ML20056B412
| ML20056B412 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 07/23/1990 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20056B411 | List: |
| References | |
| NUDOCS 9008280252 | |
| Download: ML20056B412 (97) | |
Text
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^ OFFICIAL TRANSCRII'r OF PROCEEDINGS -
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Nuclear Regulatory Commission Office of Nuclear Reactor Regulations
Title:
Meeting on Sequoyah Nuclear Plant cable Testing Program Docket No.
.O C-LOCATION:
Rockville, Maryland DATE:
Monday, July 23, 1990 PAGES:
1 - 95 ANN RILEY & ASSOCIATES, LTD.
1612 K St. N.W, Suite 300 Wishington, D.C. 20006 (202) 293-3950 pSge2%@$@[ oSoS 27 P
1 1
UNITED STATES OF AMERICA'
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NUCLEAR REGULATORY COMMISSION t
3.
4 OFFICE OF NUCLEAR REACTOR REGULATIONS 5
MEETING.ON SEQUOYAH NUCLEAR PLANT CABLE TESTING PROGRAM 6
i 7
'8 Nuclear Regulatory Commission 9
One White Flint 10 17555 Rockville Pike 11 Rockville, Maryland'
-12 i(
)
13 Monday, July 23, 1990 l
14 The meeting was called to order, pursuant to 16 notice, at 1:00 p.m.,
when were present:
-j 11'7 18 OFFICE OF NUCLEAR REACTOR REGULATIONS:
19 J. Donohew E. Marinos
'20 A. Thadani S. Newberry 21 S.
Black Mr. Brady 22 Mr. Hayes Mr. Ross 23 H. Garg S. Thierry 24 G.
Lainas 25
2 1
PRESENT FOR TENNESSEE VALLEY AUTHORITY:
(
2 A. Burzynski K.
Brown 3
R.
Lumpkin~
J.
Bynum 4
M. Medford P. Trudel 5'
B. Kimsey 6
7 8
9 10 11 12 (N
(j-
- 13 14 15 16 17 18 19 20 21 1
- 22 23 D\\
25
3 l
1 P.R O C'E E D I N G S l
~x
- ^J 2
(1:00 p.m.];
3 MR. DONOHEW:
This meeting is on the Sequoyah 4
Cable Testing Program, the program that was run in 1987.
If 5
anyone happens to be at the wrong meeting, they can leave
+
6 now.
7 The purpose'of the meeting is for TVA to make a 8
presentation to us on what they have learned about the 9
calculations that were originally written to determine the 10 15 worst conduits that TVA had committed to test as pat of 11 resolving the cable installation issue in Sequoyah in 1987.
12 After that presentation, I want to open the floor'to lO '
(,/
13 questions about the justification for continued operation 14 that was submitted by TVA last July 17th on Sequoyah.
- Then, 15 the intent is for staff to caucus to decide in terms of any 16 limitations on the JCO and on any questions that we have on 17 the programs and schedule.
18 I think before starting the meeting, what I would 19 like to do is have everybody introduce themselves.
I am 20 Jack Donohew, the Project Manager for NRC on Sequoyah.
21 Angelo Marinos you know me very well from working on the 22 cable issue for sometime.
Ashook Thadani, Director of 23 Division of Systems Technology.
Scott Newberry, Chief, INC
'/^T 24 Branch.
Bruce Wilson, Region II.
U 25 Paul Trudel, Project Engineer, Sequoyah.
Mark
i 4
1 Medford, Vice President Nuclear Technology and Licensing.
- 7s 2
Bob Bynum, Vice-President TVA and Acting Site Director 3
Sequoyah. Roy Lumpkin, Site Quality' Manager, Sequoyah. Ken 4
Brown, Cable Specialist from Knoxville.
Mark Burzynski, 5
Sequoyah Site Licensing Manager.
6 MR. DONOHEW:
Just to make sure that there is 7
three sheets going around in terms of signing your names 8
before you leave.
With that, Mark, I will turn the meeting 9
over to you, i
10 MR. BURZYNSKI:
Thank you, Jack.
As you 11 indicated, the purpose of this meeting is to review the 12 recent findings that resulted from our review of the 1987 m()
13 ranking calculation that was performed to support the pullby 14 test program.
In addition, we want to describe to you our 1LS current plans for resolution of the problems identified, and 16 discuss with you the-nature of those findings.
17 (Slides.]
18 In particular, I would like to make some 19 introductory remarks and discuss some background information 20 so that we all have a common understanding of what the test 21 program was in 1987 and introduce some of the terminology 22 that would be utilized in our discussions of our sampling 23 and findings related to our review.
Kent Brown, the Cable
/
)
Specialist, will discuss the evaluation of the calculation 24 25 as well as our current plans to resolve the issues.
Roy
5
_1-Lumpkin, the QM manager at Sequoyah, will discuss some of
,1c)_
i 2
the audit activities he has ongoing to identify the root 3
cause of the-problem.
4 (Slide.)
i 5
With that, let me get started to the introduction.
6 As most of you are aware, TVA and NRC have been having 7-discussions regarding the impact of the Watts Bar Cable 8
Damage on the Sequoyah Cable Test Program.
In particular, 9
a damaged cable was found at Watts Bar during review and 10 resolution of a problem unrelated to the cable issue.
In 11 particular, there was some concern about heat damage from 12 some welding that was taking place in the proximity.of the 13
. conduit.
When the cable was removed to review that issue, 14 the damage that appeared to be pullby damage was noted.
15 In particular, this cable damage was found prior 16 to the implementation of the Watts Bar Cable Test program, 17 and some questions were raised as to the validity and 18 acceptability of the test program itself which was modeled j
19 after-the Sequoyah Test Program.
TVA and NRC had numerous 20 discussions and, in particular, we met in May of this year 21 to discuss the subject and NRC subsequently conducted an 22 audit at Sequoyah to review background information that went 23 into our evaluation of the program merits.
(~'Y 24 It is important in the chronology of things that Q) 25 it was at this audit that TVA informed NRC that the cable l
l l
L U
1 selection calculation for-pullby test had not been issued.
[
-2 As a-result of that audit, TVA agreed to pursue issuance of 3
the calculation and an assessment was made of the work that 4
would be required to formally issue that calculation.
As 5
this work was going on the assessment and evaluation of what 6
it would take to resolve it, TVA became aware of an-7 allegation that alleged that the selection criteria had not i
8 been properly applied.
9 As-a result of that information, TVA thought it
'10 would be prudent to sample the selection calculation results 11' and as a result of that review, we identified the 12 discrepancies existed within the calculation.
I do want to
)
13 note that we reviewed the application of the criteria and 14 not the criteria itself.
15 As a result of those findings, we have identified 16 that further work is needed in order to resolve the Cable 17 Test Program issue.
