7 your synopsis of why we're having this meeting.. I've 8 put together a proposed agenda which lists those 9 issues which have been deferred until this meeting, i
10 and I would like to pass this out to the people here, 11 and also enter it into the record.
,_ 12 MR. DURR: At this point in time I
$_J 13 would like to take a look at those'first. You 14 submitted to us a letter which contained your i 15 concerns back in -- what's the date?
16 MR. GRAY: November 12, '87.
17 MS. TRACY: Right, i
18 MR. DURR: On November the 12th you 19 sent us a letter with your concerns and the issues
, 20 that you had questions about that would be discussed 21 at this meeting. So based on that letter that you 22 sent us we had the appropriate people here, and so I I 23 would like to work from that letter, if we could, l, 24 because everybody is familiar with that. This is a t
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1-6 1 new piece of information.
I 2 MS. TRACY: This isn't new 3 information. This simply amplifies what I put in the 4 letter that I wrote to you, and lists specific issues 5 that we have raised that are mentioned in that ;
6 letter.
I 7 Why don't I pass this out? You can 8 all look at it. I think I have enough copies for 9 everyone. There is 3 pages each. '
i 10 I would also like to enter this into 11 the record as my understanding of whp we're convening 12 here today.
13 MR. DURR: For this point in time I'm 14 going to lay this aside for now because I see things I 15 in here that I do not recognize that were in your 16 letter of November the 12th. We'll come back to this 17 after we've gone through your initial November 12th I
18 letter because that was really the thrust of this 19 meeting.
20 MS. TRACY: Could I look at the 21 letter? Is that what you have right there?
22 MR. DURR: We have prepared our .
I 23 responses -- !
( 24 MS. TRACY: You're talking about our i
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( t 1 response to 87-077 g- 1 2 MR. DURR: Yes. That was the purpose 3 of the meeting.
4 MS. TRACY: The purpose of the meeting 5 was to deal with procedural questions which have not 6 been addressed in either 86-52 or 87-07.
1 7 MR. DURR: The purpose of the meeting 8 was to discuss -- and that's why we requested you to 9 send us in your November the 12th letter your 10 concerns that you wanted to discuss, so that we could 11 prepare and have the adequate staff available for 12 this meeting. That's why I'd like to gear it to your
'" 13 November the 12th letter. I assume the November the 14 12th letter contains all of your concerns.
I 15 MS. TRACY: At the end of the letter, 1G which is our response to your report, I list all the 17 different issues that haven't been dealt with yet.
I 18 MR. DURR: I understand.
19 We'll deal with your November the 1
20 12th letter because it should contain all those same 7
21 things.
22 MS. TRACY: It should. ;
j I 23 MR. DURR: Very good.
r, 24 MR. GREENSTEIN: Are there any copiec
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, 1 of the November 12th letter?
l-2 MR. DURR: There are, but I don't have 3 one with me right at this point. We can get you one.
4 MS. TRACY: It's the 87-07 response.
5 MR. DURR: Here. I'd like that back.
6 But for the purpose of the meeting, here's a copy.
I 7 With that, the first page of your 8 letter is an introduction, and the first issue that 9 we noted in there was a statement that says, i
10 "Biofouling discussed in b.oth the body of this report 11 and in Appendix A is a contention under litigation
, 12 before the NRC by the New England Coalition on ;
13 Nuclear Pollution".
14 That is a new issue. Biofouling has i 15 not been discussed in either one of the inspection 16 reports. It is, in fact, under litigation before the 17 Hearing Board, and it was presented by the t
10 Interveners. So we will not address that particular 19 subject, other than the fact to say that we have done 20 some preliminary inspections, and to our knowledge 21 biofouling has not been a problem at the Seabrook 22 Plant. But rather than preempt whatever the Hearing I 23 Board decisions are relative to biofouling because it
( 24 is an Intervener contention, we will not discuss that AREA-WIDE FEDERAL REPORTING, INC. (215) 925-5777
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I; J ! 1 in this particular meeting. It's outside of the t-i 2 scope of the meeting really.
3 MS. TRACY: I just would like to-point ,
4 out that microbiological 1y induced corrosion, 7 5 according to NRC documents that I've read, does fall 6 under the category of biofouling. i I 7 MR. DURR: Not true. They are 2 8 separate issues. Biofouling is one issue, and f 9 microbiologically induced corrosion is another issue. i i
10 MS. TRACY: Is caused by biofouling. ;
11 MR. RICHARDSON: We have been-treating .
,__ 12 them as related issues. !
h 13 MR. DURR: We understand that you 14 have, but we would like to point out to you that it's 4 15 inappropriate to treat those 2 as the same thing l 16 because they are different sources, different j 17 issues.
8 18 MR. RICHARDSON: They are still l 19 related.
, 20 MR. DURR: I have a technical 21 corrosion expert here, and within the technical ,
22 community they are 2 separate issues, and the NRC i
1 23 treats them as 2 separate issues. ;
7,
! , 24 MS. TRACY: Are you the expert?
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e 10 1 MR. GRAY: Right.
I 2 MS. TRACY: I am fine with that.
3 MR. DURR: So the biofouling 4 question --
5 MS. TRACY: We will defer. ,
6 MR. DURR: Because that's under 1 7 hearing. We would prefer not to discuss that. We 8 will be prepared to discuss MIC.
9 Your first question in your November 10 12th response in Section 1.3 -- ,
11 MS. TRACY: Excuse me, Jacque.
12 MR. DURR: Certainly. ,
13 MS. TRACY: I am concerned about our ,
14 timo limitations today, and I am also concerned that i 15 we do get to the programmatic issues which it was my 16 understanding that we were going to deal with. So I 17 would like at some point to have an assessment of how I
18 far we've gotten toward dealing with the issues. At ,
19 some point, say, in an hour or so we can renegotiate 20 perhaps.
21 MR. DURR: I would like to stay as !
i 22 much focused on your November 12th submittal as we I 23 can.
! 24 MS. TRACY: I'm referring to pages 17, 9 l l
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t 11' L ! 1 18 and 19.
i iJ 2 MR. DURR: We will make it to that. I 3 feel confident.
, 4 MS. TRACY: Because those.were the 5 issues that I felt we were down here to talk about 6 today.
7 MR. DURR: I would hope that we leave 8 here with no stone unturned.
9 MS. TRACY: I would be surprised, 10 MR. DURR: Moving on, Section 1.3, ,
11 paragraph 3, discusses programmatic weaknesses, poor 12 .uality q assurance / quality control, technical l I
13 training, et cetera. (A) under that says ongoing i 14 problems reflected in current NRC inspection reports I
15 up to October, 1987 show that even if programmatic 16 deficiencies were corrected before 1987, the problems 17 caused by those deficiencies are now built into the i
18 plant and are continuing to become evident. The l 19 programmatic deficiencies themselves are still 20 continuing and are being dismissed as isolated 21 incidents by the NRC.
22 We took that as a statement of l
' 23 opinion on your part. Are there any questions with
, j 24 that?
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f 12 1 MS. TRACY: These are issues we will 4
2 deal with later on. These are the programmatic 3 issues.
4 MR. DURR: That is a statement of 5 opinion on the ELP's_part. It's not a question. Is 6 that correct?
- 7 MS. TRACY: I would say'it's a 8 statement, yes. There is no question mark at the 9 end.
t 10 MR. DURR: With 1.3 what are your 11 specific questions that you want answered by the
, 12 technical staff?
13 MS. TRACY: Well, you have my list 14 right here. I would say that what is listed here --
f 15 MR. DURR: Let's stay with the 16 Novenber 12th document. We are familiar with that.
17 We have read it. We've all reviewed it. We know ,
i 18 what the direction of focus for your comments are, 19 and we are prepared to respond to those. So if you 20 could stay with that, it would make it much easier.
i ,
i 21 MS. TRACY: Okay. Programmatic 22 weaknesses are listed at the end of this report on i 23 pages 17, 18, 19 and 20.
( 24 MR. DURR: We will get back to those.
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.I 13 I : 1 Let's take them sequentially, if we can.
,eJ 2 MS. TRACY: Sure.
3 MR. DURR: Is there anything under 1.3 p 4 that you would like to discuss now that the staff is 5 prepared to respond to?
6 MS. TRACY: Do you have anything? You I 7 say you assembled your people here today.
8 MR. DURR: Yes.
9 MS. TRACY: Does anyone here have
(
10 something to say about 1.37 11 MR. DURR: We've said it all in the 12 inspection reports 86-52 and 87-07. We thought that 13 you had questions concerning these issues.
14 MS. TRACY: Yes. Quality assurance --
1 15 MR. DURR: That's why you sent this to 16 us. Are there any questions under 1.3 that you would 17 like to have the staff address?
f 18 MS. TRACY: Programmatic deficiencies 19 related to quality assurance / quality control, y
20 document control, design control and training. This 21 is what I wrote up in my proposed agenda for today.
22 If you want to deal with those issues that are I 23 mentioned briefly in 1.3, if you want to deal with 7,
- 24 them now, we can. If you want to wait until we get 4
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14 1 back to the Appendices where I list those issues in 2 more detail, we can do that too.
3 MR. DURR: I-think we're having a 4 communications gap.
.5 MS. TRACY: Not unusual.
6 MR. RICHARDSON: I'll start us off, if 7 you would like.
8 MR. DURR: Let me explain what I think 9 we're supposed to be doing here. You have specific 10 co-; erns.
11 MS. TRACY: Yes.
12 MR. DURR: Inspection reports 86-52 13 and 87-07 both dealt with these areas, and as far as 14 the NRC is concerned, it has been adequately 15 inspected and those issues are closed. We don't 16 intend to do anymore on those issues.
17 However, in your reading of those 18 inspection reports if there was comething in there 19 that technically you did not understand or that you 20 would like further clarification on, then I think we 21 are prepared to respond to that.
22 MS. TRACY: I understand.
I 23 MR. DURR: So using those 2 inspection i 24 reports as the basis for your questions, what in i
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! i 1 there technically did you not understand that you
(_ a 2 need clarification from the staff on? Because we 3 feel that a technically competent person reading
, 4 those reports would arrive at the same conclusions.
5 We are essentially the "technical arm" that inspects 6 those things, and we have looked at them and to our I 7 satisfaction they have been resolved. So what I need .
8 from you then, what specific questions do you have 9 relative to those paragraphs in those reports that i
10 you don't understand that you need clarification or 11 amplification on?
12 MS. TRACY: My point is, Jacque, that OJ 13 particularly dealing with Section 1.3 is that there 14 are programmatic weaknesses.
I 15 MR. DURR: Such as?
16 MS. TRACY: Such as problems with 17 quality assurance --
I 18 MR. DURR: Specifics, please.
19 MS. TRACY: The specifics are written 20 down in the document that I just passed around that 21 we can either deal with now, or we can deal with when 22 we get to where they're listed at the back of the 1 23 report. ,
7m 1
, 24 MR. DURR: You should have given us i
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1 all.that information back'in 1986, andawe ~ addressed 4
2 all that information in 1986 and 1987.
3 MS. TRACY: That's right.
4 MR. DURR: Specifically, other than a 5 general statement that you feel uncomfortable with i
6 quality assurance, what specifically don't you I 7 understand? ;
8 MS. TRACY: I understand that there 9 has been a breakdown in quality assurance / quality 10 control.
'\
11 MR. DURR: We can't substantiate that. >
12 MS. TRACY: That's because you have i
13 not looked.
i 14 MR. DURR: That's not a true i 15 statement. It's obvious from the 2 inspection
] 16 reports that we have l o o k .ed .
1
', 17 MS. TRACY: Jacque, you have told me .
I i 18 in our past meetings that your job is to deal with 19 technical issues. ;
20 MR. DURR: It is.
21 MS. TRACY: If I bring you something 22 and say there are specific welds in a specific area 1 23 which have been done incorrectly, you will go and I 24 attempt to look at them and attempt to see if they're i
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17 1 all right. If you cannot reach those welds 2 physically, you will look at the documentation. That 3 is a technical problem which you will resolve by 4 looking at the technicol information.
5 I have brought you other kinds of 6 information which you have not regarded as being 7 technical information. You, therefore, have not had 8 the techniques necessary to investigate whether these 9 charges are true or not. Those charges which I have 10 generally factored out into falling under QA/QC, 11 document control, design control and poor training 12 have not at any time been addressed to our ;
13 satisfaction, to resolve them to our satisfaction to 14 say that these were not a problem, particularly with 15 document control.
16 MR. DURR: Let me answer your question 17 before you get too far on. Let me interrupt you just ,
t 18 for a minute.
19 MS. TRACY: Yes.
20 MR. DURR: Our job is not to resolve 21 any issues to your satisfaction. They are to resolve 22 them to our satisfaction. That's what our Charter is 1 23 from Congress. We're the technical experts. I don't t
n i I i 24 know that you have any technical experts on your 1 l
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't 18 1 staff that have any vast experience in quality a
2 assurance / quality control, construction of nuclear 3 power plants. We are the technical experts, and it's 4 our Charter, i
5 No one individual makes that 6 decision. Our allegation process is such that a i 7 panel reviews what the inspection team has done, and 8 they determine that that is an acceptable 9 resolution. So if you expect the NRC to "satisfy" I
10 ELP, that's not our Charter. Our Charter is to ,
11 satisfy ourselves that there is no wrongdoing; that ,
12 the plant was properly constructed, and that's what 13 we have done.
14 So that's why I wanted to respond to i 15 that part because there is a misunderstanding on your r i
16 part. (
17 MS. TRACY: I don't think so, Jacque.
18 Let me say something. It's my understanding that you 19 all are public servants.
20 MR. DURR That's correct.
I 21 MS. TRACY: And that ultimately you 22 have to resolve these issues to the satisfaction, not i 23 just of yourselves, but of the Congress and of the I 24 public.
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i 19 i 1 MR. DURR: That's correct.
'. J 2 MS. TRACY: So in a sense what you 3 just said is not entirely accurate. You have to 4 satisfy the public to the fact that you are 5 protecting their health and safety, not just 6 yourselves, but the public. ,
7 I represent, not just the people who 8 worked at the Seabrook Nuclear Plant, but also to 9 some extent the public, and certainly Congressman 10 Mavroules does.
11 MR. DURR: We have been utterly 12 responsive to everyone's concerns. That is to say, 13 we have spent an inordinate amount of manpower in j 14 dealing with these issues. We have had focused, i 15 directed allegations presented by you which we have i 16 looked at specifically, and we have come up with 17 nothing. In all of these inspections we have not i
18 found anything that would indicate that there was bad 19 construction or cover-ups or anything of that 20 nature.
21 So at some point the NRC has to say 22 we are spending all these efforts, and we are not I 23 getting anything in return for it. We don't find any l'
r] 24 credibility in your statements because we have looked AREA-WIDE FEDERAL REPORTING, INC. (215) 925-5777
20 1 at your very focused, very specific allegations.
2 Even in the very specific ones we cannot find 3 anything the matter. So at some point in time we 4 have to start saying the credibility of these 5 allegations is such that at some point in time we i
6 have to disengage from this.
7 Now, we do not have to satisfy every 8 single individual in the community that that plant is 9 technically safe. We ' satisfy" the public through 10 the process, and that's what the licensing and 11 hearing process is all about. That's where the 12 public gets satisfied. If the public has valid 13 concerns or valid contentions, then the process is 14 set up such that they can be heard. Nobody, other .
15 than a few people, have taken that route to present ,
16 their concerns, and those concerns are being 6
I 17 addressed in that forum, and they will be. The ;
18 process is set up so the public can be heard 19 throughout this whole thing.
20 Now, when you come in with I
21 allegations, that's a different process, and that '
22 process says that we will inspect and satisfy 1 23 ourselves that there is nothing wrong with the plant, ,
I
. 24 and that's we are doing here. Now, if you have other I
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t-21 is i 1 concerns that you want to run through the other
,eJ 2 forum, that's where you can be heard. So the NRC, I 3 think, is being very fair in this respect; that we !
4 are taking the concerned citizen at your level 5 outside of the formal process, and we are pursuing 6 your concerns.
7 MS. TRACY: That's very generous of
. 8 you, Jacque.
9 MR. DURR: We only have to pursue them 10 to the extent that we feel that the plant is saf- l 11 MS. TRACY: I think Mike has 12 something to say.
13 MR. GREENSTEIN: I would just like tt 14 interject. I think that we're getting off on the 4
15 wrong track, and we're talking about philosophy, 16 rather than dealing with specifics. ;
)
17 MR. DURR: That's correct. :
I 18 MR. GREENSTEIN: There are a great 19 many specific allegations that have been raised that f
,, 20 the Congressman is aware of and is concerned about.
21 MR. DURR: Certainly.
22 MR. GREENSTEIN: That's the reason why
- 1 23 I am here today. I would like some of those specific 1
. 3 24 allegations to be addressed.
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1 MR. DURR: They will be, whatevet is f
2 in this November 12 letter.
3 MR. GREENSTEIN: The Congressman is on 4 record, along with a number of his colleagues,.in 5 asking for an independent investigatien.
6 MR. DURR: I understand that.
7 MR. GREENSTEIN: The NRC in its wisdom '
8 saw fit to reject that request. In that light, the ,
9 Congressman, who believes that evacuation is ;
t 10 impossible, is committed to getting answers to all of
~
11 the allegations that are raised by the ELP. It's 12 important that those allegations be thoroughly
, i 13 addressed, at least to the Congressman's 14 satisfaction. !
15 jt So rather than discuss philosophies 16 here, if we could get down to some specifics. It 17 strikes me that this first statement is an umbrella !
i 18 statement under which there are dozens and dozens of ;
i 19 specific allegations that can be raised.
l l
20 What I would ask Sharon and Doug to 21 do is, to start with the first step. Let us identify
, 22 an allegation. Let's put the allegation on the i 23 table, and let the technical expertise of the NRC 24 come into play.
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23 N '
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! 1 MR. DURN: And_that'c the direction we i-J 2 are trying to head in.
That',s the point I was trying r, .
3 to make earlier. .,- ,. ~
g 4 We have looked at these issues that 4 5 you have se'nt us. We have read through them and a ;
6 we're prepared to address them. ,
You just have to i cme point the NRC has decided 7 understand that at 8 that-they have done enough ur. der the quality
~
9 assurance / quality'c'ontrol aspects, and that you have ',
,f 10 not given ussenough specifics that we can go out and .
~ -
~
l
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11 find anything t!ie hatter with it. We have our own c _=
^
12 inspection record ,that e.3sentia11y tells us that the f
i i quality assuiance/ quality control program was
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13
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14 functional and~did exist. Were there isolated cases?
II 15 Certainly. There3alwEys will be. That's human 1
~...
16 error. You can't design out that. But we feel that 17 that particular issue'h,as bhen adequately addressed.
l t s 18 Now, do you_ have any specifics in i 19 this atha that you want to d i s es.ss?
i .
' s^
, 20 MS. TRAC (I Yes, I do.
21 MR. DURRt Please do.
22 MS. TRACY: All right. Let's start i 23 with the is'sud raised byJScott K e n'n e d y in our April
-, /' . ,
, 24 meeting lasy. year - ~rdtry - ,this year. April, 1987
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24 1 it was. He raised the issue that the legs on the t
2 pumps that run from the pumo to a pipe into the 3 reactor; that the legs -- one leg on each pump was 4 put in an incorrect position according to the 5 design. In discussing with him his reaction to your 6 report, he mentioned that.you said what had happened 7 to 4 of those legs -- there are 12 legs altogether 8 involved in this. Le would like to know what 9 happened with the other 8 lega. He would like more 10 specific information on how you reached your 11 conclusions that the ch nge in design allows for the 12 safe operation of the plant. He would like to know ;
13 if the pumps were moved, and he would also like to 14 know if this change in design vill result in i t 15 preraature bearing wear for the pumps.
16 MR. DURR: What does that have to do 17 with this first issue, 1.3?
I I 18 MS. TRACY: This is one of the ;
)
19 problems with design control.
i 20 MR. DURR: Design control? '
21 MS. TRACY: Yes.
4 1
22 MR. DURR: It was a specific f 23 allegation concerning the pump, and that really ought l
l' 24 to be a separate issue because it's an isolated l
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f 25.
(
1 case. But I think'we are prepared to address it.
- LJ 2 The fact is, I think that was all fairly much
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3 discussed in 87-07. Was it not?
4 MR. MANOLY: Yes.
5 MS. TRACY: Jacque, I think we have a 6 problem because 1.3 is very general. As Mike said, 7 it's an umbrella statement. It encompasses many many 8 issues that you have looked at to some extent, and 9 some-of which you haven't, and some of it which you 10 have touched on a bit. I think that each issue that 11 I raise which falls in my mind under the broader 12 problems --
LJ 13 MR. DURR: It can, sure.
14 MS. TRACY: -- and you will find a j 15 technical issue that you may or may not have dealt 16 with. This particular issue falls under what I call 17 problems with design control. It was not built 18 according to the design of the plant, and then I am 19 asking specific questions within that concern.
20 MR. DURR: Sure.
I 21 MS. TRACY: We have other concerns.
22 We have them here.
I 23 MR. DURR: You need to understand, 24 Sharon, that's one of the reasons why we feel that 4
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i c 26 1 there is not any basis for this quality assurance /
2 design control concern. Because in each insta: ice tne 3 specific that you have given us, such as the pump, we 4 looked-at that. We looked at it in depth. Kamal 5 Manoly looked at it. He's a qualified structural 6 mechanics engineer. He understands the design. He was 7 a designer for an AE. So he knows that area. He has 8 looked at it, and he has determined that there is not 9 a problem there; that it was appropriately 10 dispositioned. So from the quality assurance / design 11 control perspective we found it was not a problem; 12 that it was adequately controlled; that it was i
13 controlled within the confines of the procedures that 14 they had there.
15 So, therefore, from a quality 16 assurance aspect or design control we have no concern 17 because it was handled the way it was supposed to 18 be. From the technical --
is the pump okay, and are 19 the supports the way they are supposed to be, we also 20 came out of there and we didn't have a problem 21 because we went back all the way back to Westinghouse 22 to get the information concerning -- and that was i 23 off-site. That was the constructor of the --
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27 t 1 MR. DURR: The NSSS vender that built 1
,3 .
2 the thi.79 They designed it. We went all the way 3 back to them and looked at their calculations, and we
?
4 came away and we didn't have a problem. So what 3 specifically in that pump concern do you think 6 creates a design control question?
7 MR. MANOLY: Did you read the response 8 1.6 the reports?
9 MS. TRACY: Yes. ,
10 MR. MANOLY: Did you understand what 11 was in there?
12 MS. TRACY: I generally understood j 13 what was in there.
14 The person who brought the concern
' 15 up, do you recall Scott Kennedy?
16 MR. MANOLY: Yes.
17 You are repeating the same thing that i
18 wsa already answered here. ;
19 MR. DURR: If you remember, I asked 20 him point blank in that interview, was this an 21 allegation. He said no. It was just a concern, and .
22 he'd really like to know how it turned out. We said, f 23 sure, Scott. We'll look into it. We recognize it's 7
i i 24 not an allegation. Do you remember that? He I
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f 28 1 specifically slid in his transcript that's not an 2 allegation.
3 MS. TRACY: Jacque, you pulled a fast 4 one on poor Scott. He did not know what you meant.
5 He did not understand. There are semantic 6 differences. But we're getting off the track again.
7 Let's deal with some specific questions.
8 MR. DURR All right. Give me the 9 specific questions.
10 MS. TRACY: I take it you feel, Kamal, 11 that the questions that I just raised have been 12 answered in 87-07?
13 MR. MANOLY: Yes, on page 52 in the 14 report.
i
~
15 MR. RICHARDSON: I had some questions .
i 16 about your response to this here. Leaving aside i 17 whether we have a programmatic issue here or not, 18 dealing strictly with the technical aspects of it, 1 19 maybe it's out of place right now, but we may as well ,
1 20 get it over with. I 21 First off, my understanding of the 22 original question was that one leg on each of the
23 steam generator supports had had to be relocated at l
24 its base in order to clear some interfering piping, I AREA-WIDE FEDERAL REPORTING, INC. (215) 925-5777
t~ i 29 ^
{
j
, F1 1 and that Mr. Kennedy's concern was that because of-
,;a- l 4
2 the way the relocation was done that that leg would l 3 drop as the system was heated up. Whereas the other !
1 4 2 legs would rise because of the pipe connecting the i 5 reactor coolant pump to, I guess it would be the reactor vessel, because of its expansion. !
6 And in his 7 preparation for that he did the sketches that we 8 received at the April meeting.
9 Your answer to the question doesn't ,
10 make an awful lot of sense in a couple of areas. In 11 your discussion on page 52 of 87-07, just below the ;
12 center line of the page, you go into some description .
I i !
j 13 of the maximum pump flange rise at operating l l 14 conditions, maximum rise in the columns, and the fact t i
15 that the pump as installed was level.
- The pump was I
16 installed, we can assume, cold. You described the i r
l 17 rise of the pump flange, but you make no reference at i j 18 all to whether it will remain level when_it rises, 19 whether, if it does not remain level, that will or
, 20 will not put an unacceptable stress on the piping I
! 21 associated with that. i l
j 22 Also, it's my understanding that when l l
58 23 you're dealing with a rapidly rotating piece of i 24 equipment, ideally you want it to remain level in l
?
I l
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30-1 order to prevent an uneven load on bearings and I I
2 subsequent premature bearing wear. So I am concerned 3 myself with whether you have adequately addressed the ,
4 question of will the pump remain level when the 5 system is heated.
6 MR. MANOLY: Did you read page 52 of 7 the report?
8 MR. RICHARDSON: Yes.
9 MR. MANOLY: Maximum postulated pump i
10 flange rise at operating transient condition is 100 11 mils. ;
} i 12 MR. RICHARDSON: Yes, but you haven't [
13 addressed the question of, is it level.
14 MR. MANOLY: The maximum permitted i 15 rise of RCP support column during modification was 40
{
16 mils.
7 17 MR. RICHARDSON: Can you explain how i i( !
18 that answe:s the question?
19 MR. MANOLY: That means after heating ;
j, 20 up, after the pump operates it's not going to exceed l 21 the 100 mils that the original design intended to 22 have.
1
! I 23 MR. RICHARDSON: I'll show you 1
{ 24 Mr. Kennedy's sketch here. His understanding of the j s
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! I way the modification was done was that 2 legs had
,L_
2 been designed to rise from a slope toward the reactor 3 vessel to a vertical position.
4 MR. MANOLY: Uh huh.
5 MR. RICHARDSON: And that because the 6 third leg at its base had been moved toward the 7 reactor that it would then be as installed cold, 8 sloped away from the reactor, and as the piping to 9 the reactor vessel would expand that that slope would 10 increase, and thus the side of the reactor coolant 11 pump which is supported by that leg would drop while 12 the opposite side would rise.
'" 13 MR. MANOLY: The weld was not 14 performed on the pipe end until after the 15 installation of the modification of the leg.
16 MR. RICHARDSON: It doesn't matter.
17 MR. MANOLY: That's what matters to 18 me.
19 MR. RICHARDSON: No. If the system is :
i
, 20 cold, you're going to have it in its as-installed l l
21 position, and up through the final weld it's going to l 22 be perfectly fine, but as you heat it up, as this i l
3 23 pipe expands, the back 2 legs are going to come to a I
, 24 vertical position and they will rise.
l l
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1 4
32 '
1 MR. MANOLY: They are allowed 100 mils e
2 to rise.- '
3 MR. RICHARDSON: Yes. That's not the 4 concern.
5 MR. MANOLY: It is the concern.
6 l MR. RICHARDSON: No. I'm not saying I 7 that that's unacceptable. The concern is that the 8 third leg, which is installed at an angle heading !
9 away from the reactor, as that pipe expands, the top i l
i I 10 of that leg is going to move farther out of plumb, ;
I 11 and this is going to result in the inner side of the 12 reactor coolant pump dropping, as opposed to the 13 other side of the reactor coolant pump rising. So 14 that as the system is heated up -- this wouldn't be ,
j i 15 expected to show in a cold condition. As the system i
l 16 heats up, that pump is going to cock out of level.
) 17 MR. MANOLYi When the system heats up, ;
i 18 the pipe will take a distos:ted position or deformed 19 position.
20 MR. RICHARDSON: Yes. He's calculated ,
4 21 in for that. His concern was whether that was 22 acceptable.
i I i 23 MR. MANOLY: The position of the i i
I 24 piping at the pump flange allowed, based on code I
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t !
33 i i
1 limits, is 100 mils. Oxay. That's what we are T-]
2 saying in the report. When you look at the stress 3 level in the piping-in the heated condition, it's not 4 going to be heightened with the allowed code limits 5 of 100 mils.
6 MR. RICHARDSON: Then ehe 100-mils 7 limit would be acceptable when it is hot as well? -
8 MR. MANOLY: Yes.
9 MR. RICHARDSON: Mr. Kennedy I
- 10 calculated that the deflection that would be caused i
11 when the pump was heated up is 125 thousandths of an l 12 inch, 1/8 of an inch.
i 13 MR. MANOLY: The numbers that the pump o
14 legs were shifted is listed in the second paragraph l 15 of the report on all 4 pumps. If you look at the 16 numbers you see 2 inches --
l 17 MR. RICHARDSON: The numbers don't add i
, 1 i
18 up either. '
19 MR. MANOLY: These are the true l l
, 20 numbers. These are numbers that were changed for the 21 movement of the leg. The highest angle of change was ;
22 2.33 degrees. '
l I 23 MR. RICHARDSON: How does that affect '
7 I
i 24 your --
i I
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34 1 MR. MANOLY: I just told you.
2 MR. RICHARDSON: What you are saying 3 is that his numbers here are not correct. Is that
. 4 right?
- 5 MR. MANOLY
- The numbers that you have ;
J 6 in the report are the correct numberc. i 7 MR. RICHARDSON: That's a matter of 8 concern to me too. They don't appear to me to work 9 out properly.
I 10 MR. DURR: Wait a minute. How did you 11 arrive at that conclusion? I 12 MR. RICHARDSON: Basic triegonometry. l 13 MR. DURR: What are you basing that 14 concern on?
i 15 MR. RICHARDSON: I am about to explain i l 16 it to you.
17 MR. DURR: All right. i I
j 18 MR. MANOLY: Some of these numbers are i
19 pretty close to ours. You have 5 and 1/4 and 5 and ,
I 20 3/8.
21 MR. RICHARDSON: Yes. That's why I'm ;
I 22 concerned. The numbers are close enough to be !
t 23 accurate for purposes of discussion, i
( 24 His design drawing, how this piece of 4 !
1 AREA-WIDE PEDERAL REPORTING, INC. (215) 925-5777 l
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- e.
35 i
i 1 ~ equipment was supposed to originally have been
.-J 2 installed, shows a position as these legs are 3 installed approximately 2 inches off of plumb leaning 4 toward the reactor vessel in a-cold condition. Is 5 that accurate?
6 MR. MANOLY: That number is irrelevant 7 here.
8 MR. RICHARDSON: No. It's not-9 irrelevant.
10 MR. MANOLY: It does not pertain-to 11 what we are talking about.
12 MR. RICHARDSON: It does indeed.
LJ 13 MR. MANOLY: The concern we have is 14 the movement of the lege.
15 MR. RICHARDSON: Yes. That's why the 16 number is relevant.
17 MR. MANOLY: The movement of-the base, i
18 that's what is important to the issue, because what :
1 19 you do, you change the angic of the face of the pump.
, 20 MR. RICHARDSON: That's precisely what 21 I'm concerned about.
22 MR. MANOLY: That's the only thing i 23 that's changed in here, the leg movement. I 24 MR. RICHARDSON: But the question is i
AREA-WIDE FEDERAL REPORTING, INC. (215) D25-5777
I 36
, 1 that the numbers you are using don't appear to me to a
2 work out right. Let me explain. For a design figure 3 you've got 2 inches offset at the top of the leg from 4 the bottom.
5 MR. MANOLY: I didn't_say that.
6 MR. RICHARDSON: The first question ,
t 7 I'm asking is, is this accurate.
8 MR. MANOLY: No, it's not.
9 MR. RICHARDSON: What is the correct i
10 figure? e 11 MR. MANOLY: That number, he had no 12 way of knowing how much that point moves rel'ative to 13 the vessel.
14 MR. RICHARDSON: I would assume -- -
4 1 15 MR. GRAY: Can we take a break on this j 16 question for a second? I'd like to back up to the t 17 original question. The original question from ;
i 18 Kennedy was, I have a concern about what happened to i
- 19 the pump after I left. You have a concern as to l
20 design control. This is an example of design i ;
) 21 control.
22 MR. RICHARDSON: Yes, it is.
' 1
( 23 ---
l l
( 24 (Mr. Wiggins is not present at this time).
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4 37 l
i 1
> l' 2 MR. GRAY: The components could not be ;
3 constructed in accordance with the original drawing.
4 As a result of that, the modification was made. The 5 information from this modification was worked on by 1
6 Westinghouse, who reviewed the projected changes, and 7 then reviewed the effecte of those changes. This is 8 an example where design control is -- or was done properly.
10 Exactly the details of these numbers 11 and things is a different issue entirely. The fact 12 is that Westinghouse, the NSSS supplier who has the
- I 13 responsibility for the pump, was involved in the 14 description of the problem, the construction in an l 15 attempt to install this, and was involved in the 16 resolution of the problem. This is not an example of 17 a design control problem.
18 MR. DURRt The fact is, it's an 19 example of design control working the way it's !
I 20 supposed to.
21 MR. MANOLY: The numbers you see in l'
22 the report are numbers that were recorded after the 1 23 change was made. That's what the analysis was based i ~7 24
, on, the modified location of the piping in the I
i AREA-WIDE PEDERAL REPORTING, INC. (215) 925-5777
t 38 1 as-built condition.
t 2 MR. RICHARDSON: Aside from the 3 question of whether we have a design control problem 4 here, I'm particularly interested myself in 5 addressing the question I have, which is that I-feel 6 that your analysis may have failed to take into 7 account the question that Mr. Kennedy originally 8 raised. What I was trying to do was to discuss it to 9 the point where you can explain to me why your 10 numbers do work because on the surface it doesn't 11 appear that they do. If this is a matter that would 12 best be left to later on in the day, I have no 13 problem with that, but it looks like it's going to 14 take quite awhile to discuss. I do want to go through 15 it completely.
16 MR. DURR: You're extrapolating, and 17 that's not the way the systems works. Mr. Kennedy 18 had a concern which is very clearly stated on page 50 19 of the inspection report. We took that concern 20 verbatim, and we addressed that concern. We assumed 21 that to be an' allegation, although he clearly stated 22 it wasn't. We addressed it. We addressed the 23 question that he asked. Do you agree that we 24 addressed the question that he asked?
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39 ,
( 1 1 MS. TRACY: He feels --
g lJ 2 MR. DURR: That only requires a yes or 3 a no.
4 MS. TRACY: He feels that there is 5 some --
6 MR. DURR: Additional question.
I 7 MR. RICHARDSON: I feel you did not #
8 address this question.
9 MS. TRACY: Would you like to know l t
10 exactly what Mr. Kennedy said?
11 MR. DURR: I know exactly what he .
, 12 said.
~~
13 MS. TRACY: He said that you have 14 given an answer to the question, but not "the" 1 15 answer. That was what Scott Kennedy told me the 16 other night on the phone when I e.sked him how he --
17 that answers your question.
I 18 MR. DURR: We have his question very i 19 clearly set forth during the interviews of April the
, 20 20th, and a qualified engineer -- are you a qualified 21 engineer, sir?
22 MR. RICHARDSON: No.
I 23 MR. DURR: A qualified engineer, who
_, a
, 24 is experienced in design, stresses, calculations, and i
AREA-WIDE FEDERAL REPORTING, INC. (215) 925-5777 ;
i 1 40 1 knows how to do these things, looked at this. This i
2 man is just short of having a Ph.D. in the area that 3 we're talking about. He has a Master's Degree for 4 sure. ;
s Now, he is thoroughly competent and 4 6 qualified to look at this technical issue and :
7 determine if it's adequate, and he has done that, and 8 in his professional opinion -- he's a Professional 9 Engineer, Registered Professional Engineer. In his 1
10 opinion, in his technical judgment this is-adequately 11 resolved.
I i 12 Now, once you have an allegation and ,
13 you address the allegation, we don't want to get into
{
14 the mode where now you are going to second and third '
, I is quarter iterate that from that. That's not an ;
16 allegation. That's your technical concern. If it l 17 turns out to be an allegation, we'll try to l
18 accommodate that. I want you to understand that you, ,
i l 19 sitting down with information after the fact and not i,
20 having any prior knowledge, other than what you have
- 21 garnered from Mr. Kennedy's discussion and from our j J
22 inspection reports, really throws into question your l1 23 ability or your right to make these concerns and
{ 24 these added --
1 ll 1
aux-mE n nRat ne uIn , In .
(213( 925-syyy-- j i
f
.s.
41 r1 1 MS. TRACYt Excuse me, Jacque. Does ;
, 3.J- !
1 2 Scott. Kennedy have the right toLeome back and ask you ;
r 3 that question? i 1
i ,
', 4 MR. DURR Mr. Kennedy has-an- !
i .
! 5 allegation which we originally addressed here. If he !
L 6 has additional. allegations that.he wishes to make t o. j j 7 the NRC --
l'
[ 8 MS. TRACY: Regarding this? '
e 4
9 MR. DURR: We will be happy to 10 entertain them. !
11 MS. TRACY: If he has additional i
!, 12 questions -- !
l 13 MR. DURR: If he has additional l !
14 questions, we may not answer additional. questions l 1
1 15 because they are just questions. We are not here to !
16 ecucate the public in engineering. ;
i !
- 17 We are here to protect the health and j li i
18 the safety of the public, but we do not have the time )
19 or the wherewithal to answer every question that the t
l, 20 public has. Because what we'd have to do is send 1 i j 21 them to college to get them enough background --
j i- !
I 22 MS. TRACY: I think we're getting off !
i !
II 23 the track again. l
) 7 I 4
I i 24 MR. DURR: Yes. !
I i i ;
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i I 42 1 MS. TRACY: I_have a procedural y 2 suggestion. You have called in certain of your ~
3 experts to deal with particular issues that were l 4 raised in our response to your report. Some of them !
5 are under time constraints and have to leave. Mike 6 has some concerns as well, and he is also under a 7 time constraint. What I would like to suggest.is, [
8 you have come to this meeting and your people have l 9 come prepared to deal with specific issues. I think [
i 10 you probably have some, and so forth and so on. >
I 11 MR. DURR: Yes. l 12 MS. TRACY: I would suggest that i
13 instead of asking me to raise questions which are all 14 listed here in the paper that I passed out, that we !
i 15 deal with the issues that your people came here to l
16 address. l t
17 MR. DURR: Certainly.
I 18 MS. TRhCY: And then we go on, just so j 19 that people don't have to sit around and listen to l l
20 discussions that may not concern them.