Kent Brown will discuss that 18 information with you as well as review the results of the 19 sampling program and types of discrepancies that we found.
20 MS. BLACK:
Mark, I think back in the May 31, 1990 21 meet'ng you ought to give some background for the people 22 that weren't involved back then.
The CAQR that was written 23 as a result of the Watts Bar damage was applied on an
'l 24 engineering basis at the other plants, and this was your
[V 25 resolution of what you are going to do based on -- you are
7 I
coming in to-tell us whether-your testing covered what was
\\'
2 found at Watts Bar or what identified similar damage, right?
4 3
As a result,_did you need to propose particular 4
testing at that time?
5 MR. BURZYNSKI:
I think in a couple of my later 6
,lides I can weed that in, so that you can get a flavor of 7
what the types of discussions were.
I did want to point out
'8 that in addition to the work that we are going to be 9
undertaking to resolve the Cable Test Program, we also 10 identified the need to evaluate the root cause.
Roy Lumpkin-11 will discuss some activities ongoing by QA to the heart of 12
-that matter.
-f(
13 (Slide.]
14 I think in order to understand the Sequoyah Test 15 Program and understand the calculation that1 supports it and
-16 to accomplish what Suzi asked to weave in, the nature of the 17 review of this program in light of the Watts Bar damage it 18 is important to understand the selection criteria itself.
L 19 In particular there were seven criteria that were L
20 established.
The first six were the primary ones used to 21 rank in order conduits, the seventh being proposed as a tie 22 breaker in the event that the worst case family had more 23 conduits than the program identified for testing.
(
)
We identified that we would test 15 out of 20, and 24 25 in the event that the worst case family had more than 20 a l-
8 l'
tie breaker was proposed to further focus the test program.-
Ab
/'
2 The criteria were based on parameters that were thought t
3-believed to be important to pullby damage or potential for 4
pullby damage, parti;ularly the first one, seven or more 5
cables in the conduit.
If you don't have a large number of 6
cables, pullbys become relatively easy.
That was a 7
discriminator.
8 Secondly, you had to have pullbys in order to have 9
pullby damage, and a threshold of two was identified to 10 target a more susceptible population.
Third, criteria L
11 looked at whether or not PVC jacketed cables were resident 12 in the conduit. prior to the final pullby.
The basis for
( )
13 that is, PVC is a thermal plastic jacketed material, and 14 that is more susceptible to pulling damage than thermal 15 setting jackets.
Fourth, that the pullbys occurred prior to 16 August, 1984.
The basis for that criteria is the fact that 17 in 1984 TVA switched lubricants from the yellow 77 to the 18 poly water J, and it was believed that the yellow 77 was not 19 as an effective lubricant as the poly water.
20 The fifth criteria involves total lengths of 21 degrees of band between pull points -- this is a 22 configuration attribute -- and the discriminator was those 23 that exceeded or came closest to exceeding TVA's definition
}
24 of an easy pull.
In other words, we are looking for the 25 pulls that were hard pulls, so we used the criteria in a
9' 1
reverse manner.
Sixth, there was.the two condolets.
That
,..I 'I 2
was an attribute that was included in.the program based on
. the presence of numerous pull points in Sequoyah and the 4
postulation that not all of the pull points may have been 5-utilized.
So, that was thrown in as another criteria.
6 Another~way.to look at it is, criteria three and 7-four are related to material properties and give this 8
selection criteria a material bias or material 9
susceptibility.
The basis for that was all things being
,10 equal, 9e felt that material that is more rusceptible to i
11 pullby damage is a better targeted population.
Work that had gone on at Watts Bar aad the cable j
m l-13 that was identified, the cable that was damaged was a 14 thermal setting plastic as opposed to this thermal plastic 15 type here.-
The question came up, would you have identified 16 this, would you have found it.
It appeared from the L
17-evidence that pulling force was an important parameter which' 18-is really captured in a qualitative way through criteria L
19' five and not in a quantitative fashion.
That was the nature p
'20 of the discussions and the points that were reviewed in our 21 letters in March and our meeting in May.
?.
L 22 TVA contended that the Watts Bar Program, had it
{
L 23 been allowed to proceed, would have identified cable damage
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24 because, in fact, there were pullby damage cables of this 25 variety in the population that was targeted for testing.
It
P k
- 10
_q was just that we found other damage before the test program 1-2 had run.
This was still a valid criteria for support 3
'because of the general conformance to good pulling practices 4
as Sequoyah.
In particular, those parameters were conduit 5'
fill whereas, at Sequoyah, there is very little evidence 6
that we violate the conduit fill.
Out of all the conduits 7
we looked at in this test program and other modification 8
work recently, we have only identified one conduit that'just 9
exceeds our conduit fill criteria, where as Watts Bar there 10 was a whole separate program to address that.
11 Secondly, from the evidence was have in looking at 12 configurations, we. generally conform to easy pulls.
In
()
13 fact, that was documented with TER saying that we had many 14 pull points and we couldn't have possibly used those, 15 whereas at Sequoyah you have just the opposite.
You have-16 rather severe violations of those pulling practices.
We i
17 felt that there were a couple of other parameters; the use 18 of bulk pulls at Sequoyah as opposed to pulls on a system 19 basis led to more pullbys at Watts Bar than is generally 20 typical at Sequoyah.
No evidence of the une of parachute 21 cords -- we felt that a parachute cord was a major 22 contributor to the damage found at Watts Bar.
At Sequoyah 23 there is no evidence of that.
r'
)
When we considered all those things, we still felt 24 25 that what we know about configuration pulling practices --
11-1-
the material bias would still be a sound program.
7s e(} ')'
2 MR.-BURZYNSKI:
Mark, I have a1 question on that.
3 On your first point about the material bias, you seem to say
~4 that the Watts Bar test would have found the damage that was 5
found at Watts Bar anyway, in spite of the fact that --
6 MR. BURZYNSKI:
No, let me clarify.that.
The i
7 Watts Bar Cable Test Program had in the top 15 scheduled to 8
be tested, conduits that subsequently have been identified 9
as having pullby damage.
We believe they would have been 10 identified through the tests.
That would have led to an 11 expansion of the program, either additional testing or other 12 reviews or programmatic attributes to my cable pullby
. ?"
i 13 problems.
14 MR. MARINOS:
Mark, did I hear --
15 Mh, BURZYNSKI:
It wouldn't have necessarily gone 16 right in and picked the conduit that we found, but we 17-believe we would have been into the remedial phase of a 18 cable test program and have had to have tailored the program 19 differently because of the negative findings.
20 MS. BLACK:
Because that was not in the high risk 21 category, was it?
22 MR. BURZYNSKI:
It was not in the high risk 23 category, but we believe we would have ended up with a h ()
24 program very similar to where we are today based on all the 25 attributes that we have discovered.