21 MR. DURR: That's why I'm trying to l i
22 get past 1.3. !
l
't 23 MS. TRACY: Then we can go on to the f
\
1 24 issues that I came down here to address. j t _
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't 43 i r
I F1 1 MR. GREENSTEIN: I sense that there is *
!,LJ 2 an adversary-atmosphere in this room that isn't 3 necessary.
l, 4 MR. DURR: That's true. I agree. l l
l 5 MR. GREENSTEIN: It's really being 6 destructive of what this meeting is all about.
7 Obviously there is disagreement. Let's accept the 8 fact that there is a disagreement, and let's try to 9 put the questions on the table and have some answers 10 to the questions without any argument. You are being 11 a tad bit legalistic, Jacque, which is also clouding 12 what we're trying to do here.
'~~
13 MR. DURR: I understand that. But 14 you've only just arrived. We've been dealing with 15 this since 1984, and specifically with ELP since 16 1986, and we have not had adversarial relationships l 17 in the past. But at some point we, the NRC, have to 18 make the point that we cannot go on ad infinitum with 1 19 this thing, and we will not go on ad infinitum with l 20 it. I 21 At some point, if you can establish 22 your credibility - giving us the allegation that ,
t 23 says this is wrong, and we can go out and find that
-, l i , 24 that is, in fact, wrong, now we've got something to 9
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1 deal with. We've spent over 1000 man hours turning 2 over every rock out there, and we cannot find -- we 3 cannot substantiate anything that you say.
4 MS. TRACY: Can we get down to brass 5 tacks here?
- 6 MR. DURR
- Let's go beyond 1.3, and ;
7 we'll come back to that.
8 MR. RICHARDSON: Let's not just yet.
j 9 MR. DURR: Let's get into the 10 technical, and get out of the programmatic stuff. ,
j 11 MS. TRACY: But with the agreement i 12 that we will deal with the programmatic issues. l i .
13 MR. DURR: We will come back to it. [
f
, 14 MS. TRACY: All right. !
l t 15 MR. MANOLY: Do you have anymore 16 questions?
17 MS. TRACY: Are you under a time i
{
18 contraint, Kamal? Are you going to be around?
- 19 MR. MANOLY: Yes. I am going back to 20 Washington.
l' l 21 We looked at all 4 pumps. He t 22 mentioned only one. I looked at 4. The numbers in 1
lt 23 here are the offsets that were applied to all 4 l
' 24 legs. Only one leg that's close to the reactor was lt AREA-WIDE FEDERAL REPORTING, INC. (215) 925-5777
45 F1 1 moved. So he mentioned one. I look at all 4 of
,LJ i 2 them, and that's an evaluation for all 4 of them.
3 MS. TRACY: And you looked at all 12 4 legs, not just the --
5 MR. MANOLY: What. counts is the one 6 that was moved.
7 MR. RICHARDSON: What counts is the
] 8 one that was moved.
J 9 MR. MANOLY: Each pump has 4 legs for [
10 support. The one that moves, that's the one that 11 counts. i 12 MR. RICHARDSON: 4 or 3?
'" 13 MR. MANOLY: 3. I'm sorry.
i
, 14 MS. TRACY: So you looked at the leg 15 on each pump that had been moved. t i
IG MR. MANOLY: Yes. That's what's 17 important because you don't want to have the pipe -
- 18 installed in a rotation erceeding what is allowed by l
j 19 the manufacturer. When they did the relocation of
- 20 the leg, they monitored the levelness at that 21 process.
22 MR. RICHARDSON: During construction?
23 MR. MANOLY: Yes. They monitored it.
3 [ 24 MR. RICHARDSON: That wasn't the s
1 AREA-WIDE FEDERAL REPORTING, INC. (215) 925-5777
i 46 1 question --
2 MR. MANOLY: Wait. My concern, I want 3 to see the pipe installed with initial rotation on it 4 exceeding what the NSSS required, and what we found 5 is that the NSSS required a maximum of 40 mils. It 6 did not get there. 100 is the maximum allowed under 7 hot condition. The NSSS said they didn't want it to 8 exceed 40 mils during installation, and to maintain 9 levelness to remain under 40 mils during erection, 10 and they maintained that. That's what's a concern to 11 me.
12 MR. RICHARDSON: Our problem is, 13 however, that Mr. Kennedy's concern was with the pump 14 comaining level when the system is heated, not the 15 construction.
16 MR. MANOLY: No. When the pump is 17 heated, it can tolerate up to 100 mils of rise.
18 MR. RICHARDSON: Okay. Can you 19 translate mils into decimils? We're talking 10 20 thousandths of an inch?
21 MR. MANOLY: .l. !
t 22 MR. DURR: .1 inches.
I 23 MS. TRACY: So what you're saying is I
( 24 that according to the NSSS requirements that the pump l l
l l AREA-WIDE FEDERAL REPORTING, INC. (215) 925-5777
1 47 will remain adequately level, both when it's cool and g.
{-] .
1 2 when it's hot.
3 MR. MANOLY: When it's hot, it's 4 supposed to rise, yes.
5 MR. RICHARDSON: It's supposed to 6 rise, but stay level.
I 7 MS. TRACY: But it will stay level 8 when it's heated, as well as when it's cool. There 9 won't be any tipping.
I 10 MR. MANOLY: The tipping concern is 11 only important a9 it induces stress on the piping, 12 and the piping was evaluated in the as-built ai condition, and the stress limits were within the code 13 14 limits. That's all we care about. There is no such ;
I 15 thing that, well, if it's not level, that's something 16 of concern to whoever. But what you care about is 17 the pipsng stress. I l l 18 MS. TRACY: Bearing wear. If the pump l
19 isn't level whether the bearings in the pump will be 20 worn unevenly as well. That's also a concern if the 1
21 pump doesn't remain level. ,
l 22 MR. MANOLY: I understand what he's I 23 saying. But the issue that he raised in the last w'
g_; 24 meeting was about the stress of the piping, and I l
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'l.
n l 48
- i i.
I think we addressed that. We told you what the stresc j 2 levels were before and after. I 3 MR. RICHARDSON: Mr. Kennedy's figures l 4 indicate that he calculates that the pipe going to
, 5 the reactor vessel will rise approximately 125 l 6 thousandths of an inch. j I l 7 MR. MANOLY: There is no way that he l 8 can compute that. You know why? These numbers are i
9 arrived to from a computer analysis. The only way he
]
10 can really know is to look at the model and see what c
11 the results are. There is no way, with the geology ,
12 of the piping and the temperature of the transients ;
I i 13 it's going to go through that he ca'n estimate how l 14 much it's going to rise. ;
- 15 MR. DURR: You have to understand that !
16 the pump and the piping is moving, but also the !
l j 17 reactor vessel itself is moving. You've got relative 18 motion between all of these things. So when you heat i 1
) 19 up the reactor pressure vessel, it grows also. So l 1 :
20 everything is moving.
f
- 21 MR. RICHARDSON
- It would be bowed d
22 more or less. 4 I( 23 The question I had about your figures ;
I 24 on the placement of the legs, Mr. Kennedy's sketch ;
l l i :
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I l
49 I shows the pump as originally installed to have legs f
}
2 set at a slight angle off perpendicular, leaning l l <
3 toward the reactor vessel, so that as the pipe i
4 expands, the reactor coolant pump will move outward 5 and the legs will come up to perpendicular. Is that .
6 the correct intent of the design? f f 7 MR. MANOLY: The pipe will mov9, yes. l 1
8 MR. RICHARDSON: His sketch of the ;
9 as-built condition shows the leg closest to the 10 reactor vessel.having been moved in order to clear i 11 the -- !
i 12 MR. MANOLY: Interference. l 13 MR. RICHARDSON: --
the piping behind >
14 it. That the bottom leg was moved approximately 5 I i
15 inches toward the reactor vessel. !
16 MR. MANOLY: That's a final 1
17 adjustment. It already had slope in it.
18 MR. RICHARDSON: In which direction 19 was its original slope?
20 MR. MANOLY: You did not really read 21 my report. It moves the amount of 2, 2, 1 1/2, and 1 22 3/4, not 5. That's the final offset.
23 MR. RICHARDSON: The problem is it's r, '
__, 24 in the other direction.
AREA-WIDE FEDERAL REPORTING, INC. (215) 925-5777
50 1 MR. MANOLY What other direction?
2 MR. RICHARDSON: Your original design, l
3 if this is correct, would have called for all 3 legs i 4 to be slanted toward the reactor vessel at the top.
5 Let's take the figure of 2 inches fi 6 because that's what he had here as the design. Now, 7 if you move this leg to get to a position where 8 you're 5 1/4 inches toward the reactor vessel from 9 the pump, then you can move that leg a total of
! 10 closer to 7 inches, not 2.
11 MR. MANOLY: No. That is not 12 correct. The columns are moved by 2, 2, 1 1/2, and 1 13 3/4.
14 MR. RICHARDbON: How do you get from 2 l
l 15 inches farther away from the reactor vessel to 5 l
l 16 inches clocer to the vessel?
l 17 MR. MANOLY: They already had 3 and '
18 some numbers. It was 5 and 3/8, 5 3/8, 4 7/8, and 4 [
l 19 15/16. You substract the 2, 2, 1 1/2, and 1 3/4 from 20 the final numbers. That was the original offset.
1 21 MR. RICHARDSON: Then your original {
22 offset would have to have been with the legs at the )
23 bottom, closer to the reactor pressure vessel. That 24 doesn't match his design. That doesn't match *he l AkEA-WIDE FEDERAL REPORTING, INC. (215) 925-5777
^^
1a 51
/
r l 1 drawing F.hSt---Mr. Kennedy p0.i in his question to you,
. J -
2 which I~have,to, assume'was based on design drawings.
3 He appears to b.c' competent enough, knowledgeable 4 enough to ha.vc. --
5 M R' . MANOLY: He was a surveyor.
6 MR. RICHARDSON: Yes. He would have 7 had access to design drawings as necessary.
F MR. MANOLY: No. He would not have
., access. The surveyors, all they use is the surveying 10 drawings that was given to him to work with.
11 MR. GREENSTEIN: For the record, can 12 we identify who this Mr. Kennedy is?
13 MR. DURR: Mr. Kennedy was a 14 surveyor. We've'got the original transcripts. He 15 was a surveyor working'in the reactor building, and 16 he was aware that this occurred. He never saw the 17 end of this evolution. He saw the beginning of it. He 18 knew they.ha to move tlie feat, but he did not know 19 what the resulth were. He moved on to a6meplace else 20 before they finilhed it. He was concerned as a 21 concerned citigen, He was interested in finding.out ;
rislults.
22 what were.the final '
23 '
MS.'TRACY: He-was c~oncerned that the j 1
_g 24 way that thd legs h$b be'en placed -- -
it was different !
n ;
^ , ..- .,
l s %--
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52 1 from the original design -- would place undue stress 2 on the pipe.
3 MR. GREENSTEIN: Is that a fact? Were 4 the legs placed differently than as designed?
5 MS. TRACY: Yes.
6 ;MR. MANOLY: Yes. The legs were moved, 7 the modification on the legs.
8 MR. DURR: Let's clarify that. There 9 was-a design change from the original design. It's 10 not that they were placed differently than they were 11 designed. They were put where they were supposed to 12 be in the final design. It was a design modification 13 or a design change.
14 MS. TRACY: He had raised the issue, i 15 perhaps with you, Tony, I'm not sure, when he was at 16 the plant.
17 MR. CERNE: Yes.
18 MS. TRACY: And he had felt that the 19 response didn't really satisfy.him. So he went to 20 Representative Hilt, his representative in 21 Massachusetts who raised this issue and brought it to 22 us, and eventually we all got together.
23 What I would like to do is to convey 24 what you have had to say at this meeting and the I
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53
! ! 1 discussion that will turn up in the transcript to ;
.J 2 Scott Kennedy because he was the one who asked me to 3 raise this issue again, and perhaps he can even_give 4 you a call in Washington or wherever you are, if he 5 wants to talk to you about it further. Would that be 6 okay?
7 MR. MANOLY: Yes.
8 ---
9 (Ms. Gentleman is now present at the meeting).
10 ---
11 MR. DURR: We need to add one more )
12 person to the record. For the benefit of everyone 1
13 here and Mary Beth, this is Mary Beth Gentleman.
14 You are from the --
)
I 15 MS. GENTLEMAN: Executive Office of I l
16 Energy Resources, State of Massachusetts.
i 17 MR. DURR: So she knows who everyone l t '
18 is, we will identify ourselves. I'm Jacque Durr. I'm 19 Acting Deputy Director of Division of Reactor Safety.
, 20 MR. HAVERKAMP I'm Don'Haverkamp, 21 Project Section Chief for Seabrook.
22 MR. KAUCHER: I'm Jim Kaucher. I'm I
i 23 the Project Engineer in the section of which Seabrook l
, 24 is a part.
4 AREA-WIDE FEDERAL REPORTING, INC. (215) 925-5777 L, J
t 54 1 MR. GREENSTEIN: Mike Greenstein, c
2 -District Director. I'm here representing U.S.
3 Representative Nicholas Mavroules.
4 MR. RICHARDSON: I'm Douglas '
5 Richardson, Researcher for Employee's Legal ~ Project.
6 MS. TRACY: Sharon Tracy, Employee's 7 Legal Project. ;
8 MR. GRAY: Harold Gray, Region I.
9 MR. MANOLY: Kamal Manoly, NRR, 10 Division of Engineering and System Technology.
11 MR. CERNE: Tony Cerne, Senior 12 Resident Inspector at Seabrook for Region I.
i 13 MR. RUSCITTO: Dave Ruscitto, Resident 14 Inspector at Seabrook.
I 15 MR. DURR: With that, we'll start 16 again. Are all the questions now --
are we finished 17 with pumps?
18 MR. CERNE: There is one point that 19 Kamal and I were jus" discussing. Very simply put, 20 what Scott Kennedy has in the design drawing there is -
21 incorrect. nuug's entire problem with this in the 22 way the geometry works out is erroneously based on !
I 23 that incorrect drawing because the offset originally 24 always was --
I AREA-WIDE FEDERAL REPORTING, INC. (215) 925-5777
l 55 l
1 MR. RICHARDSON: The offset would have L;
2 been then all the way through; that the top of the 3 support columns in a cold position should have'been 4 farther from the reactor.
5 MR. CERNE: At least on the leg.that ,
6 was moved.
7 MR. RICHARDSON: Mr. Kennedy's 8 question is not with the leg that was moved per se, 9 but the relation of the leg that was moved to the 10 other 2 legs. Because if the other 2 legs are 11 leaning toward the reactor at the top, and the third 12 leg is leaning away from the reactor at the top, as 13 the system heats up the pump is going to move away 14 from the reactor. We all can agree on that; is that 15 correct? And the 2 legs that are slanted toward the 16 reactor at the top will come up to plumb, and the 17 tops of the legs wi:1 rise by a fraction of an inch, 18 and the third leg, which is already slanted away from 19 the reactor to begin with, is going to move to a 20 greater degree of slope, and it's top is going to 21 drop. It was Mr. Kennedy's concern that this would 22 create an out-of-level condition on the pump, rather ,
f 23 than having all 3 legs moving parallel which would
] 24 keep it level. That appears not to have been AREA-WIDE FEDERAL REPORTING, INC. (215) 925-5777
56 1 addressed, at least from the discussion in the 87-07 2 report.
3 MR. DURR: This is a new question.
4 MR. RICHARDSON: No. This is the 5 original question. That's the problem.
6 MS. TRACY: This was definitely Scott 7 Kennedy's original concern.
8 MR. RICHARDSON: I refe you to the 9 second page of the text of the paper that he had put 10 together.
11 MS. TRACY: Just read it.
12 MR. RICHARDSON: In the as-built 13 condition, however --
this is using Mr. Kennedy's 14 information -- in the as-built condition, however, 15 the rear legs of the pump cause a rise of about 0.015 16 inch, while the front leg lowers the pump 17 approximately 0.036 inch, making a total difference 18 of about 0.051 inch.
19 His estimate is that this would tend 20 to make the pump leading to the reactor -- the pipe 21 leading to the reactor deflect approximately 1/8 of 22 an inch. So this was the original concern.
- 23 MR. DURR: No. This is a quote. The t
24 quote from the ELP document attachment D says, "Since i
AREA-WIDE FEDERAL REPORTING, INC. (215) 925-5777
l 57 I this pipe is quite rigid most of the stress would, I
.J 2 believe, fall on the welds of the pump in the 3 reactor. This condition would also cause a slight 4 twist in the cross-over piping".
5 So he's talking about stresses in the 6 piping.
7 MR. RICHARDSON: He's talking about a 8 variety of expected results.
9 MR. DURR: I'm just reading what it 10 says here. It says, "This condition would also cause 11 a slight twist in the cross-over piping".
12 He is talking about stresses in the 13 welds at the pump in the reactor. I'm just reading a 14 quote.
15 MS. TRACY: It's a matter of 16 interpretation, what you choose to pick out as being 17 Scott Kennedy's concern. I spoke with him a number 18 of times about this, and he was concerned, yes, about 19 the stress, bearing wear. He was also very concerned 20 about the fact that the pump would not remain level, 21 thus causing these problems.
22 MR. MANOLY: It says that it can move 1
23 100 mils. So obviously he was not aware of that.
24 MR. RICHARDSON: Is it permitted to AREA-WIDE FEDERAL REPORTING, INC. (215) 925-5777
58 1 move 100 mils, if it remains in a level position, or 2 is it --
3 MR. MANOLY: It rises.
4 MR. RICHARDSON: Is it permitted to 5 tip?
t 6 MR. MANOLY: 100 mils. That's a 7 flange. The flange of the pump would rise 100 mils.
8 MR. RICHARDSON: Which flange?
9 MR. MANOLY: Where the pipe is welded.
10 MR. RICHARDSON: Can you show me on 11 this drawing, or do you have another one that would 12 show it?
13 MR. DURR: What? The pump flange?
14 MR. RICHARDSON: Yes.
15 MR. DURR: There is only one flange on 16 that pump that I know of, and that's where the motor 17 mounts to it. It's the top flange.
18 MR. RICHARDSON: Here?
19 MR. MANOLY: Yes.
1 20 MR. RICHARDSON: The question I'm l
21 still trying to get at is, that flange is permitted '
22 to rise 100 mils. I have no problem with that. But 23 is it permitted to tip? Is it permitted to go out of 24 level?
4 AREA-WIDE FEDERAL REPORTING, INC. (215) 925-5777
59 i 1 MR. DURR: That's a new question.
t; 2 MR. RICHARDSON: No. That's the 3 original question.
4 MR. DURR: Based on-what we have here 5 that's a new question.
6 Are we prepared to answer that 7 question?
8 MS. TRACY: I think there is Jome 9 disagreement as to whether it's a new question or 10 simply an augmentation --
11 MR. DURR: To the NRC, that's a new 12 question.
-J 13 MR. MANOLY: Yes.
14 MR. DURR: As far as we're concerned, 15 that's a new question. Whether it's a 16 miscommunication or how it arises, to the NRC that's i 1
17 a new question, and we're not prepared to respond to 18 that question. However -- !
19 MS. TRACY: In the future perhaps.
20 MR. RICHARDSON: Would you be willing l 21 to discuss it in the future?
22 MR. DURR: Yes.
23 MR. CERNE: There is another point to r,
l , 24 be made here though. I will go back to the record.
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1 60 1
1 1 Mr. Kennedy's drawing.is in error. If that's how he j l
2 perceived it, and. that's how you people arrived at j 3 calculations which seem to dispute the NRC's 4 findings, that may be the source of the problem.
5 MR. RICHARDSON: That was part of what 6 I was trying to discuss, to find out if his 7 information was, in fact, correct. That's why I've 8 been asking about the plan.
9 MR. MANOLY: Some of the numbers shown 10 ,in his drawing do not agree with the numbers I got 11 from the documents.
12 MR. RICHARDSON: Which ones? Can you 13 explain them?
14 MR. MANOLY: 5 inches, that is not the 15 movement of the leg. This is the final position from 16 --
it was only moved 2 inches.
17 MR. CERNE: You are assuming that it 18 was 2 inches on the other side, and then it moved 5 19 inches for a total offsec of about 7 inches.
20 MR. RICHARDSON: That appears to be 21 his understanding.
22 MR. CERNE: If you take the fact that i 23 the pump -- or the leg was already offset 2 inches in i
24 the opposite direction, and then it moved to the AREA-WIDE FEDERAL REPORTING, INC. (215) 925-5777
e 61
' i 1 final position of 5 inches, the difference is only 3
,_J 2 inches.
3 MR. RICHARDSON: So the original 4 position then on this leg --
5 MR. CERNE: Was already in that 6 direction.
7 MR. RICHARDSON: - was already sloped 8 from the reactor vessel at the top. The other legs 9 as well, or just that one?
f 10 MR. MANOLY: The other legs were not ;
11 moved. Only the leg that had intorference with the
, 12 piping, that leg was moved.
13 MR. RICHARDSON: What is the position 14 then of the other 2 legs? Are they parallel to the i 15 third leg, or are they at an opposite angle? <
l 16 MR. MANOLY: I don't know exactly what l
l 17 the angles are of the 3 legs, but I know those have 1
18 not been moved. They are consistent with the way
)
19 they are originally designed.
20 MR. RICHARDSON: Can you tell us --
21 MR. DURR Wait. Let's keep the 22 question simple. I think the question is, is the f 23 pump acceptably level at heat up.
] 24 MR. RICHARDSON: That was the e
AREA-WIDE PEDERAL REPORTING, INC. (215) 925-5777
l 62 1 question.
2 MR. DURR: What you are interested in, 3 is the pump acceptably level after a heat up. Is 4 that correct?
5 MR. RICHARDSON: That, as I understood 6 it, was his concern.
7 MR. DURR: That's the question we'll 8 answer. Is the pump acceptably level after it heats 9 up. And we can answer that question.
10 MR. GREENSTEIN: And it only took us 116 about an hour to get to the first question of the 12 day.
13 MS. TRACY: That brings me back to my 14 suggestion before. I know Don had said that several 15 people had to leave around noon or something.
16 Perhaps we should deal with why those people came, so
- 17 that they can leave on time.
18 MR. DURR: Let's move on to something 19 a little less knotty than 1.3, and maybe it will move 20 a lot faster.
21 MS. TRACY: Yes, I agree. We'll come 22 back to 1.3.
23 MR. DURR: On 2.1, what is your 24 specific question on 2.17 4 i AREA-WIDE FEDERAL REPORTINu, INC. (215) 925-5777
63
' i 1 MR. RICHARDSON: First off, specific iJ 2 case, the case where I believe I saw cold pulling 3 being attempted in condensive piping. The first time 4 I mentioned this it was addressed in the 86-52 5 report, and your response in that report was --
I'm 6 going to paraphrase -- was that I was talking about 7 the main steam or feedwater cold pulling incident 8 that is documented. That's incorrect, first off.
9 MR. DURR: What is incorrect?
10 MR. RICHARDSON: The assertion that 11 that was the instance of cold pulling that I was 12 referring to. l 13 MR. DURR: No. We never said that.
l 14 We said that that was a documented case of cold 15 pulling. I don't think we attributed that to you.
16 MR. RICHARDSON: Let me find it, 17 report 86-52. Cold pulling was discussed in a couple 18 of sections in that report. It's discussed on page 19 91, allegation number 55. The first paragraph cites 20 a list of possible problems, and item F is cold 21 pulling pipe. The third paragraph down, page 91, 22 there is a quote, "On one occasion I saw a crew 23 a t t cinp t in g to force a pipe spool into location by use
, 24 of a chainfall".
I AREA-WIDE FEDERAL REPORTING, INC. (215) 925-5777
64 1 In the context of the affidavit I 2 gave you I was referring to piping within the 3 condenser.
4 MR. DURR: We understand.
5 MR. RICHARDSON: Your response on page 6 92, second paragraph from the bottom, it says that 7 cold pulling of pipe is discussed in allegations 8 number 40 and 46. However, one cold pulling incident 9 did occur.
1 10 MR. DURR: Yes. We didn't attribute 11 that to you. We just said that we recognized that 12 there were other allegations.
13 MR. RICHARDSON: That same quote or 14 another one that I did is cited in one of those which 15 reads --
16 MR. DURR: You have to understand that 17 there were multiple allegations, others in cold 18 pulling, and we lumped them together because it was a 19 common issue. We looked at those and number 40 and
, 20 46, allegation 40 and 46. There was a specific 21 allegation in number 40 that said one of the main 22 pipes from the reactor to the turbine building did i 23 not fit, so workers had to use a comealong to make 24 the connection.
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I 65 t 1 MR. RICHARDSON: That was not mine.
2 Cold pulling to align pipes, which is cited as' number 3 46, I believe may have been mine.
4 MR. DURR: That may be-true, but it 5 was so broad and general we lumped-it with number 6 40.
7 MR. RICHARDSON: I gave you a fairly 8 specific location.
9 MR. DURR: In number 46?
10 MR. RICHARDSON: In a discussion in 11 the original affidavit I gave you. I was 12 specifically dealing with piping within the i
13 condenser. There were a number of criticisms.
14 MR. DURR: And we went back and looked j 15 at that in 87-07, right?
16 MR. RICHARDSON: You did to some 17 extent. That was another area-I'm concerned about 18 because in 87-07 you say that that particular j 19 incident --
I believe it was a transcription error.
, 20 You quote me as saying that that particular incident 21 occurred in condenser number B, and that there is no 22 condenser number H.
I 23 I specifically said condenser number
, 24 A. If the transcriptionist got that wrong, I'm i
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66 1 sorry. But I think you should have at least given me 2 a phone call to ask why the discrepancy. We were 3 working with the general arrangement drawings right i 4 there. I believe I pointed out to you'where in' the 5 condensers we were talking about. It should have 6 been obvious that there was a communication error 7 there, and that should have been checked out, rather 8 than to simply assume that because the 9 transcriptionist put it as condenser H, that I didn't 10 have a valid concern.
11 Furthermore, the pipe in question, 12 the 13-etage steam dump, you cite as being attached 13 to the turbine on the upper end and open ended on the 14 lower end, and therefore, because t was open on the i 15 lower end there is no closure weld, and a case of 16 cold pulling could not have occurred. That piping is 17 welded to the condenser wall at the far end, and that i
18 weld would function as a closure weld.
19 MR. MANOLY: No, it's not. Closure 20 means closure. It means closed both ends. This --
21 MR. RICHARDSON: You are forcing a 22 pipe - .
I 23 MR. MANOLY: You are using the wrong I 24 terminology here.
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i 67 1 MR. DURR: Let's slow down. First of l
,_J 2 all, you are arguing with an expert.
3 MR. RICHARDSON: I'm sorry.if I'm 3
4 arguing with an expert.
5 MR. DURR: What's your credentials for 6 arguing with an expert that he doesn't know what 8
7 closure means. He knows what closure means.
8 MS. TRACY: It's another semantic 9 difference.
i 10 MR. MANOLY: No, it's not.
11 MR. DURR: Let me finish. We're
,_ _ 12 talking about induced stresses in piping. I want to 13 know where you have your credentials from induced 14 stresses in piping systems. Where do you have your i 15 experience from?
16 MR. RICHARDSON: I saw that pipe being 17 cold pulled in place. It was supposed to be welded i
18 to the condenser. What you are doing is fixing the 19 pipe at two locations and --
, 20 MR. DURR: I am not disputing what 21 you saw. Buu when he said it does not have, and you 22 said yes, it does, I want to know what the basis for i 23 your argument is.
1 r7 l J 1 24 MR. RICHARDSON: The basis for my j AREA-WIDE FEDERAL REPORTING, INC. (215) 925-5777 l l
l 1
68 i l
1 argument is this, apparently the question of cold I
2 pulling refers to pipe : hat is fixed at one end, I i
3 forced into position at another end, and fixed in 4 place at that end subsequently with the stress still 5 incorporated. Is that correct?
6 MR. MANOLY: Close.
7 MR. RICHARDSON: Would you define it 8 more accurately then, please?
9 MR. MANOLY: Cold pull is when you 10 weld a piping in addition to a pre-prescribed amount 11 that is already accounted for in the design. The 12 design will always allow for a certain amount of 13 closure, offset due to closure of piping. The amount 14 is prescribed depending on the length of the piping 15 from the fixed end, and if you exceed that, that is a 16 cold pull. That only happens during the closure !
17 weld, the very final weld on the system. When you 18 are talking about the piping that you are referring 19 to in the condenser, that's a free ended pipe. By )
20 definition it has no closure weld. l l
l 21 MR. RICHARDSON: It is welded to the i 22 condenser shell. Is that correct?
23 MR. MANOLY: The other end is free.
24 MR. CERNE: An inspection was made of l
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69 1 that, and it is free ended on one end.
2 MR. RICHARDSON: Which end?
3 MR. CERNE: The down end.
4 MR. MANOLY: The down end is free.
5 MR. RICHARDSON: We are accepting the 6 expansion joint which is attached as a fixed point.
7 Is that correct?
8 MR. MANOLY: It's only welded at one 9 i point.
10 MS. TRACY: Here we have a map.
11 MR. GRAY: First, is that the piping
,__ 12 that you are talking about?
13 MR. RICHARDSON: Yes, it is.
14 MR. GRAY: That piping is not welded i 15 from the end of the condenser wall.
16 MR. RICHARDSON: What's the attachment 17 here?
I 18 MR. GRAY: That's a pipe support.
19 MR. RICHARDSON: Let me explain to you 20 the situation I saw. This pipe was installed at the 21 upper end. The people who were getting it into place 22 had a chainfall attached to it --
3 23 MR. DURR: Let me ask you a question 24 --
let me make a statement, more appropriately, I i
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-s 70 1 think. You understand that piping is normally put in 2 place using comealongs and chainfalls.
3 MR. RICHARDSON: Yes.
4 MR. E i1R R : So you are aware, just 5 because there's a comcalong or a chainfall on a pipe 6 does not constitute cold pull because some of these 7 spools are very very heavy and they have to.have some 8 mechanism to move them into place.
9 MR. RICHARDSON: I wouldn't try to 10 pick up most of them. I agree.
11 MR. DURR: Just because there's a 12 chainfall on there doesn't necessily constitute cold 13 pulling.
14 MR. RICHARDSON: Let me continue. What 15 the crew was trying to do, what they were discussing 16 was, they were pulling on the chainfall, and the t
17 blocking was somewhere over my head and I could hear .
18 it cracking, and they were talking about not being 19 able to bring this end of the pipe into its required 20 location. This end was already attached. They were 21 putting a considerable amount of stress on the pipe 22 to bring it up to the location they wanted to and --
3 23 MR. CERNE: That's not cold pulling.
24 MR. GREENSTEIN: What's the
' I AREA-WIDE FEDERAL REPORTING, .INC. (215) 925-5777
1 l -
l 71 l
l r' 1 terminology-then?
_ J 2 MR. RUSCITTO: Cold pull is, you take 3 a pipe and you bend it, and then when you weld it, 4 that induces stresses in this weld, not the one at 5 the pivot. There was never a weld at the end. So it 6 couldn't have been a cold pull.
7 MR. RICHARDSON: I'm not concerned 8 sbout the pivot.
9 MR. CERNE: You don't have a weld at 10 both ends. ,
11 MR. RICHARDSON: Okay. Not at both 12 ends, but you have $ weld toward that end of'the 13 pipe.
14 MR. DURR: The other thing you have to
15 understand is that here again, we went far beyond our 16 n o rtaa l scope of inspection. The condenser itself is 17 not safety related. The rules and procedures that ,
I l 18 the NRC imposes on the licensee are not in effect in 19 this particular case because that entire condenser is
, 20 not safety related, nor is the piping that is 21 attached to it, nor are any of those things that are 22 around it. Even the turbine is not safety related.
I I
23 So you have to understand that, yes, you may have l
, l i 24 seen cold pull. However, we went out and looked at l i
AREA-WIDE FEDERAL REPORTING, INC. (215) 925-5777
i I
72 1 it, and we feel very strongly from a professional 2 that cold pull in this particular case probably did 3 not exist. Now, maybe it does. That's a moot 4 point.
5 The other thing-is that it's open on ,
6 one end. It's not a closure weld. It doesn't fit j 7 the definition of cold pulling. It's non-safety 8 related. It's beyond the NRC's purview to even look i
9 at that piping. However, we did, just to satisfy 10 ourselves that there wasn't some other underlying 11 issue going on here that we needed to be aware of.
12 From the NRC's point of view, yes, we are interested 13 in did the licensee control cold pulling, and we 14 looked at that issue. We, the NRC, looked at that 15 issue a long time ago, independent of the 16 allegation. In this particular instance we went back 17 one more time in a non-safety related area beycnd the 18 NRC's purview, and we looked at that specific one .
19 trying to be responsive to the public's concerns.
t 4
20 MS. TRACY: That was very good of 21 you.
22 MR. DURR: We have found that there is ;
)
23 no problem there. So I don't know where we are going 24 to go with this discussion. As far as the NRC is I I
\
~
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73 i 1 concerned it's over with. There's nothing there.
2 MR. RICHARDSON: Can I get one more 3 clarification from you?
4 MR. DURR: Certainly.
5 MR. RICHARDSON: As far as cold pull 6 then, your specific concern is with the integrity of 7 the closure weld, in that if the weld deteriorates, 8 you're going to be opening the pipe?
9 MR. RUSCITTO: No. You're welding the 10 pipe that's under stress, so that stresses induced in 11 that weld exceed the stresses that are allowed for in 12 the design of the weld.
l 13 MR. RICHARDSON: You're not concerned i
14 specifically with the stresses in that weld because l 15 it's --
16 MR. MANOLY: Once you have a weld it 17 becomes like the pipe. It's really part of the pipe.
18 Once the weld is finished, it's like part of the .
1 19 pipe.
20 MR. RICHARDSON: Your concern is for 21 the integrity of the pipe itself, rather than the 22 integrity, say, of any attaching welds.
I 23 MR. MANOLY: Yes. When the 2 ends of 24 the pipe are welded together, it becomes one part.
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1 MR. RICHARL5CN: A closure weld, and 2 in this case a weld fixing one end of the pipe to a 3 support.
4 MR. MANOLY: No. Supports are 5 different. Don't mix up supports with piping.
6 MR. RICHARDSON: It's a support '
7 regardless.
8 MR. MANOLY: No, it's not. When a 9 pipe is welded at a support, that's an anchor.
10 That's a different story. He're talking about closure 11 welds which is 2 ends of a pipe welded together to 12 make a continuous system. The concern would be if I 13 moved the 2 ends. They are like this, and I push them 14 towards each other. I will overstress the piping.
i 15 If the other end of that piping is closed at anchor 16 point, which is a support, then I'll be going beyond i 17 the code limit for the design. 1 1
18 MR. RICHARDSON: So your concern for 19 the stress then, are you specifically concerned with i i
20 stress at that weld, or the stress induced by moving )
21 that pipe in any other place?
22 MR. RUSCITTO: That is part of the 1 23 as-built.
24 MR. RICHARDSON: Are you concerned I
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75 i 1 specifically with the weld, or with stresses induced
_a 2 in the length of the pipe?
3 MR. MANOLY: The weld becomes part of 4 the pipe. It's a continuous system. Then you would 5 want to see the other points on the line where the 6 stress rise would be, as pushing the 2 ends of the 7 pipe to each other.
8 MR. RICHARDSON: So your concern then 9 is primarily with the pipe having wound up in a 10 location it's not supposed to be.
f 11 MR. DURR: We are concerned about f. h e 12 stresses in the piping system.
-" MR. MANOLY: It will change at every 13 14 point in the pipe. The highest change would be at ,
15 the anchor end.
16 MR. DURR: Those are limited by the 17 ASME Piping Code that limits the amount of stress 18 that you can have in that piping, and this 19 contributes to it.
20 MR. RICHARDSON: So if the piping is i
21 forced into a position and held in that position by 22 other than a closure weld, say, for example, by a 23 support, is that still considered a case of cold 24 pull?
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a 76 1 MR. MANOLY: No. That is a different 2 situation.
3 MR. RICHARDSON: Is that a matter for 4 concern?
5 MR. MANOLY: If the support is f
6 installed in a location other than its design 7 location, that's part of the as-built program.
8 That's a different program. I 9 MR. RICHARDSON: If the pipe is forced 10 into a position other than what it would naturally 1
11 lie if one end is fixed, is the fact that that pipe .
12 has been forced into a different position, and if it 13 is fixed in that position, is that a matter for i 14 concern in and of itself? Or is it only a matter for 15 concern if there is a closure weld connecting it at 1
16 both ends through further piping? Are we concerned 17 with the fact that the pipe is closure welded, or are i f l 18 we concerned with the fact that the pipe may or may j 19 not be stressed by nature of its position? l 20 MR. MANOLY: You can only induce a 21 stress in a pipe if one of the ends is restrained.
22 If the pipe is free, then you are not inducing stress ji 23 in it. '
I I
i 24 MR. RICHARDSON: That's the point I'm ;
I j' I i AREA-WIDE FEDERAL REPORTING, INC. (215) 925-5777 l 1 . - - - . _ . -
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77 i I trying to get to with the condenser piping. It's not
_J 2 a closure weld at the open end of it. We agree that 3 it dumps into the condenser, but it is fixed in 4 location at that end by whatever the item is that's 5 shown on that drawing tying into it. Is that 6 dorrect?
7 MR. GRAY: Pipe support, yes.
8 MR. RICHARDSON: It is fixed in that 9 1ccation?
10 MR. GRAY: No, it in not fixed. It is 11 supported at that location.
12 MS. TRACY: So it can move.
13 .
MR. MANOLY: Stress can only be --
the 14 kind you are talking about here would be caused by a 15 seismic restraint or an anchor. A dead-weight 16 support is not going to stress a piping, if you move 17 6 dead-weight support.
18 MR. RICHARDSON And that's a dead-19 weight support?
i 20, MR. DURRt I suspect very strongly i
21 that's not seismically qualified pipe.
22 MR. GRAY: Could I summarize where we i i
23 are on this one from my point of view? l m
_; 24 MS. TRACY: Yes. ,
)
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78 1 MR. GRAY: Doug had a concern with 2 potential cold pulling on the stage 13 piping. We 3 went to the field. We reviewed the drawings 4 applicable to that. We went into the condenser. We 5 looked at the piping. We saw how it was in place at 6 this point in time, and we asked ourselves whether or 7 net that it's possible that there could be 6 significant cold pulling of this piping.