Many of those L
.=
12 1
attributes are not present at Sequoyah,'so they don't cause ij-)c.
2 us to question ~some of the biases that this sample had.
3 That was the nature of the discussions.
That is 4
still an issue that hasn't been resolved.
I think you will 5
see when we get done today, hopefully we have a program that 6
will answer that question in a different manner all together:
7 and eliminate it from the consideration.
8 MR. MARINOS:
Mark, did I hear you correctly that 9
for the Watts Bar program you had already identified the 10 cables that you would be recommending for testing to the 11 staff and would have -- you were that far along in 12 identifying specific conduits?
(3 T,)
13 MR. BROWN:
We had a contractor who came in and, s
14 using criteria almost identical to this, had gone through 15 the same process for Watts Bar that we had gone through at 16 Sequoyah.
I bc11 eve it was the third conduit in their top 17 15 that wat conduit MC-400 B when, after finding damage in 18 the conduit that was being inspected regarding the welding i
19-concerns that Mark mentioned, we said how widespread is 20 this.
21 The first thing that we did was, we went to the 22 existing calculation that said here is the worst case.
If 23 we found it over here in one that had the welding suspect,
[
}
24 then it should be somewhere also if our criteria is good, it 25 should also be in this group of worst case.
When we gutted
l 13 i,,_ -
1 conduit MC-400 B, we indeed-did-find evidence of pullby Y/
2 damage,.and that was approximately the number three conduit, 3
having. invoked the same criteria as this.
4 MR. MARINOS:
You took that conduit apart, is that 5
what you are saying?
l 6
MR. BROWN:
Yes.
i 7
MR. MARINOS:
That was in the --
8 MR. BROWN:
We pulled back -- it was about 35,000 9
feet -- an approximate number of additional cable after that 10 initial' finding.
Tht t was one of the conduits that we 11' emptied.
I think it was 27 conduits or so that we gutted to 12 look for that phenomenon.
That was one of them found by
(
13
'this criteria.
I 14 MR. MARINOS:
The PVC jacketed on those cables?
l 15-MR. BROWN:
Yes, it did.
16 MR. MARINOS:
That was in the high rish group.
17 MR. BROWN:
At that point in time, we didn't even 18 have the high, moderate and low concept.
Rather, the only L
1 19 thing that we had was the calculation performed in this i
20 manner for Watts Bar.
We simply went to that calculation --
l 21 MR. MARINOS:
Did you go back and calculate and 22 see where it would-have run?
Yes, we did that, but I simply don't 24 remember what that is.
)
25 MR. MARINOS:
The first one you found with the l
l:
1
14 i
1 welding problem was not in the high. risk anyway, it was in
)
7_
2 the low risk run.
3 MR. BROWN:
No, not in-low, f
f 4
MR. BURZYNSKI:
Medium.
l f
5 MR. MARINOS:
Was it medium?
6 MR. BROWN:
- Yes, Portions were medium and j
7 portions were high.
Of course, that was the reason we ended 8
up drawing the line where we did.
l l
i 9
MR. MARINOS:
The one that you found by comparison i
10 to the criteria, namely the one that we were just talking 11 about, was it overfilled or --
1 1
12
- MR. BROWN:
I don't recall.
i
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i
(,}f.
13 MR. MARINOS:
The one that you found from the l
14 welding arc was not overfill, it was 32 percent fill --
15 MR. BROWN:
That's right.
-16 MR. MARINOS:
So, it was not an overfill condition 17 that you found the first one.
Subsequent failures that you l-18 found, I don't recall any of them, if any at all, being 19 overfilled at Watts Bar.
So, the overfill issue is sort of-t l
20 21 MR. BROWN:
The fill issue was included because I l
L 22 think not only do we believe but also the industry has taken 23 a position that says pullbys into highly filled conduits is r]
24 a dangerous thing to begin with because it is so much more
(_./
25 difficult to obtain a c. ear path.
Clearly, in the process
15 I
1 of screening to find those where danger might be expected --
)~,f' q
A-
-2 MR. MARINOS:
If you need to be selective, of 3
course, you will choose the one that is-overfill'with more 4
pullbys than any other conduit to check and see.
5 MR. BURZYNSKI:
I think the point there that I was 6
trying to make was that in the absence of any other q
7 programmatic problems that would skew the results 8
differently, we think all things being equal, material 9
biased has more value.
If you had evidence of programmatic 10 things that were wrong, that can skew your thinking in a 11 different direction.
12 So really, in the absence of those indicators at rh Q.
13 Sequoyah we.think this was still --
14 MR. MARINOS:
Unless there is a more dominant 15 attribute like the pulling forces --
16 MR. BURZYNSKI:
Yes, and that was really --
17 MR. MARINOS:
Unmasked the materials.
18-MR. BURZYNSKI:
That is really where we left the 119 issue that, that was the point to be resolved.
I think one i
l 20 other thing I want to point out before I get off this slide 21 is related to the information and data that was used so that i
22 it will fit in with Kent's discussion on the calculation.
23 In the application of criteria number one, we went
}
to our computerized cable conduit database to very quickly 24 25 target safety-related conduits and a number of cables within
16
'l~
the conduits.- It'was through that review that we were able
~
three and four were
'j 2
to apply criterion one.
Criteria two, 3
evaluated by going to the cable pull card records-and 4
pulling off the information relative to pullbys, dates of 5
pullbys and the types of cables that were utilized in those 6
operations.
7 Finally, criteria five and six were evaluated from 8
sketches prepared through walk downs to make that final 9
evaluation.
10 PARTICIPANT:
When you talk about calculations, 11_
those aren't calculations are they?
12 MR. BURZYNSKI:
They are not calculations in the i
13 sense that we crunch numbers.
14 The next thing I want to do is give you some more
- 15 background on where the conduits ended up as a result of the 16 application and the criteria.
There is a Category F, if you 17 will, of those that had less than -- six or less cables.
I 18 didn't put that on here.
Those are ones that did not meet 19 criteria one.
20 In general, we had five categories where the 21 conduits ended up.
Category E where only criteria one.was 22 met prior to-- and was dropped out after the application of 23 criteria two, three and four.
No walkdowns or sketches were f'/)
24 prepared of these.
Category D, those that met the material
\\_
25 attributes but did not meet the test on criteria five or
17 1
six.
In other words, those would be easy pulls.
,-s\\
4
'~/
2 We ended up with' Category B and C, which were 3
backup populations, those that met five of the six criteria.
4 These are'through a more difficult pull or having the 5
condolets.
Finally, Category A, which was what we called 6
the worst case for the family or population of conduits that 7
'have some credible chance to have sustained insulation 8
damage because of pullbys.
9 The reason we came up with Category B and C was to_
10 round out categor'f A, as well as to have our backup 11' population ready.
The test program had us test-15 out of 12 the top 20, and if there was a failure in that we had to go O
(_,o 13 and test the second population of 20.
Through this process 14 we are able to identify up front the top 20 and backup 20 a
15 before we got into the test program.
16 MS. BLACK:
Can I'ask you a question on your wet 17 versus dry testing that was involved.
How did you decide 18' which ones are wet tested and which ones are dry tested?
19 MR. BURZYNSKI:
Really through the application of 20 several criteria.
One had to do with the routing.
We did 21 not want to introduce water into conduits that went over the
'l 22 top of safety-related equipment if there was a potential for 23 it to drain out on safety-related equipment.
Another
,C 24 attribute was the availability of high points to introduce
(
25 water.
I think a third was the availability of -- ability
18 1
to drain water from low points.
There were a number of
,3 i' ')
2 factors-that went into it, but they generally met that kind 3
of test.
4 In the way of background, just so that you have an 5
idea of where all the conduits went, the total population 6
was more than 7,000 conduits.
Through the application of
+
7 criteria one, more than 6,000 of them were eliminated.
8 Seven hundred and 70 remained for further evaluation.
Our 9
of that 770, pull records were reviewed and pull dates, 10 pullby numbers and cable information which tabulated 11 criteria two, three and four, were evaluated.
12 Three hundred and sixty-six dropped out that j
/s
(,)
13 point, leaving 404 material susceptible conduits for further 14 evaluation.
Those 404 then had walkdown sketches prepared 15 and criteria five and six applied.
Ultimately, we ended up 16 with 12 in Category A meeting all six criteria, 10 in 17 Category B being hard pulls without condolets and Category C 18 being easy pulls with condolets.
19 MR. MARINOS:
Is Kent going to discuss with us the
-20 isometrics that you developed for the 404, cr is this part 21 of this discussion now and hold any questions that I have?
22 MR. BURZYNSKI:
He is going to get into the 23 calculation itself and what the calculations are made up of.
(}
24 I just wanted to give you a flavor of what the criteria was 25 and how it was applied, what records were used and where we
/
19 l'
ended up in 1987.
At this point, we needed to 15.
We had
[_'\\ -
A-2
-12 here and an additional three were selected-from Category
~
3 B to make up the test populations.
4 This was the family ranking, if you will, at the*.
5 point in time which we believed went from all of them down 6
to materials susceptible'down to materials susceptible hard 7
pull category.
Tnat was the approach.
8 HR. THIERRY:- Category B, if B is one through 9
five, what is one through six.
10 MR. BURZYNSKI:
You have to add up the 404 11 material susceptible is this plus this, plus this, plus 12 this.
()
13 MR. THIERRY:
hey are not cumulative.
14 MR. BURZYNSKI-This is not a subset of this, this 15 is not a subset of that.
This total number.here is the 770 16 that met criteria one.
These four are the 404 that had the 17 materials.
Does that clarify it for you.
18 MR. THIERRY:
Yes.
19 MR. BURZYNSKI:
What I wanted to do was just 20-refresh your memory as far as the criteria, introduce how it 21 was applied and how the records were used, and what the 22 results looked like at the time, what went into them and the 23 basis for what was tested to get at the allegation that we V("'s 24 were looking at.
First, we were looking at what it would 25 take to issue the count and then we became aware of the
20 1
allegation that said.you didn't' apply the criteria correctly j%'\\-)
2 or in the right order.
In pursuing that to see if there was 3
any merit to that, we discover that there were errors made 4
in the application of the criteria -- not in the order but 5
in deciding whether it met attributes or criteria one, yes 6
or no, criteria two yes or now, when'then had some affect'on 7
the ranking.
8 I would like to introduce Kent Brown at this time 9
and let him discuss with you the assessment we did of the 10 calculation as well as the sampling of the technical aspects
'1 11 of the CALC and the findings and conclusions that we drew 12 from that.
O f'%
-l
(
J-13 MR. BROWN:
In the next few minutes what I want to j
14 do is take a li'tle time and bring you up-to-date on the 15-kind of actions thac we have taken over the11ast few weeks 16 in order to assess or review and scope out the nature of 17-the problems that had been identified, tell you what we 18 think the impact is, what are we going to do in response to 19 those, and what kind of schedule can we offer to you in p
l-20 order to implement those particular activities.
21 As Mark mentioned earlier, when the NRC came in 22 back during June in order to do an inspection, we informed l
23 them at that point in time that we were aware that this CALC 24 had not been issued.
As has been mentioned already, it L
25 wasn't clear to us -- it is not clear to us now -- all the l
21 1
reasons for that.
We are going to be discussing with you in O
2 a few minutes our plan to go back and look at that 3
particular process and find out where we broke down.
4 Probably the next thing I,want to do, before we 5
get into some of these details of what we found and 6
questions have already come up is, what really is this 7
document.
Let's talk for a minute, what is this thing that 8
we are calling a calculation.
First of all, if I brought it 9
all here today, it would be a stack of paper probably two 10 and one-half feet high.
There is a lot of sketches; a lot 11 of data sheets, a lot of compilation.
In the classice.1 12 sense it is not a calculation.
f) 13 If you get in there you are not going to find 14 anything multiplied by anything.
Really, this is a 15 compilation of data based upon going out and gathering up, 16 pull information as far as dates, numbers and types of 17 cables based on sketches that were done out in the field and 18 brought back, and then an evaluation is done if you meet 19 some criteria -- how many bends did you have, et cetera.
We 20 are not looking at a calculation in the classical sense.
21 This happens to be the vehicl3 that we decided to 22 use internally to capture this two and one-half foot stack 23 of data.
By the way, a good pertion of that two and one-
{)
half foot stack is just a printout from our computerized 24 25
-schedule, just so that we can capture what family it was a
Q i
22 1
that we were looking at back in 1987.
2 MR. MARINOS:
Kent, the colculations in your 3
Appendix F of your G-38 standard where you compara the 4
conduit length with the bends to your populations in order 5
to make a decision whether you will value that conduit or 6
not.
There was an implicit calculation that was already 7
done for you where you use a table, so there's a 8
calculation.
9 MR. BROWN:
What Angelo was talking about is in 10 our installation specification there were a series of tables
'11 which defined one of the criteria that Mark talked about 12 earlier, the easy pull.
What defines an easy pull.
There I
13 was a table in the installation specification where if, you 14 had a conduit of a given diameter; that, for a certain 15 length as long as you had no more than "X" number of degrees 16 of bends, you were an easy pull.
Anything up to a certain 17 combination of length, conduit diameter and degrees of bends 18 could be said to be an easy pull.
19 What the people did in doing this assessment was 20 simply take field sketches that showed length, total number 21 of degrees between pull point and conduit size, and make a 22 yes/no comparison, greater than, less than type of analysis.