9 Our conclusion was that there is not 10 a significant cold pulling on this pipe. Therefore, 11 your allegation is not substantiated. You may have 12 seen them pulling the pipe, forcing the pipe, but at 13 this point it really has no bearing on the as-14 constructed condition.
15 MR. RICHARDSON: Why is that?
16 MR. RUSCITTO: Even if it was safety 17 related, it would not have an impact on the design.
1B By virtue of its physical design, what you saw could 19 not have induced abnormal stresses on it because of 20 the method that it's fixed.
21 MR. KAUCHER: Abnormal residual 22 stresses.
23 MR. RICHARDSON: Why could it not 24 have, if you've got it fixed at the turbine enhaust i
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i 1 and you've got'it fixed'at t M d e ad-we i'ght support?
2 ,MR. MANOLY: Because dea,d-weight 3 supports do not restrain the'totation of; piping.
./ ,
4 MR. CERNE: You d'on't know what a support does. There are dhf2Irent-types of supports.
5 l 6 Some do not-totally restrain the p'ipe, f rom moving.
7 There are different types on e'apports.
~
8 MR. DURH's.They.are flexible.
9 MR. RICHARDSON: If thi's is the case, ,
10 then th'e cold pull)ng question i s moot because the 11 pipe support will. permit movement in the pipe?
,__ 12 MR.,CERNE: Exactly.
13 MR. ~ RICHARDSON: Okay. I wish it had 14 been better explained.
a 15 -
MR. CERNE: I think that's the point 16 Jacque made to begin with. The point of looking at 17 an allegation is to satisfy the experts, the NRC, and i
18 the public that th(re is no concern. Harold did that 19 when he wrote the report. What we just spent a half 20 hour doing is trying to re-educate you as to how this 21 system is designed and is supposed to work.
22 MR. RICHARDSON: To me, that's a very f 23 desirable thing, and I appreciate it when you would
. 24 take the time to do that.
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80 1 MR. CERNE: I don't think we have the 2 luxury of time to do that, particularly with this 3 amount of effort.
4 MR. DURR: lie obviously want to do i
5 this. We want to make everybody comfortable. We 6 can't do it with everybody. It's physically ,
7 Impossible to take everybody in the New England area 8 and re-educate them, so to speak.
9 What you have to believe is that 10 there are experts who are highly qualified going out 11 and looking at these things, taking what you are 12 saying seriously. When it comes to allegations, we 13 take them very seriously. We process them through a 14 panel. They are looked at. We select experts in the i 15 area to go out and resolve them, and then the panel 16 of upper management looks at what the resolution was, .
17 and agrees that's acceptable or unacceptable, whether i
18 we need more or less. So it's not just any one 19 individual taking what you've said and going out and 20 sweeping it under the rug, so to speak, but it's a 21 body of people looking at these things and taking i 1
22 each one seriously because we don't know where the 1 23 big one really is.
24 MS. TRACY: And neither do we, Jacque.
I l
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1 81 P1 1 MR. DURR: Some of them are
,.J 2 innocuous. I understand that. ,
3 MS. TRACY: Yes. That's why if 4 perhaps your explanations to some of the allegations 5 that have been raised don't entirely satisfy the 6 people who raised the allegations, that's why we come
+
7 back and talk to you some more about it. I do 8 appreciate the fact that, as Tony said, you're taking 9 time out to explain it in some detail.
10 MR. DURR: Some of these are very very 11 knotty technical problems.
12 MS. TRACY: I know they are.
13 MR. DURR: The fact is, in one or two 14 cases we've gone out and gotten consultants to come 15 in and look at these issues because we felt that we L 16 needed just a little bit more depth than what we had 17 available on our staff. So you have to understand 1
1 18 that we're taking these very seriously, spending a 19 tremendous amount of time trying to resolve them.
20 MS. TRACY: Definitely I understand i l
l
. 21 that. I think we all do. i i
22 MR. DURR Good. i 1 23 Moving right along to 2.2.
e,
_g 24 MS. TRACY: I would say that this i 1
l 4
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82 1 issue having to'do with the CBA drawings also falls i
2 under some of the programmatic concerns that I 3 raised. However, there is some specifics here that I 4 think Doug can probably speak to, having to do with ,
5 the fact that there were no construct 2on drawings for 6 specific pipes in the CBA system. .
7 MR. DURR: Suresh Chaudhary, who B followed this one, he's out. He's not well.
9 What's your specific concern here?
i 10 MR. RICHARDSON: First off, you've got 11 a fair amount of electrical equipment, the operating 12 equipment in the area in the diesel generator 13 building where the air conditioning for the control
~
14 room is. There is no isolation between the trains 15 for that system as far as physical barrier for fire ,
16 protection.
17 MR. DURR: I think we've got 2 i
i 18 different issues going.
19 MS. TRACY: Let's stick to this une t
20 right now; that there were no design drawings.
21 MR. RICHARDSON: You mentioned in one 22 of your reports that construction drawings were I 23 issued. .
I 24 MR. DURR: Yes.
i e
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83 1 MR. RICHARDSON: I did the as-builts
.a ,
2 for the smaller refrigerant lines on the CBA system.
3 I don't recall the unit numbers, but the lines were -
4 1/2 and 3/4 diameter, I believe. There were no 4
5 installation drawings that were done before those.
6 The ones I did were it.
7 MR. DURR: I'm going to operate from 8 my memory, but when we originally looked at that 9 issue, I thought we found that there were drawings 10 issued in 1978 --
11 MR. MANOLY: Yes. i
,__ 12 MR. DURR -- on that system that 13 showed that there was an original set of design 14 drawings. We found drawings dated 1978, I think was 1 15 the date --
we are going from my memory now -- that 16 were issued back then. You did the as-builts, we 17 understand. i 4
i :
18 MR. RICHARDSON: I did the as-builts
-19 on a supplemental train. There might be a '
20 difference.
21 MR. DURR: I'm not clear on this. I 22 think this was field run piping; was it not?
i 4
9 23 MR. RICHARDSON: Yes. i
] 24 MR. DURR: There is nothing wrong with e
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84 1 field run piping. We do that all the time, 2 especially in small bore piping.
3 You have to understand that when you !
4 build a nuclear power plant, they generally very l 5 specifically locate the big stuff. The 30-inch I
6 piping is planned very specifically where it goes 7 through the building, but where you start getting 8 down into smaller diameter piping, that goes in 9 last. It goes wherever there is space available 10 that's leftover, if you will, after you put the 11 highly critical, large, heavy equipment in. So field 12 run piping, field run cable, there is all kinds of 13 what they call field run. An engineer goes out and 14 says we'll go from A to B because there's no 15 interference there, or we may have to go A, B, C 16 because there is interference and we'll go around 17 it. So they field run it, or it's not "designed" 18 back in the AE's office specific location because you 19 have all of these interferences that you can't 20 account for. So field run piping is common, and 21 there's nothing wrong with it. That's a controlled 22 process.
23 MR. RICHARDSON: Tht,t concept, I have 24 no problem with.
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85 1 Specifically with this system, the 2 problem I've got with it is that at the areas where 3 this tubing was run into the air conditioning 4 equipment, at one point they underwent a series of 5 revisions and reinsta11ations. There were things, 6 like expansion joints were installed incorrectly to 7 vender's specifications. There were supports that 8 didn't adequately keep the pipe in place. In some of 9 these areas it went back and forth over several 10 design revisions.
11 I am concerned that there may not 12 have been adequate control in design process to make 13 sure that it was done right. At one point on one of 14 the units I was told by a fitter who was working on 15 it that the system would not operate as it was 16 designed as he was installing it. I have to assume 17 he knew what he was talking about. He was, I 18 believe, a refrigeration mechanic. He did seem to l l
19 have a pretty good knowledge of what he should and i 20 shouldn't be doing.
21 This year you have lost one unit of i 22 one of the supplemental trains. I don't know if it's
?
23 specifically one of the ones I was working on, or the j
] 24 other one. I was working on one of these supplemental l
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i 86 Is there any connection between t h's loss of l 1 trains.
2 that unit and any deficiencies to the design of the 3 refrigerant piping? -
4 MR. DURR: Are you familiar with the 5 loss of one of these units? ,
6 MR. RUSCITTO: Yes. I don't see any 7 connection.
8 MR. DURR: As I say, with field run 9 things you are going to end up with changes and 10 alterations because they may have had to move it, and 11 we don't know for what reasons they moved these 12 things. If something else comes along that is more 13 important than that, they're apt to move that --
14 they're subject to move that piece of equipment i 15 several times because something preempts it, 16 something more important preempts it. It's easier to 17 move a small diameter piping than it is to re-route i
18 another larger, more critical piece of equipment.
19 MR. RUSCITTO: I don't see the tie 20 that you are making though. Could you be more 21 specific? If you could be more specific, maybe I 22 could address the issue. I assume you're referring i 23 to the CBA air conditioning units that sit on either I I 24 side of the diesel generator building and horizontal 1
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87
"' 1 fan cooling coils, and the refrigerant lines run down J
2 to the cooling coils in the control building to the 3 fan cooling units that cool the control room. That's 4 the safety related system we are talking about.
5 MR. RICHARDSON: Yes. That's 6 generally where I'm talking about. Specifically what 7 I'm concerned with is the smaller supplemental unit.
8 MR. RUSCITTO: The AC5 A and B.
9 MR. RICHARDSON: Yes, I believe so.
10 Specifically with regard to the set that's on the 11 right-hand side as you're facing the diesel generator 12 control building wall, the unit that's on the control 13 building side of that wall, I don't recall the 14 equipment designation, but that particular train, the 15 piping within the last couple of feet going into that 16 unit was revised repeatedly. At one point they did 17 have an expansion joint --
flexible coupling, rather 18 in a vertical position. Whereas the manufacturer's !
19 specs called for it to be horizontal. That 20 configuration was changed repeatedly. I lost track 21 how many times. I believe it was least 3. That was 22 the area in which the person I was talking to said at 23 one point that it would not function; that it had F7 24 i , been designed incorrectly.
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s 88 1 Also down at the unit associated with t
2 that train on the diesel generator side of the wall I 3 found a support when I was doing as-builts that --
4 I'm using the term support in a generic sense -- but 5 there is a supporting structure that was supposed to ;
6 hold that tubing in place that had no provision for 7 any horizontal restraint, where you could take the L 8 pipe and flick it, and it would move several inches 9 back and forth like this (indicating).
10 MR. RUSCITTO: It's not an uncommon 11 design.
12 MR. RICHARDSON: No, but I called it 13 to the attention of, I believe, a field engineer, and 14 it was later modified. It was my understanding that i 15 these things are supposed to be QC accepted before ,
16 they go to as-built; is that correct?
17 MR. DURR: No. QC takes the as-built I
18 drawings usually and walks them down. That's the i 19 last thing that happens. What usually QC uses for 20 their final acceptance is the as-builts.
21 MR. RICHARDSON: It is certified 22 complete and turned over to as-builders then.
'q 23 MR. CERNE: The Pullman process for I 24 piping was a 2-part process. They had a form 10 A or i
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g 89 .
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' 1 B.
,'.J 2 MR. RICHARDSON: This is at the time I j 3 was working for Pullman, if that helps clarify your 4 question.
5 MR. CERNE: What you did was, you had 6 a QC process which was going on, and also an -
7 as-building process that was going on. Normally the 8 QC process would be completed before the as-building 9 process, to answer your question. ;
10 MR. RICHARDSON: So how did that l 11 support get by? How come nobody else flicked it to :
1 12 see if it moved?
i 4
) 13 MR. RUSCITTO: The support design has -
i ,
14 several facets. One of them includes seismic design.
15 MR. RICHARDSON: Is that system d
j 16 seismically supported?
i 17 MR. RUSCITTO: Yes. One is seismic.
18 Then there are other supports that may be added once 19 the system is placed in operation due to vibration.
, 20 These are supports that are not accounted for in the !
21 seismic design because you can only find out where i 22 the piping vibrates once it's in operation. ,
t 23 As a matter of fact, we've had j 24 concerns that you may have read in our reports about AREA-WIDE FEDERAL REPORTING, INC. (215) 925-5777
90 1 other areas where we went out and saw equipment 2 vibrating and talked to the licensee, and they said 3 yes, by seismic design it's not required, but it ,
4 appears to be a good idea to put these additional 5 supports in, and they do that over the life of the ! ,
6 plant.
7 Not knowing the specific support, I 8 can't address the specific support, but that could 9 very well be a normal process of someone going out l 10 and saying hey, it looks like maybe we could put this 11 in now. They want to be conservative. Throw in i 12 another support here. In the final design the 13 as-built reconciliation and the stress reconciliation 14 will make sure that there's no undue stresses 15 applied.
7 16 MR. CERNE: So what you're implying is 17 that you're talking to the engineer or somebody about 18 this. It was contrary to design. The QC inspector 19 checks if it's in accordance with design. If you
-t 20 asked the question that caused the individual to look
- 21 at it and change it, we don't ht;w the rationale 22 behind that.
23 MR. RICHARDSON: That basically was 24 what happened. I pointed out that that tubing could 1
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91 .
r1 1 be moved easily, and the support was modified to hold '
2 it in place horizontally. My original question was, 3 how come that had been allowed to happen in the first 4 place.
5 Concerning the seismic qualification 6 of the supports, at the time we were doing as-builts 7 on that system we had no information that indicated 8 they were supposed to be seismically designed.
9 MR. RUSCITTO: When was that?
10 MR. MANOLY: What year?
11 MR. RICHARDSON: Summer of '82.
,__ 12 MR. DURR I don't understand. You 13 were doing as-built drawings?
14 MR. RICHARDSON: That's correct.
I 15 MR. RUSCITTO: Supports or piping? '
16 MR. RICHARDSON: Piping. We had to 17 indicate locations of supports, of course.
I 18 MR. RUSCITTO: Why --
19 MR. RICHARDSON: When I was doing the 20 as-building, I was also generating construction -
21 isometrics to support that line. I 22 MR. DURR I understand.
I 23 MR. RICHARDSON: As part of that l 24 process we had to enter building materials, some t
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i 92 1 other items, and also support classification. I gave 4
2 you a copy of a couple of the as-built drawings I did 3 from that.
4 MR. DURR: Yes. I understand.
5 MR. RICHARDSON: If you recall --
6 MR. DURR: But you were working for 7 engineering then, and you were generating drawings 8 that would later go to engineering and be further 9 processed; is that correct?
I l 10 MR. RICHARDSON: I was generating the 11 drawings, as I did the as-builts. I was doing both.
12 MR. DURR: I understand that, but l 13 those drawings were further processed by engineering.
14 MR. RICHARDSON: During the course of
,i 15 putting those drawings together we were required to 16 indicate the -- I guess you would call it the class ,
17 requirements and the supports. .
- i 18 MR. RUSCITTO
- How would you know 19 that?
20 MR. RICHARDSON: I was told to, i 21 MR. RUSCITTO: How would know what the l 22 class of support was? l
~
I 23 MR. RICHARDSON: I asked my i 24 tapervisor, and he looked it up, and --
4 l
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r1 1 MR. DURR: He had the information. i
. J 2 MR. RICHARDSON: He gave it to me as 3 non-nuclear, non-seismic, non-safety related.
4 MR. DURR So he made a mistake. Is 5 that what you're saying?
6 MR. RICHARDSON: I am saying his 7 information was bad. He probably got it right 8 according to the book.
9 MR. DURR: This sounds like a new I
10 allegation to me.
11 MR. RICHARDSON: I discussed it with
,_, 12 you in April. That's why I gave you the copy of that ;
LU 13 drawing.
14 MR. DURR But you never said anything I 15 about not knowing the seismic qualification of the 16 piping system, and having it denoted, and that your 17 supervisor had bad information. I will go back to 1
18 the transcripts, but I'm almost sure that's not in 19 there. I don't remember any of that.
, 20 MS. TRACY: Perhaps it didn't get l 21 stated exactly that way. .
22 MR. CERNE: Let's clarify where we're
,i 23 at now. Are you saying that those things are i 24 non-nuclear-safety, non-seismic right now, or just l
t l l
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94 1 that in the process of information between you and 2 your supervisor at one point you thought they were 3 non-seismic, but they really were seismic?
4 MR. RICHARDSON: I don't'know whether 5 they are right now or not. One of the reports that 6 you people did says that they are. I believe it was 7 the first one. I was surprised by that because the 8 drawings I had from that period indicated that they 9 were not. That's why I brought the drawings down to 10 the meeting in April, and that's why I called it to l 11 your attention.
12 MR. CERNE: So what's the current 13 problem?
14 MR. RICHARDSON: It comes under the 15 hecding of design control. We had apparently a 16 number of --
17 MR. CERNE: Are you a designer?
18 MR. RICHARDSON: No. t 19 MR. CERNE: Was your supervisor a 20 designer?
21 MR. RICBARDSON: No. But why did we 22 have bad information?
s l 23 MR. DURR: I'm not sure we've I 24 established yet that you had bad information. You I
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95
- 1 suspect that your superviser had bad information. l l
s-~ .
2 MR. CERNE: It's quite possible that 3 at one point they were non-seismic, and they got f 4 changed to seismic.
5 MR. RICHARDSON: I've considered that j 6 possibility.
I 7 MR. CERNE: What are we chasing at 8 here that's wrong with the plant as-built?
9 MR. DURR Today. What's our ;
i i 10 problem? ,
11 MR. CERNE: That's what we're after,
, _ _ 12 is the plant going to operate as designed.
13 MR. RICHARDSON: My question would be, 14 if these supports were originally designed to i 15 non-seismic quality specifications, if they were, has 16- the situation been corrected.
4 17 MR. CERNE: Our documents say it is ;
I i
j 18 seismic. l 19 MR. RICHARDSON: Your report says it 20 is. I I i 21 MR. CERNE: And you have information 22 that is different?
4 23 MR. RICHARDSON: At the time we were I] 24 as-building them, the information we had said that 0
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i 96 1 they weren't. If that information was also what the i 2 construction people had, then how can we be sura that 3 they were, in fact, seismically qualified designed 4 and built?
5 MR. RUSCITTO: So really your question i
6 is that the CBA system as. presently designed should 7 be seismic, but may not be constructed that way. Am 8 I paraphrasing you correctly?
9 MR. RICHARDSON: I believe that would
- 10 be a close approximation.
1 11 MR. RUSCITTO: So then we can answer j 12 the question that we've either looked at that, or we
) 13 haven't. We may not have looked at it, if you've i
14 never raised that as an issue.
i 15 MR. F.ICHARDSON: I thought I had 4
l 16 raised that in April. That's why I brought in copies I 17 of those drawings.
t 4
I
- 18 MS. TRACY: Could I ask a question? !
19 MR. RICHARDSON: I assume it was 20 supposed to be seismic, and the information we had
! 21 indicated that it wasn't. And if that information
) 22 had also gone to the construction people, then is i
i 23 there assurance that it was, in fact, constructed to i 24 seismic standards, 1
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97 1-l l.a ,
1 MS. TRACY: When you check a system, j 2 when you say you can check whether or not this is 3 seismically built, do you go and look at the >
4 documents, or do you go and look at the actual systen, }
5 itself? :
6 MR. RUSCITTO: It depends on what you ,
7 want to find out. ,
8 MR. CERNE: What often happens, and we 1 9 found this in our own inspections, that you can't !
10 always tell from the isometric drawings how the
- 11 supports are designed. You have to go to the 12 specific support drawings because sometimes there are l 13 detailing errors in the isometrics which might draw 14 the class break of a non-nuclear safety versus an !
15 ASME line in the wrong place, and yet when you say !
16 there's an error here and you go into the non-nuclear j 17 safety and go to the specific support drawing, you i 18 find it's an ASME support designed and built support. l 19 MS. TRACY: So after you go to that 20 support drawing and it says it's ASME and seismically j 21 proper and so forth, do you ever go and look at the
- l 4
l i 22 actual thing? i i l 23 MR. RUSCITTO: Oh, yes.
]1 l
j i 24 MS. TRACY: To make sure that it i
iI
98 1 matches up with the drawings that you're looking at?
2 MR. RUSCITTO: Yes. As a matter of 3 fact, that's part of one of the things our NDE van 4 examination does, which came out to the cite on 5 several occasions, and I've accompanied them. They 6 go around with specific pipe support drawings and 7 evaluate the quality of the welds, the thickness of 8 the welds.
9 MR. RICHARDSON: Where did we say that 10 it was seismically quali!.ied?
11 MR. RICHARDSON: I believe it was in 12 86-52.
13 MR. DURR Number 54.
14 MR. CERNE: There is another gate 15 there that you meet. If you're non-nuclear safety, 16 non-seismic, it doesn't require QC/QA. If it's 17 either ASME, which is your safety grade of piping, or 18 non-nuclear safety, but it has seismic design because 19 it possibly could affect something safety related, QC 20 is applied to that.
21 So not only are we looking over the 22 shoulder of how it's built, we're also looking over i 23 whether the QC process worked, in looking over the 24 shoulder of the people who decide that.
1 I
I AREA-WIDE FEDERAL REPORTING, INC. (215) 925-5777
. t 99 i r7 1 MS. TRACY: Do you look to make sure
.J 2 that the QC is used appropriately as well? !
3 MR. CERNE: It would only evidence 4 itself if there was something wrong. If you don't 5 find anything wrong with the way it's built, then the 6 QC process worked because that's the intent of the QC 7 process. The QC is not an entity in itself. QC is a 8 means of assuring that the plant is built correctly.
9 If the plant is built correctly, then QC worked.
10 MS. TRACY: However, if QC did not i <
3 11 work, you won't be able to know either that, or I
12 whether the plant was built properly. If there is a I i
13 failure of QC, you won't know that there was a i
14 failure of QC because there is nothing to "QC" QC, i 15 except you guys, j
16 MR. CERNE: That's not correct.
17 There's levels of QC. There's QC inspection, QC 18 surveillance, QA, audit. That's all part of the 19 defense in depth of the QC process. They call us the 1
. 20 fourth level of inspection, looking over the 21 shoulder. We do a sampling process, but when we do a l
22 sample of different areas and can't find anything i
23 wrong in the final construction, that gives us our l1 , 24 assurance that their QC process is working. That's t
i l
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1 the way the system works.
2 MR. RUSCITTO: If you have a question ,
3 now that the CBA system may or may not be installed i
4 properly, if it hasn't been addressed before, you can 5 either raise it as a new allegation, or a concern -
6 which is not an allegation.
l 7 MR. RICHARDSON: What exactly is the l
l 8 difference between the two?
9 MR. RUSCITTO: Because an allegation l
l 10 says that you believe that there is something wrong.
11 MR. DURR: The process.
12 MR. RUSCITTO: A concern or question 13 says, hey, I'm a concerned citizen. I don't know if 14 there's anything wrong, but I don't understand.
15 Would you mind explaining it to me? If you have a l 16 concern, we can say that we'll do our best to explain )
i 17 it to you. We don't have any obligation to do it, if 18 we have other constraints.
19 MR. CERNE: It may sound like 20 semantics to you, but an allegation is a statement of l 21 wrongdoing. I know that is wrong; not I suspect l 22 something is wrong, and would you please, the NRC, go t 23 look at it for me.
24 MR. MANOLY: The pump support, that l
i t
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101 I was a concern, and we looked at it because we werc 1 1
l 2 interested in it, t
3 MS. TRACY: You treated it as an ,
4 allegation.
5 MR. MANOLY: I did whatever I thought 6 I needed to do to assure myself that it was not a l
7 concern. !
i 8 MR. RUSCITTO: A concern is a basis 9 for inspection. Concerns by everyday people in the !
10 plant, concerns by citizens can often-lead us in an j 11 area where inspection can give us valuable insights 12 into the quality. In some cases the concerns that >
13 you guys generated caused us to do inspection over 14 ano above what would be required because of an 15 allegation because we wanted to insure ourselves that 16 there was no problem. Regardless of whether the f
17 allegation was justified, we go off on tangents. !
i 18 MR. DURR: I think there was a point 19 made that needs to be emphasized, an,d that is that an i i
20 allegation is an individual who has first-hand ,
21 knowledge that something is wrong, and presents that .
22 to us in that form. I know something is wrong, and 23 therefore, you need to look at point B. That's an I I
24 allegation.
i AREA-WIDE FEDERAL REPORTING, INC. (215} y25-5771 l l l 1
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.i 102 1 The things that you're talking about j
2 here today are really concerns. You're saying I '
4 3 think this, or I suspect that, or I'm not sure about l 4 this. That's not an allegation. That's just a ,
i !
5 question on your part because you don't understan6 }
3 1 6 the process; that you haven't been privy to the wholel. -
4 l
7 picture. We're trying to respond to some of those 8 things, but those are not "allegations".
9 But if you look me in the eye and
, 10 said, my supervisor had bad information, and he got !
11 it out of this book, that's an allegation, and I can r
] 12 do something with that. '
i -- .
] 13 MS. TRACY: Do you want to on this
) 14 particular thing?
i 15 MR. DURR: Is he making an ,
t
, 16 allegation? Because if he is, we Will treat that -
9 17 accordingly. '
1
- 18 MS. TRACY
- Do you want to me.ke that l i
i l 19 an allegation?
I 20 MR. DURR: Do you have first-hand 1
21 knowledge that there is wrongdoing there? .
22 MR. RICHARDSON: No. What I do have
!, 23 is first-hand knowledge that I was told that the j I i
- r7 24 system -- l
- i l l
9 k i
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103
{
r 1 MR. DURR: You have a question.
2 MR. RUSCITTO: You being told the !
3 incorrect information may not have any effect on the 4 safety of the nuclear power plant.
5 MR. CERNE: If there was incorrect f
. 6 information and if it wasn't changed subsequent to 7 that. -
8 MR. RICHARDSON: Stated as a concern, 9 I would say that I am concerned that the correct 10 information may not have been applied when the plant 11 was built.
f 12 As an allegation, what I would say is 1
1 13 that I was given information concerning the seismic l -
i 14 requirements for that system that does not match your l i'
15 statement that it is seismic as reported. I gave you !
16 copies of drawings at the April meeting. I don't t i
17 have them with me now. i 18 MR. TRACY: Do you still have those? .
19 MR. DURR: I don't know. I've got 2 4 20 boxes full of things. But once we write an 21 inspection report we throw all that stuff away.
l 22 MR. RICHARDSON: Okay. I can send you ;
23 new copies. ,
24 MR. DURR Send us :cw copies, and 9
I l4 i AREA-WIDE FEDERAL REPORTING, INC. (213) y23-d///
I 104 I we'll do something with it. Once we get those copies !
2 and it's clear to us that there's a discrepancy, i
3 we'll take some kind of further action with it. If 4 those drawings support your statement --
if they say ,
5 -- what you're essentially is, your drawings -
6 essentially say non-seismic? ,
7 MR. RICHARDSON: Non-seismic, i 8 non-nuclear, non-safety. Those are the drawings I [
! 9 gave you in April. The reason I gave you them --
1 10 MR. DURR: And you're sure that they 1 11 were part of the air handling system that is supposed
(
12 to be safety related, j -- .
l 13 MR. RICHARDSON: That, I don't know.
2 I
i 14 You have to tell me what part of it is supposed to be
- 15 safety related. I can tell you what part they are.
j 16 MR. DURR: We'll take your drawings ;
2 ;
j 17 and we'll decide if we have an allegation. We may :
- +
- 8 18 not have an allegation.
19 MR. RICHARDSON: That was the small
, 20 bore, 1/2 and 3/4 inch refrigerant lines in the
'I i l 21 supplemental --
22 MR. DURR: When are you going to send i
, 23 those to us, Doug?
m, 24 MR. RICHARDSON: I'll be able to ser.d ;
) !
s J
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105 i i
i !
1 them to you sometime this week, i 4
2 MR. DURR:' All right. !
3 MP. RICHARDSON: Can you give me a 4 mailing address?
5 MS. TRACY: I've got it. [
j t
- 6 MR.-CERNE
- -They list the supports as j 6
! 7 NNS.
i i j.
8 MR. RICHARDSON: I don't recall i 9 exactly what they're listed as. They were a very I I
10 unspecified thing at the time.
I 11 MR. CT.RNE: I am unclear then what !
1 !
l 12 makes it non-seismic, non-safety, if it's not in !
I i
13 writing. l
- 14 MR. RICHARDSON
- I wish I had a copy i I
] 15 of them with me. There was space.on the drawing title j i i 4 16 blocks that was used to designate the type of support i i
- 17 requirement that the system was built to use. There i i !
j 18 were 3 or 4 categories that would be applied as l
! 19 appropriate, and this one, I was told, was to be i a !
1 P
! 20 designated as non-nuclear, non-seismic, non-safety.
4 t
i 21 MR. DURR: But that's written right on j i
~
I 22 the drawing? l 2
23 MR. RICHARDSON: Yes, it is. The
],
l 24 majority of those drawings I have are designated as ;
J 1
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f l
1 partial as-builts. I believe a few are 100 percent [
-~
1 2 as-builts. Even the partia?. ones did reflect the I
3 information thc.t they had available at the time. The 4
4 reason I'm concerned 10 that that information ;
5 apparently is in .onflict with what you say in 86-52. l
): 6 MR. DURR: We will take this under
! 7 advisement as a concern now. Once we receive the ;
i 8 drawings and we determine that there is a i 9 discrepancy, we may change this thing to an I e
, 10 allegation. J 11 MS. TRACY: He doesn't have the '
I i 12 drawings with him.
13 MS. DURR He doesn't sound too l 4 .
14 positive at this moment that there is a problem. l.
15 MR. TRACY: It's too bad you tossed !
y 16 the other ones he gave you or we would have them i
a 17 right here.
l
\
18 MR. DURR: I didn't say I tossed them,.
19 I said that I usually throw all those things away. I i
1
- 20 don't know whether I still have them or not.
1 d
21 MR. RICHARDSON: I can tell you as an j 22 absolute that I was told to --
1 23 MR. TRACY: Let's move on.
1' 24 MR. DURR: On 2.3, what's your
{
i 1
ie i AarA-wAur rzurnar asrvnTanu, Anv. gzaai rea aris l
=_.
8 107 1 concern?
I 2 'MS..TRACY: My feeling is that we can 3 entirely skip'2.3,sihc6 it's simply a refutation of 4 what you all s o.i d , and it has nothing to do with the 1
5 safety of the plant. It has to do with Doug 6 Richardson's qualif-icati'ons to talk about what he's 7 been talking about.
8 [So let's go on to 2.4.
9 MR. RICHARDSON: I would like to i 10 discuss a couple'of things.
11 MS. TRACY: How about if we skip it 12 for now because our time -- Mike has to leave soon, 13 and I'd rather deal with some of the more meaty 14 issues.
15 MR. RICHARDSON: Your evaluation in 16 2.3 here does not match --
17 MR. DURR: 2.37 I thought we skipped
- 18 that.
19 MR. RICHARDSON: I would just like to 20 note that it does not match the discussion of the i
21 UE&C as-built program in the 8407 report.
22 MS. TRACY: Which we mentioned in 23 here.
I
~
24 '.MR. CERNE: In terms of --
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108 1 MR. RICHARDSON: As-builders having 2 responsibility as to qualifications.
3 MR. CERNE: They have to be qualified, 4 but not as inspectors.
5 MR. RICHARDSON: I was qualified level 6 2R.
7 MR. DURR: That doesn't mean you had 8 to be. That just means you were.
9 MR. RICHARDSON: I was required --
10 MR. CERNE: But that doesn't mean you 11 were an inspector. All QC inspectors were qualified 12 ANSI N45.2.6. As-builders were qualified to other s
13 criteria which may have included some of the criteria 14 used to qualify QC people, but that doesn't mean that 15 you were an inspector because an inspector is making 16 judgments based on the criteria and training. You 17 were documenting things and not making those ,
! 18 judgments.
1 19 MR. RICHARDSON: We were responsible j 20 for identifying non-conformance as well.
r i 21 MR. CERNE: Everybody in the plant 22 was.
23 MS. TRACY: Excuse me. I would really
, 24 rather not deal with this particular issue, f
I AMEA-W1DL t'tD% MAL MLFUMTINu, ANL. (215) 925-5777
109 ,
l 1 MR. DURR: Fine. 2.4, here we go . !
I 2 MS. TRACY: --
as to who was or was <
3 not qualified to-do what or what not.
4 MR. CERNE: What is the status of that 5 though?
6 MR. RICHARDSON: We would like to 7 discuss it later, if there is time.
8 MS. TRACY: Why don't we leave those 9 for discussion later, if there is time.
10 MS. GENTLEMAN: May I ask one question 11 on our prior discussion?
12 MR. DURR: Certainly.
13 MS. GENTLEMAN: Regarding the comment 14 that where a plant meets seisnic qualifications for 15 the piping system and satisfies seismic criteria 16 as-built, but later on when it operates as you 17 mentione6 vitrations appear, you indicated that you i 18 could ask the licensee to add a support to deal with 19 the vibration that shows up during operation. Is 20 that correct?
I 21 MR. RUSCITTO: I would say we would 22 ask the licensee to do an evaluation whether a 23 support was required based on a visual observation 24 vibration. You can't really stand there and watch a f
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110 1 pipe vibrate and determine whether it's an adequate 2 vibration or not because different piping s y s t e n,s 3 have vibration specs. From a professional point of 4 view, you can have a good feel for whether a 5 vibration is excessive. They may go down there and 6 measure it, and even though it looks excessive, if 7 it's within the scope of the code that's applicable, 8 it may not be required. But in some cases, yes, it 9 may be.
10 MS. GENTLEMAN: If their report or 11 study indicates that a support is needed, does the 12 NRC have the authority to order a support added?
13 MR. CERNE: The determination of 14 whether it's needed is based on engineering analysis 15 which we may spot-check. We're not making them put i
16 in the support. Part of the testing program, they 17 instrument all the piping and take vibration ,
l t 18 measurements. If they design something and they say i 19 this is an anomoly, it's not acting exactly, if 20 something is not acting exactly the way it was t
21 designed for whatever reason, their testing and the 22 instrumentation tells them that it's beyond spec in 23 vibration, they would then analyze that and determine
-, 24 whether, even though it's beyond criteria, it's still I
axsa-wius rsutaab acruhiAn6, Aac. (215) 325-5777
l 111 1 acceptable for some other reason, or no, we're going l 2 to address it by putting something into it to fix 3 it.
4 MS. GENTLEMAN: Let's suppose the 5 answer is the second; that it needs to be addressed.
6 MR. CERNE: They determine that.
7 MS. GENTLEMAN: The licensee 8 determines that it needs to be addressed. What if 9 the licensee determines that it needs to be 10 addressed, bu 't cannot address it?
11 MR. DURR: Cannot, or will not?
12 MS. GENTLEMAN: Let's say cannot for 13 financial reasons.
14 MR. DURR: We've never run into that 15 case. That's a case that I am afraid we have never l l
16 had to deal with, where a licensee was financially 17 incapable of dealing with a need. We have never run 18 across that, not in my experience. I don't know if l
19 anybody else on staff has. i 20 MR. CERNE: Once they generate a piece I
21 of paper to identify the problem for resolution, it i l
22 has to get resolved. There is no way of saying well, 23 we'll just leave this thing hanging out there. It 24 has to be resolved. If we disagree, if we in our i
AREA-WIDE FEDERAL REPORTING, INC. (215) 925-b///
112 1 review disagree with their resolution, there's I !
- J 2 mechanisms for the NRC to take action, including 1
3 orders to make them do things. But like Jacque said, 4 we've never reached that point.
5 MS. GENTLEMAN: Okay.
6 MR. DURR: 2.4?
7 MS. TRACY: I think 2.4 raises a 8 number of questions. This deals with the apparently 9 irreparable cracks 1chking groundwater in a variety 10 of buildings. 2.4.3.1 talks about the containment 11 itself where there was no water seepage seen, 12 although there are cracks in the containment concrete
, 13 which you have said are to be expected, and I believe 14 in the pact you have told me that you go out and map 15 them and so forth.
16 I guess the question we raised in 17 this particular part was, if there's a steel liner 18 inside the containment wall, how would you be able to 19 see if there was seepage within the containment wall 20 because it wouldn't seep through the steel liner.
21 MR. DURR: What you have to understand 22 is, there are multiple structures throughout the ,
l 23 United States and the world in water. They are built 1
, 24 in water. A good example is a dam. It's built in l
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1 water. All concrete is porous and water permeates l I
2 through. So concrete and water is not bad. We 3 recognize that. The world knows that.
i 4 If I have a concrete structure and 5 it's in water, but there is no flow, so now I have a 6 steel liner on one side and I've got water coming in, 7 but it can't go anywhere, and I have no flow, that's 8 not bad. Once you establish the basic environment it 9 protects the steel. There is no corrosion of the .
10 reinforcing steel. It's not detrimental to the 11 concrete structure. Ergo, it's not a problem.
12 MS. TRACY: How is it that you know 13 that there is no corrosion of the reinforcement 14 steel?
15 MR. DURR: Because the environment 16 created by concrete itself protects the reinforcing 17 steel. The chemistry of concrete itself creates a 18 very basic pH.
19 MS. TRACY: Literally.
20 MR. DURR: Literally. And we know 21 that that protects the steel in a watery environment.
22 MS. TRACY: Therefore, it's only when 23 that base material leaches out, that you reach a 24 point.
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l 1 AR. DURR: Yes. -j i R
}
J' 2 MS. TRACY: What you're saying is that 1
3 that material will not leach out because there is no i l
4 flow.
5 MR. DURR: No where for it-to go.
6 There'is no flow of water around the containment.
7 MS. TRACY: That addresses the 8 question about the containment possibly having 9 problems. However, what about the leaks in the 10 equipment vault, the primary auxilliary building, the-11 waste process building, and the electric cable tray 12 tunnel where there is flow?
i i r 13 MR. DURR: As we explained in the 14 report, we have taken water samples both inside and 15 outside the walls and looked at chemistries, because 16 here again, that same concrete is protected because 17 of the high basic pH that it sees that the steel is 18 in, and the concrete provides that. So if we don't 19 see a big change in the water chemistry from outside 20 and inside, then we know that that steel is still i
21 protected.
22 MS. TRACY: Right now.
23 MR. DURR: Yes.
24 MS. TRACY: Is this why you have said 71i i
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t 115 1 that it's not a safety problem right now?
I 2 MR. DURR: Yes.
3 MS. TRACY: Meani,ng that if the' base 4 leaches out, and when you do your pH tests it shows 5 that there has been a problem that way, or might even 6 show that there's some rust happening, your water 7 tests could show that, and then you would consider it 8 to be to a safety problem.