23 This two and one-half stack of papers, let's talk about what 24 it really is.
25 The first portion here -- it's really in three
23 1
parts.
The first portion which was both prepared and I
)
\\_/
2 checked, constitutes the text portion of the CALC and has 3
the synopsis of all the work or review of the methodology, 4
purpose.
It tells you where the various input data came 5
from, how the work was done, what the results are and, of 6
course, what the conclusions are.
This section of the 7
calculation probably amounts to 20 or 30 sheets.
8 The next, somewhat larger portion are attachments.
9 They are attachments A through F.
These were also prepared 10 and checked.
They fall into three general categories, one 11 being work r+heets.
You think of it as an empty spread sheet 12 that list across the top the various criteria and down the
()
13 side conduits, and they simply represent to some degree to 14 recults of going through making comparison, does this meet 15 Criteria one, yes or no, et cetera.
We had worksheets, we 16 had isometrics that showed specific conduit arrangements as 17 well as the type and nature of pull points so that we could 18 answer criteria for instance, a certain number of condolets.
19 The bulk of the calculation as far as the volume 20 of that material for the appendices that were set on a vote, 21 and we looked and saw that all of those had been prepared r
22 and checked with the exception of appendices three and 23 appendices six.
What those are, are checklists.
- Again,
(g 24 across the top we find the different criteria and then for O
l 25 each row you have an entry of a specific conduit which has
i 24 l
l 1
met the initial screening criteria, number one.
It will
\\m l 2
show how many cables are in that conduit, and then do I neet 3
criteria two, three, four, five, six and seven and so forth.
4 This is simply a table as opposed to a calculation.
5 That is a general overview, if you will, of what 6
constitutes this particular document that we are calling a 7
calculation.
Again, it was TVA's decision to capture this e
analysis in a format that was known to us and one that was 9
well understood.
10 0-initial process was to -- we discussed in the 11 June meeting -- was to go back and see what it would take to 12 issue a calculation.
At this point in time we had no reason
()
13 to believe there was any problem with it, with the exception 14 that it was an issue.
So, we set out on an administrative 15 review just to find out what it was going to take in 1990 to 16 issue work that was done back in 1987 and was done by a 17 contractor for us.
Of course, it was at that point in time 18 that we saw that there were a couple of sections that were 19 not prepared and checked, so we had a mechanics problem if 20 you will, on how to issue a document, the bulk of it 21 prepared and checked by one group and now we are going to 22 either modify it or we are going to supplement it.
How does 23 someone in our organization in this day and time take the 24 responsibility and can you take the responsibility to issue 25 an assign, check, prepared, check, et cetera, can they
25 1
review it.
2 We had what we saw was a ticklish mechanics 3
problem, but at this point in time we were not aware of any 4
deficiency in the calculation.
Then we became aware of the 5
allegations that Mark alluded to a little bit earlier, and 6
we changed the thrust of our review at that point in time 7
and decided it was necessary to give ourselves the 8
confidence that what we were contemplating issuing did, 9'
indeed, express what it purported to express.
10 So, we set out to do a review.
Initially, we said 11 let's just take a random sample of conduits that are covered 12 in this calculation, let's take the data that exists in
()
13 Appendix 4 that we talked about just a moment ago, the data 14 that exists in Appendix 4 -- you will see that is the pullby 15 schedules, pull dates and jacket types -- and let's then 16 take the criteria that Mark discussed earlier that would be 17 embodied up here in the methodology -- let's take the 18 criteria that Mark discussed earlier, run this data through 19 that criteria and see if we come up with the same results 20 that show up in Appendix 3, the one portion of the document 21 that was neither prepared or checked with regard to pullbys.
22 That's what we did.
We took 59, we ran through 23 those and found errors in 12 of the 59 conduits.
Some of l
24 the errors were inconsequential.
You changed a yes to a 25 now, but the conduit fell out of the screening process for l
I
s 26 1
other reasons.
However, we did find in one of the conduits k-2 that we sampled was from the top 15, a conduit M-1605, as we s
3 reviewed that conduit we found that criteria five and six --
4 that which had to do with whether there -- number six was 5
whether there were two condolets within the run and criteria 6
five had to do with whether it met this table from our 7
installation specification which defined what was an easy 8
pull -- did it exceed that or not.
9 We found that for this conduit the answers on the 10 check sheet as supplied by the contractor said yes to both 11 criteria.
Our review found if we took the same data from 12 which he started in Appendix 4 and flushed it through the
( )
13 criteria, we had to answer those two criteria no, which 14 meant that there was an impact to the top 15.
15 MR. MARINOS:
Kent, let me ask you -- I am losing 16 you a little bit.
17 MR. BROWN:
Okay.
18 MR. MARINOS:
This 59 that you selected, this was 19 irrespective of the criteria.
You just picked up 59 from 20 the population of 7,000 or 770?
21 MR. BROWN:
Seven hundred-seventy.
22 MR. MARINOS:
Then you checked those 59 against 23 the criteria and see whether they met the criteria?
24 MR. BROWN:
This is a case of did the contractor 25 apply the criteria correctly.
This is what we are asking
+
l 27 I
1 eurselves.
(s l
(-
2 MR. THIERRY:
On what ones?
3 MR. BROWN:
On those 59.
4 MR. MARINOS:
If one had been picked up it would 5
have been in there -- I see what you are saying.
I 6
understand.
7 MR. BROWN:
This is a simple matter where we said
}
8 we have a criteria that we agreed upon, now was it properly 9
carried through.
10 MR. MARINOS:
I'm with you.
11 MR. BROWN:
Up until that point in time we thought 12 we had a mechanics problem on just how to issue this n
(]
13 document.
14 MR. LAINAS:
Why 59; is there any basis to that, 15 or somebody said one more than 58?
16 MR. BROWN:
In the past the spec for a large 17 population like that, 59 was a good number for random.. So, 18 we pickod that number because we wanted to get the --
19 MR. LAINAS:
Some statistical basis.
20 MR. BROWN:
Right.
21 MR. MARINOS:
It's a separate statistical basis.
22 MR. BROWN:
We found errors in nine of those 59 23 conduits.
r'T 24 MR. THIERRY:
Nine?
t 25 MR. BROWN:
Yes.
28 1
MS. BLACK:
I thought you said 12?
r,,
x-2 MR. BROWN:
I may have, and you will understand it 3
in a minute. I am going to tell you there were 12 down here.
4 So, if I have gotten them flipped around, excuse me.
The 5
other thing that we noted was that there were certain data 6
that was missing, and that some conduits had not been fully 7
evaluated because when they got to the point to where they 8
were supposed to get the cable pull cards and look at the 9
dates and the cable types which would define what kind of 10 jacket material they had, et cetera, there was a notation 11 that indicated that the data was not available.