9 MR. DURR: But you have to understand 10 that there are a lot of buildings, skyscrapers and 11 everything else, that are below the water table that 12 are constantly seeing water. To my knowledge --
I'm 4
13 not an expert in concrete. Maybe Tony can add 14 something. Suresh is not here. This is his area. I 15 don't know of any concrete structures failing because 16 of water leaching the silicates out of the concrete 17 and --
t 18 MS. TRACY: However, if there was a 19 previous report where it was mentioned that there 20 could be --
for one thing, the water-proof membrane i
21 has apparently failed.
22 For another thing, the report 23 mentioned that this corrosion of the reinforcement I I 24 bar could be a problem in the future. So apparently '
I l I
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i 1 whoever wrote that report --
I don't know if that was I 1 2 you.
3 MR. DURR: We're watching it. We're 4 monitoring-it.
5 MR. MANOLY: All supports of bridges 6 are under water.
7 MS. TRACY: Yes, that's true.
8 Another concern that I had based on 9 both 87-07 and 86-52 was the fact that there are new 10 leaks; that there is not a problem that's been 11 contained; that leaks are increasing, and I 12 understood that this was perhaps due to the fact that 13 they have discontinued their dewatering program 14 because construction is complete.
15 MR. DURR: One of the things you need 16 to remember is -- I don't need to tell you because 17 you were there -- but you had an inordinate amount of 18 rain during that period that we were up there looking 19 at that. The water table is probably much above its-20 normal level.
21 MS. TRACY: Right.
22 MR. DURR: So that would account for 23 the new seepage that you're seeing. When we talk
, 24 about leaks, we are talking about a puddle on the AREA-WIDb YbDbMAL KbFUMTINU, INC. (413) y45-5777
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' 117 1 floor. We're not talking about something that's a t 2 torrent coming in.
3 MS.-TRACY: I didn't imagine a 4 torrent, Jacque, s
5 MR. DURR: .It's like a leaky 6 basement. We're talking about very small amounts of 7 water permeating through the concrete, and during 8 that period they not only stopped the dewaterinc, but 9 you had heavy rains in that area during that period.
10 MS. TRACY: I understand that.
11 One question I have about these leaks 12 and the new leaks as well is, is the plant perhaps 13 settling and that's why these things are occurring?
14 MR. DURR: I'm glad you asked that 15 question.
16 MS. TRACY: I'm sure you are. It 17 sounds like you have a dandy answer.
18 MR. DURR: No. This is where we told 19 you that we had consultants in. We weren't so-much 20 concerned about the cracks because there was water 21 seeping through. We were concerned about the cracks 22 because some of them had the indications that they 23 could have been settlement cracks. We've had 24 consultants from Brookhaven National Laboratory come i
AREA-WIDE FEDERAL REPORTING, INC. (215) yZb-b///
118 1 in and do an independent evaluation and assessment of-2 those cracks in the waste process buildi;.g and the 1 3 other areas, and they say not to worry. That plant 4 is built on solid rock. There is'nowhere it can 5 settle unless New England is sinking into the ocean.
6 MS. TRACY: That could be a problem.
7 MR. DURR: We very well established j 8 that. We had a meeting with UE&C in Philadelphia 9 because that's where their home address is, 10 concerning just these cracks and settlement, and they 11 went back and did a review, plus our people from NRR, 12 and the consultants have looked at this and it's L_j 13 still under review.
14 MS. TRACY: NRR?
15 MR. DURR: Yes, Nuclear Reactor 16 Regulation. His office in Washington, the licensing 17 people.
18 MR. RICHARDSON: Have you identified <
19 the cause for why you've still got leaks developing?
20 MR. DURR: The reason that you have i 21 leaks developing is just as you stated, that the 22 waterproof membrane has obviously been ruptured, and 23 there is nothing you can do about that. That's 7, 24 there.
l l
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119 1 MS. TRACY: So it seems as if you have-t 2 sort of a multi-barrier situation here. You have your 3 waterproof membrane, you have your concrete, and you 4 have your rebar inside, and probably other things.
5 too, like in containment you have your steel 6 membrane. It seems that if there was a waterproof 7 membrane put in there, it was put in.for a good 8 reason.
9 MR. DURR: True.
1 10 MR. RUSCITTO: There is no waterproof 11 membrane. I think Jacque is talking about that in a 12 general sense as a barrier to water. There is no 13 physical piece of plastic or rubber that is installed 14 throughout the wall.
15 MS. TRACY: Are you sure?
16 MR. CERNE: It's on the outside next 17 to the ground level.
I 18 MR. RUSCITTO: It's waterproofing.
19 MR. CERNE: Let's get back to what the 20 situation is now. If you're saying that the i
21 waterproof membrane as designed shouldn't have 22 failed, I'll give that. The point is, you analyze l
< l 23 what you're seeing right now, water coming through l I 1 24 the cracks.
3 l
l
.e l AREA-WIDE FEDERAL REPORTING, ING. (Z1d) yZd-d/))
f 120 a i 1 Are the cracks' structural nature CJ 2 that they would detrimentally affect the building as 3 it's designed? Our answer to that so far'has been no, 4 although it's still under review by people in NRR.
5 The second question, is the water 6 affecting the rebar detrimentally, and the answer to
- 7 that is no.
8 MS. TRACY: So far. And you are 9 monitoring it on a regular basis.
10 MR. DURR: That's correct. '
11 MR. CERNE: And we have open items to 12 track that.
P 13 You want to get back into the process 14 of the way things happened, and we want to look at i 15 the result. Is the plant built correctly as it now 16 stands? That's why when we look at some of these 17 concerns from the back end, we are looking at their i
18 impact at this point in time.
19 MS. TRACY: I understand that. Just 20 as you understand that I attempt to look at the wnole 21 process because I'm dealing with people who have been 22 involved in the ongoing process. So sometimes I i 23 raise issues that may seem as if they're process I] 24 issues, but they actually come down to being things i
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l a l 121-1 thatLyou're dealing with on a very concrete basis, j 2 shall we say.- o 3 MR. GREENSTEIN: Are you saying that 4 there are new cracks developing?.
5 MS. TRACY: Yes. ,
6 MR. CERNE: No, not new cracks.
7 Because the water table may have risen, either by 8 stopping the dewatering process around the plant 9 which is normally only there --
10 MR. GREENSTEIN: There's leakage.
11 MS. TRACY: It's new leaks.
L 12 MR. CERNE: There's new leakage. It's t
13 exposing existing cracks. That goes back to the 14 basis that concrete does crack, and these cracks have
- 15 not evidenced themselves as structural cracks. There 16 are no settling cracks, no shear cracks. These are
'l 17 cracks that don't affect the. structural integrity of r
18 the concrete of the building.
19 MR. GREENSTEIN: And the increased ,
20 water table is just exposing them for the first time.
21 MR. DURR: That's right.
l 22 MR. CERNE: And depending on where the
( 23 water table is in the future, may either expose them )
I :
( 24 again, or not expose them. l l
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t 122 i i 1 MR. GREENSTEIN: You're saying this g '. J 2 problem is under review now. Is there a-timeframe on 3 this review? Is it an open-ended review?
4 MR. CERNE: It's an open-ended review 5 because we've asked the question, whether this would 6 affect anything --
we have to always ask the question 7 for any of our open items, which these constitute-2 8 open items, whether they would affect the delay of 9 the issuance of a low power license,'if it's issued, 10 and our technical experts have come back and said no.
11 MR. GREENSTEIN: So at this point in 12 time it's not a problem.
b- 13 MR. CERNE: That's right.
14 And it's.not a problem for the future 15 as they see it right now because they're willing to 16 give a low power license, aside from other issues 17 that are currently under litigation. On these i
18 specific issues this would not delay issuance of the 19 license because it does not have impact on the health 20 and safety of the public.
21 MR. DURR: I think this is a good 22 example of where a concern was raised by an alleger 1 23 which, during all the review of that concern, we have
~] 24 expanded the scope. Because from a professional I
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t 123-1 aspect of it we looked at ~1t, and we didn't see much 6
2 problem with the water seepage, but we did see crack 3 patterns that caused us concern about the settlement 4 question, shear cracks, structural damage, these 5 kinds of things, which go far beyond.what ELP 6 originally asked.
7 The fact is, we have a structure that 8 we are looking at now, even in more depth than the 9 ones that you were talking about, for totally
'i 10 different reasons, because we went back and took 11 these other looks. These are the ones that we made 12 and resolved in reports. ,
13 MS. TRACY: Are you actually saying we 14 are cooperating?
I 15 MR. DURR: We are cooperating? Yes, 16 we are, j 17 MS. TRACY: I have a couple of other I
18 issues on this particular item. One is the problem 19 with repairing the cracks, in other words, stopping 20 the water from leaking.
21 MR. DURR They attempt to do that.
22 But as every homeowner has tried to stop the water in i 23 their basement, sometimes you're successful, and
( 24 sometimes you're not, i
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t 124 f,
l 1 MS. TRACY: Thus far, it's not been
, -- J 2 successful; is that correct?
3 MR. RUSCITTO: That's correct._ In 4 some areas it has not been successful, i
5 MR. CERNE: In some areas the natural 6 process stops the leak.
7 MR. DURR: It heals itself.
8 MR. CERNE: The leaking of the 9 sulfates and whatever is in the concrete actually 10 plugged up the hole, the effervescents.
11 In other cases they've attempted 12 repair, and it's worked. In other cases they've J
13 attempted repair, and it hasn't worked.
14 Again, back to the bottom line.
15 Assume it doesn't work, and it's not going to work 16 for the 40-year life of the plant. What is the 17 impact?
e 18 MS. TRACY: Yes.
19 MR. CERNE: That's what the unresolved 1
20 items are. l 21 MR. DURR: I guess your original !
22 question, and this is day-to-day, I think, if I'm not i 23 mistaken, but the original question was that they l
]
~
24 used a material other than what he thought should l
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I 125 1 have been used.
I 2 I think from an engineering 3 perspective it doesn't make any difference which one 4 of the crack sealers that you use. Once the 5 hydraulic pressure becomes more than what that sealer 6 can withstand, it's going to leak again. That's the 1 7 question that he's concerned with. He thought they 8 ought to use brand X, and we used brand Y.
9 MS. TRACY: No. He was concerned 10 because he felt that the particular brand that they ;
11 were using would not work. He wasn't recommending a 12 brand himself. He was saying the repair matet 4. a 1 13 that he believed them to be using was not working, 14 which apparently is, at least in some instances, the
( 15 case.
16 MR. DURR: In some cases it works, and ,
I 17 in some cases it doesn't. Here again, it's a i i
18 function of whatever the hydraulic pressure is on the 19 other side, it's going to overcome whatever you put 20 in there. If the elevation head gets high enough, it 21 will seep through whatever you put in.
22 MS. TRACY: It seems almost --
I g 23 hesitate to use lack of structural integrity, the
( 24 problem with these cracks. Seabrook sits on an I
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126 1 earthquake fault. Do you think that these cracks j g.
p ;i -
2 would be -- ;
3 MR. CERNE: That was part of the 4 design review. When we say structural integrity of 5 the building, it's not meaning structural integrity 6 only now. It's structural integrity of the building I 7 as designed capable of withstanding an intensity 8 level 3 earthquake.
9 MS. TRACY: Because you are mentioning i
10 that you checked out whether these cracks could be a 11 problem of settling, and the fact that it's sitting 12 right on bedrock, and I would presume if there were 13 an earthquake, which there are from time to time, <
14 that that would sort of change the situation.
I 15 MR. CERNE: It would, if designed for 16 modified locality intensity level 8 earthquake.
17 These cracks have no bearing upon that design. They 1
18 are not structural in nature to the extent that they 19 affect the design of the plant to withstand the 20 highest earthquake that it was designed for.
21 MR. DURR: Most people don't 22 understand it, but all concrete cracks. !
)
I 23 MS. TRACY: I understand that, l k] 24 Jacque. We've had this conversation many times. All l
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l i l 127 l 1 concrete cracks. All concrete is porous. Yes, I do 2 understand that. I believe you. j i
3 MR. DURR: If you don't believe that, j 4 just look at my patio.
5 MS. TRACY: Maybe it's how you mixed 6 your concrete.
7 MR. DURR: Could be.
8 MS. TRACY: So these tests to check 9 the pH of the water coming through the wall, these 10 are ongoing, the utility is engaged in ongoing tests, 11 and will continue to do so --
12 MR. DURR: Until we are satisfied, or s
13 until they are satisfied and we agree.
14 MS. TRACY: Because it seems to me i 15 that as time goes on the likelihood of the .
16 reinforcement bar rusting heightens as the base 17 leaches out. It seems you could test it for a couple
(
18 of years and things would be dandy, and the utility 19 could say well, it's fine. No need to test anymore.
20 That decision to stop testing could occur right when 21 you might need it the most. So right now, it's 22 considered to be an ongoing program.
j 23 MR. DURR That's correct. l
( 24 MR. RICHARDSON: Did you say that l
1
" "*" " ' " ' ' "'~' "
- _ _ - - - - - - - - - - - - - - - - - - - - - -[ "~" " " " " l
I 128 I
ii 1 water from outside the walls is being monitored as !
giJ !
2 well?
i 3 MR. DURR: We used that as a base l 4 reference. I don't know whether we're testing the i
5 water outside now because I don't think'it's 6 changed. But I think the program that they have does 7 definitely monitor the water coming through the 8 wall. I don't know what the specifics of that test 9 program was. That was Suresh's area.
10 MR. CERNE: That was one of the issues ;
11 that was also turned over to the NRR for review. One 12 of the two unresolved items talks about water 13 chemistry contrc .
14 MS. TRACY: Do you all have any other i 15 comments on this section?
16 MR. DURR: Not that I'm aware of.
17 Let's go on to the next one, 2.5.
I 18 You have no comments on that. That was Cadweld t
19 splices.
20 2.6?
I 4
21 MS. TRACY: I assume this is Harold's?
22 MR. GRAY: That's right.
I 23 MR. DURR: What are your questions
[] 24 concerning the fire protection system?
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l 129 1 MS. TRACY: This deals with the 1
2 problem that was first mentioned regarding the fire 3 protection system, what was first raised by Raymond 4 Lavoy as being as being sediment, but which was 5 defined by you all as being microbiological 1y induced 6 corrosion. And having read, probably not as much as i 7 you have, on the issue of biofouling in 8 microbiological 1y induced corrosion, it seemed that 9 certain ongoing problems, current problems at the i
10 plant were also caused by MIC. So that is our 11 belief. I would like to know -- you might have 12 something to say about that.
I 13 MR. CERNE: Yes. I think the ongoing 14 problems that occurred at the plant, which have not i 15 arisen from allegations, but from licensee identified 16 items which needed correction, and we were informed 17 about them through the proper channels, have given us ;
i 18 an opportunity to look in the service water system, 19 and to visibly inspect the heat exchangers, to 20 visibly inspect the strainers, to have chemical 21 samples taken on the wall where corrosion was 22 exhibited to check for MIC. And the answer is that 23 biofouling is not a problem at Seabrook. MIC is
{ 24 certainly not a problem in the service water system.
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i i 130 I i
i 1 So the premise of your statement is exactly opposite, l ij l 2 borne out opposite by our ability to independently 3 inspect the system because it was open for other 4 problems.
5 MS. TRACY: What caused the pitting 6 and corrosion on the heat exchanger tubing?
7 MR. RUSCITTO: One.was the general 8 seawater copper nickel tubing corrosion lwhich is 9 typical of heat e.schangers, and the other one was 10 caused by cavitation which can also be seen in any 11 fluid system. These are typical engineering problems 12 that are found throughout the industry and have 13 various solutions.
14 MS. TRACY: You're saying it's
"' 15 electrolyte corrosion?
16 MR. RUSCITTO:' Cavitation is the 17 formation and subsequent collapse of vapor bubbles in 18 a fluid stream due to pressure changes. It causes 19 shockwaves when the bubble collapses. We're talking 20 about it on a very small scale now. It will cause a i
21 vibration and errosion of the pipe.
22 MR. DURR: Probably the best i 23 description of cavitation I can give you is, do you i] 24 live close to the water?
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131 ,
i 1 MR. GREENSTEIN: Yes.
2 MR. DURR: Do you ride on boats?
3 MR. GREENSTEIN: Yes.-
4 MR. DURR. Do you see the bubbles. stir 5 up when the turbine starts the propeller?
6 MR. GREENSTEIN: Yes. ,
7 MR. DURR: That's cavitation. Because 8 the propeller changes the pressure of the water and 9 you form bubbles, and those buibles, when they 10 impinge and collapse, they errode away material.
t 11 MR. RICHARDSON: I have another 12 question for you. In one of your recent reports you ,
13 indicated that a check valve on the primary component r
14 cooling system had developed a pin-hole leak. Have 4
a 15 you assigned a cause for that yet?
16 MR. RUSCITTO: Yes. That was not a 17 corrosion problem. That was just a casting flaw i
18 within the body of the check valve. It was not a 19 corrosion-related problem. It's a fresh-water 20 system. L 21 MR. DURR: We seem like we're getting ,
I 22 kind of far afield here. This thing was the fire 1 23 protection system. Do we have anymore questions on
{ 24 the fire protection? ;
l t !
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I 132-
! i 1 MS. TRACY: We go beyond the fire
'. J 2 protection system.
3 MR. DURR: We do?
4 MS. TRACY: Yes.
5 MR. DURR: In 86-52?
6 MR. RUSCITTO: All we're saying is, 7 there is no MIC, and there is no biofouling.
8 MR. CERNE: This isn't an allegation.
9 It's a statement on your part that is attempting to 10 tie an earlier allegation, which was resolved by 11 Mr. Gray, into things that the NRC has identified in i 12 our own inspection reports, and drawing some premise
'2 13 that they're related. We're unequivocably saying 14 that we've looked at that in advance and they're 15 unrelated.
16 MR. GREENSTEIN: Your conclusion that d
17 there is no MIC or biofouling, what is the foundation 18 for the conclusion?
19 MR. CERNE: We've looked inside the 20 service water system which is in question, in which 21 MIC was not discovered --
it's totally divorced from 22 the fire protection system. It was opened up for
' 23 other reasons, some valve problems. At the time it I
-, l' 24 was opened up we had the opportunity to look at the 1
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133 1 heat exchange. We had the opportunity to look inside 2 the pipe. We had the opportunity to look at the 3 strainers to see the amount of debris that had 4 accummulated.
5 It was an extremely clean system, 6 probably because you got a long tunnel that 7 chlorinates. Biofouling wac not a problem. Chemical 8 swab samples were taken on the piping. That chemical 9 swab sampling and analysis will tell you the amount 1C of bacterial contamination on the pipe wall, and it 11 was way below the level at which you would see in microbiological 1y induced corrosion.
t 13 MR. GREENSTEIN: Who did the 14 analysis?
3 15 MR. CERNE: The 31censee and an 16 independent contractor. And we rev'iewed the results.
l 17 MS. TRACY: Who was the contractor?
l 18 MR. DURR: I less to put this in I 19 focus, the original issue was sedimentation in the l l
20 fire protection system. And from that evolved -- the 21 only way we got into microbiological 1y induced 22 corrosion was the fact that that was in conjunction. l r 23 The licensee was replacing some piping at the time j 4
i 24 that the alleger saw other piping that had concrete
- 1 AREA-WIDE FEDBRAL REPORTING, INC.'(215) 925-5777
i 134 ip 1 lining in it, and he assumed that these 2 were
.J 2 connected, and they were not connected.
3 MS. TRACY: No. He saw -- your latest 4 explanation was that he did see sediment. You are 5 allowing them that. But thit he saw sediment in 6 pipes which had been removed from the fire pump house 7 outside the pump house for cleaning.
8 MR. DURR: No. They were concrete 9 lined.
10 MS. TRACY: No.
11 MR. DURR: They were cleaning outside, 12 and there was pipe outside the pump house that was !
13 concrete lined that was also exposed.
14 MS. TRACY: Yes, Jacque, but what 15 Raymond Lavoy saw was not concrete lined pipe. He saw 16 pipe with sediment in it, and that pipe with sediment 17 in it was not the pipe that was in the ground outside 18 the fire pump house. It was apparently, according to 19 your explanation, pipe that had been removed from the ;
20 fire pump house for cleaning outside the fire pump 21 house. So he did see pipe with sediment and MIC in 22 it.
! 23 MR. CERNE: It's granted. Again, at
{] 24 the risk of being adversarial here, let's bring us 1
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s ..
135 1 back to the presel . The fire protection piping and 2 the MIC which was admitted to occur, and which was 3 cleaned up by-the licencoe, has been addressed by ,
4 Mr. Gray in NRC-inspection reports.
5 What you appear to be presenting here 6 is some trans'ition asing our own repbrts to try to 7 tie that with HIC in the service water system ot 8 biofouling in the service water system, which we have 9 said does not exist because we've looked for it.
10 MR. GREENSTEINr Getting back to the 11 original point about the fire protection system, 12 there was some MIC and sediment which'has been 1
4 13 removed. Was there any discussion as to how the 14 sediment got there in the first place?
16 H3. GREENSTEIN: Yes.
17 MR. CERNE: Yes, and basically what i
28 you had is, you had a certain --
fire protection 19 piping was first filled with water from the site ,
'20 which had some organic mechanism -- organic material 21 in it, and as it sat stagnant for several years, or 1 22 over the course of construction the MIC process 23 developed.
( 24 MR. GREENSTEIN: And the pipe was I
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i 136 p 1 removed?
~. J 2 MR. GRAY: The majority of it_was 3 cleaned.
4 MR. GREENSTEIN: Is it a likelihood 5 that this problem is likely to redevelop?
t 6 MR. CERNE: No. We've fixed it. Part 7 of the corrective action was to put -- the-first 8 consideration was for its ozonater, which if you 9 flood the water with oxygen, you'll kill the 10 bacteria, and then the licensee decided to treat it 11 with ultraviolet light which also inhibits corrosion i
,_ 12 of the bacteria in the future. So for future systems
-J 13 where this could occur, like fire protection, the new 14 system that they have in place will prevent it from if 15 recurring. Of course, their water chemistry, we'll +
, 16 continue to check it.
17 MR. GRAY: And another thing, they art 18 using now Seabrook drinking water for the fire 19 protection system, not pump to groundwater. i 20 MS. TRACY: They were using 21 groundwater that was pumped right out.
22 MR. CERNE: Yes. That was part of the 1 23 source of the organic material.
[] 24 MS. TRACY: They weren't using well i l AREA-WIDE FEDERAL REPORTING, INC. (215) 925-5777
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1 137 1 water back then?
2 MR. GRAY: That was a part of the 3 cause of the original problem, the pump groundwater 4 had more organics in it --
5 MS. TRACY: So now they're using 6 treated water.
7 MR. GRAY: -- sufficient organics to t
8 cause this problem under conditions of long-term 9 stagnation. i 10 MR. GREENSTEIN: You're saying they 11 installed ozonaters?
12 MR. CERNE: No. Ultraviolet light.
13 Ozonaters would have been one option. They
[ 14 established the ultrr"' Sst light option.
15 MS. .,n e t : Is that an ongoing ,
16 program, the ultraviolet light?
17 MR. CERNE: Yes.
4 18 MS. TRACY: What do they do? Beam it 19 on the water before it goes into the pipes?
20 MR. CERNE: I'm not exactly sure how 21 the process works, but basically it's at the water
, 22 treatment facility that they actually treat it with 4
i 23 UV. So the water coming into the plant systems -- of l
t 24 course, some of the more critical systems in terms of i
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e 138 ii 1 reactor coolant water and secondary and tertiary
,'_J 2 systems are demineralized water anyway.
3 MR. RICHARDSON: How is that done?
4 MR. CERNE: The demineralizing 5 process?
6 MR. RUSCITTO: It comes through a 7 demineralizing plant that uses demineralizers.
8 MR. DURR: Have you ever seen the 9 little bottles that you get for your iron at home to I
10 take the hardness out of the water that has little 11 pellets in it?
a 12 MR. RUSCITTO: That's a demineralizer.
I 71 13 MR. DURR: It's the same kind of 14 thing.
I 15 MR. RUSCITTO: It's ion exchange.
16 MR. DURR: It's an ion exchange i 17 process. That's what the little brown beads in the 4
g 18 bottle are.
I 19 MR. RUSCITTO: A demineralizer is a 20 big, huge tankfull of that. I I
i 21 MR. RICHARDSON: All right. We're not 22 exposing it to great degrees of heat then?
23 MR. DURR: No.
i] 24 MS. TRACY: I have a question i .
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i l 139 j 1 regarding the fire protection system and why MIC grew i i
2 there. Weren't they doing chlorination for a number 3 of years before 19867 l 4 MR. CERNE: Not in the fire protection i
5 system. Chlorination is in the service water system.
6 MR. RICHARDSON: Your report cites 7 chlorination.
8 MR. GRAY: There is also chlorination 9 in the fire protection system.
10 MR. RUSCITTO: In the pottable water 11 system. That's a different kind of chlorination.
12 MR. CERNE: Not for the biofouling 13 process.
14 MS. TRACY: It's not part of the 15 biofouling treatment prevention?
16 MR. RICHARDSON: The reason I'm 17 curious about that is, that in -- I believe it's 18 discussed in both 86-52 and 87-07 --
there is a 19 statement to the effect that the chlorination was 1
20 instituted in 1983, and that the piping was 21 disassembled in 1986. Why is there a difference of 3 22 years between when the chlorination process was 23 started? The way the report reads it suggests that
( 24 it was in relation to the fire protection i
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t i 140 :
1 1 microbiological problem. If that is the case, why L_
2 was the piping dismantled 3 years after the 3 chlorination program was started?
4 MR. DURR: The question, I guess, is, '
5 where are you going with this. What difference does 6 it make?
7 MR. RICHARDSON: Basically your report ,
8 suggests that a treatment program was started in 9 1983, and that the piping was dismantled and cleaned 10 in 1986.
I 11 MR. DURR: So? 1
, 12 MR. RICHARDSON: What I'm asking is, 13 was the problem discovered after the chlorination 14 program was started? ;
15 MR. DURR: I guess the question is, U
i 16 when did they first discover that they had a MIC 17 problem.
18 MR. RICHARDSON: That's part of the i i
19 question, yes.
20 MR. DURR: Do we know that? t
!t ;
} 21 MR. GRAY: I don't recall the answer 22 to that. :
t t 23 MR. DURR: Is that in a report? I l
- (j 24 MS. TRACY: No.
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141 1 MR. CERNE: I think we have that in 2 one of our resident reports.
3 MS. TRACY: I think that a corrolary ;
4 to the question, or what I was leading to is --
and 5 also when you answered about whether.they're 6 chlorinating that in the fire protection system -- I 7 had understood that chlorination was taking place as 8 part of the chlorination program-to do away with 9 biofouling, and that it was being done in the fire 10 protection system too, which would mean that it 11 wasn't working, if it had been going on for 3 years.
12 MR. RUSCITTO: The chlorination in the 13 fire protection system is related to the chlorination >
14 of the pottable water system for drinking. Just like i 15 any other city water supply, it has a chlorine I
16 residual. ;
17 MR. CERNE: To answer Doug's question, i I
18 and I'm going from memory, but as I recall, the 19 resident report that first addressed it, because we :
20 knew about the problem as soon as the licensee did, i I
21 was at least a couple of years after 1983.
22 MS. TRACY: So 1985?
q 23 MR. CERNE: To my memory, yes. t I
( 24 MR. RICHARDSON: That chlorination I
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i 142
- 1 program then is not intended to address i
l s 2 microbiological corrosion?
3 MR. CERNE: Not for the fire 4 protection. It's intended to address biofouling in 5 the service water system because there's massively 6 more amounts of chlorine because it's not pottable 7 water.
8 MR. GRAY: We may have a conflict. As i
9 I recall, I believe I saw a chlorination system 10 installed in the fire pump house system, and that-it 31 had some intention to act on this MIC problem which 12 had oc urred in the fire pump house.
13 MR. CERNE: It doesn't jive with the 14 dates we are talking about. It could have been used 15 post-discovery of MIC to try to fix the problem.
16 MR. GRAY: As I understand it at this 17 point, as I recall it, chlorination was installed in 18 the fire pump house water system after the discovery 19 of the MIC as a part of the corrective action to 20 prevent it from recurring.
21 MR. CERNE: I have no problem with 22 that statement. What I'm saying is, if they stay i 23 chlorination was installed in 1983, I don't have any
[] 24 facts that would argue that. I'm just saying that if i
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i 143 1 that were true, that was not to combat MIC because 2 they didn't discover MIC in 1983.
3 MS. TRACY: And at1that time they were 4 using groundwater. They weren't using drinking 5 water, which is slightly chlorinated.anyway. So it 6 'seems like there was no chlorination program going on 7 to prevent, to combat or_ prevent MIC in the fire 8 protection system until after the problem was 9 discovered.
10 MR. CERNE: Based on our own confusion 11 from memory here, we would have to go back and get l, J
12 the specific dates. From what I recall, MIC was not
- i 1 13 discovered in my mind until like a 1985 timeframe.
14 So if your dates indicate something happened earlier, ,-
4 15 I don't believe that was related to MIC.
16 Let me read the section which Harold ,-
17 has documented. "Chlorination of the fire system 18 water which was initiated in October, 1983 was noted
! 19 to be in progress. This chlorination was initiated r
20 as a measure to prevent microbiological 1y induced 21 corrosion in the unlined portions of the fire 22 protection system piping".
- t 23 I won't dispute what Harold has 1
i 24 researched, more than I have researched. What I'm i
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p 144
, 1 saying is, they didn't discover MIC prior to 1983.
, _. J 2 They may have had a system in place in part to 3 prevent it, but they didn't identify it as a problem T 4 to be on circa 1985 timeframe.
5 MS. TRACY: My point is that if there 6 was. chlorination going on to prevent it, and after 7 the program had been going on for 2 years they found 8 it to be a fairly serious problem, it seems as if 9 that program wasn't really effective against MIC, i
10 which is why you are doing UV light now, right?
11 MR. CERNE: Yes. '
12 MR. DURR: Also, you have to 13 understand they changed the source of water.
14 MS. TRACY: Right, from groundwater to 15 drinking water.
16 MR. RICHARDSON: When did they change 17 the water source?
18 MR. DURR I don't know.
19 Do we know that?
20 MR. CERNE: What are we getting to, l t
\
21 the bottom line? I'm still failing to see --
l l
22 MR. RICHARDSON: The bottom line is ;
l t 23 this, according to this report, the paragraph that l
1 l
i i
24 you just read, the chlorination program was s
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I 145 1 instituted in 1983. It specifically states that'it (
2 was to prevent a MIC problem. Now, in 1906 we have 3 fire protection piping being dismantled and cleaned 4 of microbiological 1y induced corrosion deposits.
5 MR. DURR: True.
6 MR. RICHARDSON: The timing there, the 7 fact that the piping was dismantled and cleaned 3 8 years after the chlorination program was instituted, 9 appears to suggest that the chlorination program was-10 not effective.
11 MR. RUSCITTO: Wait a second. I don't J
12 know that we know that the fire protection system was 13 in operation in 1983 when the chlorination was 14 installed. Just because the chlorination was 15 installed doesn't mean the system was operating and 16 being chlorinated.
. 17 MS. TRACY: Let's take a break.
18 MR. DURR: At 12:00 o' clock I'd like 19 to break.
20 But what you have to understand is, i
21 you have a lot of unknowns, and we don't have the 22 answers to them either. The unknown is, we don't )
l t 23 know when the MIC occurred. The MIC could have j l
t 24 occurred before 1983, and they finally discovered it l
t l
AREA-WIDE FEDERAL REPORTING, INC. (215) 925-5777 l'
f 146 1 ; 1 in 1986. So we don't know that. There's a lot of ,
. J 2 unknowns.
3 I guess the point is, the bottom f
4 line, that the piping has been removed and cleaned, 5 they've changed the water source, they've introduced 6 new methods for killing bacteria, and we've tested 7 the system, and'everything works fine. So what's the 8 problem?
9 MS. TRACY: I think that one of the 10 reasons why we threw in these other systems, aside 11 from not being completely up on the technological f
12 aspects of things, was it appeared that the i- ,
13 chlorination program for the fire protection system 14 was not working, i 15 MR. RUSCITTO: I don't think you can 16 draw that conclusion based on the fact that we don't ,
17 know that the fire protection system was operating in i 18 1983.
19 MS. TRACY: Right. I agree with you j 20 that we have raised more questions --
21 MR. CERNE: You're stilling trying to 22 jump over the service water system, and that's not an 23 allegation. That's some premise you have put l 24 together based on an allegation which has been i l
t AREA-WIDE FEDERAL REPORTING, INC. (215) 925-5777 l
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1 147 1 already investigated, and our own reports which t
2 identify inspection issues --
3 MR. DURR: Let's solve one problem.
4 Is your prcblem with the fire protection system? Do 5 you have a problem with the fire protection system?
6 MS. TRACY: I'm not sure today.
5 7 MR. DURR: We've looked at it. We've 8 tested it. We've watched them test it. We were 9 physically there when they ran water through it and i
10 performed the test. The authorized nuclear inspector 11 for the insurance company was there. We watched him 12 do his thing. We know the system works.
I 4
13 MS. TRACY: Who was that inspector, by 14 the way? Do you recall?
i 15 MR. DURR: I don't know.
16 Do you know, Harold?
17 Harold was with him.
! I 18 MR. GRAY: The company's name is 19 there. ,
20 MR. CERNE: Kemper Insurance Company?
i1 l
21 MR. GRAY: No. This is different.
22 This is a company who insures the buildings against t 23 fire loss, as opposed to the authorized nuclear
{ 24 inspector. It's a different ballgame altogether.
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.4 148 e i 1 MS. TRACY: Is it a different company
,L J 2 entirely?
3 MR. GRAY: I gave you the company name 4 in the report.
5 MS. TRACY: I think you did.
6 MR. DURR: Hartford, or something like -
7 that.
8 MS. TRACY: Yes.
9 MR. CERNE: Do you have a problem with 10 the fire protection, or are you trying to flow it 11 over to the service water system?
12 MS. TRACY, Yes.
I 13 MR. D U F'A s Because right now we don't '
4 14 have a problem with the fire protection system. Is e 15 there a querstion you need to ask on the fire 16 protection system?
17 MS. TRACY: I think that at this time 18 you have answered my questions about the fire i
19 protection system.
20 MR. DURR: Now, are there peripheral 21 issues that you think that you want to discuss 22 concerning this issue?
r 23 MS. TRACY: My feeling is at this
~] 24 point we have discussed the peripheral issues that I
{
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i 149 I wanted to discuss.- 1 2 MR. RICHARDSON: I would like to ask 3 one question. If the chlorination process in the J 4 fire protection system may not have worked, 5 suggesting it as a possibility because it was 6 dismantled and cleaned in 1986, 3 years after the 7 chlorination procedure was instituted, are there 8 other procedures, other than chlorinization, to treat 1
9 service water, and if not, is it possible that a ,
l 10 chlorinization process may not work in that system.as 11 well?
12 MR. CERNE: First of all, you're 1
)
13 talking about much different doses. There are other l 14 processes, like thermal backflushing of the system.
, 15 Where you bring in water, you throw heat out.
16 Secondly, you're talking about salt ,
17 water versus pottable water.
18 Thirdly, you're talking about an I
19 ocean supply which is 3 and a half miles out.
i j 20 The systems that could be i
21 detrimentally affected by, for example, the 22 biofouling, having strainers in the system, and the i 23 microbiological 1y induced corrosion, you're talking i
i 24 about inspection processes which look for it.
4 4
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3 150 r 1 And I guess finally I would_just say -
~
2 that the reason we haven't suspected it to date is l
3 that we've checked for it in our most recent L -
4 inspections, and it hasn't existed. It doesn't exist 5 right now.
6 MR. DURR Is your question relative l l 7 to the fire protection system? :
8 MR. CERNE: No. The service water l
i 9 system -- j 10 MR. DURR: Let him answer.
11 Is your question relative to the fire 12 protection system and the chlorination? Given the 13 fact that it may not have worked, how are we 1
14 convinced that we don't have a problem? Is that the 15 question in fire protection?
16 MR. RICHARDSON: That basically is the 17 question.
18 MS. DURR: Correct me if I'm wrong, 19 Harold, but on a periodic basis the fire protection f
20 system is tested?
21 MR. GRAY: That's correct.
22 MR. DURR Flow tested. We run water i
1 23 through it. We make sure that it works, and that's
[] 24 on a periodic basis.
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1 151 l 1 Now, I can get my fire protection '
2 engineer in here, and he'll probably give us a whole 3 lot more details, if he's in today. But those 4 systems, they do fire drills. We witness the fire-I 5 drills. We witness them hooking up the hoses and all 6 those kind of things.
t 7 So from a fire protection program (
8 aspect we have a separate group, a separate gang that 9 goes out and looks at fire protection. We do indepth 10 inspections in fire protection for all power plants, 11 including Seabrook. So I really feel comfortable 12 that I don't think we have a problem here. If MIC ,
.e 1
13 re-occurs, I think it will be detected, and 14 appropriate steps would be taken to fix it because we i 15 have an inspection program that goes back and looks
- i 16 at the fire protection system.
17 MR. RICHARDSON: Are you also covering !
I j 18 the other freshwater supply systems as well?
1 19 MR. DURR: What freshwater supply :
a 20 systems? -
21 MR. RICHARDSON: Primary component, :
l
, 22 secondary component --
t 23 MR. DURR Those are closed-route t 24 cooling water systems.
l
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152 r1 1 MR. RUSCITTO: You're talking about a 2 very heavily chromated system. I am not aware of MIC 3 occurring in a system like that.
4 MR. RICHARDSON: What are you !
5 chromating? ,
6 MR. RUSCITTO: Potassium chromate is 7 put in the system -- ;
8 MR. DURR: It's a corrosion inhibitor.
9 MR. RUSCITTO: -- to inhibit corrosion 10 of those systems. '
11 MR. DURR: It's like the stuff you put 12 in your radiator. It's not ethylene glycol to
-J 13 prevent it from freezing, but there's also a f
14 corrosion inhibitor that's in your radiator.
15 MR. RICHARaSON: It's inhibited as a 16 biocide, or just as a corrosion inhibitor? ;
17 MR. DURR: It's a corrosion inhibitor.
i 18 MR. CERNE: They're closed systems, 19 and they're supplied from chemically controlled '
i 20 environments. They're not hooked into the pottable !
21 water supply, like fire protection. !
22 At the expense of being ruda, I'll l t 23 say that even though Jacque is talking about fire :
-, l lI , 24 protection piping, because that's the allegation that l t
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153 ,
I was raised, we don't have an allegation-before us 2 that talks about MIC in the service water system. !