So, there 12 was missing data.
We saw that there were errors and there
()
13 was missing data, and some conduits had not beer fully 14 evaluated for that reason.
15 As a result of these nine errors we decided it was 16 necessary -- particularly the nature of the one error which 17 caused MC-1605 to drop -- we decided it was necessary to 18 take a further review.
We went to the top 40 as defined by 19 this document -- as Mark alluded a few minute ago, there 20 were two groups of 20 that had been picked.
Let me put it 21 back in context again.
We were looking for the top 20 and 22 we were going to test 15 out of the top 20, and we picket 23 the second group of 20 in case there were test deficiencs-s 24 in the first group.
25 There were two very specifically identified groups
29 1
of 20 and we decided to take those groups, go back to the
(- /
2 cable data, go back to the sketdhes that existed, flush them 3
through the criteria in the same fashion that we had the 59, 4
and see what the results were there.
If there was one from 5
this group that was in the top 15, there is one overlap.
We 6
looked at a total of 98 conduits in this process.
Here, we 7
found that there were 12 conduits which had errors.
Once 8
again, same situation.
Some of the errors were 9
inconsequential in nature, and some of the errors would 10 result in a shifting categories.
11 You remember earlier Mark pointed out to you that 12 we had gone and categorized a number of conduits according
()
13 to how many of the criteria that they had.
So, when we 14 looked at these 98 we indeed did find that there was a shift 15 sometimes in the categorization process.
16 MR. MARINOS:
Is this 12 plus the ninc or are 17 there some --
18 MR. BROWN:
There would be one overlap in that, so t
19 it's -- it would be a total of 20 that we are talking about.
20 The MC-1605 was included in both of those evaluations.
21 Let's look at the results of the review that we have done.
22 We have a busy chart, if you will, just to refresh your 23 memory of category definition is the same as Mark gave you
(~S 24 earlier.
l
%_]
25 (Slide.]
30 1
We have given you the same graph with the data in i
/,_T
(_ l 2
black here from the 1987 work that was done, and then with f,
the lines we show the results of our July 1990 review.
4 Finally, in the lower right hand corner, I give you the 4
5 results, the sum totals if you will of the category changes.
6 I have shown which categories gained and which categories 7
lost conduit as a result of the changes.
8 What you see as a result of this overall review is 9
that where we said that there were 12 conduits that met all 10 six of the criteria, what we indeed find is that there were 11 only four that meet all of the six criteria.
In a similar j
12 fashion you will see for Category B there were ten and still A) 13 are ten.
You will notice over here in the notation that l (
14 there was exactly one that changed from B to D and one that 15 went from B to C and one that went from D to B.
No net 16 change, but there was movement.
17 In all, you will see that there was movement 18 amongst the conduits that were tested.
of the tested ones, 19 a total of four went to Category C.
That means that they 20 met criteria one through four and Criteria six.
Two went to 21 category D which says they met criteria one through four, 22 which has to do with number of cables, presence of pullbys, 23 certain materials available and particular full dates but i
24 did not meet criteria five and six.
25 MR. MARINOS:
How many are tested that did not L
--.m.
31 1
meet five which seems to be the critical attribute?
ks 2
MR. BROWN Eight.
3 MR. MARINOS:
Eight did not meet five.
Category C 4
and D?
5 MR. BROWN:
These two categories -- category five 6
answered in the affirmative.
Seven did meet and eight did 7
not.
MR. THIERRY:
This is based on what reporting 8
requirements?
9 MR. BROWN:
This is based on a review of 98 10 conduits.
We looked at 99 in the first that ran and now we 11 have looked at the top 40, and I said there was one overlap.
12 We have gone back and reflushed 98 through this particular
()
13 process, and these are the changes that we see.
14 MR. THIERRY:
Out of those 59, how many were in 15 the calculation?
16 MR. BROWN:
Out of the 59 there-was one.
That's 17 why we went back and did the review of the top 40 because we 18 did see some movement and specifically wanted to know what 19 did happen; would there be a good number that would rise to 20 category A, would have been the greatest concern to us.
21 At this point in time as we finished this review, 22 clearly we were at a decision point.
We recognized that the 23 calculation had errors, that the errors affect the 24 categorization as we assigned it in the past, the errors 25 affected some of the conduits in which testing had occurred, n
32 1
and we realized that we needed to do one of two things.
We g)-
t\\/
2 either needed to regenerate this calculation and start 3
basically from scratch and go back through the same criteria 4
that we had fully prepare and check and fully issue in a 5
process according to today's methodologies and see what the 6
answers are -- see how they compare.
7 The other option was to take, if you will, the 8
benefit of the work we had done at the other plants at Watts 9
Barr and Sequoyah and the ranking and analysis that we have 40 done there and apply the same kind of criteria, the same 11 kind of ranking process where great consideration is given 12 to forces -- installation forces during the pullby process.
I 13 That is what we wanted to do.
We wanted to take a look at 14 this family of conduits -- look at them in light of the 15 latest criteria and proceed from there.
16 Let's go to the next slide which is going to give 17 you an overview of the kind of work that we have targeted in 18 order to resolve the issue.
The first thing that we have 19 is, we have a little bit of knowledge now after looking 20 through this two and one-half foot stack of material that 21 says to us that there certainly was a problem with 22 application of some of the criteria.
There were errors with 23 the criteria -- I don't see anything systematic at this 24 point in time and I don't see flocks of things moving to the 25 top, but I do see movement.
33 1
Though I see a problem ' lith application of a (D
V 2
criteria, at this point in time we haven't found any problem 3
with the data itself.
We feel because of the questions that 4
we have raised with regard to the calculation that -- before 5
we can use this tremendous piece of work, that we have to 6
give ourselves the confidence that just the raw data that is 7
there -- not the compilation and not the assessment of it 8
but just the raw data -- we have to give ourselves the i
9 confidence that there is integrity.
10 The first thing that we have to do is verify by 11 sampling the raw data that it is, indeed, correct.
A lot of 12 good data there with regard to which cables are in which I
13 conduits, when were they pulled, the number of pullbys, et 14 cetera, the very same kind of information that we need to --
15 MR. MARINOS:
Size of the pullby.
16 MR. BROWN:
Size of the pullby.
The same kind of 17 information that we need to complete an analysis that is 18 based on sidewall bearing pressure during a pullby 19 application.
The first block of work will be to give 20 ourselves that confidence that actually exists.
21 The next thing we would do then would be to 22 perform screening calculations in a fashion very similar to 23 that, that has recently been completed for the Browns Ferry 24 Plant.
The reason we use the word similar here is just that 25 we feel like we have been through a lot of work, we feel
34 1
like at that plant we have learned some things.
We
\\~/
2 initially did a screening or preliminary ranking there and 3
it didn't meet the accuracy that we wanted mutually.