3 You have raised, in my mind, some 4 contentions which try to bridge a gap between MIC in 5 the fire protection system which everybody agreed 6 occurred, to the potential for it occurring in the 1
7 service water system, and our inspections have looked 8 at and documented the fact that that is currently not 9 a problem. That's where we stand. We have no i
10 allegation that we're pursuing in the service water l 11 system with respect to MIC. (
2 12 MR. RUSCITTO: I think that anything 13 else is pure supposition on anyone's part, and we're 14 just as interested as you about future possibility of !
( 15 MIC. But to give it anymore effort, I think would be f,
, 16 inappropriate. i
. 17 MR. DURR: That whole question is
( '
18 under the Hearing Board. I don't think we need to ,
l 19 pursue it any further. That will be addressed later 20 to everybody's satisfaction, I would hope.
~
21 At this point in time I think it's
- 22 appropriate that we take a break for lunch. It's
]I 23 12:00 o' clock. Let's say, we reconvene at 1:00, i i
l i 24 With that, I close the record. l l
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~~ ~
7 g 1 tJ !
2 (Whereupon a recess was taken at this time.) '
3 4 (The meeting resumes at 1:00 o' clock).
5 ... l i
6 MR. LURR: Did we finish with section 7 2.67 Were there any additional questions?
,t 8 MS. TRACY: I think for the moment 1 9 we've finished with that.
10 1 would like to, once again, refer to 11 this proposed agenda that I brought which refers to 12 the end part of this report and see if we can deal l 3
'J 13 with some of these issues.
- I would like to get this q
14 entered into the record as my understanding of what 15 this meeting was to concern, and then look at some of 16 the specifics in here. So is it all right with you i 17 to anter this into the record? t 18 MR. DURR: I don't have a problem with !
- 19 entering it into the record. I am reluctant to i I 20 divert from what we were discussing in sequence here l
) 21 for fear that something will remain undone. If we 22 pursue it in an orderly fashion, we'll get through l t 23 all of them because it's not our intent to go from m
, ;g 24 beginning to end here to answer your question.
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i 155 1 MS. TRACY: My feeling is that our i
2 time is fairly ~1imited now. We have about 1 3/4 hours 3 left, and there are some fairly overriding cancerns 4 that are at the end here which are organized in a 5 fashion in this agenda. What I would like to suggest 6 is that we touch on some of these, and then if we 7 have time, go back. I would rather deal with these 8 then find ourselves in an hour and 3/4 not to have 9 dealt with these at all, if that's all right.
j 10 We could perhaps call this Exhibit 11 A.
12 MR. DURR: However you would like to 13 include it in the record.
14 (Whereupon the proposed e.genda was j
- 15 marked as Exhibit A).
- 16 MR, DURR
- What specific part of this 17 agenda would you like to address?
18 MS. TRACY: First, let me say that it
] 19 was my understanding this meeting was to deal with 20 procedural issues that had not necessarily been fully 21 addressed in 86-52 or 87-07. In order to conserve 22 our time, and since we have those issues listed, l' 23 perhaps we could concentrate on a couple that are of 1- 24 particular concern. Essentially what this does is, I
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i 156
- ; 1 it lists the overriding concern, and then it lists
- J ,
2 the different allegations that have been made to our 3 project that support these concerns. So under 4 quality assurance / quality control I would like to 5 look specifically at F, I, J, 0, O and S.
6 MR. DURR: F, I, J, O and S?
- 7 MS. TRACY
- Q and S. Under document
> 8 control --
9 MR. DURR: Let's do them sequentially, i
10 and then we'll get them done. What is your specific
, 11 question for 2(F)? I haven't had time to read them 12 all, but from what I have glanced at they all were 13 discussed in either 86-52 or 87-07 in some form or 14 fashions is that correct?
15 j MS. TRACY: They were acknowledged.
16 They were not necessarily discussed in the sense that i 17 these are not specific technical issues that you can lr 4
18 go and look at the particular weld, and for that l 19 reason you did not discuss them in any kind of j ,
20 detail.
21 MR. DURR: That's correct.
22 MS. TRACY: However, it's our feeling 4 1 23 that these procedural problems, what you call
{] 24 procedural problems in 87-07 are issues which point
)
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1 to overriding safety concerns about the plant.
2 MR. DURR: How?
3 MS. TRACY: In that they point to the 4 fact that, for instance, quality assurance / quality 5 control had some serious problems. If quality 6 assurance / quality control had some serious ptchlers, 7 then the safety of the equipment inspected, the 8 systems inspected is also questionable.
9 The same thing with, for instance, 10 document control. You all make a lot of your !
11 judgments based on the utility's documents. If there 12 is a problem with the documents, an unrecognized f 13 problem with the documents, then the information that 14 you base your inspections on is also questionable.
i 15 MR. DURR: To answer that question, to r i
16 respond to that, you have to understand that the NRC 17 did, in fact, look at the licensee's documents. They i
18 also did hands-on inspections. We did as-built 19 inspections, not only after the plant was built, but [
20 we did hands-on inspections while the plant was being 21 built. So throughout the construction of the plant f 22 there was essentially nearly a continuum of audits !
1 23 being performed, not only on the hardware and the ;
1 1 24 installation and the implementation of the AREA-WIDE FEDERAL REPORTING, INC. (215) 925-5777
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- 1 procedures, but the quality assurance aspects of the t . J 2 plant itself, and the implerentation of the 3 licensee's quality assurance program.
4 i 4 One of the main underpinnings of the i 5 NRC's inspection program was that by rule we require 1
6 the licensee to have their own quality 7 assurance / quality control pregram. We require them 8 to put the people in place and to have a viable 9 program, and we audit to insure that that quality I i
10 assurance prograr. is viable and functions.
11 Now, are you saying, were there 12 isolated cases wherein people didn't follow 0J 13 procedures? More than likely. Here again, that's 14 the human element, and you can't make that an i 15 absolute. No one can make anything like that 16 absolute.
17 MS. TRACY: But we are not saying i
18 there's been isolated cases.
l 19 MR. DURR: We haven't seen anything to 3 20 indic te that that's true. Witness the fact that if ,
9 i 21 there were serious breakdowns in quality 4
22 assurance / quality control, they would have manifested 1 23 themselves somewhere in the hardware because that's
)) 24 the ultimate concern. Those programe, are in place to i
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159 1 insure that the hardware, the physical plant itself 6 2 is built according to the design and the intent. So 3 if there were series breakdowns withln that program, 4 which I'm not sure that at this point ip time anybody 5 !
vould ever be able to prove or disapprove, then what i 6 we have to look for is where did that manifest itself ,
7 as a deficiency in the plant.
8 With all the allegations that ELP has j 9 given us and other allegations, we have not been able 10 to ascertain that it has manifested itself in a 11 deficiency within the plant, and that's what's 12 important. Because whether the QA/QC program did or I
13 did not function appropriately back during the I '
14 construction of the plant, I don't think anybody can j< 15 determine that today. That's history.
] 16 So what we have to be concerned with 17 is, how did that show up in the plant as a 18 deficiency. And not only through our construction i
19 program, but through our construction inspection 20 program, our as-built programs, our independent !
I j 21 design audits, and the focused allegations that you !
l l 22 have given us, we have not been able to show that I i
i 23 quality assurance was deficient in any of those i l
i 24 instances. Ergo, we have to assume that that still is AREA-WIDE FEDERAL REPORTING, INC. (215) 925-5777
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, t r
r1 1 true; that quality assurance / quality control did not :
'. J 2 suffer from significant breakdowns because we don't .
! 3. have anything to prove counter, j 4 MS. TRACY: You may feel you need to !
5 assume that. However, having talked to a number of 6 quality assurance engineers, who all had serious 7 criticisms of the program, who were told that they
]
l 8 'were -- forced might be too strong of a word --
were i 4
k r 9 pressured in a serious way to pass on equipment and i 10 items that they did not feel comfortable about, and 11 that that was a continuing procedure that they were l l ;
12 subject to, and that if they were too careful in I
l 13 their checking of quality assurance, that they would I r
, 14 face firing, that is a concern which reflects on the :'
! 15 safety of the plant. Because they are talking about, f j 16 not just isolated instances, but about an ongoing 17 situation that they had to deal with. j 4
i j 18 MR. DURR: If that's the case, then >
i 19 they need to give us a specific where that pressure 20 resulted in a deficiency in the plant that they f I 21 bought off or were forced to buy off on, and they l
j 22 know it's deficient, and we can go out and inspect !
- 9 23 that and confirm that, and we can verify that very I
, 24 aspect. If those individuals have knowledge of just f
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s 161 1 that condition, we can inspect that. All they have i I
2 to do is give it to us, and we can verify that, and 3 then we can make that case.
- 4 But as to date no one has been able 5 to give us a specific that resulted in an equipment 6 deficiency that we can go out and inspect and verify 7 that yea and verily the quality assurance / quality 8 control program did not function. We don't have 9 anything, and that's what we keep asking for you-to
- 10 give us. If you have that kind of knowledge, we need 11 that very specific information because that will 12 prove your case. ,
^
i 13 MS. TRACY: It seems that we're caught 14 in a ' Catch 22' because these people no longer work i 15 at the plant. They d$n't have access to the kinds of -
, 16 records that they need to exactly pinpoint their ;
j
] 17 concerns, t
18 Another part of that ' Catch 22' is if l
)
19 they were to exactly pinpoint their inspection l l
20 sheets, then they themselves are pinpointed, and 21 they're absolutely positive that they would be l
22 blacklisted. Many of them still work in the nuclear j
' 1 t 23 industry. So it is, as I say, a ' Catch 22' type j
( 24 situation in many cases. They don't have access to l l
l
]
I l
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11 162 g i 1 the proof that you need to even investigateLit ;
4-a j 2 because it's proprietary information at the plant.
3 They didn't leave with the documents.
4 MR. DURR: I understand that, but the j 5 individual having that kind of knowledge would be ;
6 able to point out.some specifics,.or at least give us 7 an area to look in. For instance, if he just~ says !
pipe supports in a certain area, we can go look at
~
8 9 pipe supports in a certain area. We've looked at 10 hundreds, literally hundrods of pipe supports', end we -i 11 couldn't find anything wrong. ,
12 MS. TRACY: What you're saying is that !
it's irrelevant to you whether or not quality 13 i i
14 assurance works.
15 MR. DURR: It's not irrelevant. No, '
16 it's not. I i
17 MS. TRACY: Because what is relevant 18 to you is the results of quality assurance / quality i 19 control. If this person says I was forced to pass on !
20 X number of welds that I was not'sure about --
l 21 MR. DURR: I understand. l 22 MS. TRACY: --
and they weren't sure. ;
i 1 23 And you say okay, show me exactly those welds. Now,
! , 24 this might have been in the course of 3 days of work l I
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T l 163 1 and they had worked there for months. You go and i
2 look at those wolds, and you say well, there's no 3 problem with these welde, then it's resolved to your 4 satisfaction.
I 5 That does not deal with the issue 6 that quality assurance did not work. As a procedure 7 it did not work because people felt pressured to the 8 point where they went along with what the utility 9 wanted, rather than reporting problems, i
10 Another example, perhaps an example 11 of that is, I'm sure you're aware of the case of 12 James Padevano, who fa1s'.fied documentation on
(~
13 apparently thousands of wilds, was arrested, 14 convicted, and hc3 subsequently aaid that he was a
' 15 scapegoat, and it's my belief he probably dio' it to 16 more of an extreme defree than other inspectors, but 17 he said that he wac a. scapegoat; that what he did was i '
18 common practice. That has been substant.iated by 19 other QA people who I've spoken with who s. aid, it's l 20 too bad about JI2 m e s . He was a little extreme, but 21 what he did was not unusual. To me it would secd 22 that would be a matter of concern.
RRJ. DURR: It is a matter of concern,
~
I 23 i 1
( 24 and we looked at that. But based on the fact that we i i I AREA-WIDE FEDERAL REh0RTING. INC. (215) 925-5777 D- _ _ .
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i 164 i I can't find anything wrong, even before the t _
i 2 allegations came in, we've gone back and looked at 3 our. inspection record, independent of all that. We 4 don't find any underlying problems'there, other than 5 the ones that were identified, addressed and 6 resolved.
I 7 Granted, there were problems back 8 there. Our inspection reports reflect that. It also 9 reflects the fact that we followed those things to i
10 resolution. So we aren't just saying that we can't 11 find anything wrong. Ergo, we're not worried about 12 it. That's not true. I don't think that's a proper
- I 13 characterization of it. We are always concerned.
14 What I'm saying now is, whether it i 15 did or didn't work back then becomes moot when you go 16 look at the final as-built condition of the plant.
17 We have thoroughly looked at the hardware. We have i
18 thoroughly reviewed the start-up and testing 19 process. We had somebody up there almost 20 continuously through that start-up testing program 21 and the pre-operational tests. All of those things 22 are designed to make sure that that plant is safe to i 23 operate. So far we don't find anything to indicate 1
, 24 otherwise.
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i 165 1 Now, granted there is_ underlying-f.
2 concern in the community about the safety of the 3' plant, and we appreciate that.
4 MS. TRACY: It's n o t' just the' 5 community, Jacque. It's people that work there who 6 built it.
7 MR. DURR: You have'to understand that 8 we can't convict them until we have some evidence.
9 We don't have any evidence, concrete evidence that's 10 going to convince anybody that that plant is unsafe.
11 I cannot make hollow allegations about the safety of 12 that plant. I have to have something substantial to 13 prove my point. That's what we are asking for, ano 14 so far it's not forthcoming. Everything that we have 15 chased, we already knew about it, and we were already 16 pursuing it. The licensee had properly documented it 17 and had identified it himself and was pursuing it.
( 1 18 We have multiple indications of where people saw 19 things that they thought were wrong, and they have 20 been at that point in time wrong, and they were 21 pursued within the program, 22 MS. TRACY: Let's talk about some of i 23 these specific issues, f 24 MR. DURR: Okay. Which one? l AREA-WIDE FEDERAL REPORTING, INC. (215) 925-5777
~1 166 i 1 MR. GRAY: Do you want to try "I"?
j '. _
2 MS. TRACY: Let's deal with F for just 3 a second.
4 MR. DURR: Okay.
5 MS. TRACYi When construction 6 procedures were violated, procedures were rewritten
' Procedures were 7 to allow the violations to stand.
8 implemented to eliminate inspection tests.
9 Was that a common way of dealing with i
10 problems when construction procedures were violated?
11 MR. DURR: In F, here we don't have 12= any specifics, do we, just this statement? We have dJ 13 this statement as it stands by itself. We don't have 14 any specifics to point where things were changed i 15 improperly to circumvent some problem. We don't have 16 anything of that nature. So all we're going on is 17 this statement. This is the alleger's f
18 characterization of what he thought he saw.
19 Do they revise procedures? Yes. Are 20 procedures rewritten because there may be a design 21 problem or some other underlying problem? Yes, and 22 there is mechanisms for them to do that, but it has i 23 to be reviewed and engineeringly acceptable to do i , 24 that. They just can't arbitrarily go out and say i
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167 1 gosh, I can't do this. I'll rewrite the whole 2 procedure to go around it.
3 That's all a controlled process. That 4 all comes under that umbrella of quality assurance.
5 We require them to have procedures that allow them to 6 make these changes in a controlled manner.
7 MS. TRACY: Let deal with "I".
8 MR. GREENSTEIN: Can I ask a question?
9 MR. DURR: Sure.
10 MR. GREENSTEIN: During the 21,000 11 hours that the NRC was doing inspections, did NRC 12 personnel ever witness any violation of construction 13 procedures?
14 MR. DURR: Oh, yes.
15 MR. GREENSTEIN: Was it endemic?
16 MR. CERNE: Endemic in the sense that 17 the causal analysis had root in some generic problem, 18 no. But it has to be reviewed for that reason.
19 There may be a cause that goes beyond the individual 20 guy who just failed to follow procedures. Maybe there 21 was a training problem, maybe the instructions were 22 written unclearly, maybe really what they were asking 23 him to do was too rigorous, and code allowed looser 24 things to be done. That's what Jacque was referring i
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168
[
g 1 to. Sometimes you can change procedures, and still
. J 2 meet the construction codes.
3 All those things are reviewed, and 4 when we do write a violation for failure to follow 5 procedures, which is a violation of 10 CFR 50 6 Appendix B, we request the licensee, not only to 7 address corrective action for a specific violation, 8 but also how they will correct it to prevent it from 9 occurring again.
10 MR. DURR: Where it has implications 11 of spilling over into other areas, we also ask them 12 to address that particular aspect. So they just
{n LJ 13 don't solve John Doe not putting in something 14 properly, but look at the broader aspects of why did 15 that occur, and what other areas could have been 16 impacted by that same deficiency.
17 MS. TRACY: Doug, did you have 18 something you were going to say about that?
19 MR. RICHARDSON: Yes.
20 I remember back in 1986 I told you 21 that the B31.1 as-built program had been dropped 22 because it was getting too costly to implement, at i 23 least that was my understanding. It seems to tie in ;
li] 24 with a number of problems that Pullman-Higgins had at I
AREA-WIDE FEDERAL REPORTING, INC. (215) 925-5777 i
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I-169 1 that time. The conditions that were going on'at that i
2 time appear to have been continuing for sometime 3 after that. In the 84-07 construction assessment 4 team report it is also mentioned that that --
I 5 believe it was the piping support as-built program 6 was dropped. This was conducted by United Engineers
' 7 at that time; is that correct?
8 MR. CERNE: Well, Pullman at that time 9 was still doing the pipe supports.
10 MR. RICHARDSON: Pullman was doing QC, 11 I believe, and United, if I remember correctly, was 12 doing the as-built work.
13 MR. DURR: Can we find the specific 14 point in the report?
I 15 MR. RICHARDSON: Yes. It takes a 16 little bit of discussion to get to.
17 Basically United's piping support i
18 as-built program had been identifying deficiencies in 19 approximately 75 percent of the supports they looked 20 at. The reason that the as-built program was dropped 21 was claimed to be because they were overly 22 restrictive in their identification of welding i 23 deficiencies. But the deficiencies that they were
{ 24 identifying extended far beyond simply weld i
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- 1 deficiencies.
2 MR. DURR: Is this the B31.1 3 as-built?
4 MR. RICHARDSON: I don't know if this 5 is B311 or safety. I believe at the time the CAT team 6 was looking at safety equipment, but I.am not 7 completely sure. We can find that out easily enough 8 by going through the report.
9 At the time I was working for Pullman 10 I was told not to write non-conformance reports in
^
11 such a way as to indicate that Pullman craft people 12 were to blame; that basically that they had done
'"O ,
' I 13 faulty work. It appears from the discussion in the 14 reports up and through dealing with that era that 15 Pullman r.as under a lot of pressure at the time for 16 the quality of their work. They got a 3 in the SALP 17 in '82, and a 3 in the SALP in '81, and the '80 SALP 18 was said to have been pretty bad. At the end of '82 19 there was a massive reorganization of Pullman's 20 responsibilities; is that correct?
21 MR. CERNE: I think it was a little l l
22 bit later area, but you are correct. There were 1 23 several recurrent SALP's where piping and pipe j_g 24 supports was a problem, a problem in the sense that l
l i
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( 1 171' 1 that we gave them a category 3.
t i 2 MR. RICHARDSON: Some of the stuff I
3 that shows up, for example, in the '82 CAT, you have I 4 engineers who are dispositioning NCR's, particularly 5 the ones that were dispositioned accept as is. Your 6 inspectors reviewed something over 100 NCR's. The 7 wording of that report indicates that not some of the 8 ones that were accepted as is, but enough of a 9 majority of the ones that were marked accept as is, 10 that they simply said those marked accept as is were 11 not adequately reviewed, and that the engineers who 12 did those reviews were not qualified to do that.
4 4
13 If this is the case, how can you be 14 sure that they were reviewed adequately all the way 15 along the line?
16 MR. DURR: We said that in our 17 inspection report 86-52?
(
18 MR. RICHARDSON: I'm sorry. 82-06.
19 MR. DURR: That's outside the scope of 20 this. This is 86-52 and 87-07.
I 21 MR. RICHARDSON: That inspection was 22 done at the time period approximately that I was i 23 working at Pullman. I told you about problems that I
( 24 thought existed in Pullman's as-built program that t
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I 172 I, i 1 appear to be related.
'(_ J 2 MR. DURR: I don't follow you.
3 MR. GRAY: 82-06 was done during the 4 time that everybody was laid off at the site.
5 MR. RICHARDSON: No. That was 84-07.
6 MR. CERNE: 82-06 was the team you led 7 up there, Jacque, the original CAT.
8 I feel that you are taking our 9 inspection reports and saying that we're smart enough 10 to identify items, but we're not smart enough to 11 resolve the resolution of the problems we 12 identified.
1 LJ ~3 We identified that there were problems with Pullman-Higgins. We awarded category 3 15 ratings because areas needed correction. Those areas 16 were re-reviewed, and there were some recurrent l ', problems. Jacque's report, the recurrring or 18 repetitive resident reports, the specialist's reports 19 all contributed to those findings that led to those !
20 SALP ratings. So if you say were there problems at ;
21 that time, without getting specific, yes, there were.
22 Otherwise, they wouldn't have gotten category 3 1
1 23 ratings. I guess what Jacque is saying and what I'm I] 24 saying is, what does that have to do with this issue I l l
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't 173 1 that is the subject of the ELP allegations at this t
2 point?
3 MR. RICHARDSON: According to your 4
4 reports, then and on to about '84 apparently there 5 was in this area inadequate review of the NCR's as to 6 whether the accept as is dispositions were really 7 valid. In the 1984 CAT there is an extensive 8 discussion of failures by the United as-built crew to 9 identify and properly record non-conformances.
10 MR. DURR: I'm curious. What is the 11 point that you are trying to make?
12 MR. RICHARDSON: Given that you've got i
13 failures over this long period of time to adequately 14 maintain a quality assurance program, how can you say 15 that the quality assurance program demonstrates that 16 the plant is safe, when you've got non-conformances 17 that weren't evaluated properly, non-conformances 18 that weren't answered, that weren't properly 19 reporte6?
l 20 MR. DURR: Let me answer your l l
l 21 question. First of all, when you say quality j 4
22 assurance / quality control, there were a multitude of 23 contractors on that site, Pullman-Higgins being i 24 one --
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i
i 174 r, 1 MR. RICHARDSON: But a.Very important g_
2 one.
3 MR. DURR: -- which we singled out as 4 being a recalcitrant performer. The NRC identified 5 them as a poor performer, and we applied pressure to 6 the licensee to get that act straightened up, so to 7 speak. Is that correct?
8 MR. RICHARDSON: That's my ,
9 understanding.
10 MR. DURR: Now, you have-to understand 11 that Pullman-Higgins --
but there was also a civil 12 structural contractor on site, there were people
[lI 13 putting in the HVAC, there's the electrical 14 contractor. You have to understand, all those 15 aspects, nobody has ever attacked that. So to have a 16 total breakdown of the quality assurance program you 17 have to have all these people making mistakes, and 18 that wasn't the case. That's not what I'm hearing.
19 What I'm hearing is, you have a 20 specific problem with the Pullman-Higgins quality 21 assurance / quality control program which we-22 identified, and which we forced the issue to get the 1 23 licensee to straighten it out. So now, what's the l, 24 problem?
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I 175 1 MR. RICHARDSON: Part of the problem 2 is that Pullman's deficiencies were identified for a 3 period ranging for several years and were not 4 corrected.
5 MR. DURR: That's right. But we 6 finally fixed that problem. That's all acknowledged
. 7 in another report.
8 MR. CERNE: There is a r.o t h e r factor 9 here that bears directly on the point you're trying 10 to make. You're quoting from obr SALP's, and our 11 SALP's clearly identify in the write-ups, if you will 12 research them, that the problems that were identified 13 with Pullman-Higgins were primarily process control 14 problems which did not necessarily result in i 15 deficient hardware.
16 MR. RICHARDSON: Then how do you 17 account for 75 percent of the supports that the I
18 United as-built team were inspecting showing up with 19 deficiencies after they've been through Pullman's 20 QA? And this is in 1984. Your problems were I
l 21 supposed to have been corrected. 1 1
22 MR. CERNE: We've reviewed that g 23 process --
it's a long story that has nothing to do
{ 24 with the ELP allegations. But the as-built ig AREA-WIDE FEDERAL REPORTING, INC. (215) 925-5777 1
i 176
- i 1 inspectors were using different criteria than would 1 g Ca 2 be used by QC inspectors in determining what was 3 acceptable and what wasn't acceptable.
4 MR. RICHARDSON: Why would they be 5 using different criteria? Aren't'we all supposed to 6 be working toward the same standards?
7 MR. MANOLY: What deficiencies are you i 8 referring co? You said 75 percent. In what area?
9 MR. RICHARDSON: Let me find the 10 report. It's your 84-07 consttuction assessment team 11 report.
12 MR. CERNE: The as-built inspection I '
13 criteria are different. The whole process of 14 as-building is to document, like you were doing, i
15 dimensions and things that can be done for stress 16 reconciliation of the piping program.
17 The QC inspection is totally f
18 different, like we were talking about before. A QC 19 inspector makes a judgment based on criteria which he 20 has to be trained for. There is a big difference 21 between as-built inspection -- it's not even 22 inspection-- the as-building process, and the QC l
t 23 inspection program. I 1
I 24 MR. RICHARDSON: We were trained l f
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f 177 1 through probably the same criteria. I had a Leve] 1 1
2 certification --
3 MR. DURR: You're making statements 4 that I don't think that you can adequately support, t
5 Doug. Were you ever a quality assurance / quality 6 control inspector?
- 7 MS. TRACY: I think that's fairly 8 irrelevant in the issues that we are discussing here.
9 MR. DURR: No. He's making assertions 10 here and casting dispersions about a program, and I'm 11 trying to figure it out.
12 What's your technical qualifications t
13 that allow you to do this?
14 MS. TRACY: We've been through this
- 15 before.
16 MR. RICHARDSON: The information that l
17 we generated was used in preparing --
I 18 MR. DURR: The last time we talked l 19 about this, I asked you what your job title was, and 1
20 you didn't even know what your job title was. l t i 21 MS. TRACY: We're getting off the l 22 track. j g 23 MR. DURR: No. He keeps bearing down f 24 on this point, trying to make these assertions that l
l AREA-WIDE FEDERAL REPORTING, INC. (215) 925-5777 ;
't 178 1 are not relevant to what we have in here.
,t J 2 I just want to establish the fact 3 that you are making questions, not allegations. I 4 can understand your not understanding some of these 5 things and having problems assimilating all this.
6 MR. RICHARDSON: Let's read you a line 7 here from the report.
8 MS. DURR: Wait a minute. Is this 9 relevant?
10 MR. RICHARDSON: It may answer your 11 question as to whether I'm qualified to talk about 12 this stuff.
i I
13 This is section 3, page 9 of your 14 84-07 CAT report. The second paragraph starts off, 15 in addition to the fact that ANSI certified 16 inspectors (UE&C as-builders).
17 MR. DURR: So what?
18 MR. RICHARDSON: So was I certified, 19 or was I not?
20 MR. CERNE: You were certified as an-21 as-builder, not as an inspector. All the QC/QA 22 inspectors at Seabrook were certified to ANSI N45.2.6
?
23 requirements. They had to be to conduct inspections.
Il 24 MR. RICHARDSON: This is true. The s 1 AREA-WIDE FEDERAL REPORTING, INC. (215) 925-5777
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179 !
1 assumption I am making is that I was certified 2 adequately to perform the work I was doing.
3 MR. CERNE: Which was not ANSI 4 N45.2.6.
5 MR. RICHARDSON: According to the 6 paperwork I have --
7 MR. TRACY: I would really like to 8 deal with some of the substantive problems.
9 MR. DURR: Me too. But he keeps 10 bringing the subject back to this.
11 MS. TRACY: And you keep worrying at 12 it endlessly too, Jacque. It's a dialogue going on 13 here.
14 MR. DURR I~ understand that.
15 MR. CERNE: I don't understand what's ,
16 going on when people are going back through our 17 inspection reports. If you wanted to have an
~
18 independent agency come and look at our inspection 19 reports, yes, they'll find several problems. That's 20 us doing our job, finding the problems and seeing i
21 that they are getting corrected.
22 Now, if somebody goes back to support q 23 ELP allegations and raises issues that have been i 24 identified, corrected, and put to bed in our I .
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I 180 r 1 inspection reports, and rehashes them in support of
,d _
2 some item that has no factual basis, it seems to be 3 stretching.
4 MS. TRACY: I think that you are 5 incorrect when you say they have no factual basis, 6 Tony. I think that that's an assumption on your
( 7 part.
8 MR. CERNE: The factual basis I'm 9 talking about is what Jacque needs'for us to verify i
10 that there are problems or aren't problems in the 11 plant. You're telling us things we already know.
12 That's not an allegation. You're reading from our i
iJ 13 report and telling us what? We didn't do our job 14 properly? You want to go to the Office of i 15 Congressional Affairs?
16 MR. DURR: Time.
17 That's what I was trying to set clear 18 at the opening of the meeting, and Mike thought that 19 it was adversarial. But I was really trying to 20 establish the protocol, the method, the procedure, 21 parlimentary procedure, if you will, by which we have 22 to bound this thing. Otherwise, we end up off the 23 track all the time. That's why I said it was I] 24 confined to 87-07 and 86-52 issues. That's why I i
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i 181 1 wanted to address the ones that we requested in the 2 letter that we sent you, to please tell us up front
, 3 what you wanted to discuss. So we would have the 4 appropriate people here, and we would be prepared to 5 intelligently discuss it.
6 MS. TRACY: Well, why don't we forge 7 forward then, Jacque?
8 MR. DURR: I keep trying to, but Doug 9 keeps wanting to go back to this other issue.
10 MR. RICHARDSON: I have a specific 11 question. You've got quite a performance problem 12 with Pullman.
13 MR. DURR: We don't dispute that.
14 MR. RICHARDSON: What was the 15 appropriateness of deleting any inspection program ;
16 whatsoever, when you've got as-builders catching that 17 portion of mistakes?
18 MR. DURR: That's a question. That's 19 not an allegation.
20 MR. RICHARDSON: I never said it was 21 an allegation.
22 MR. DURR: Okay. And the question i 23 that you ask is, they deleted the B31.1 program. Is 24 that correct? Is that what you want to know, why 0
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182 i i 1 they deleted that? All I'm telling you is, that from
, L.a 2 the NRC's perspective that's a non-safety related 3 program. It had no impact on the safety of that 4 plant, none whatsoever, or we wouldn't have_let them 5 do it. That is the answer to your question.
6 MR. RICHARDSON: Fine. I disagree with 7 the answer. The reason I disgree is that the as-built 8 programs have been catching a hell of a lot of 9 mistakes, and when you have a piping contractor with 10 that kind of conformance problem --
11 MR. DURR: You have to understand.
12 What impact does it have on the safety of the plant, 13 the nuclear safety of the plant? I'm not talking 14 about occupational hazard. I'm talking about nuclear i 15 safety.
16 MR. RICHARDSON: As you noted, it's in 17 everybody's best interest te insure that the i
18 non-nuclear portions of the plant are fully 19 functional and fully capable in order to prevent 20 having to use the safety systems. i I
i 1
21 MR. DURR: We agree.
22 MR. RICHARDSON: That's the reason on i 23 that particular section.
~] 24 On the other one, if you've got a 1
8 i
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i 183 1 problem with documenting and analyzing --
2 MR. DURR: You're burning up her 3 time. She wants to go on. I'm prepared to move on.
4 It's up to you how you want to spend the time.
5 MR. RICHARDSON: I would like to know 6 if it appears inappropriate to be reducing inspection 7 efforts on the part of the contractors --
8 MR. DURR: So noted that you made that 9 statement. Moving on.
10 MR. RICHARDSON: Very well.
11 MR. DURR: Sharon, what would you like 12 to talk about next?
13 MS. TRACY: I believe "I", the Dravo 14 shop welds in the turbine building were detective and 15 uncorrected.
16 Did you want to say something about 17 that, Harold?
18 MR. GRAY: Yes. We have to draw back 19 to another report. The 84-12 report on page 40 to 20 about 43 discusses that question in depth, and leaves 21 it as an unresolved item, pending them to radiograph 22 the weld. This weld was not a radiographic quality i 23 weld to start with. The weld was later radiographed,
- 24 found to have a small indication, which was not l 1
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t 184 1 related to the original allegation,_which was not I-2 contained on the inside surface of the weld, which 3 the allegation pointed to. This defect was repaired 4 and re-radiographed, found acceptable, and it was 5 cleared in a later report. So that "I" is not true.
6 MS. TRACY: How many' welds were we 7 dealing with there?
8 MR. GRAY: The alleger gave us a 9 specific single weld that he saw was a problem.
10 MS. TRACY: So you only dealt with 11 that one weld?
12 MR. GRAY: That's correct.
'J 13 MS. TRACY: When he spoke to me about 14 it he seemed to indicate that there were -- there is i 15 apparently a lot of Dravo piping, and he felt that 16 the welds in general in that Dravo piping --
17 MR. GRAY: He didn't tell us that in Ii 18 1984.
19 MS. TRACY: So you only looked at that 20 one?
l 21 MR. GRAY: That's correct.
22 MR. DURR: He was interviewed directly 1 23 in 1984.
n 3
24 MR. CERNE: When you say Dravo shop i
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185 l
1 welds in the turbine building, again, you're talking 2 about non-safety related welds. Dravo, just like the 3 piping contractor on site, built their piping to 4 specific standards. The safety-related piping was 5 build to ASME standards. The non-safety piping was 6 built to B31.1 standards. The turbine building piping
- 7 is all non-safety piping.
8 MR. RICHARDSON: Did Dravo also do 9 safety piping?
10 MR. CERNE: Yes, but to different 11 standards, including QA at the shop. The QA at the 12 Dravo shop was only applied to the ASME piping, or --
r 13 yes, the ASME piping, not the B31.3 piping.
14 MR. RICHARDSON: There's no i 15 requirement for 100 percent radiographic inspection?
16 MR. CERNE4 100 percent radiographic 17 inspection only takes place in ASME class 1 and 2 18 piping anyway. ASME class 3 only gets surface 19 examination.
20 MS. TRACY So this is ASME class 3?.
I 21 MR. RICHARDSON: No. B31.1.
22 MS. TRACY: It's even lower than class
- 23 3.
24 MR. CERNE: No QA was applied. It t
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l 8 l 186 ]
l l
I i 1 wasn't required because, as Jacque pointed out, there j
, L; 2 is no safety consequence to the weld blowing away, 3 for example.
4 MS. ~ RACY: I find it odd that-when I i
5 spoke with this person, he mentioned pleural welds, 6 and that there was only one that he mentioned to you i 7 and that you dealt with. I would kind of like to 8 check back on that with him.
9 MR. DURR: It's interesting to note 1
10 that this is an allegation that we already looked 11 at. We already knew about this. We already inspected 12 this one before back in 1984 when he made his I
i- J 13 original concern known to us.
14 MS. TRACY: You might find it i 15 interesting, Jacque, I don't know. I just know what
, 16 people come to me with, and he said that he was not 17 really satisfied with how it had been dealt with. He 18 spoke with him with April too.
19 Okay J -- or was there more you 20 wanted to say?
I 21 MR. GRAY: Excuse me. I did explain 22 to him that in April.
23 MS. TRACY: Did you?
24 MR. GRAY: Yes.
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t 187 1 MS. TRACY: Was that on the record?
2 MR. GRAY: I think it was on the 3 record.
4 MS.'TRACY: I think that you all were 5 speaking to each other off the record after the 6 meeting.
7 MR. DURR: J. What's the question?
8 This is, as Mike's characterized earlier, an umbrella 9 allegation.
10 MS. TRACY: Yes, it certainly is.
11 MR. DURR: The welds were bad, but we 12 don't have any specifics. To counter that, we have 13 physically gone out and done independent radiography, 14 using our own equipment, our own technicians, our own 15 sources. We have independently done our own ,
16 radiographs, and done magnetic particle liquid .
17 penetrant tests, and we have not found any welds that 18 required repair. !
l 19 MS. GENTLEMAN: Regarding the Padavano 20 lines, maybe you can straighten me out on this 21 issue. The NRC did a sample of his welds; is that 22 correct?
?3 MR. DURR I cannot address that.
' 24 Maybe you can. I can't.
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188 1 j 1 MS. GENTLEMAN: About 136 welds.
.J 2 MR. CERNE: There were a total 3 approximately of --
I'm going approximately from 4 memory. This is documented, not only.in our follow-5 up inspection reports, but also by an Office of 6 Investigation report which looked into the wrongdoing 7 aspects of the issue, the qualifications aspects.
8 There were about 2400 welds in question, not that he 9 had falsified 2400 welds.
10 What the licensee did was, because 11 even one of his welds was in questica, they said that 12 the integrity of this individual cannot be counted 13 on. We're going to look at every single weld that 14 this individual did a surface examination on.
15 They're not radiographed welds. They were just 16 surface examinations which cut it down to a lower 17 class of piping.
18 Out of the 2400 only 800 15 approximately were safety related. The licensee said 20 despite that fact, we'll go back and try to redo the 21 examination on all 2400. Some of them were l l
22 inaccessible. By inaccessible, it's almost like a l 4 23 misnomer because when you get into a weld, you may j f] 24 have to do a repair in process, and then build the 1
l AREA-WIDE FEDERAL REPORTING, INC. (215) 925-5777
189 1 weld back out, and now the PT surface examination 2 that was done is inaccessible. But if that weld got 3 radiographed anyway, for example, a class 2 line, 4 then you're looking at the volumetric section of the 5 weld anyway.
6 ES. GENTLEMAN: Isn't inaccessibility 7 also occurring where a weld is encased in concrete 8 and not accessible for that reason?
9 MR. CERNE: Yes, but I can think of i
10 very few welds that were encased in concrete. Some 11 were buried underground, but it's not standard 12 practice to encase piping welds in concrete. I can't 13 even think of any, off the top of my head. Because 14 the important ones have to be accessible for ongoing i 15 evaluation throughout the life of the plant.
16 MR. RICHARDSON: I have a question on 17 that. Between unit 1 and unit 2 approximately in the 18 area between the containment and unit 1 PAB diesel 19 generator building there was a trenched-out area 20 running north / south on the site that had a rack of f
21 what appeared to be about 8 or 10-inch stainless pipe 22 maybe 4 or 6 wide, 3 or 4 deep, and I believe that
- 23 was encased in concrete.
24 MR. CERNE: You're talking about cable AREA-WIDE '.'EDERAL REPORTING, INC. (215) 925-5777
4 1
190*
i; I conduit. It's not stainless. It's galvanized steel
, .J 2 cable conduit. That's encased in concrete.