We 4
ended up opening up that screening a little bit wider.
We 5
actually doubled the size of the conduits that we are 6
looking here.
7 Here I think I have an advantage, in that I 8
already have a tremendous amount of data regarding cables as 9
to when they were pulled and what size the pullby was. I 10 already have a large number of field sketches that tells me 11 what the length of a given segment is between bends and how 12 many degrees there are between bends.
I don't have rigid
()
13 isometrics --
14 MS. BLACK:
One of the criteria that you used 15 first was, are there more than seven cables.
You only have 16 770 for which you have that data already pulled.
17 MR. BROWN:
Yes, that's correct.
i 18 MS. BLACK:
Is that one of the screening criteria 19 at Browns Ferry?
20 MR. BROWN:
Actually, there we said --
21 MR. MARINOS:
It was eight cables.
22 MS. BLACK:
Eight?
t I
23 MR. MARINOS:
This is a little more inclusive.
rs 24 MR. BROWN:
The thought process there of course
\\J 25 is, until you get to a certain number of cables it is not
)
4 I-l
35 1
likely that there's been a whole lot of pullback to any
/
l
(_)S 2
given conduit and, if there has been, the pullby haven't 3
been too large.
Once the cable numbers begin to get into 4
the double digits and the possibility for either frequent 5
pullbys or large pullbys certainly can be said to exist.
6 So, we want to improve a bit on the preliminary 7
ranking that we do to these 770 based on what we learned at 8
Browns Ferry and based on the fact that we already have some 9
configuratial data available.
When we did the preliminary 10 rankings at Browns Ferry we did not have configuration data, 11 we did not know what the size of the pullbys had been, et 12 cetera.
So, we think we can be smarter and be more
(
13 accurate.
s_-
14 MR. MARINOS:
This is data that your 59 random 15 sample did not question; is that what you are talking about?
16 MR. BROWN:
Remember, the 59 random sample was 17 looking at the application of that data to the criteria.
18 MR. MARINOS:
Not the integrity of the data 19 itself.
20 MR. BROWN:
This bullet right here says we have to 21 go and look at the data to make sure the data is covered.
l 22 It is -- we use it.
23 MR. TRUDEL:
As part of some of the work we have l
l 'r'N 24 done already though, haven't we had an opportunity to verify 25 some of the field sketches versus some isometrics, and those l
36 1
have come out in pretty good shape.
We have some reasonable
()
(_-
2 confidence, but we still need to go through this effort.
3 MR. BROWN:
I think part of it we will go through 4
now will be to go through it and just switch the ones we 5
have looked at and document -- write down on paper that we 6
looked at this amount of data and found this consistency and 7
we do or don't agree with it.
So, it's a matter of 8
confirming on paper.
Now that we have said that we can 9
use an approach similar to Browns Ferry, we can run that 10 data through some kind of screening / ranking process just 11 like we did at Browns Ferry so that I can order them one to 12 770.
()
13 MR. MARINOS:
Would you care to explain to us you 14 are going to do that?
Are you going to use that --
15 MR. BROWN:
It's going to have to be an 16 enhancement of that.
I think we both agree with that.
How 17 am I going to enhance it, it's because I already know on the 18 basis of say field sketches, I already know how many degrees 19 have bent between pull points.
As Angelo is referring to, 20 the little equation that we used for preliminary ranking at 21 Browns Ferry, we did not have any consideration for the 22 configuration of the conduit, it was unknown to us at the 23 time.
Now we are working with a known.
(g 24 The second thing is the equation that you are
(_/
l 25 referring to was used initially at Browns Ferry.
It didn't
37 1
discrimination between whether the size of your pullby was 2~
two cables or five cables or ten cables.
Because of the 3
presence of this data already accumulated in the 009 i
4 calculation, we know that there were four pullbys or six 5
pullbys or there were two pullbys and how large was that 1
6 pullby.
My intent is to use some of that configuration and 7
pull sequence data, modify the screening calculation that we 8
used at Browns Ferry and hopefully do a lot better job of 9
ranking -- initial ranking.
10 Our intent would be that having done the initial 11 rankings, that we could go and pick the top conduits -- and 12 I'm not sure what that number would be -- the number would (q
13 be dependent on our correlation.
We already have some g
14 conduits that we have rigorous sidewall bearing pressure 15 data on.
We have gone out and have done sketches, we have 16 done rigorous calculations -- not the screening 17 calculations. If I take those same conduits and run that 18 same information through my screening calculation, I will be l
19 able to see how those two numbers correlate.
The intent 20 would be to either achieve very good correlation so that you 21.
can keep your number fairly small that you have to go out 22 and walkdown and prepare isometrics, or if there is not 23 adequate correlation we will do as we did at Browns Ferry, l-24 open it up until we gain that confidence, add more conduits 25 in other words.
l l
l 1
-,g m-
i 38 1
MR. THIERRY:
The sketches, they did not include
,_IT i) 2 any points at where the degrees of hends were.
They did not m
3 include any general -- you could not call it an isometric. I 4
don't know how you can get --
5 MR. BROWN:
The sketches -- remember the point of i
6 the sketch was to show the length between pull points and 7
the degrees of bends.
Quite honestly, the sketch didn't
)
8 care where the degree of bonds were; that io, whether a 90 9
degree bend occurred 15 feet in or 50 feet in, it rather 10 just showed that the total conduit was 75 feet long and l
11 roughly somewhere along through here there was a 90 degree 12 bend and a 60 degree _ offset.
(Of 13 So, you couldn't use it as -- you could not call 14 it an isometric, absolutely.
We agree with that.
15 MR. THIERRY:
It was on a screening -- it did not 16 account for bends.
17 MR. MARINOS:
That is not the point.
All bends 18 were not accounted for.
It is not where they are accounted 19 at.
20 MR. BROWN:
We have to do in Step one -- this is 21 the first time we have heard this.
In Step one we have to 22 verify where --
23 MR. MARINOS:
For the 15 tests that -- apparently
(~%
24 we are told -- the isometrics were double checked by i
25 specific walkdowns because you needed to do that to
39 I
1-establish points where --
\\_/'
2 MR. BROWN:
Where to put in the drain water --
3 MR. MARINOS:
Those 15 we were convinced --
4 perhaps you need to look at it again -- that you have 5
accurate isometric with the degrees of bends accounted for.
6 I don't care whether they are at the beginning point of 7
pullbys A or at the end of pullbys B, but they are accounted 8
for.
The other ones in your large population you don't 9
have, that's what we were told.
10 MR. THIERRY:
Fifteen plus 14.
11 MR. BROWN:
We have a total now.
It's 55 that we 12 have honest to goodness isometrics on.