3 MS. TRACY: Go on about Padavano.
4 MS. GENTLEMAN: My final question 5 would be -- maybe you can direct me to a document 6 that would be helpful. Of the 136 welds or 4 7 thereabouts that the NRC tcok a look at itself, my 8 understanding is tha? none of those welds are the 9 welds that Mr. Padavano actually pleaded to. Is that
, 6 10 correct?
11 MR. CERNE: No.
12 MS. GENTLEMAN: All of the welds that LJ 13 he pleaded were inspected by the NRC7 14 MR. CERNE: No. There is a cross i 15 there. When the licensee reported this problem and 16 said this is what we're going to do about it, t.tey I 17 lauched into correction action which is to inspect i
18 their welds, or as many of the 2400 as they could get 19 to.
t 20 The ones they couldn't get to, they 21 had to disposition either by engineering evaluation 22 or some other technique. A lot of the ones that were a 23 non-safety related, if they weren't accessible, they 24 just said they're non-safety related, they're crane
[]
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i /
- ' 191-1 hooks or something that's not part of the permanent i
2 plant.
3 The s:a f ety related_ones, we -- and I 4 can rifer you to the; inspection reports -- we looked '
t 5 over their shoulder in this entire process and ,
6 watche[dthce._dc,theircorrective action. Then we i 7 came'back wilh bu r ' vin- and did independent inspection 8 on some c~f"the welds that they had redone and said
~ -
~_ ,
9 was nc. problem. -
10 -
, In otherowords, not all of the ones 11 thatPu}davanodidwere faulty, some were ones they 12 said -- and'one percent sticks in my mind.
i Maybe one 13 perce t'of the ones had to be redone. We d id a 14 samp1E on the ones that had t o ajo redone to assure i 15 that the final weld wa's' a p rope r repairing process.
16 In tlieonec,the[dispositioned to say 17 that we Joa't have to do ahything with it, we did a
' ~
18 sample uf th655. So we took a sample and our sample
~
19 -- 13@,.if you got that out of some report, I'll 20 believe you-;~I don't remember the exact number. We 21 took a sample,.like w :' $n in all our inspections, on 22 any category where the licensee mado some rationale !
, 23 decision as to why they 6td it the way they were i 24 doina i t .~ We judgId.'thatldecisionas it was being i
l i
1 AR3A-WIDE FEDERAL R E P OR T I Nri , INC. (215) 925-5777 !
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f-192- :i
- a, t 1 made, and then we brought our van in and did a f g
ta ;
2 sampl'ing to assure ourselves that it.was a good l 3 decision. All.of that is documented.
- 4 MS. GENTLEMAN
- Within those samples ,
- I 5 did you test the welds that he pleaded to?
6 MR. CERNE: Yes. _That was partHof the 1 7 sampling.
e 8 MS. GENTLEMAN: The specific welds: ?
9 that he pleaded to.
j 10 MR.'CERNE: Pleaded to? All o' the i 11 2400 we sampled --
l 4
3 1:1 MR. RUSCITTO: Are you talking about a l
'l i:""
- 13 legal -- where he admitted under oath --
- 14 MS. GENTLEMAN
- Yes.
1 15 MR. RUSCITTO: I'm not sure we know :
l 16 what those welds are. We made no. distinction as to 17 the ones he admitted to. We looked at every weld he i l-I
- i 18 ever did, whether he admitted to falsifying it or
- 19 not.
i 20 MS. GENTLEMAN: The welds that he !
g ,
j 21 pleaded to in court that he had falsified, you are ;
e j 22 not sure if you re-inspected those or not? .
! l lt 23 MR. CERNE: We don't know of any --
i i] 24 MS. GENTLEMAN: You may have, if nu e :
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i
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1-193 1 caught them in the sample, but then again, you may i
2 not have?
3 MR. DURR: That's correct. I think 4 that's true.
I 5 MR. CERNE: I don't understand the tie 6 between what you're leading to --
I 7 MR. DURR: Let's break it up into a 8 set theory here. There's 2400 in the set.
9 MS. GENTLEMAN: There's 2400 in the 10 set, but there's a sub-set of welds that an inspector r
11 indicated --
12 MR. DURR: Under oath that he --
13 MS. GENTLEMAN: Under oath.
14 MR. DURR: That he didn't inspect i 15 them; that he had falsified.
16 MS. GENTLEMAN: My simple question ist 17 did you check them.
18 MR. DURR: Specifically did we looh I 19 for those welds? I think the answer is no. We took 20 sub-sets of 2400 and did some of each sub-set, the I I
I 21 ones that they said were okay, the ones that they 22 said were done by Padavano, and the ones that they i 23 said that they didn't have to do. We looked at i
24 sub-sets of all of those or a sampling of each one of I i AREA-WIDE FEDERAL REPORTING, INC. (215) 925-5777 j
I 194 i i 1 those. We didn't take a slice and say these are the J
i.
2 ones that Padavano said were bad, and we'll go look 3 at those again. We looked at the whole population.
4 We didn't want to focus in. We wanted to make sure 1
5 the whole set was good.
6 MR. CERNE: When you say he pleaded to 7 11, I don't think that the legal part of that where 8 the Department of Justice got involved and is 9 pleading to certain contentions, it was maybe a 10 generic pleading to 11. I will admit I did it 11 11 times. But there wasn't in that process, here's weld 12 54-X75.
I 13 MS. GENTLEMAN: Oh, yes, there was.
14 MS. TRACY: Yes. It was very i 15 specific.
16 MR. DURR: Aside from that, the 17 responsibility to go back and correct it was the 18 licensee's. What we went back and looked at was his 19 program to make sure that everything was okay. We 20 looked at the programmatic aspect of it, and we 21 sampled the sub-sets.
22 MS. GENTLEMAN: I understand, as best i 23 I can, your sample approach. My question is more, a
~] 24 simple citizen in the world knows that a quality I
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1 control inspector identified. welds whose documents he a
'2 falsified, and my question is simply, have you looked 3 at those. I guess your answer is that maybe you did, <
4 and maybe you'didn't.
5 MR. KAUCHER: All the welds were 6 looked at, but-not specifically by the NRC.
4 7 MR. DURR The NRC did not 8 specifically look at the 11 or however many it was, 9 unless they were in that sub-set that we looked at.
10 MR. CERNE: But the licensee's look at-11 it is no different than the program they used to look f
12 at all welds. In other words, when they re-looked at i 13 the weld, it was no different than any other weld we :
14 may have picked as a sample for other reasons, t 15 MS. GENTLEMAN: Thank you.
16 MR. RUSCITTO: The fact that he 17 falsified the records on the weld doesn't mean that 18 it was an improper weld. It just means that there ,
19 was no assurance.
20 MS. GENTLEMAN: What percentage of the i
21 800 safety related welds that the licensee looked at l
22 failed? Can you direct me to a document with that l
- 4 23 number?
I 24 MR. CERNE: I think the failure rate f
i 4 i i
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t i 196 g i 1 is documented, and I'want to.say in.the neighborhood ,
- ,'-J i 2 of one percent. Failed in the sense that a repair i 3 had to be done to the weld. In other words, the 4 examination process yielded something that.said 5 something needed to be corrected. ;
l 6 'MR. RICHARDSON: I have a' question for 1
7 you. One of your earlier CAT reports gets into an 8 area-on weld examination that was done. It cites a 9 sample of 29 welds that were radiographed, and of '
'i 10 those, I believe 6 of them came up with reportable 11 deficiencies. My understanding was that these had j
12 passed Pullman's QA. Is this a common occurrence? .
l "J 13 MR. DURR: What do you mean common?. !
14 Relative to what? Other nuclear power plants? i
- i 15 MR. RICHARDSON
- No. !
l d
16 Do you have a significant portion of 4 17 your inspections where you go back and x-ray welds ;
i
- 18 that have already been bought off by QA? Do you have j .
4 19 any significant amount of cases where you find l 1
20 deficiencies weren't identified by the contractor?
l 21 MR. CERNE: The 29 you're talking ;
1
] 22 about was not an NRC identified case for Pullman q i
- t 23 welds. The licensee shows above the code requirements i 24 to review all radiographs on the site, either done by
, . _..a l !
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a 1 Dravo or Pullman or done by anybody, and in the 2 process of doing that review in some cases they 3 identified some problems.
4 Now, not in all cases --
29 might be 1
5 a number you have documented, and-I'll believe you if 6 you say you read it. Not in all cases are we talking 1 7 about problems where the weld was bad. It may have 8 been a problem with the radiograph. In some cases it 9 required re-shooting of the radiograph. In other 10 cases it could be dispositioned by a code 11 interpretation or other engineering evaluations.
12 MR. DURR: Do you have an example?
4 13 No. Don't dig it out now. After the meeting bring 14 it to me, and I will take a look at it because the i 15 NDE van comes under my branch, and I can probably 16 tell you what the answer is, if I see it.
17 MR. RICHARDSON: I believe it --
t 18 MR. DURR: But in an effort to speed 19 things along, so that Sharon can get her salient 20 points covered, see me after the meeting, and I will i
21 discuss it with you.
22 MS. TRACY: It seems, given the 23 restrictions on dealing with things that are too 24 general, that we've perhaps covered the major points t l AREA-WIDE FEDERAL REPORTING, INC. (215) 925-5777 l
I 198 i : 1 I wanted to address in the quality assurance / quality s '. >
2 control section, since I would imagine that Q, welds 3 were improperly certified and quality assurance was 4 poor according to a third QA engineer, would be too 5 general for you to deal with. And clso, there was a 6 lack of weld safety, and people were harassed, if i I 7 they raised safety problems. Am I correct?
8 MR. DURR: Sorry? They're too broad?
t 9 MS. TRACY: For you, yes.
I 10 MR. DURR: I don't think they're too 11 broad. I think we addressed all these things in 12 86-52.
13 MS. TRACY: Let's go on to 3, the 14 document control section. The problem with pipe and i 15 pipe supports being assembled using the wrong 16 materials after the identification numbers were 17 ground out and rescribed, that was something that was ,
t 18 brought up in some of the statements that I gave you 19 in April, and it was not really addressed in your 20 87-07 report. We feel that this also points to a i
21 problem with controlled documentation. !
l 22 MR. DURR I don't understand how that l l
( 23 has anything to do with document control.
, i 24 MS. TRACY: This is the way I imagine '
l
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E 199 1 it works, Jacque. You have your design, and your 1
2 design has the equipment laid out with'the numbers 3 for the different pieces that belong in various 4 locations,-and if the incorrect equipment is used, 5 then your documents do not reflect the real 6 situation. In other words, the numbers on the 7 equipment might appear to match the documents -- -
8 MR. DURR: I understand where you're 9 coming from.
10 MS. TRACY: -- but they don't because 11 they been ground out and rescribed.
12 MR. DURR: But the root cause is not a '
e 13 document control problem. The root cause in this 14 particular case is a material control problem.
I 15
~
MS. TRACY: Okay. Let's call it a 16 material control problem.
17 MR. DURR: And that ultimately results i
18 possibly in document control -- not document control, 19 but inaccuracies in the documentation.
20 But to me a document control problem 1
21 is one wherein the formal document control system, l
and there is such an entity that controls procedures, 22 i 23 drawings and specifications and those things to make 24 sure that the appropriate document is at the right ;
~
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200 r
( i 1 pince in the right revision, that's the document
.J 2 control system. So when you say this is a document 3 control problem, from my perspective it's a material l 4 control problem. It ultimately results in l 5 in: Accuracies in the documentation, but that's not a 6 "document control problem".
i 7 MS. TRACY: But it is a problem.
8 MR. DURR: I understand where you're 9 coming from, yes.
10 MS. TRACY: It wasn't really addressed 11 in 87-07 either.
t 12 MR. DURR: What about 86-527 L" 13 MS. TRACY: No. It wasn't even raised ,
14 in 86-52.
15 MR. DURR: When did you give us this?
16 MS. TRACY: I gave this to you in 17 April.
18 MR. DURR: Is this one of the issues i
19 that we sent you a letter and said these are kind of 20 general, and we need some more information? There 21 were some of those things that you gave us in April, 22 and we said yeah, we can do something with these l
t 23 because they're specific enough. And then I sent you '
-]
24 a letter and said that on these, I've got some
- i AREA-WIDE PEDERAL REPORTING, INC. (215) 925-5777 ,
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t 201 1 questions for you.
s 2 MS. TRACY Right, and I answered some 3 of those questions, and some of them I didn't.
4 MR. DURR: Those we have not done I
4 5 anything with, to my knowledge. If it was not in 6 87-07 or 86-52, we heven't done anything with it.
I 7 Those were awaiting responses from ELP, and those 8 will be turned over the residents, I think, and that 9 will be addressed in a subsequent inspection report.
I 10 Yes, there's some of these things that we didn't talk 11 about in 87-07, and that's why we sent you a-letter. ,
12 We felt that we really couldn't do anything with them 13 at that particular time.
1 14 MS. TRACY: Again we're caught in this 4 15 ' Catch 22' situation where the person who made this i
16 allegation does not have access to the documents he i 17 needs in order to be specific enough for you to act i
18 on the exact equipment. If he were to wander through 19 the plant in the locations where he was working, he 20 would be able to point the equipment out to you, if l 21 he had access to the documents. 1 l
l 22 MR. 'USCITTO: But even so, I am not 23 sure we understand the statement of the problem.
! 24 What was wrong with what they did? If equipment was I
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! ! I changed under a proper design control procedure, then
,-' J ,
2 maybe what he ssw wasn't evsn a problem.
l 3 MS. TRACY: It was not that way. The l
4 way it was explained to-me was, this crew was working a
5 on some pipes in the turbine building. They needed a 6 piece of pipe. They went out to the yard to find the 1 7 pipe. They were looking for a specific number. They 8 could not find it. They found another pipe that 9 approximated what they needed. They cut it off to i
10 the size that they needed. They ground out the 11 number that was on it, and scribed in the number that l
l,,__, 12 they were looking for, with no docunentation.
13 MR. DURR: In the turbine building?
14 MS. TRACY: No.
15 MR. DURR: That may not be safety 16 related piping.
17 MS. TRACY: I think I'm wrong about
,i 18 that. I can dig out exactly where he was working.
i 19 MR. RUSCITTO: What you are describing '
1
, 20 is not necessarily wrong. :
l1 21 MR. CERNE: We need more c'etails . [
22 MR. DURR: We can't decide that now.
I 23 MS. TRACY: I think that I should '
24 maybe need to talk to you to find out exactly what 1
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-1 more details you need in order for me to get-i 2 information. f i
3 MR. CERNE: I think Jacque asked the r 4 questions. We can go on from that basis. l l t -
i 5 MR. DURR: That may be in those ;
i
- 6 questions. Let us take a look at - that. ;
i t i 7 MS. TRACY: You'll check back on that.
t
[ 8 MR. DURR We'll be_in touch:with you. :
9 MS. TRACY: I'm curious that you say 4
10 it might not necessarily be a problem. I would 11 assume -- ;
i 12 MR. RUSCITTO: As long as there's
- 13 traceability of the switch or the re-tag. If it's an 4
14 equivalent substitution, it's a perfectly valid ,
jt 15 change that occurs all the time. As a matter of i
j 16 fact, that's what we would want them to do, would be ';
i r i 17 to re-number the part to what the design shows.
I 18 MS. DURR: There's a couple of numbers I
19 that you have to be concerned with. Some are system
]
20 identification numbers, pipeline numbers, but the !
21 number from the material document control that you're l
- t j 22 concerned about is the heat numbers. If they change !
4 23 the heat number, now they've changed the ;
- ; 24 identification of the kind of material and its [
4 t
! i 1
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1 allowable stresses and those kinds of things. If 2 it's ASME stuff, it has a code data tag on it. That 3 code data tag has to remain intact. If the code data 4 tag isn't on there, they can't put the piece of pipe 5 in the system.
6 MR. CERNE: If it was safety related 7 piping, that's one of the QC inspection points they 8 would be looking for.
9 MS. TRACY: The tag, 10 MR. DURR: They look for those tags. ,
11 Those are unique tags. If you take one of those taga 12 off, you either have to save the tag, or you have to ,
q <
-J 13 take a stencil of it or something. Those have to all l
14 be accounted for. So if it was ASME code piping, 15 that kind of a scenario is pretty hard to envision 16 without controls on it because even if you put it in, i
17 you can't verify what it is after it's in there, and ;
L I
18 they're going to make you take it back out again.
19 MR. RUSCITTO: But if they are just 1
20 changing line numbers, it's just like changing the !
21 license plate on your car versus changing the serial 22 number on the engine block. You can change the I
23 license plate on the car, but you can't falsify what I] 24 engine is put in there.
1 AREA-WIDE FEDERAL REPORTING, INC. (215) 925-5777
i 205 1 MS. TRACY: I understand the 2 distinction. I'm glad you explained that. Also, 3 this explanation will make it easier for me to get 4 more details that would be relevant to your dealing 5 with the problem.
6 MR. RICHARDSON: 'I would like to ask a 7 question about something that I hadn't thought of 8 until recently. One of the emergency feedwater lines 9 -- this is in :he area of the emergency feedwater 10 pump house -- was supposed'to make a 90-degree bend 11 with, I believe, a weldalet attached to the bend.
12 When I did as-builts on the line, the stamped 13 identification on the fitting was ground out. The 14 whole fitting was ground, as a matter of fact, and :
I 15 the identification was scribed into the piece by !
16 hand.
^
17 The reason I'm concerned about it is 18 that a weldalet or an elbowlet, I believe, according i
19 to the catalog cuts I've got, is supposed to have the !
20 particular break through its taper in order to give !
I I 21 you the concentrated internal pipe, the thicker 22 section at a particular point in the internal wall.
23 This one didn't have that configuration. It was a 24 straight taper all the way out. Have we got a piece e
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j 1 that shouldn't be there? Is that an improper piece J
ri 2 tc be in that location if the weldalet was called i c ,
3 for? .
4 MR. DURR: That's a question.
5 MR. RICHARDSON: I can give you a more i 6 specific location. It's a general question now.
1 7 MR. DURR It's hard for us to answer 8 that question without going out and doing some 9 inspection on it.
't 10 MR. RICHARDSON: The reason I'm 11 concerned is because the outside contour of the piece 12 doesn't appear to match the product catalog that I've 13 got. The entire surface is ground, and the -
14 identifying information is hand-scribed in.
! i 15 MR. DURR My question is, is this an
- l j 16 allegation? Are you alleging that there is a bad ,
i 17 piece in that line out there, or are you just t >
18 concerned and have a question? If it's an 19 allegation, we will go out and do inspections and t
20 make sure that's not true. Do you have first-hand iI j 21 information that that's a concern? I.t you are just a
l 22 asking a question, if this is c question, we will not t 23 be able to respond to you. j I' 24 MR. RICHARDSON: I can tell you first
. _a i
i i
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-1 hand that the contour of that particular fitting I
2 doesn't match the catalog cuts that we were issued at 3 the time, and that the information on it is 4 hand-scribed, as opposed to the factory stamping that 5 could be expected to be there.
6 MR. DURR: You never answered my 7 question.
8 MS. TRACY: It's an allegation, 9 Jacque.
10 MR. DURR: We will treat that as an 11 allegation, and we will do something with it.
12 MS. TRACY: Thank you. Very good.
13 MR. RUSCITTO: But we need more 14 information.
15 MR. DURR: But we need to know exactly 16 where this alleged piece of pipe is. l l
^
17 MR. RICHARDSON: The emergency 18 feedwater pump house on the floor that would be at 19 approximately elevation -- what, 25 feet, 28 feet? l l
20 MR. RUSCITTO: Yes, j i
21 MR. RICHARDSON: That approximate 22 range. A few steps up from ground level.
t 23 MR. DURR: And it's on an elbow? l 1
t 24 MR. RICHARDSON: It's on an elbow l
l AREA-WIDE FEDERAL REPORTING, INC. (215) 925-5777
i 208 3 i 1 where the pipe --
,LJ 2 MR. RUSCITTO: Do you know what size 3 pipe?
4 MR. RICHARDSON: I believe jt's 8 or t
5 10 inch.
6 MR. RUCCITTO! Do You know if it's 7 sucticn piping in the emergency feedwater pump?
8 MR. RICHARDSON: Yes, I believe it is.
9 There are 2 lines directly over each other that come <
10 through from the yard, go through the stairwell, and (
11 pass through the east wall of the emergency feedwater 12 pump house, go north along the inside of the east l '
13 wall, and then go west along the inside of the north 14 wall, and then the 2 of them go south in different 15 directions to go to the pumps.
j 16 MR. RUSCITTO: Okay.
I 17 MR. RICHARDSON: And it is on the 18 elbow on one of those lines --
I don't know which --
l 19 where it comes off the wall and goes south to the 20 pump.
21 MR. RUSCITTO: Okay. That's good and 22 specific. ,
1 1 23 What size is the tap? I J
24 MR. RICHARDSON: I'm not sure. I I i l
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4 209 1 guess a 1 to possibly 2-inch range.
2 MR. RUSCITTO: We'll take a look at 1
3 it, but just to tell you off the cuff, that piping ;
4 probably isn't even there anymore because that whole !
8 ;
, 5 line.was re-designed after -- for totally unrelated t i
~
6 reasons, for testing during the start of the test i 7 program. EFW research lines were totally changed.
8 So based.on what you're telling me, I think we're 1
9 going to find that that's not even there anymore.
I 10 But we will take a look at it. That's certainly easy f r
11 enough to do.
12 MR. DURR: Next?
13 MS. TRACY: Still under document l 14 control, the fact that blueprints were not updated, ;
,i 15 workers in the document control department were 16 untrained, did not know how to read blueprints, and +
17 put incorrect numbers on blueprints. There is some 18 documentation of these problems in your own reports, !
1
) 19 but this information came from someone who worked in ,
20 the blueprint room.
i 21 MR. DURR This was looked at in !
l 22 86-52. I'm almost certain of that. Am I not l l I i 23 correct?
4 1 24 MS. TRACY: It might have been a ]
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4 210 r
] 1 slightly different issue.
,a J l 2 MR. DURR: It sounds familiar.
l 3 MS. TRACY: I brought this to you in 4 April, and 86-52 was done prior to April.
! 5 MR. RICHARDSON: I had discussed 6 document control in 86-52, but this --
i 7 MS. TRACY: This is from a different 8 person, put it that way, someone who worked with 9 blueprints. And it has not been dealt with 4
10 specifically, although I did give you this 11 information in April.
I 12 MR. CERNE: Was this related to I
13 piping?
14 AS. TRACY: I would say that this is i 15 related --
16 HR. DURR This falls under the same 17 general heading as tracking of blueprints is an i
18 impossibility, and drawing revision control was 19 ineffective. The alleger was doing as-built 20 inspection on the fire protection system.
21 Is this the one that you made?
22 MR. RICHARDSON: Not entirely. Drawing i 23 revision control was ineffective is me. Tracking of
[] 24 blueprints an impossibility isn't.
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l 1 MR. DURR: But this one we're talking 2 about here, blueprints were not updated, and workers 3 in the document control department were untrained, is 4 that your allegation?
5 MS. TRACY: No, it's not.
6 MR. RICHARDSON: I think what you've 7 done is combined 2 of them.
8 MR. DURR: We did. They all say the ;
l 9 same thing.
e i 10 MR. RICHARDSON: That's not all mine.
i 11 MR. DURR: I understand. All I am 12 saying is, these are all similar issues.
13 MS. TRACY: They are similar, but this 14 particular issue that we're looking at, letter C, was t 15 in a statement that was submitted to you in April.
16 MR. DURR: I understand, but how is i
j 17 that different from what we looked at in number 32 18 and 57, those allegations?
I 19 MS. TRACY: I'm looking at the exact
, 20 affidavit right now because I think -- !
4 1
21 MR. DURR: It sounds like the same i
22 thing.
- 1 23 MR. RICHARDSON
- What was the 2
l I '
24 allegation numbet in 86-52? ;
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212 1 MR.-DURR 32. '
F 2 MS. TRACY: This was Perrini, the. .
I l 3 document control department of Perrini, and in the.
i 4 permanent materials department keeping track of 5 materials. Whoever it was that asked if this had to 6 do with piping,.I. don't know if that answers your
- 1 7 question.
8 MR.~DURR: I think if we had that same !
9 . allegation when we did 86-52, it would have-gone !
10 under 32 and 57 where we went back and looked at i i
11 drawing control.
i 12 MS. TRACY: In the document control 1 13 department. So this was for Perrini, and the f
14 document control department person in charge was so lt 15 and so. He was fired after an investigation.
1 j 16 MR. DURR: Because to support those l 17 other 2 allegations we essentially recounted all the
,1 18 inspections that we've done of document control, the 19 fact, we've done as-builts using independent as-built 2' l 20 inspections of equipment, and the fact that we have I
21 also done drawing revision control inspections. And l
]
- 22 in those cases we didn't find any significant i 23 breakdowns in the document control process. I don't i
24 know what else you can do with that.
1 i I O
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l l' f 213 1 MS. TRACY: I don't know either, t
2 Jacque. I think that we have a disagreement of l 3 opinion here.
4 MR. DURR: What's that?
t I
l 5 MS. TRACY: I think that there are 6 quite a number of people who said that there were l
- I 7 problems in that area, and you are looking at it from j 8 a different perspective than they were.
9 MR. DURR: That's correct.
i 10 MS. TRACY: And, therefore, reached 11 different conclusions.
12 MR. DURR: Here again, it goes back to 13 what's there today. Does that plant meet the design 14 drawings? And everytime we go out and inspect it, we
- i 15 find that it does meet the design drawings.
l 16 Everytime we look in a specific area we find that it l
17 meets what it's supposed to meet. That.'s the bottom 18 line. i
' l 19 If these things occurred, and here '
20 again, it's speculation whether they did or they 1
21 didn't, it's hearsay, it's their word against tha 22 system. All I'm saying is that we can't find any
- 23 instances where this resulted in hardware 24 deficiencies in the field. That's what we are l
1 i
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6 214 h) 1 interested in.
'LJ 2 li R . RUSCITTO: Also, all drawings are t
3 not either safety related -- not all drawings have P
4 the same controls put on them, or some drawings are 5 updated, and some are not, depending on what their 6 purpose is. Lacking some mors :racifics on which --
4 7 even the catagory of drawings, we might be able to do 8 something more with it. To say safety related piping ;
9 instrumentation drawings, yes,-but vender fabrication i
10 drawings may not even be part of the official design 11 process, although the drawings were available on site 12 and were used for a certain period of time.
13 MR. CERNE: Particularly in the area !
14 of civil structural, the process of issuing an '
i 15 engineering change authorization, which is a document
[
16 which changes the design, not in all cases there was l
17 an explicit decision made on the ECA as to whether i
18 the affected drawing had to be changed or not. When 19 it didn't have to be changed, then thht ECA would 20 become part of the design for that what you call 21 blueprint. We call it design drawing. So if you 22 just looked at the design drawing, you wouldn't get a i
I 23 complete picture of what it's supposed to look like '
[] 24 out in the plant. You would have to pull out all the
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I 215, 1 .ECA's that went along with it. That process of 2 keeping track of those ECA's was done on a computer 3 controlled system which has been inspectioned many 4 times by the NRC. ;
5 MS. TRACY: D and E sort of reflect 6 the same hinf of problem which is the destruction or i 7 theft of documents and blueprints and so forth.
8 MR. DURR: That D is blueprints were 9 destroyed in the blueprint room. I believe that.
10 Obsolete revisions should have been destroyed in the !
1 11 blueprint room. Are they alleging that good drawings
- 12 vere destroyed in the blueprint room, ones that were 13 supposed to go to the field that never got there? Is 14 that what they're alleging? All I have here is that i
i 15 they dentroyed blueprints. That's like they destroyed 16 money at the mint. Yes, they do. )
17 MS. TRACY: The specific allegation 18 was that the people who were working in the blueprint !
I 19 room were getting rather high on controlled '
20 substances, and when blueprints came in that they
, t i 1
j 21 were supposed to make revisions on, occasionally they l 1
] 22 would say forget it and throw them in the shredder, '
1
, a 23 if that's what it is you have. I j
I i 24 MR. DURR: That is a possibility, j i
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l 1 That may be true or untrue. I don't know. What we 2 do know is that the:e are checks and balances for 3 that kind of thing. There have been instances at 4 other nuclear power plants where people have been 5 found -- they were supposed to be delivering -
6 blueprints and were trasti!ng-them in the trash can i 7 instead. That always gets found because QA does 0 audits of those things to make sure that the stick c
9 files are kept up to date, and that the people have i
10 the appropriate drawings in the field. So any one 11 individual trying to -- it's like the mailman that 12 doesn't deliver the mail. Sooner or later they find l , ,
13
- out.
14 MS. TRACY: It might take 40 years,
]
- i 15 but -- .
16 MR. DURR: It doesn't take 40 years in i
17 a nuclear power plant because we're a lot faster than 1 18 that. We have found those cases, but there's checks 1
19 and balances that compensate for that. ,
i I
20 MS. TRACY: The next item, E, is that J4 q 21 there was massive destruction and theft of documents
~
22 during the 1984 reduction in force according to a 23 former United Engineers and Constructors manager.
l4 I
[ ,, 24 put that in here, although you did, I admit, deal J
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I 217 1 with this in report 86-52, simply because it i
2 substantiated our contention that document control is 3 ample as a problem.
4 Mn. GREENSTEIN: Was that a 1
5 significant incident? There was destruction of 6 documents; is that correct' i 7 MR. DURR: I den't remember the 8 details on that. I didn't do that one.
9 MR. CERNE: No. There was a massive I
10 --
in 1984 when they shut down for a period of time, 11 there was a massive layoff. We didn't have any 12 evidence of massive destruction and theft of 13 documente. If people got Inid off and they cleaned 14 out their desks, thoek should 'not have been any i 15 drawings that were other than informational drawings 16 because the controlled stick files and the official 17 drawings were all kept in locked cabinets and locked i
18 rooms and so forth, l i
19 MR. GREENSTEIN: You can't agree with l
20 that statement? l 1
t 21 MR. CERNE: I can agree that probably 22 several documents were taken off site and destroyed, s 23 We didn't have any evidence that wh'.le they were 24 going through this process that these v_:. any formal
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218 l t
r1 1 design or records or documents that were stolen or 2 destroyed. The licensee would have had to report 3 that.
4 MR. GREENSTEIN: You believe that you 5 have a complete blueprint record then; is that 6 correct?
7 MR. RUSCITTO: We don't have any 8 indication that the official design drawings are 9 deficient in quantity or accuracy at this point.
10 MR. DURR: What, I guess, needs to be ,
11 pointed out here, and I don't know what the 12 statistics are, periodically we get allegations that
'-- 13 are fruitful, that lead us right to the source and r
14 they are just exactly as characterized. And those
{
15 are easy and we can deal with those and correct it 16 very quickly.
17 But a lot of these allegations are 18 like myths. There is enough cubstance to them.
19 Somebody did see something, but they saw it out of i 20 context, or it's been taken out of context, and when 21 we go to investigate, we found that, yes -- a good 22 example is an individual saw a pump that was i 23 deficient down in one of the lower levels of the i e,
l' 24 plan'.
c When I went to look at it, yes, the pump was i l
4 AREA-WIDE PEDERAL REPORTING, INC. (215) 925-5777
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1 deficient,. Yes, the lic.ensee had identified.it.
t ., .,.
2 Yes, there wat'a, design change in proceas. Yes the u ?
3 engineer kned all aboat Mid was-judE' ready-to discuos
. . . , , + . , , , ,
4 it with me. S o 't h e y e w a s s o m'e s u b's t a n c e - t o w h a t the 5 individual had, but ne had it out I !
of4hr.tep,t. He saw 6 the' front part o f 'i t, ( b u t h e never saw,the fix.
7 That's what"a lot of these turn out *o be. They saw 8 t h e p r obl e:n ,. bit they never saw t h e 'f.i x . They left 9 or were moved comewhere else and they only saw that 10 little piece of the picture.
11 '
MS. TRACY: But, Jacque,' I have an
, 12 obligation to bring to you-many of these l'ssues.
33 MR. DURR: We,- app; ec i at e -it .
14 MS. T U F.C Y I,have,no way of-checking 15 myself to see how valid theys a r e ,' . a n d I have an 16 obligation t o b..:in f t h eI t o' y o u . _
17 N'<. D U R R': We expect you to br'ing them 18 to us. ,.
19 MS."TRACY: This is life.
20 MR. DURR;7Hhve we ever discouraged 21 you from bringing us these allogation.s?
22 M,Sr TRAC;: No, but you'do ,
t 23 occasionally make 1,ittle comr2ents about how --
t 24 MR. D U R R : ?', ' O.n l y b e c a u s e --
,, . ~ s
\ ,-
. ...~ . ..
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l 1 MS. TRACY: We don't know anything --
- g. J 2 MR. DURR: No. What I'm trying to 3 point out to you, it's like going to the doctor and
., 4 he said take'2 of these, and you go home and say I'm 5 not going to take any of them. You don't take the 6 advise once we give it. You bring us the allegation.
7 We go out and do the best job that is possible, and 8 then when we bring them back here, you are not 9 comfortable or you feel uncomfortable and 10 dissatisfied. That's the disconnect that I'm trying 11 to correct. Whan you bring these to the doctor and 12 he looks at them and says this is okay, then 13 somewhere you have to believe the doctor.
14 MS. TRACY: Well, maybe some day I 15 will, Jacque.
16 MR. DURR: Good.
17 MR. GRAY: Could I add to this E 18 here?
19 MR. DURR: Sure.
20 MR. GRAY: I was on the CAT team 21 inspection that occurred shortly after the big 22 layoff. There were approximately 10 or 12 people in i 23 the CAT team. No one came back with an issue that ln 3 24 documents were missing. There were items that they I
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221 I 1 were inspecting during the course of that )
1 2 inspection. That was a 4-week inspection. I spent a 3 fair amount of time looking at the ECA's, RFI's and 4 drawings, and did not find a single case of a missing 5 document, ECA or drawing. ;
6 MR. DURR: The 2-week CAT in '82, when 1 7 I was up there with a construction team, and Jane 8 Grant was on that, she spent 2 weeks, the woman ,
9 engineer spent 2 weeks looking at the document i
10 control system and she came up with 1 or 2 11 violations, but they were minor things, very minor, 12 not to indicate that the entire system was breaking
.3 down, but isolated cases that were obvious that they 14 needed to get the latest documents reviewed. There 15 was nothing to indicate tisat the whole system was 16 coming unraveled.
17 MR. RUSCITTO: We use this document 18 control system and the change document tracking 19 system. We've been using it for years and years and 20 years, and we never have a problem coming up with a 21 drawing. It's not like there's one master drawing 22 that gets lost. Drawings can be lost and originals 23 can be destroyed, but there is always a copy where i 24 you can go back and reproduce it and replace it.
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There are controlled drawings which l r ; 1 l'J l 2 have to be updated by the document control system, ;
3 and there are also drawings called information only.
4 Anyone who needs one goes into the document. tracking 5, system, pulls the drawing out. It gets stamped 6 information only, meaning it's current for the time i 7 that you got it, but if someone makes a design change 8 next week, they're not going to track you down and 9 update your drawing. When you're done with whatever i
10 you were doing, you might throw the drawing away.
11 That could be construed as disposing of drawings or 12 whatever.
I 13 There's an awful lot of documents 14 floating around, and it's really in the licensee's 1 15 best interest to make sure that information-only 16 drawings have a very short life, and people aren't 17 using them when they should be using controlled i
18 drawings. And as a result information-only drawings 19 are supposed to be trashed as soon as you're done 20 with them.
I 21 MS. TRACY: I believe that this 22 allegation revolved around the time when i 23 Pullman-Higgins was leaving the site and there were 24 apparently some fairly bitter feelings on the part of AREA-WIDE PEDERAL REPORTING, INC. (215) 925-5777
-i 223 1 some of the people who were leaving, at least this
'i 2 was the impression that-I was given by the person --
3 or the people who told me this. So it seemed that 4 almost just revenge or something like that that there 5 were documents.being destroyed. But you all seemed 6 to have had the documents that you needed to have
. 7 access to subsequent to that.
8 MR. CERNE: Particularly in the 9 Pullman-Higgins. That's why I asked.if it was piping t~
10 because the piping was as-built and stress 11 reconciled. So any errors that would have been in 12 the plant as a result of some drawing control 13 problems would have evidenced themselves during the i
14 as-built process', particularly with piping. There i 15 were controls in the other disciplines, but 16 particularly in piping it would be very hard to have u 17 a mistake get all the way through the system. !
( !
18 MR. DURR: And source design l 19 documents, I mean the "original" design documents, 20 those are not in the field available to any one 21 individual to destroy. Those are back in the l 22 corporate office someplace. So anything, other than i 23 those kind of documents, most of that stuff is !
( 24 replaceable.
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i 224 i i 1 MR.-GREENSTEIN: You can't recall a i L J 2 single instance of where you went looking for a 3 document and it could not'be found?
4 MR. CERNE: No. There have been cases i
5 of document control errors. We've written them up on 6 violations. We're talking about 26,000 inspection 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br /> over the course of this plant.
8 Using your term again, there has not 9 been anything endemic. And if you tie it 10 specifically to the layoff in '84, this CAT team that 11 Harold participated on, which was consultants and 12 people from Washington, spent time there right after
' f 13 the layoff. It was like April, May --
14 MR. GRAY: We started there the week i 15 after the layoff, and then it extended. It was a 16 2-week inspection, followed by a week back in the 17 office, followed by 2 more weeks at the site. We were i
18 there almost 2 months.
19 MR. CERNE: I think Harold was looking 20 at design control. ,
21 MR. GRAY: I was design control and 22 ECA and RFI review.
I 23 MR. CERNE: That's the best time you 5 24 could have investigated this question. We weren't i
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i 225 1 doing it for that reason. He was doing the normal CAT 2 inspection _ function.
3 MR._GREENSTEIN: There was nothing 4 missing?
5 MR. GRAY: No. That area was.still 6 staffed with a few people.
7 MS. GENTLEMAN: Just for the-record 8 though, statements have been made several times, and 9 just now by you, that the as-built process and so 10 forth would have uncovered any under1,ying 11 discrepancies in the drawings. It's my' understanding 12 from having read the NRC's inspection report i 13 regarding Skylar Mitchell's allegations on as-built '
14 drawings that were, in fact, descrepancies, although t 15 not in your view significant descrepancies between 16 the way the plant looks and the way drawings looked.
17 MR. CERNE: When you talk about 18 descrepancies, all systems that are as-built have 19 criteria within which you build it. Some are 20 acceptable.
I 21 MS. GENTLEMAN: I understand that --
22 MR. CERNE: When I say descrepancy, I 23 say beyond the criteria that was --
the Skylar f 24 Mitchell allegations were investigated and closed.
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1 1 226 i; 1 One of the gentlemen that worked on that is in this
.J 2 room right now. None of the descrepancies were 3 beyond the design tolerance, and that doesn't make a 4 descrepancy. That's the point. None of the issues 5 he raised were descrepancies because they were within 6 design tolerances placing the pipe in that particular i 7 location.
8 MR. MANOLY: There wasn't a whole lot 9 in the Skylar Mitchell allegation as far as getting i
10 .anywhere close to a design difference. It was a 11 trivial dimensional difference within the tolerance.
12 MR. DURR: You look perplexed.
13 MS. GENTLEMAN: I am not perplexed. I 14 don't want to debate the Skylar Mitchell issues i 15 today.
16 MR. CERNE: They are closed.
17 MR. DURR: But the point being, and I 18 guess something that the world needs to understand, l
19 and probably does, but subconsciously, and that is, i 20 there are no absolutes. That is to say that when we i
21 put 10 feet 6 inches on a drawing, it's physically i 22 impossible to make the piece 10 feet 6 inches l 23 exactly. It's 10 feet 6 inches, plus or minus I] 24 something. The plus or minus something is what i
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1 they're talking about. In the design specifications I
2 the plus or minuses, recognizing that there are no 3 absolutes, the plus or_ minuses cover the 4 descrepancies or the differences that you'll find 5 between what's in the plant and what the 6 specification called for. It falls within that plus
- 7 or minus value. Skylar Mitchell's problem ----
8 MS. GENTLEMAN: I'm talking about the 9 difference between the drawing and the plant, not i
10 between the plant and the spec.
11 MR. DURR: But the drawing is part of 12 that. The drawing is the thing that models all of i
13 that. And recognizing that even when.you put it on 14 the drawing, 10 feet 6 inches exactly, it may come i 15 out 10 feet 6 inches and 1/2, or 10 feet 6 inches and 16 3/4 or more or less. The s p e c i f i c a t i o ri , the design, 17 recognizes there are no absolutes. So it sets 18 tolerances within which they can live because the 19 ultimate goal is to make sure that when they install 20 that piping it fits the structural design analysis.
21 MS. GENTLEMAN: I am understanding 22 that the design has tolerances attached to it. I'm 23 just talking about the difference between as-built 24 drawing measurements and the physical measurements.
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i i 1 MR. MANOLY: You might be correct.
LJ {
2 MS. GENTLEMAN: I'm not debating )
1 3 whether or not those are beyond or not beyond ,
i 4 tolerances. All I am picking up is, on the fact 5 issue, that some of the drawings are not as precise 6 as you are alleging they are. Your own inspection 7 report pointed out --
8 MR. MANOLY: I believe there were 4 9 measurements in the report that we said that did not 10 agree with what was shown in the drawing. However, 11 those numbers were all within the accepted 12 tolerances.
13 MS. GENTLEMAN: Fine. That's not the 14 i s s ti e . The first point is a simple issue that I'm
- 15 raising now.
16 I would also note that Skylar 17 Mitchell's work was based on 300 feet of pipe, and to 1
18 find 4 on 300 feet of pipe --
19 MR. MANOLY: No. The 4 that we are 20 talking about here were based on samples I did and 21 was not Skylar's. It was part of Skylar's other 22 stuff. When I did my inspection, I looked at Skylar's l
l 23 and other things. I went through the other things 24 that were not brought up so I could get a good sample 1
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1 of what the drawings looked like. The 4 I found were 2 really trivial numbers that you can't even get c 3 excited about. It was ridiculous.
4 MR. RUSCITTO: Isn't'it correct that 5 there is also a tolerance in measurement on 6 as-builts -- i 7 MR. MANOLY: Yes.
8 MR. RUSCITTO: It's correct to.say 9 that an as-built drawing correctly reflects the 10 plant, even though there may be a dercrepancy between 11 what is measured in the plant and what is given on 12 the drawing, if what is measured in the plant is ,
13 within the tolerance accepted to the as-built 14 standards. So you can have a drawing that is as-built 15 as 6 and 3/4 inches, and if you go out and measure it 16 in the plant and it's 6 und 1/2 inches, if that is 17 within the accepted as-building tolerance, that is 18 not considered a descrepancy.
19 MR. DURR: They won't change the 4
20 draving.
i 21 MR. RUSCITTO: It's not worth changing 22 the drawing for 1/4 of an inch because the standard 23 says that when you as-build, you know you're going to
! 24 be within -- I'm just using a rough number -- plus or i
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- ; 1 minus a half an inch.
,tJ 2 MS. GENTLEMAN: It depends on what you
'3 measure.
4 MR. MANOLY: There is tolerance on 5 measurement of drawings that's accepted for 6 installation. That's much larger. The new guidelines 7 coming out would be that even if the deviations 8 exceed the measurement, but are within the accepted 9 tolerance, the drawing does not have to reflect 10 that.
11 MS. GENTLEMAN: Good.
12 MR. MANOLY: Because they are f 13 meaningless. They don't serve any purpose. They 14 just waste time.
15 MR. CERNE: The bottom line is, is the 16 plant built well in accordance with design.
17 MS. GENTLEMAN: I think that's
. i 18 everyone's bottom line.
19 MR. DURR: Did that answer your 20 question?
I 21 MS. GENTLEMAN: Yes.
22 MR. DURR: Anything else? '
- 23 MS. TRACY
- Yes.
24 MR. DURR: Go ahead.
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, 1 MS. TRACY: I would like to leap ahead i
2 to page 3 here, under additional issues. Two issues 3 raised since April, 1987, number 1, a crack in the 4 core barrel, and number 2, felsification by a vender 5 of certification required from the manufacturer.
6 I was wondering what kind of progress I 7 has been made on these 2 issues. It seems to me that 8 an 18-inch crack in the core barrel would be 9 something you would leap on with all 4 feet, and I i
10 was wondering if you had come to any conclusions with 11 that one yet.
12 MR. DURR: This is not part of the 13 87-07, is it, or 86-52?
14 MS. TRACY: It is written into 87-07
,t 15 in response to the letter that I wrote to you, yes.
16 It is contained in the material.
17 MR. DURR: No. I'm saying we didn't 18 inspect this during 87-07; is that correct?
19 MR. RICHARDSON: That's correct. It
~
20 was brought to the NRC's attention after that i
21 inspection.
22 MS. TRACY: And it is included in the l 23 response that I sent you. So it is within the I 24 purview of this.
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! i 1 MR. DURR: I understand, but it's not
,'_ J 2 part of 87-07. We have never gone out and done a 3 formal inspection on that. ;
4 MS. TRACY: You haven't?
5 MR. CERNE: We've.done some inspection 6 on that.
7 MR. DURR: We've done something on 8 that. There's been something done on it, but it was 9 not part of 87-07.
10 MS. TRACY: We've been communicating 11 about it since June. So I figured that you all must 12 have done something.
13 MR. CERNE: I did.
14 MR. DURR: We talked to the guy, t 15 didn't we?
16 MR. RUSCITTO: Yes.
17 MR. DURR: The supervisor that was on f
18 site that went out with the guy was still on site ,
19 when we were up there, and you talked to him.
20 MR. RUSCITTO: As soon as we got the 21 allegation I went to the supervisor that he brought 22 out with him to look at the crack on the core barrel, t 23 and we discussed the issue. And basically from the 24 NRC's point of view there was no crack. I am not i
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l 233 1 saying that only based on this discussion because I 2 personally inspected the core barrel when it was 3 being installed, and there was no crack in the core l 4 barrel as described.
5 The way the supervisor described it 6 as a shimmer, which on polished low alloy steels you 7 get reflections of light, that it could have been 8 miscontrued. But when you went out with the alleger, 9 the alleger was unable to point and identify anything 10 other than a glimmer of light on the piece of metal.
11 The alleger at,that time walked away satisfied that 12 there was no problem. Now, he came back to you later 13 on indicating that he still wasn't satisfied.
14 MS. TRACY: He came back to the 15 utility later on. I 16 MR. CERNE: There was a third 17 inspection. He went to the EAR program as he was 18 leaving the site, and besides Daves inspection, 19 besides the inspection done by the particular 20 supervisor of the individual, an EAR individual went i
21 out with the gentleman again looking for the crack in 22 the core barrel, and it could not be found. If you s' 23 looked at the coloration of the core barrel, either 24 sitting in place or moving around on a crane as it's i
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- i 1 going into the vessel --
,La 2 MR. RUSCITTO: With the bright lights ,
3 of the containment it's conceivable he might have 4 thought he saw something.
5 MS. TRACY: Yet it was dismissed as ,
6 something that had been scored and that had been i 7 dealt with at one point in their documents --
8 MR. RUSCITTO: I can say unequivocably 9 that his description of that is not accurate to what i
10 the core barrel was when I inspected it. '
11 MS. TRACY: Did you read the docume..t 12 that was generated?
n 13 MR. RUSCITTO: Yes.
14 MS. TRACY: And there was nothing i 15 about scoring at all?
16 MR. RUSCITTO: Yes, in his affidavit 17 there was. In the affidavits of the people who went 18 out and inspected it, both in his presence and 19 afterwards independently, no one was able to identify 20 either a crack in the zigzag shape which he 21 described, or the stop holes that he said he thought 22 had been drilled in to prevent the crack fron l 23 spreading. There just has been no substantiation of
_]
24 that issue, and from the NRC's point of view we don't i
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235 1 feel that there's anything to pursue that.
2 MR. CERNE: You're right. If we 3 thought there was a crack in the core barrel, we 4 certainly would pursue it.
5 MR. RUSCITTO: You bet..
6 MS. TRACY: It would have been really 1
i 7 considerate of you to have gottan back to me, so --
8 MR. CERNE: We have given you the 9 courtesy of incomplete documented inspection 10 findings.
11 MR. RUSCITTO: We don't normally give f
12 preliminary inspection findings out.
13 MS. TRACY: So you are going to put 14 this in a report?
t 15 MR. RUSCITTO: It will be in a future 16 inspection report.
17 NS. TRACY: Okay. Because I had i
18 written to Bill Kane a number of times about this, 19 and never heard anything back about it. So I 20 appreciate you're giving me a preliminary.
l 21 MR. HAVERKAMP: I believe we did 22 respond to that matter. In one of the letters that
- 23 we sent you this year we also included references in 24 the letter that when you gave us information about l
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r 1 the crack in the core-barrel, we said that we !
2 believed we had enough information to pursue the ;
3 matter. We did not need anymore information. At 4 that point, as far as our interaction with you is i 5 concerned, we had no more questions to ask.
6 MR. RICHARDSON: I-think her question 7 or her concern was that we had not b'een apprised of 8 what your evaluation was.
9 MR. RUSCITTO: That will be included 10 in a future inspection report. ,
11 MS. TRACY: Do you know when, or do 12 you have any idea?
i 13 MR. CERNE: No.
14 MR. DURR: I think, for the record, 15 that action that you took was early this Spring.
16 MR. RUSCITTO: It was immediately .
17 after we got the allegation because the-supervisor '
18 was leaving the site --
19 MR. HAVERKAMP: July or August. -
20 MR. RUSCITTO: We were able to get to 21 him before he left.
22 MR. CERNE: With some of the issues 1
t 23 that are here and how we are going to package this in f] 24 an inspection report, instead of scattering and P
l i
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237 1 shotgunning it today, that's sort of an 2 administrative decision. But to date, these are the 3 inspection findings that we have on this issue.
4 MS. TRACY: You are not going to 5 really go into it any further. I'm just curious 6 because I know that you've put out.a couple of 7 inspection reports since you apparently looked into 8 it, and I was just wondering when I would have 9 something to send to this guy, who feels like he sort 10 of put himself out on a limb to bring it up.
11 MR. RUSCITTO: I can't commit --
12 MR. CERNE: That will be an ,
13 administrative and a management decision.
14 MR. RUSCITTO: Management is trying to ,
15 make a decision on how to best deal with the 16 remaining issues that have not been put to bed.
17 That's the best I can tell you.
f 18 MS. TRACY: Management? i 19 MR. RUSCITTO: NRC management. l l
20 MR. DURR: Us. The buck stops here. l l I
21 MR. CERNE: Without belaboring the 22 point, it's consistent with our philosophy to satisfy 1
23 ourselves that there is not a problem. ;
l 24 MS. TRACY: I am sure. I would i AREA-WIDE FEDERAL REPORTING, INC. (215) 925-5777 l
I 238 L ! 1 definitely believe that you would be concerned about i.J 2 this and want to satisfy yourselves.
3 MR. RUSCITTO: I think if there was 4 any indication; that we felt that there was a defect 5 in the core barrel, it would be grounds for 6 significant re-inspection. ,
1 7 MS. TRACY: I will get back to him and 8 let him know what the conclusions were.
9 The other item was the falsification i
10 by a vender of certification required from the 11 manufacturer. Were you able to look into that?
12 MR. CERNE: That's one, as a matter of 13 fact, when we were going through trying to package 14 your items, where it stood in your November 12th 1 15 letter 1 through 12, where it stood in the stuff you 16 gave Jacque, A through M, where it stood in previous 17 inspection reports, and to tell you the truth, we 1
18 couldn't find anything on it.
19 MS. TRACY: You couldn't find it?
20 MR. CERNE: Which issue is it? Can you 21 identify A through M?
22 ---
t 23 (Whereupon a short break was taken at this time.)
I] 24 - -
4 i
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239 1 (Ms. Gentleman, Mr. Greenstein, and Mr. Haverkamp
-2 excused themselves from the meeting and are not 3 present at this time).
4 - - -
5 MR. DURR: Let's reopen the* record.
6 We're back to you. Sharon.
7 MS. TRACY: Tony had asked me, and 1 8 understand your question to be, where was this issue 9 raised. And where it was raised was in my answer to 4
10 some of the questions that Jacque had asked me.
11 Perhaps it was Bill Kane.
r 12 MR. CERNE: Could you point that out?
13 MR. DURR: In the transcript?
14 MS. TRACY: In the cover letter. In 15 the cover letter to my response to some of those 16 questions there were two issues raised. One was the 17 issue of the crack in the core barrel, and the other 18 was the issue of falsification by a vender of 19 certification required from the manufacturer. Do you I 20 see that there?
21 MR. CERNE: Yes.
22 - - -
1 23 (Mr. Haverkamp is now present at the meeting). ]
24 - - -
)
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240 l l
l 1 MR. CERNE: To answer your question,
(
l g_
2 we haven't done anything with that, and Mass. Gas and 3 Electric is not a safety related supplier. It has'to 4 do with turbine building work, and it would be a 5 management decision as to whether we do anything with 6 it at all, given the fact that the vender you are 1 7 mentioning here is not a safety related supplier.
8 MR. HAVERKAMP: Before we talk anymore 9 specifically on the record, I guess I would like to
.6 10 get a discussion off the record, if I could --
11 MR. RUSCITTO: We are already on the 12 record.
t 13 MR. HAVERKAMP: I know, but you 14 haven't identified yet the vender. Is that right?
I 15 MR. CERNE: No. Before you walked in 16 Sharon identified the reason I couldn't find it in 17 the attachment things she put it in the cover letter i So I was looking 18 to the response to Jacque's report.
19 for it in the information you gave Jacque on April 20 20th and couldn't find it.
I 21 MS. TRACY: I see.
22 MR. CERNE: So that's where my i 23 question mark drew a blank. Now you've pointed it
] 24 out to me, and this is the first time I'm looking at i
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1 it in terms of what we would do, if anything, to tell i
2 you right now, just like we did on the core barrel, 3 the status. We haven't done anything with that yet.
4 It will be a management decision whether we do I
5 anything with it, given that that, as I know it, is a 6 non-safety related supplier. So the vender i 7 application would not require OA.
8 MS. TRACY: And if you need further i
9 information, you will contact me.
10 MR. HAVERKAMP: Yes. We would like to 11 discuss this separately because I don't want to get 12 too much information on this record as to what the o
13 specifics of the matter are. We will continue the 14 discussion later.
4 15 MS. TRACY: Okay.
16 Now, there is some issues you wanted 17 to talk about, Don, but are not related to what is 18 right in front of us. Do we want to wait until 19 later?
20 MR. HAVERKAMP: Have we covered all of I
21 the issues that you considered important to discuss 22 that were on your agenda?
- 23 MR. GRAY
- I would like to say l l
24 something about D, 6(D). l i
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242 1 MS. TRACY: Okay.
3 2 MR. GRAY: Previously there was a 3 question of 100 bad welds. That was in 1984. It was 4 not on the service water system. It was on piping in 5 the radioactive pipe tunnel. The alleger, when 6 interviewed by our Office of Investigation, said that 7 he did not consider those to be 100 bad welds. He 8 only didn't like them. But he was not of the opinion 9 that they were truly bad welds.
10 What I'm really asking, is D talking 11 about that 100 welds which were not in the service 12 water system, or are you making a claim that there t
' i 13 are 100 bad welds in the service water system. I 14 suspect that your answer is going to be that you are a 15 not.
16 MS. TRACY: I suspect that your answer 17 is correct; that there was some confusion there. ,
18 MR. RICHARDSON: One thing that might 19 help clarify that is that that alleger had also 20 discussed with us some welds that --
my understanding i
21 of the area he was referring to was service water 22 piping in the yard --
that were also questionable.
1 23 His specific concern was that the pipe that was being 24
, welded had not been adequately pre-heated, and they AREA-WIDE FEDERAL REPORTING, INC. (215) 925-5777 i
i 243 i l
1 had problems with condensation gathering in the lower j i
2 area of the pipe, and this was producing some 3 porosity in the welds. I don't know whether he had 4 also found other problems as well, but I believe' 5 perhaps what we've got here is an inadvertent 6 combination of the two. Where we would have a 7 question concerning the service wate: system, I 8 believe what we would be dealing with is the effect 9 of these welds that he had told us about.
10 MR. GRAY: That's the 3 bad welds that 11 he talked about in the April 20th interview.
12 MR. RICHARDSON: I believe they were 13 discussed in the April 20th interview.
34 MR. GRAY: And we've answered those in 15 the 87-07.
16 MS. TRACY: Yes. You did address that ;
17 in the 87-07, that's true. You are correct. There i
18 is an incorrect mixing of issues.
19 MR. GRAY: 6(D) is no longer a problem 20 from our point of view.
21 MR. RICHARDSON: From our point of 22 view one of your recent reports indicates that there i 23 is beginning to be identified a little bit of flaking l
, 24 around some of the repair joints. I believe what was l
1 AREA-WIDE FEDERAL REPORTING, INC. (215) 925-5777 j
i 244 i; 1 cited specifically was around in the area near the
- L a 2 service water valve number D-15. It was one of the 3 most recent reports.
4 Basically our concern, I guess, was 5 whether the effect of the welds that the alleger 6 perceives to be questionable on the integrity of the 7 system would be -- whether the quality of those. welds ,
8 would be affected by the microbiological 9 contamination problem in light of the continuation of 10 flaking.
11 MR. RUSCITTO: I think you've got 12 apples and oranges here. You're talking about weld LJ 13 problems. What you're referring to in our inspection 14 report is liner problems. The fact that that liner i 15 is having a problem where the welds are, makes cense 16 because that's the place where the liner was 17 repaired.
1 I 18 MR. RICHARDSON: Yes, i 19 MR. RUSCITTO: But the flaking ;
1
, 20 problems and any problems that are hypothesized on i
<\ l 21 welds are 2 separate issues. The answer to your l
1 22 question is, no, we don't see that as a problem. j l 23 Number 2, we've already said that we
[] 24 don't believe that we have a MIC problem in service I
)
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f ,
i 245 I water anyway. So even assuming there were problem i
2 welds, which you have no indication of, we don't see 3 any reason to worry about MIC there at this point.
4 MR. RICUARDSON: Okay. I guess our 5 concern was that if the concrete lining is flaking, 6 does'this expose the steel in the pipe.
t 7 MR. RUSCITTO: Yes. That is of 8 concern to the NRC, bot not because of MIC.
9 MP. CERNE; And not because of the i
10 weld problem. The pipe is designed to have a c e rae n t 17 lining to prevent that from happening. It has ,
12 nothing to do with any allegation.
13 MR. RICHARDSON: You're aware of it 14 and keeping an eye on it?
) 15 MR. RUSCITTO: Oh, yes. Unrelated to 16 MIC though.
17 MR. DURR: Is there anything else that I
18 you would like to discuss relative to the agenda or 19 the items that are in your Novemoer 12th letter?
20 MS. TRACY: I think that generally we 21 have gotten answers to your --
or I would know how 22 you would respond to each item now.
I 23 So if you would like, we can go back
( 24 to the process we were going through before we AREA-WIDE FEDERAL REPORTING, INC. (215) 925-5777
y 246
( 1 diverted to this.
2 MR. DURR: If you have questions in 3 there, yes.
4 MR. HAVERKAMP: I would suggest that 5 we go back where we left off and at least walk 6 through the issues, and see if there is any i 7 additional questions you have.
8 MS. TRACY: Right.
9 MR. D !.t R R : We are just beginning i
10 2.1.4. This was the electrical conduit fire. I 11 would like to respond to A of that, because there is 12 difficulty in identifying the location of the conduit
'- 13 there is no guarat. Lee that the appropriate system was 14 examined.
I 15 Based on the drawing you gave me, and 16 then the subsequent drawing which was made part of 17 the report, and the actual building drawing, I think i
18 it's very clear that we have the correct corridor 19 which the alleger was describing because of the lead 20 window that he was talking about, and the door and 21 all those things, and the computer. All of that fits 22 very sell. So it's narrowed down to that corridor.
l 23 I think that's the upside down photograph in the
[] 24 report, my secretary did to me.
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, ;_ - u:;,- -
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~ r. / ~ ; 247 1 ,',;' Needless to say, if, you look at that 2 . corridor, it's very obvious that th'ere are only a 6 , --
3 couti le ,of conduits th9t even r .J .o t e l y .c o s. e m b l e the 4 things that he was tan ing db3u t . - so I feel very 5 confident'that w e a r e, : n' t h e r i g h t , l o c a t i o n , and I
~
6 feel<
even more contident'because p ' of hxa 20 feet down 7 the corridor that that narro,usnit d o w'n' 't o t h a t single n- , /
, d
8 tra'nsfo5mer in that lighting distributi,on panel. So
,,, ~
~
~
9 I feel o?.dy comfortable,that there in'no.qcestion in q]'
e' s
10 my . niind that w e ' v e g h't ^ t h e rihht location,* and the
- ,, . ['. , e. .- ' ,f, .
t e r. t s .t.b 9t we performed w'ou.13 indicate
~
11
' n o t ,o.nl y 12 did T.make t) e m d o ,,e l e,a t t,1 c a l insulation r3aistance ,
13 test's, but I madei.,t h at m t a k e', t.h e uovers off'so I could -
14 look inside tie Q,ndsit'w!terefthe
... . /
alleged fire took.
15 place. And tndre was obviob s't y rio fire damage in 16 that area, "- '# '~
4
.. /
/
17 ,
x Not/ i ,t may have. occurred and they t-18 replaced t o '. . fixed it, but right now I don't think
~
19 there is any question.that the'e1qettical aspects of 20 that see safe, anQ there's nothing to be concerned ;
1 1 21 with. J .,
22 MS. TPACY: The issue you raite,'about I
g 23 th'em perlipps having replaced it is o n e t, E rst I hadn't I e . :
i i 24 coniridered before. / l.
~
l t .. ,
1
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AREA-WIDE PEDhhAL Ri? PORTING , INC . (215) 925-5777 l
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J 248 ,
r i, 1 1 MR. DURR: Assuming the alleger was
- J. .
2 telling the truth and there was fire in that area, 3 and that was really the only place it could be, then ,
4 if there was, in fact, a fire, it's been repaired.
5 MS. TRACY: That would explain.why you 6 couldn't find any evidence of the fire.
1 7 MR. DURR: There is no evidence today 8 that there was any damage to the cabling and the 9 wiring.
I 10 MS. TRACY: Because I'm positive that 11 he's telling the truth.
12 MR. DURR: I don't have any reason to EJ 13 doubt him, i 14 MR. RICHARDSON: If any repair work j 35 had been done, would it be documented?
16 MR. DURR: I don't know that because 17 that's non-safety related stuff. It's a lighting i
18 transformer. It provides no safety function. Very
, 19 little .,quipment in that building is safety related.
1 20 I think that's a correct statement. There are only 21 one or two components in that building that are 22 safety related at all.
l 23 Anything else on 2.1.47 I 24 MS. TEACY: No.
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249 1 MR. DURR: 2.1.5, this is the 2 emergency feedwater system. -
3 MR. RICHARDSON: The firut time that 4 question was discussed it was in 86-52. Some of the 5 aspects of the concern I raised did not appear to 6 have been addressed, specifically with regard to the 7 emergency feedwater pumps. I was concerned that they 8 were both in one room with no barrier between them to 9 prevent fire from damaging both units.
10 MR. DURR: That particular aspect was 11 written up in the safety evaluation report. It was 12 reviewed by the licensing arm of the NRC. They use 13 the standard review plan which is a document that 14 says look at A, B, C, D, and tell the reviewer 15 exactly what to look at. Then if there are any 16 deviations from that, we have to resolve them. That 17 took place. That is documented. It's put out in a l 18 new reg, and I forget the number of it. But anyway, 19 that design aspect of the fact that both pumps were ,
, 20 in the same room was looked at and accepted. So a 21 technical expert has reviewed it and accepted it.
22 MR. RICHARDSON: As my understanding r 23 goes -- correct me if I'm wrong -- but that was 24 accepted on the basis of the start-up feedwater pump l
1 4
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. i 1 being available to perform emergency feedwater -
_J 2 function?
3 MR. RUSCITTO: Not exclusively.
4 MR. DURR: Not exclusively, but that 5 was a consideration. It was a consideration, but not
. 6 the sole consideration.
7 MR. RUSCITTO: There is no requirement 8 that emergency feedwater pumps be in separate 9 buildings. I don't know of any nuclear power plants 10 that have emergency feed pumps in separate buildings, 11 MR. CERNE: There are other --
12 MR. RICHARDSON: Is there a 13 requirement for a fire barrier between them?
14 MR. CERNE: No. They are allowed to 15 be in the same fire zone if it's a low --
16 MR. RICHARDSON: Low fuel.
17 MR. CERNE: Low fire hazard area.
18 There are separation constraints, and it is tied l 19 somewhat to the start-up feed pump, but not 20 exclusively. That is in accordance with design. That 21 design has been reviewed by our experts in 22 Washington, and it's been built in accordance with l
23 that design. l l
24 MR. RICHARDSON: I'm aware that you've t
AREA-WIDE PEDERAL REPORTING, INC. (215) 925-5777
251 1 approved the set-up as it is, but I'm still concerned 2 in that the start-up feed water pump apparently is 3 not constructed to seismic standards.
4 MR. DURR: Let's address that 5 question. You have to understand that the emergency 6 feedwater pumps are the_ primary source of emergency 7 feedwater.
8 MR. RICHARDSON: Yes.
9 MR. DURR: And they are seismically 10 qualified, and they are capable of performing.
11 With that issue-solved, we don't even 12 take credit for the start-up feedwater pump. So shy 13 does it become an issue?
14 MR. RUSCITTO: If it's a matter of 15 your personal technical opinion, that's different 16 than not meeting established criteria. I think 17 that's the point here.
l 18 MR. RICHARDSON: It could be. I'm not I l
19 comfortable with it. It doesn't appear to be the l 20 best possible set-up.
21 MR. DURR: You can't come up with a 22 scenario under the design criteria where that's l
'i l
- 23 unacceptable. That's what you have to come up with.
( 24 Thet's the case you have to make. Would the design I
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i 252 f
- y 1 criteria present a scenario where that doesn't' work?
l-2 Do you see what I'm saying? ;
3 MR. RICHARDSON:~Yes.
4 MR. DURR: Because the first~ thing I 5 have to do is, I have to lose my main feedwater 6 pumps, and then I have to be on emergency-feedwater, 7 and now I've come up with a scenario where I end up 8 losing both of my emergency feedwater pumps, and we ;
i 9 can't-do that under a "credible" accident scenario.
L 10 That's the criteria that we're working from. That's 11 the rationale that was driving all of this. You have 12 to come up with why can't it work. Then once you can 13 do that, then it may need redesign. 1 14 MR. RICHARDSON: Okay.
( 15 MR. DURR Next? Is that it with that ;
l 16 issue? Any other questions?
j 17 MS. TRACY: No.
!l 18 MR. DURR: Moving on to 2.16. No 19 present comment. Okay.
20 The same way with 2.17, 21 MS. TRACY: 2.17 was dealt with.
22 MR. DURR Under 2.4. I understand.
! l l 23 2.18, we're back to cold pulling. l 1
l 4 j' g 24 MS. TRACY: Cold pulling. We already '
i 4
g I
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1 dealt with the issue of the 13 stage. j i
2 MR. RICHARDSON: I'm concerned about l 3 your analysis of the cold pulling problem that was j 4 presented to you. You have discussed the one 5 instance of cold pulling that was documented at the 6 plant. A number of the people that we've talked to i 7 have said the same thing, and judging from their 8 descriptions they don't appear to be talking about 9 that same incident.
10 Now, the analysis that you appear to 11 be relying on to say that cold pulling was not a
, 12 problem, appears to address only the use of what was ,
i 13 called the Dearman clamp; that 70 sub-systems were 14 analyzed to see if the stresses put on them by the l 15 Dearman clamp would be excessive. The problem is 16 that most of the people that have contacted us about 17 cold pulling haven't been talking about that clamp.
18 They've been talking about comealongs and chainfalls 19 and the like, and you haven't got a 1 1/4 inch -- you ,
20 haven't got a positive stop at 1 1/4 inch of travel.
21 MR. DURRt I'm going to probably open 22 my mouth and put my foot in it, but let me try to i 23 address that. This is really Kamal's area. But the i 24 70 analyzed cold pulling scenarios done by the i
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254 i : 1 licensee did not involve the Dearman clamp. Those
.i
- 2 2 were 2 separate' issues. The Dearman clamp was one 3 thing, and the 70 analyzed cold pulling situations 4 were another. They were totally separate issues.
5 They were talked about in the same breath because 6 somebody, and I think it was David Day, made some 7 remark concerning using Dearman clamps and squeezing 8 pipes out of round and all of those kinds of things.
9 That was one issue that we addressed, 10 but the separate issue was that the thing that 11 umbrellas all of those cold pulling instances, if 12 they did occur, was the fact that the analysis'that 13 the licensee did shows very conclusively that you 14 would have had to cold pull excessive amounts before 15 you would exceed what is allowable. Is that a good 16 characterization?
17 MR. MANOLY: Yes.
1 18 You brought up, I think, 3 different 19 examples of what you characterized as cold pull. One i
, 20 is the CBS piping -- '
21 MR. RICHARDSON: That's not one of l l
22 mine. l 1
1 23 MR. DURR No. That was David Day from 2
24 40 feet up.
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1
f 255 1 MR. MANOLY: If you read what we wrote i
2 here on that particular piping, and the flanges were 3 --
I believe in that piping that the weld was done 4 after the --
, 5 MR. DURR: The weld that he was 6 talking about was done, and then the flanges were 1 7 made up. So there's no way that that could have been 8 a cool pull situation. If it would have been cold 9 pulling, it would have jumped, and they didn't have 10 any problem with that. ,
11 MR. RICHARDSON: I can't really say 12 anything about that because that's not something I 13 know personally.
14 MR. DURR: That brings up a very good
{ 15 point. In the service water piping where there was 16 alleged cold pulling they went back and took bolts ;
17 out of a lot of this piping, and they didn't have any ,
i 18 instances of the piping jumping around.
19 MR. MANOLY: 30 valves.
4
. 20 MR. DURR: That's a good indication.
!1 21 Had they had excessive cold pulling in those systems, 22 they would have had trouble getting the bolts back in
- 23 those things, and that wasn't the case.
24 MR. RICHARDSON: Is the area in which i
ii AREA-WIDE FEDERAL REPORTING, INC. (215) 925-5777
256 i i 1 he was talking about cold pulling close enough to the
. J 2 valves that any stresses that were being incorporated 3 would have made themselves known when the valve was 3
4 disassembled?
5 MR. DURR: The valve was not that far 6 from the flange. It's in the picture.
7 MR. MANOLY: It's very close to the 8 tank.
9 MR. GRAY: It's close for reassembly.
10 MR. DURR: I remember taking the 11 pictures. That's my photography. This picture here, 12 see the valve? That's a CBS line.
13 MR. RICHARDSON: The service water one 14 is a different one.
15 MR. DURR: Yes. The service water 16 one, that's a big 30-inch line or something like 17 that.
18 MR. RICHARDSON: Okay.
39 MR. DURR: We have pictures of that 20 one too.
, l 21 MR. RICHARDSON: I remember there was 22 some question in Mr. Day's opinion as to whether you l
' 23 had looked at the area that he had told you about on
'j _ ,
- 24 that. I'm not exactly sure. I don't think I should s !
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1 257 1 be asking questions about it.
.I ,
2 MR. DURR: This picture here is in 3 inspection report 84-- whatever it was -- 06 or 07.
y 4 MS. TRACY: 84-12.
5 MR. DURR: This is the same picture 6 that was in the other report, and he said, see that i 7 picture. That's the area I was talking about. We 8 not only looked then, but we looked at it in this 9 report also. The bolts were removed, and that plate i
10 didn't jump. ,
11 MR. MANOLY: In '85.
12 MR. RICHARDSON: Okay, if that's what 13 he said.
14 The reason I was concerned about your 21 15 analysis, or I gues: the utility's analysis of cold 16 pulling, is that perhaps in the way the inspection 17 reports have been written, where you've handled the I
18 subjects as far as our concerns, the appearance was 19 that you were relying on an analysis that was based 20 strictly on the use of the
Dearman clamp. ,
21 MR. DURR: No.
22 MR. RICHARDSON: If that's not the t 23 case, I wou1d appreciate a clarification.
24 More specifically, there is a report
- l AREA-WIDE FEDERAL REPORTING, INC. (215) 925-5777
1 258 i 1 that was done by, I guess, a consultant group to the
,. J 2 plant in 1982. It was done basically to INPO 3 guidelines, and it's in the Local Public Document 4 Room under a cover letter by you that refers to it as 5 INPO report. But there is a citation in that report 6 that there were a number of non-conformance reports i 7 written in early 1982 that dealt with cold pulling.
8 The specific area in which the report was discussing 9 those was in a concern as to a lack of trending of i
10 problems to identify recurring deficiencies.
11 Given that this is criticized in that
,_ 12 area in that report, and given that your report L-- 13 appeared to be relying on analysis of stress induced l l
14 by
Dearman clamps,
my concern there was whether the l 15 utility had adequately investigated the problem and 16 the use of other equipment. Have you reviewed the 17 INPO report?
l 18 MR. DURR: Have I personally? No.
19 Let me respond to it. You guys correct me if I'm 20 wrong, but I think I understand the question.
21 It goes back to the fact that UE&C 22 imposed originally a very strict, unreasonably tight )
l i 23 cold pulling tolerance on the piping systems. This I] 24 made it almost impossible for the people in the field i
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259 l 1 to make a fit-up where they didn't violate it.
I 2 Therefore, it generated an enormous amount of 3 non-conformance reports because QC was doing.their ;
4 job writing up cold pull when they found it. So this 5 only supports our argument that QC was doing their 6 thing.
l 7 Subsequent to that, much later, they
- 8 recognized that those cold pulling tolerances were 9 unrealistic, and they generated a more realistic set i
10 of cold pull tolerances. But during that period 11 where they had these unrealistically small cold pull 12 tolerances QC was writing them up like they were ,
13 supposed to. They were doing their job. This 14 generated an enormous amount of reports. :
] I 15 Now, I suspect that this is what INPO i
16 is talking about. They've got all of these 17 non-conformance reports, and nobody is trending them.
1 -
18 It's QA doing their job which, I guess INPO's concern 19 would be, is putting an unnecessary load on QC, and
, 20 somebody ought to look at the root cause and fix 2L whatever the root cause was. Am I in the ballpark?
22 MR. MANOLY: Yes.
I 23 MR. DURR So that's the way I l
1 24 understand the story. I think that's what we say in i
1 iL :
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[
> 1 87-07, is essentially that they unnecessarily
,_J 2 restricted themselves, and under today's 20/20 ,
3 hindsight they should have had a much more liberal 4 tolerance on cool pull, and that would have done.away 5 with a lot of those non-conformance reports.
6 MR. RICHARDSON: How does that square 7 with the information you put in 86-52 where the 8 people who were identifying cold pulling pipe were 9 unaware or the prohibition against it where --
l 10 MR. DURR: Wait a minute. That 11 statement didn't make any sense. You may want to 12 rephrase that. You said that the people that were LJ 13 identifying cold pulling were unaware of it. If they 14 were identifying it, they must have been aware of it.
I'
!t 15 MR. RICHARDSON: There's a difference 16 between the people identifying the problem and the 17 people who were actually doing the installation work.
I 18 MR. DURR: Who do you mean by the 19 people actually doing the installation work?
20 MR. RICHARDSON: Let me see if I can
,I j 21 find this thing.
22 MR. CERNE: While he's doing that let 1i 23 me clarify one point. The Dearman Clamp issue was I] 24 related to the 70 systems in the common thing,
't AREA-WIDE FEDERAL REPORTING, INC. (215) 925-5777
261 1 50.55(e). When the licensee identified under 2 50.55(e) that they had exceeded the tolerance on the 3
Dearman Clamps,
they went back and analyzed the 70 4 systems that could have been affected, and did an 5 engineering analysis of each one, taking the worst 6 case situation that the plant could have applied to 7 that pipe and dispositioning it as not being 8 detrimental to the stresses in the pipe.
9 What you said was also correct 10 though. The thing they did in tracing the ELP 11 allegation was separate from that, as was your 12 investigation. So there were 2 separate 13 investigations, but their investigation of these 70 14 systems was related to the 50.55(e) which was related 15 to the use of the Dearman clamp.
16 MR. MANOLY: It has two functions.
17 One is to -- mainly it's to bring together the 2 ends 4
18 of the pipe. The allegation was that the Dearman 19 clamp would change the cross section of the pipe on 20 one end. That's one issue.
21 The other issue is that when the 22 clamp brings the 2 ends together that have to get i 23 welded, that it might have brought it more than the l f 24 tolerance of 1/8 of an inch. And the maximum that AREA-WIDE FEDERAL REPORTING, INC. (215) 925-5777 l
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262 ,
1 the pipe can handle is 1 1/4 inch. They took the 1 r-]
,'i J '
1/4 and applied it to those 70 systems, and tried to 2
3 determine how acceptable these systems are. That's 4 what our report addressed here.
5 MR. RICHARDSON: How do you come with 1 6 out of 70 sub-systems, you've got a total 88 on the i
, 1 7 graph --
8 MR. MANOLY: That system involves many ,
9 piping systems. The piping system is not just one i
10 row of pipe.
11 MR. RICHARDSON: Any one of those [
,_ 12 could have been broken down into a number of I -
13 components.
14 MR. MANOLY: Yes.
I 15 MR. RICHARDSON: The citation I'm 16 talking about is partially on page 74. ,
i 17 MR. DURR: Of which report?
}l 18 MR. RICHARDSON: Of 86-52.
19 It doesn't specify who identified i 20 that particular incident, but in the discussion it ]
21 mentions some degree of unawareness by the piping
- 22 contractor, and again, it doesn't specify the exact
- i
!I 23 nature of the cold pulling prohibition. !
l
[] 24 MR. CERNE: That was one of the things i
j AREA-WIDE FEDERAL REPORTING, INC. (215) 925-5777 J
I 263 1 we cited with the problem with Pullman-Higgins in one 2 of our SALP reports.
3 MR. RICHARDSON: Is that the i
j 4 construction practices --
5 MR. CERNE: Yes, contrary to specs, I 6 acknowledged specs. That was one of the reasons at e 7 contributed to their 3. The resolution of the 8 50.55(e) and the
Dearman clamp issue has,
again going 9 back to our basics, resulted in a plant that is built i
10 properly.
11 MR. RICHARDSON: The problem with the 12 Dearman clamp analysis that I have is that it doesn't .
13 take into account any possibility that anyone was 14 using any other equipment. The other people that i 15 we've talked to, they say comealongs, they say 16 chainfalls. I saw a chainfall being used in the 17 turbine building.
- 18 MR. CERNE
- They analyze safety 19 related systems because we're not concerned with 20 non-safety systems. ,
- I t 21 MR. RICHARDSON
- Wait a minute. If 22 that's indicative of the same practices that were ;
)i 23 used in the safety system -- l
! 24 MR. RUSCITTO: It isn't because --
i t
I AREA-WIDE FEDERAL KEPORTING, INC. (215) 925-5777 i
I 264
,; 1 MR. CERNE: When you talk about 3
2 turbine building work and non-safety work, you can't 3 naturally draw a conclusion over on the safety side 4 because there is no QA involved there. There is no 5 independent look at whether people are violating 6 procedures or not.
I 7 MR. RICHARDSON: Was the cold pulling 8 prohibition in effect for both the B31.1 and the ASME S systems?
I 10 MR. CERNE: Yes.
11 MR. RICHARDSON: So if I've seen
- 12 somebody trying to force a pipe into place with a 13 chainfall on a B31.1 line system, is it in~ conceivable l 14 then that given that you've got a contractor that is t 15 not fully familiar with the specs, that the same 16 thing could not have occurred in the safety systems?
i 17 MR. CERNE: It's not inconceivable,
't 18 but based on our ovaluation of the QA program we 19 believe that the QA would have caught that because 20 that was one of the things they were looking for in i
21 fit-up. They had to do fit-up inspections for every 22 weld.
I 23 MR. DURR: You have to understand that
[ 24 the difference here is that there is a quality AREA-WIDE FEDERAL REPORTING, INC. (215) 925-5777
I 265 1 assurance / quality control program over the safety 4
2 related, and there is none or very little over the j 3 non-safety related. So that if those practices were ,
4 being employed in the non-safety related, that's one ,
5 issue. But if it's being employed in the safety 6 related, you have the factor of quality I 7 control / quality assurance that's preempting all of 6 that, as evidenced by all the non-conformance reports 9 that were written against cold pulling.
I 10 MR. MANOLY: Closure welds on safety 11 systems are witnessed at the hold point at the fit-up 12 and -- ,
l 13 MR. RICHARDSON: Do you check at that 14 point to be sure, or do they --
- i 15 MR. MANOLY
- That's what hold point 1
16 means; that the QC would be there. It is not a
]
17 requirement on non-safety closure welds.
I 18 MR. CERNE: They have to be there for 19 the fit-up and tack process.
20 MR. MANOLY: We state in our report 1
21 that the requirement for a cold pull was addressed as 22 early at 1978 because I saw a revision of that !
t 23 procedure, X9, Pullman-Higgins. The requirement for l
{ 24 cold pull was established since 1978. j l
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i 266
,r i 1 MR. RICHARDSON: Whose personnel were
,(J
- 2 responsible for witnessing a closure, the fit-up at
- 3 the closure weld? Was that the piping contractors?
,; 4 MR. CERNE . Pullman-Higgins level 1 l 5 QC inspectors, as audited by Yankee level 2 6 surveillance inspectors and by Yankee Framingham 7 auditors.
4 8 MR. RICHARDSON: And the auditors
~
9 only --
t 10 MR. CERNE: Surveillance does a
'T 11 sample, and the QC inspectors do --
i 12 MR. RICHARDSON: I was working-for h -
1 UJ 13 Pullman at the time, and I was trained at about the '
j 14 time just before this incident occurred and --
i
. 15 MR. DURR: I think I know where your .
16 question is going.
]
17 Let me go back to a point that I 18 wanted to make before. Within the construction group 19 there are selected people who have to know that cold 20 pulling is a requirement --
or that the contraints on
. 21 cold pulling are a requirement, and that's the 22 engineers, the superintendents, the foremen, and the 3
23 people that are supervising the work in quality 24 control. Now, have any of the allegers fallen into
]{]
AREA-WIDE FEDERAL REPORTING, INC. (215) 925-5777
m5 267 1 that group? Because those are the people who are
.(
2 responsible for implementing those specifications and 3 drawings and procedures. It's the supervisory group
- 4 that has to know.
5 So for us to make a determination 6 that nobody knew about it, you have to look at that ,
7 population. Just because a. pipe fitter didn't know 8 there was a prohibition against cold pulling, he's 9 working under the supervision of a foreman at GP, or 10 a foreman or a superintendent, and the fact is, 11 that's the guy that blew the whistle on cold pulling ,
12 in the feedwater piping. It was a superintendent.
13 It's those people that are responsible for the 14 implementation. ;
15 So if it's not that population that 1 16 you're talking about, ic's conceivable that there are ;
17 people out there who didn't understand the I 18 restrictions on cold pulling. Until you start l
19 talking about that population, it doesn't have any i
20 meaning to us. Those are the people I really need to I I
21 know.
22 MR. RICHARDSON: So the evaluation l 4
23 that's cited in here was done r,trictly for the 24 effects of the Dearman clatnp; is that correct?
i i
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I 268 i 1 MR. GRAY: That's incorrect.
l,-
2 MR. MANOLY: No, that's not correct.
3 We said that the maximum movement of the 2 ends of g
4 pipe that would be welded would be 1 1/4 inch. That's 5 why we evaluated 70 systems with a maximum of 1 1/4 !
6 inch movement.
! 7 MR. RICHARDSON: But you didn't
, 8 consider any movement beyond that?
1 9 MR. MANOLY: Because the Dearman clamp 10 cannot be closer than -- you can't use it if it's 11 more than 1 1/4 inch. <
12 MR. DURR: Now you've got me curious.
l LJ 13 This table indicates that the maximum cold pull in 14 inches exceeds the 1 1/4 by this much. That's your 15 question, right, why these numbers go beyond 1 1/4 16 inch?
17 MR. RICHARDSON: No. Look at it the 18 other way.
19 MR. MANOLY: The number of systems.
20 MR. RICHARDSON: The number of
, 21 systems.
j 22 MR. DURR: I understand that, but your 23 question was, it only addressed the inch and 1/4.
i] 24 What I am saying is, this indicates that you could go AREA-WIDE FEDERAL REPORTING, INC. (215) 925-5777 1
I 269 1 well beyond an inch and 1/4 in a lot of systems, and I
2 it wouldn't not make any difference either, whether ,
3 you used a Dearman clamp or what you used.
4 MR. RICHARDSON: In some, but not 5 all? .
6 MR. DURR: In some, but not all. You 7 can see the distribution here. It's way over. It 8 exceeds its 3 1/2 inches and beyond in mont cases. I
. 9 think that may be part of the answer to your 10 question.
11 MR. HAVERKAMP: What table are you 4
12 referring to, Jacque?
13 MR. CERNE: Those aren't examples of l 14 cold pull. Those are examples of what the design
. 15 allows for --
16 MS. TRACY: Shall we move onward?
17 MR. DURR: The next one, 2.1.9.
18 MS. TRACY: I would say on this issue 19 the question is, what are the causes of the 20 problems. The reason we're asking the question is 21 that the concern that was raised about grit in the 22 valves was said to be a negligible concern. However, 4
23 there was further failure of valves. So we're asking i { 24 the cause of those failures to see if the concern we 1
1 AREA-WIDE FEDERAL REPORTING, INC. (215) 925-5777
I 270 i i 1 raised corrolates with them.
g.a 2 MR. DURR These were later inspection 3 reports. I guess, Harold, this is your stuff. ;
g 4 MR. GRAY: Yes.
5 First, there is very negligible grit 6 that has been found in the service water system. The 1 7 source of water for the service water system is.such 8 that it's unlikely to draw grit in from the outside.
9 The failure in the valve seats is not 10 due to grit, but was due to a design problem. If 11 this was a section of the valve, it's the inner 12 section of the curved surface that's rotated 90 LJ 13 degrees into a flat section that caused some abrasion 14 and eventual tearing of a very small portion of the 15 rubber liner. So it was completely unrelated to 16 grit, but that is explained in the later inspection 17 report.
18 MS. TRACY: So that's talking about i 19 the wear in the valve body liner?
20 MR. GRAY: That's right.
21 MS. TRACY: Does that also refer to l
22 the generic problem with the 30 Fisher valves, or was i
> 23 that caused by a different problem? !
1 24 MR. RUSCITTO: That is the 30 Fisher l l
l l
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271 i
l 1 valves.
l 2 MR. CERNE: The Fisher valve problem 3 is the valve liner problem.
g 4 MS. TRACY: So these 2 different t 5 reports are talking about the same valves. ,
6 MR. CERNE: We have several reports 7 that address that issue.
8 MS. TRACY: So that's basically a .
9 manufacturing problem, rather than a problem with 10 something from the outside?
r 11 MR. DURR: It's in the original design 12 of the valve, that's correct.
13 MR. RICHARDSON: I've got a question 14 for you in relation to that. One of your reports on ,
15 that subject notes that Yankee had not, at the time 16 at least, made formal notification to the 17 manufacturer that this problem had been discovered.
18 And in the discussion at the SALP meeting with the j 19 licensee back a month or so ago, somebody -- was it .
20 Mr. Kane? -- got into a discussion in the area of i
21 the steam powered emergency feedwater pump, ]
22 questioning again whether Yankee had been in touch
- 23 with other plants or with the manufacturer as to how i 24 to handle that particular situation.
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,) 1 Is this problem with passing on l_J 2 communication back and forth when they find a problem
, r 3 of some degree of severity? Is that a matter of t 4 concern to you? What do you plan to correct that? l i
5 MR. CERNE: If they violated the Code 6 of Federal Regulations, we would write a violation on t
. . 7 it. ;
8 On the original problem of the Fisher 9 valve seats, they reported it under a 10 CFR 50.55(e) 9 10 and they made a valid report, and the corrective 11 action was tracked under that mechanium. When the 12 problem recurred more recently, they reported It LJ 13 under 10 CFR Part 21. That was the regulatory i
14 reporting requirements. So there wasn't any evidence 15 where they had violated reporting requirements.
1
- 16 MR. RICHARDSON
- Is the notification 17 or discussion between the manufacturer and the
(
18 utility, or from one utility to another, is that a ,
19 requirement, or is that merely recommended? .
1 20 MR. DURR: It's only required to '
4 21 report it to the NRC. We look for generic problems 22 also.
- 23 MR. RUSCITTO: That was a
[] 24 recommendation made by one of our specialists.
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1 l . . . -
273 1 MR. CERNE: But the reporting
- i s 2 requirement under the original problem, the Fisher 3 valve' seat problem, was reported under 50.55(e). They 4 met their regulatory requirements,'and it is the 5 NRC's job to do something with that. If it was a 4
6 generic problem, there wasn't any evidence of it at ,
\ 7 the time.
l 8 MR. DURR: Next issue?
l 9 MS. TRACY: 2.2.0.
t 4
10 MR. DURR We've discussed that one, #
I 11 haven't we? Is that the one where we decided we had 12 mixed 2 issues together? ,
13 MS. TRACY: Yeah. I would scy that i 14 they aren't necessarily mixed here. Maybe I could 15 use a little clarification.
i 16 MR. DURR This is the one that's 17 addressed in inspection report 84-12.
l j 18 MS. TRACY: Right.
19 MR. DURR: We have already adde *: sed 20 that. Are there any questions concerning it?
3 l
4 21 MS. TRACY: Yes. There's a couple of l i
] 22 questions. One is, it's being downgraded in safety l 4 23 requirements when the bad welds were discovered. The
\
j ( 24 other question has to do with the OI report, and l i
1 i
lt 1
i AREA-WIDE FEDERAL REPORTING, INC. (215) 925-5777 i
-l 274 r7 1 perhaps Harold can explain again why the OI. report is
- 1. J 2 not applicable to these welds, i
3 MR. GRAY: First, the 100 poor welds g 4 in the service water system are not in the service 5 water system, if we' re discussir.g the OI -report . ,
6 MS. TRACY: Okay. They're in the f
I 7 radioactive pipe tunnel?
e 8 MR. GRAY: That's right.
9 MR. CERNE: Which were the subject of f
10 the 84-12 inspection, and they were never downgraded 11 because they were safety related. That was addressed .
12 in that report also. That's the David Day -
-J 13 allegations that have resurfaced exactly verbatim.
14 MR. GRAY: The OI report includes an 15 interview of the person that David Day received his 16 allegation from.
17 MS. TRACY: Right.
18 MR. GRAY: When OI interviewed that i
19 person, that person said that he did not have a 20 problem with the 100 welds because they were bad. He 21 had a concern about them with respect to the internal j 22 surface, but he did not consider that the welds were
! l l1 23 bad. The exact verbage is available in our OI i
l p ,, 24 report, but it leads us to conclude that there was i
r 1 i l
)
i (215) 925-5777 AREA-WIDE FEDERAL REPORTING, INC.
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. . .,= .g .
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. j/. , ,
1 nothing to fol3ob at,that (ar.ticular item.
.(
2 / > ,M S . TRACY: Shen you say the inside
, , 9 3 surface.is b'ad ,
(
4 MR. GRAY: He had a_ concern with the
~
' /,
5 automatic 'felding process and its fusion of the K
, ~ ! ,', ' /
6 insert for the route / pass of the weld, and he only
\ 7 had an opinion that there was a problem there, but he 8 did not know for a fact that there was.a problem. In 9 84-12 we looked at some of those welds on the inside 10 cf the pipe with mirrors ano did not find a problem.
11 MS. TRACY: So it's a presumption on 12 his part that this particular equipment didn't do the s
13 job properly. But when you looked at it with 14 mirrors, you felt that he was wrong in his
. 15 assumption.
i 16 MR. GRAY: That's true. But more !
1 17 importantly, he didn't feel that there was actually a 18 problem, the alleger. When the alleger was 19 interviewed in detail, he concluded that there was l 20 not a problem. I 21 MR. DURR: Anything else?
22 MS. TRACY: I would say not.
I 23 MR. DURR: On 2.2.1 you didn't have i 24 any questions. Do you have any questions nowi We
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I
~l a 276 L i 1 addressed that in 2.4.
j_J 2 MS. TRACY: Right, we did.
3 MR. DURR: 2.2.7 was on the pump.
g 4 MS. TRACY: This was the issue'I think 5 you referred to earlier, Jacque, where you said that 6 it was something that the engineers were well aware 5 7 go f , and were working on and so forth. I was 8 wondering about a timing discrepancy here, how soon 9 they caught on, if they knew right away that there 10 was a problem, that kind of thing.
11 MR. DURR: No. They knew very well 12 that there was a problem. Part of the solution to h' ' 13 the problem was a redesign. That was the time 14 element. They had to go back to the manufacturer and 15 redesign some of these supports to accommodate the 16 system.
17 MS. TRACY: That's what-took so long.
18 MR. DURR: Yes. But here again, these 19 are non-safety related components.
20 MR. RUSCITTO: I was personally aware 21 of this issue long before it was brought up as an i 1
22 allegation, and as soon as the words came out in the !
l 1 23 allegation, I was able to steer Jacque to the exact l
[ 24 room where it was. We've been following it only from l
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i ARE.v WIDE FEDERAL REPORTING, INC. (215) 925-5777
I 277 1 an interest point of view'because of it's non-safety 1
2 classification.
3 MS. TRACY: On section 2.3.1 the 4 concern was that there was a structural problem that 5 was apparently discovered by the Nuclear Regulatory 6 Commicsion, and came up when we raised the issue of
'. 7 the wracking of the building which you pretty much 8 dismissed, but it was a concern that this lack of 9 structural integrity was discovered by the NRC rather 10 than --
11 MR. DURR: We did our job.
12 MS. TRACY: You certainly did, 13 Jacque. I'm sure Tony and Dave did too.
14 MR. DURR: Yes.
, 15 MS. TRACY: However, it seems that you 16 all had to do the job because the licensee did not, 17 if you understand what I'm saying. And for that 18 reason this was raised as a further example of the 19 fact that the utility is not necessarily as-careful 20 as might be expected.
1 21 MR. DURR: That's why we have a job.
22 That's one of the reasons that we are here, is to 1 23 make sure that the licensee complies with Code and i 24 Federal Regulations, and where they don't, we force i
AREA-WIDE FEDERAL REPORTING, INC. (215) 925-5777
I 278 ;
l i 1 them to. l l-- . l 2 Now, if we felt it was a wide-spread ,
l 3 problem, then we would have taken different action g 4 obviously. But this is a very focused look at a j 5 particular structure, and I would have to defer to 6 Kamal because this is really his area. But it's an I 7 approach method, and sometimes engineers take 8 different approaches, and you have to call that into 9 question, whether it's a good judgment. I don't know i
10 in this particular case what the implications were.
11 MR. MANOLY: The staff had 12 disagreements with the licensee design engineer, at 4 !
'" 13 that time UE&C, about the methode of incorporating 14 the properties of the structure --
the concrete, not
+ 15 the steel. The issue was about steel changes. The 16 steel has no influence on the validity of seismic 17 analysis. To put your mind at ease,_there is no 19 relation. Steel contributes almost nothing to the 19 seismic analysis. It's the concrete. The analysis 20 was primarily on the concrete part. It was a
21 identified in the IDI inspection, and the purpose of 22 that, you do the IDI early enough in the process so i 23 that the staff will have a good feel of which way the
[] 24 architect o: engineer is going with the analysis of
- l AREA-WIDE FEDERAL REPORTING, INC. (215) 925-5777 '
7 279 1 the structures. Like Jacque said, it was caught and i i
2 addressed.
3 MR. CERNE: Another factor, the IDI, 4 we picked this out specifically out of the area, but 5 if you go to the summary of the IDi, it clearly i l
6 states what the purpose of that entire inspection was 1
$ 7 and what the results were. You will find that the IDI 8 records the NRC's overall result of that inspection 1 9 which is a plant in general compliance with the c ;
10 design, and built in accordance with that design.
11 MR. DURR: This wasn't the only area j 12 looked at. I 1
7 I 13 MS. TRACY: I realize that. j l
14 MR. MANULY: The plant, they have gone
. 15 beyond typical normal practice in some of the other l
16 seismic analyses, way beyond even our requirements 17 that I know of. l I
18 Do you have any other questions?
19 MS. TRACY: At this point.I'm not sure I i
20 that I do.
I 21 MR. DURR: As I have written down 22 here, we owe you an answer on the acceptibility of l 23 the reactor coolant pump levelness after heat up. We
( 24 owe you -- or you owe us the CBA drawings for 1
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280 1
1 non-seismic versus seismic.
. J 2 MR. RICHARDSON: Will you give us an 3 answer on that when you've had a chance to 4 investigate that one?
5 MR. DURR: Yes.
6 MR. RICHARDSON: There's quite a 7 discrepancy between your statement that that was 8 seismic qualified, and the papers I have that say it 9 wasn't.
10 MR. DURR: We can give you an answer -
11 on the question, if it's only a question.
12 MR. RICHARDSON: I think I would i
'J 13 prefer to word it as an allegation.
14 MR. DURR: No. We will make that 15 determination. Once we get the paper a 1 it 16 conclusively establishes that it says non-seismic on 17 your drawings, and we say seismic in the report, that 18 will make it an allegation. And then we will do 19 something with it in the normal allegation process.
20 But if we don't find that 1
21 descrepancy, or it's a simple answer, we will give 22 you the simple answer.
I 23 I assume you want those drawings
] 24 back. I sent them back to you once before.
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/
281 1 MR. RICHARDSON: I can make copies. I l
2 don't need them back.
3 MR. DURR: Fine. Just so they're 4 legible.
(
5 And then we have an allegation, a new 6 allegation on the EFW weldalet, on a 8 to 10-inch 7 line, wrong paper configuration, and scribed 8 identification number?
9 MR. RICHARDSON: That's correct.
10 MR. DURR: And we vill respond to 11 that.
12 MS. TRACY: There was one other 13 issue.
14 MR. DURR: Okay.
15 MS. TRACY: Scott Kennedy raised this, 16 and he raised it in our April meeting as well. I 17 think that in the transcript from our April meeting 18 it's identified more clearly, but he referred to some 19 seismic restraints that were put in backwards.
20 MR. DURR: Yes. I went down there and 21 looked in the area that he said, and we couldn't find 22 anything.
I 23 MS. TRACY: Nothing?
( 24 MR. DURR: We couldn't find a thing.
I AREA-WIDE FEDERAL REPORTING, INC. (215) 925-5777'
- I l 282 g i 1 MS. TRACY
- No seismic restraints?
l_J 2 MR. DURR: He's going to have to give l 3 us a much better description on what his concerns are g
4 because I looked at the bottom of about 3 or 4 5 different stairways in the containment. building, and 6 I couldn't find anything. If there is anything I 7 there, we need additional information. But, yes, I 8 looked at that. The fact is, I took pictures of that 9 whole area down there.
10 MS. TRACY: Did you?
11 MR. DURR: I couldn't find anything.
12 MS. TRACY: No seismic restraints?
13 MR. DURR: No seismic restraints.
14 MS. TRACY: I'll get back to him on 15 that.
16 MR. DURR: He'll have to give us some 17 more information on that.
18 MR. HAVERKAMP: Are there any comments 19 regarding the Appendix B items, points 1 and 2?
20 MR. DURR: I think Appendix B n
21 essentially incorporates your agenda; is that 22 correct?
( 23 MS. TRACY: That's essentially t , 24 correct. I believe that we have gone through most of l
l i
1 AREA-WIDE FEDERAL REPORTING, INC. (215) 925-5777 I
I 283 1 these issues, or if we haven't, I can make a good i
2 assumption of what your answer would be.
3 MR. DURR: I would like to j
4 re-emphasize before we close the record that the 5 issues that are discussed in 87-07 and 86-52, except 6 for those that are considered unresolved items, the I 7 NRC considers closed, and will not do anymore 8 inspection on those specifics items.
9 The items that you gave to us on 10 April 20th that are not addressed in those reports, 11 and the ones that we have sent you a letter on 12 requesting additional information, will be pursued i 13 separately from these issues, and through another 14 group. The team inspection, the 2 teare inspections
, 15 that took place at Seabrook, we've disbanded that 16 group for all intents and purposes. l l'
17 MS. TRACY: Your team?
l 18 MR. DURR: Yes. l l
19 The rest of these allegations will be 20 handled through a normal allegation process. l 3
21 MS. TRACY: What's your normal 22 allegation process?
l 23 MR. DURR: The normal allegation
( 24 process is essentially where there are one or two i
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I 284 1
l 1 items or non-specific items, the first thing that
[. J 2 will happen is, as these did, all these other 3 allegations did, they will go through the allegation g 4 review panel. The panel will decide what's to be 5 done and how they are to be dispositioned, and they 6 will probably be inspected on a one-inspector per k 7 item kind of thing. For instance, Tony or Dave will 8 probably inspect most of these, that the panel deems 9 to be inspectable. ;
(
10 MS. TRACY: Who is the panel?
11 MR. DURR: The panel? It consists of 12 either the Director or the Deputy Director of the 13 Division of Reactor Projects, Mr. Kane or his Deputy 14 Director, Sam Collins, and the Section Chief and the 15 Branch Chief who are responsible for the plant, and 16 whatever technical assistants they need from the 17 Division of Reactor Safety, which is my side of the 18 house.
19 MS. TRACY: So further allegations 20 that are brought to the Employee's Legal Project 21 should still be directed to Bill Kane.
22 MR. DURR: To Bill Kane. He is part of f 23 the fo.caal process that handles these things.
I] 24 MR. HAVERKAMPs I would encourage, to i
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I 285 1 the extent possible, that you try to contact me by 1
2 telephone on any of these matters. You don't have to 3 wait until you have a collection of items and then 4 send us a letter. You are certainly'welcome to follow
(
5 up with a letter, if that suits.you. But we will try 6 to, of course, identify the issues that are still on
!. 7 the table that are not closed by the inspections by 8 Jacque Durr and his team. We will be going through a 9 sorting process to identify how to follow those items 10 through our construction process.
11 I will try to keep you informed as to 12 how we are progressing. I'll be doing this by 13 telephone as much as possible, and as necessary, I 14 will follow it up with written letters.
. 15 MS. TRACY: Sounds good. I do like i
16 the written letter follow-up format. Then if there's I l
17 questions in the future, we have it' in writing.
l 18 MR. HAVERKAMP: We do too, but I'm j i
19 encouraging telephone communications to the extent i
20 possible, so we understand the concern, and you j i
21 understand what we've done on it. If there's more to I 22 do, we can work that out.
- 23 MR. DURR: Are there any other
( 24 subjects we need to discuss?
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286 i l 1 - - -
- j. ;
2 (There was no response).
3 MR. DURR: With that, I will'close the 4 record.
[
5 -- -
6 (The meeting adjourned at 4:05 p.m.).
\ 7 8
9
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10 11[
4 _ _ ,
12
! I 13 14
+ 15 16 17 18 19 20 21 22 l 1 23 l, 24 f
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I 287 1 C E RT I F I C A T E I
2 3 I hereby certify that the proceedings, g
4 evidence and objections noted are contained fully and 5 accurately in the notes taken by me on this meeting 6 between the Employee's Legal Project and the Nuclear
\ 7 Regulatory Commission, held on Tuesday, December 29, 8 1987, at 631 Park Avenue, King of Prussia, Penna.,
9 and that this is a correct transcription of same.
10 11 12 I
13 14
. 15 _ __ _ h~ z q _____
NORMA CARR 16 Notary Public 17 My Commission expires February 18, 1989 18 l l
19 '
20 l 21 22 4 23
{ 24 I
AREA-WIDE FEDERAL REPORTING, INC. (215) 925-5777
Alth;b,f A Emplace's Legal Praject 7/d U M N P.O. Box 633 Amesburj, MA 01913 (617)388-9620 MEETItG BE'IWED4 WE D4PLOYEE'S LEGAL PPOJECT AND THE NRC KItG OF PRUSSIA, PD4NSYLVANIA DECDdBER 29, 1987 PROPOSED AGDiDA
- 1. INSODUCTION: h is meeting's purpose is to discuss "procedural problems" at seabrook Station, raised by the Erployee's Legal Project (ELP) in September 1986 and thereafter, and not yet addressed by the NRC. %ese include evidence of breakdowns in quality assurance / quality control (OA/0C), design control, document control, poor training, and the utility's ongoing inability to deal with these problems. Numerous former Seabrook station employees have raised these concerns, and utility and NRC reports substantiate them. A breakdown of these programs, designed to ensure safe construction of the plant, means the plant has many underlying technical problems.
We ELP provides confidentiality and legal protection to nuclear plant enployees who have chosen to come forward with concerns about plant safety. Former Seabrook Station enployees have brought these issues to the attention of the ELP, at what they consider to be some risk to themselves, because they believe the plant is unsafe. %e ELP has a dual responsibility to these individuals: to protect their identities, and to ensure these problems are investigated and resolved. %is organization also extends an offer of protection to menbers of the NRC who have similar concerns.
- 2. QUALITY ASSURANCF/ QUALITY C0t7 TROL
- a. Various sorts of debris were discarded in containment concrete.
- b. Some welds were never tested.
- c. Painters did quality control checks of other painter's work. A recent NRC report shows there is peeling paint in containment areas where the OA program was relaxed
- d. People reporting safety problems suffered harassment / dismissal.
- e. Start-up checkoffs were done carelessly.
- f. When ecnstruction procedures were violated, procedures were rewritten to allow the violations to stand. Procedures were inplemented to eliminate inspection tests,
- g. During the last few years of construction, there was no quality assurance on third shift, and none for concrete on second shift.
- h. %e reactor was filthy; general practices were slovenly.
- i. Dravo shop welds in the turbine building were defective and uncorrected.
- j. Weld inspections were inadequate; welds weren't properly identified; welds were performed incorrectly.
- k. Pipes were forced into place using comealongs and sledgehanners, violating procedure.
- 1. A quality assurance person in charge of inspecting cadwelds in containment consistently reported incorrect figures.
- m. Concrete was poured when the tenperature was too low, creating cold Beams.
- n. W ere is exposed rebar in the cooling tunnels, and there are voids in the tunnel's concrete,
- o. tere was a lack of weld safety and people were harassed if they raised
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safety problems according to a OA engineer.
- p. People were hired to inspect work they had previously performed according to a different QA engineer.
- q. Welds were inproperly certified and quality assurance was poor according to h third QA engineer.
- r. A weld tejected by an inspector was penciled in with graphite, and then passed inspection,
- s. Several weld inspectors, comenting on James Padavano's conviction for falsifying weld inspections, said he was following cormon practice and was singled out.
- 3. DOCUMENT COtTfROL
- a. Drawing revision control was ineffective,
- b. Pipe and pipe supports were asse21ed using the wrong materials after the identification numbers were ground out and rescribed.
- c. Blueprints were not updated, workers in the document control department were untrained, did not know how to read blueprints, and put incorrect nurbers on blueprints,
- d. Blueprints were destroyed in the blueprint room.
- e. %ere was massive destruction and theft of documents during the 1984 reduction in force according to a former United Engineers and Constructors manager,
- f. Document traceability was a problem, and materials could not be traced back to the vendors according to a OA inspector.
- 4. DESIGN COtmOL
- a. Tracking of blueprints was inpossible.
- b. W e control building air handling equipment lacks separation, thus could fail at the same time.
- c. Se emerge..cy feedaater system is supplied from a single tank which also serves as condensate storage for the main steam feedwater system.
In an emergency an Edequate supply of water to the reactor cannot be guaranteed since a dual system is supplied from one source.
- d. Blueprints were frequently incorrect and were very difficult to interpret.
- e. Blueprints do not match the as-built plant.
- f. Bere were an exceptionally large nu2er of "accept as is" engineering ,
dispositions toward the end of construction, changing the plant's design to what had been built. @is was done to save time and money rather than for safety reasons.
- g. Large nu:rbers of nonconformance reports were voided when procedures were changed to accept the nonconforming conditico.
- h. Equipment was renunbered so it appears to conform to specifications.
- i. t e four primary cooling punps were not installed according to design, l possibly causing stress on the welds at the reactor and the punps, and l premature bearing wear.
- 5. POOR TRAINItG
- a. 'Itchnical training records do not exist prior to April 1985, preventing assessment and verification of training. Some people were untrained, some were retrained.
- b. Procedures and instructions, a primary training tool, were written in anbiguous languange. l
- c. Some welders were trained on the spot; some were inproperly trained. ;
- d. Some electricians were inproperly trained. I I
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- e. Training classes were inadequate to the needs of those being trained.
- f. There was cheating on tests several years ago, and a recent NRC I report mentioned a current cheating problem.
- 9. Prohibited work practices like cold pulling and incorrect weld identification were used throughout the plant.
- 6. ADDITIONAL ISSUES
- a. Ivo issues raised since April,1987, which have not received a response from the NRC: a crack in the core barrel, and falsification by a vendor of certification required from the manufacturer,
- b. Ongoing problems like the cracks in the equipment vault, the PAB, and other structures which are leaking water, and like the chronic equ'pment breakdowns, are much less likely to be repaired expeditiously since the plant owners are constantly on the brink of bankruptcy.
- c. Cold pulling.
- d. %e 100 bad welds in the service water system are of concern due to the possible effect of MIC, and the current problem of flaking joints in this system.
- e. %ere are a nurber of issues mentioned in current NRC reports which substantiate problems raised in the past by the ELP but which have been treated as isolated instances by the NRC.
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l4:/2A Empigee's Legal Pr; ject M * ~N[
i P.O. Box 633 Amesbury. MA 01913 (617) 388-9620 MEETItG BEWEEN 'IHE D4PLOYEE'S LEGAL PROJECT AND THE NRC KING OF PRUSSIA, PENNSYLVANIA DECDdBER 29, 1987 PROPOSED AGDiDA
- 1. INIPODUCTION: % is meeting's purpose is to discuss "procedural problems" at Seabrook Station, raised by the Erployee's Legal Project (ELP) in September 1986 and thereafter, and not yet addressed by the NRC. @ese include evidence of breakdowns in quality assurance / quality control (OA/QC), design control, document control, poor training, and the utility's ongoing inability to deal with these problems. Numerous former Seabrook Station e g loyees have raised these concerns, and utility and NRC reports substantiate them. A breakdcwn of these programs, designed to ensure safe construction of the plant, means the plant has many underlying technical problems.
%e ELP provides confidentiality and legal protection to nuclear plant e @loyees who have chosen to come forward with concerns about plant safety. Former Seabrook Station e@loyees have brought these issues to the attention of the ELP, at what they consider to be some risk to themselves, because they believe the plant is unsafe. %e ELP has a dual responsibility to these individuals: to protect their identities, and to ensure these problems are investigated and resolved. @ is organization also extends an offer of protection to menbers of the NRC who have similar concerns.
- 2. QUALITY ASSURANCE / QUALITY CDtTIROL
- a. Various sorts of debris were discarded in containment concrete.
- b. Some welds were never tested.
- c. Painters did quality control checks of other painter's work. A recent NRC report shows there is peeling paint in containment areas where the OA program was relaxed
- d. People reporting safety problems suffered harassment / dismissal.
- e. Start-up checkoffs were done carelessly.
- f. When construction procedures were violated, procedures were rewritten to allow the violations to stand. Procedures were i@lemented to eliminate inspection tests.
- g. During the last few years of construction, there was no quality assurance on third shift, and none for concrete on second shift.
- h. %e reactor was filthy; general practices were slovenly. !
- i. Dravo shop welds in the turbine building were defective and uncorrected. .
- j. Weld inspections were inadequate; welds weren't properly identified; I welds were performed incorrectly. l
- k. Pipes were forced into place using conelongs and sledgeharmers, i violating procedure. I
- 1. A quality assurance person in charge of inspecting cadwelds in containment consistently reported incorrect figures. 4
- m. Concrete was poured when the terperature was too low, creating cold i Seams.
- n. % ere is exposed rebar in the cooling tunnels, and there are voids in ,
the tunnel's concrete. i
- o. Were was a lack of weld safety and people were harassed if they raised )
safety problems according to a QA engineer.
- p. People were hired to inspect work they had previously performed according to a different QA engineer.
- g. Welds were inproperly certified and quality assurance was poor according to a third QA engineer. ;
- r. A weld tejected by an inspector was penciled in with graphite, and then I passed inspection.
- s. Several weld inspectors, conmenting on James Padavano's conviction for i falsifying weld inspections, said he was following common practice and was singled out.
- 3. DOCUMENT COtfrROL
- a. Drawing revision control was ineffective.
- b. Pipe and pipe supports were assenbled using the wrong materials after the identification nt:rbers were ground out and rescribed, i
- c. Blueprints were not updated, workers in the document control department were untrained, did not know how to read blueprints, and put incorrect nunters on blueprints,
- d. Blueprints were destroyed in the blueprint room,
- e. @ere was massive destruction and theft of documents during the 1984 reduction in force according to a former United Engineers and Constructors manager,
- f. Document traceability was a problem, and materials could not be traced back to the vendors according to a QA inspector.
- 4. DESIQ1 CDtIIK)L
- a. Tracking of blueprints was inpossible,
- b. @e control building air handling equipment lacks separation, thus could fail at the same time.
- c. The emergency feedwater system is supplied from a single tank which also serves as condensate storage for the main steam feedwater system.
In an emergency an adequate supply of water to the reactor cannot be guaranteed since a dual system is supplied from one source.
- d. Blueprints were frequently incorrect and were very difficult to interpret,
- e. Blueprints do r.2 match the as-built plant.
- f. @ ere were an exceptionally large number of "accept as is" engineering dispositions toward the end of construction, changing the plant's design to what had been built. @is was done to save time and money rather than for safety reasons.
- g. Large nunbers of nonconformance reports were voided when procedures were changed to accept the nonconforming condition.
- h. Bguipnent was renunbered so it appears to conform to specifications,
- i. @e four primary cooling punps were not installed according to design, possibly causing stress on the welds at the reactor and the punps, and premature bearing wear.
- 5. POOR TRAIT 1ItG
- a. Technical training records do not exist prior to April 1985, preventing assessment and verification of training. Some people were untrained, some were retrained.
- b. Procedures and instructions, a primary training tool, were written in anbiguous languange.
- c. Some welders were trained on the spot; some were inproperly trained,
- d. Some electricians were inproperly trained.
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- e. Training classes were inadequate to the needs of those being trained,
- f. %ere was cheating on tests several years ago, and a recent NRC report mentioned a current cheating problem.
- g. Prohibited work practices like cold pulling and incorrect weld identification were used throughout the plant.
- 6. ADDITIONAL ISSUES
- a. Two issues raised since April,1987, which have not received a response from the NRC: a crack in the core barrel, and falsification by a vendor of certification required from the manufacturer.
- b. Ongoing problems like the cracks in the equipment vault, the PAB, and other structures which are leaking water, and like the chronic equipment breakdowns, are much less likely to be repaired expeditiously since the plant owners are constantly on the brink of bankruptcy.
- c. Cold pulling,
- d. We 100 bad welds in the service water system are of concern due to the possible effect of MIC, and the current problem of flaking joints in this system,
- e. % ere are a number of issues mentioned in current NRC reports which substantiate problems raised in the past by the ELP but which have been treated as isolated instances by the tGC.
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