The balance would O) 13 just be sketches.
t%./
14 MR. THIERRY:
I don't --
15 MR. BROWN:
Our initial intent was to take the 55 16 that we have honest to goodness isometrics on, take the 17 sketches for those same conduits and compare them, so that
-l 18 we can get a quick assessment of the accuracy.
If I have 19 the detail isometrics and I have the --
20 MR. MARINOS:
These are what you are saying your 21 modified or screening calculation, compare that to the known 22 isometrics that you have and see whether you are ranking 23 them right or whether your calculation is predicting 24 correctly the ranking?
V('S 25 MR. THIERRY:
No.
They cannot use the --
40 1
MR. BROWN:
I think an important point and one 2
that we discussed about the quality of the isometrics is
~
3 that once you rank using that you go back and do the 4
detailed isometrics.
So, you get real positive feedback as P
5 to whether there is a problem with the isometrics.
- Clearly, 6
if we see a problem with the isometric, that changes some of 7
the assumptions of what we did and we have to reevaluate.
8 We think the process itself will tell us whether 9
the isometrics are good.
Those 55 would be that we have 10 sketches on those 55 and we have isometrics on those 55.
11 Let's put it this way.
Our intent is to take the sketches 12 that we have and compare them first to the isometrics that
/~N
()
13 we have.
Then, we do our screening calculation that uses 14 that sketch information, it ultimately would be compared 15 with the rigorous sidewall bearing question.
It will be the 16 results of how they order one with the other, the i
17 correlation just as we did at Browns Ferry.
It will be the 18 correlation that will count.
f 1
19 MR. MARINOS:
In the final analysis, you will 20 certify whatever isometrics or sketches you are using, they 21 are accurate; right?
22 MR. BROWN:
Yes.-
Step one is to find out whether i
23 accurate.
If it is a bust, it's a bust.
/~3 24 MR. MARINOS:
Okay.
U 25 MR. BROWN:
We take a look at this top group, the
1 41 1
size of it dependent upon the correlation between the
,,m
)
_/
2 screening CALC and take a look at the top group.
To get i
3 isometrics we perform rigorous sidewall bearing pressure 4
calculations just like the industry does as a whole, and 5
then we intend to compare the Sequoyah results to the values 6
that were found for the Browns Ferry.
7 MR. DONOHEW:
What do you mean by that?
8 MR. BROWN:
Recently we went through the same 9
process with Browns Ferry.
As we discussed in other 10 meetings, installation practices at Browns Ferry and 11 Sequoyah don't greatly differ. The cables are the same, et 12 cetera.
Our intent would be to take a look at this group of
,-(.
13 conduits that rise to the top at Sequoyah -- the top 15 or 14 20 or whatever -- compare those to those which were just 15 successfully tested at Browns Ferry which -- and see whether 16 they are bounded or not.
17 MR. DONOHEW:
You mean the sidewall bearing 18 pressure that you calculate for the top Sequoysh cables you 19 would compare to the sidewall bearing pressure for --
the 20 conduits have been tested at Browns Ferry.
21 MR. BROWN:
Yes, sir.
22 MR. DONOHEW:
Does that mean you are changing your 23 commitment for Sequoyah about testing 15 of the top 20 conduits?
- 0 24 25 MR. BURZYNSKI:
We are changing the entire
42 1
1 program.
It is not just the number of tests or whatever, rs w-)
2 it's the selection criteria and the whole bit.
3 MR. DONOHEW:
So then, you may come back to us and 4
say that based on testing at Bro, ens Ferry you would not have i
5 to do additional testing.
6 MR. BURZYNSKI:
That wou; d be a favorable outcome 7
for us, yes.
8 MR. BROWN:
Anything else before we move on?
9 (No response.]
10 MR. BROWN:
Let me talk to you about what we think 11 it's going to take to do this and how long it is going to 12 take until we get at least a good strong feeling on where we (n) 13 are going with this.
We break it down into two parts, Phase v
14 I and Phaso II.
The line of demarcation between the two 15 really has to do with the accessibility of certain conduits.
16 The first order of business is to go out and obtain 17 necessary sketches and field -- necessary sketches and cable 18 data.
l.
19 I mentioned earlier that there were some cases i
20 where conduits were simply not evaluated because it was 21 noted on the check sheets that cable pull data was not 22 available.
We have done some checking here in the last few 23 days and we find that we are able to turn up some of that L r~'
24 data.
In addition, there were a number of conduits which, L (
25 because they didn't meet criteria two, three, four in our 1
1
43 1
original program field sketches, were never prepared.
\\~-
?
We will have to go out and prepare those field 3
sketches.
We will perform the screening calculation that we 4
talked about just a few minutes ago.
We think that this 5
will be about 560 conduits.
We will identify those which 6
are inaccessible to ALARA considerations.
I guess the 7
general consensus is that this is going to be a fairly low 8
percentage that would meet these kind of criteria and not be 9
accessible.
10 We will walkdown and do the isometrics for the top 11 ranked conduits, again how large that group is dependent 12 upon my ability to put together some kind of screening
()
13 criteria that has good correlation to the results that we-s.
14 would expect from a sidewall bearing pressure evaluation.
15 We will prepare and issue sidewall bearing pressure 16 calculations for the accessible conduits and then do the 17 comparison that we spoke of just a moment ago.
18 The Phase II portion of this particular effort 19 would be the task that would be necessary to compete the 20 remaining conduits for unit two.
We would propose that it 21 would be undertaken during our cycle refueling outage at 22 which will begin in September of this year.
For Unit one, 23 since the next refueling outage is scheduled for the fourth
/
24 quarter of 1991, we are saying that the work would begin no b) 25 later than then, but may occur sooner if we have an outage l
44 1
of available length.
i i/
2 MS. BLACK:
The work you are talking about is s
3 either in those sketches or in isometrics?
4 MR. BROWN:
That's correct.
5 MS. BLACK:
What are you going to do for obtaining 6
field sketches?
It sounded like yo:1 were going to do that 7
for all of them, but nor for any inaccessible ones?
8 MR. BROWN:
Inaccessible will be in Phase II.
9 MS. BLACK:
Right, even for field sketches, 10 MR. BURZYNSKI:
When we get done with Phase II, we 11 will have addressed all of the conduits.
12 MS. BLACK:
How many do you think of the 770 are
)
13 going to be inaccessible that you don't have field sketches 14 on currently?
15 MR. TRUDEL:
I think we think that it is probably 16' less than 20 percent, which would be half by the ability to 17 go into Unit two during this upcoming outage.
That is just 18 a guess when you think about the configuration.
There is a 19 lot of conduit out on our auxiliary building.
We have 20 conduit in the containment, but it is typically short and 21 not long runs.
22 MR. BROWN:
The other thing that we would do of 23 course is, we would -- just because a conduit has seven 24 cables doesn't automatically mean that a pullby necessarily 25 occurs.
One of the other actions that we would take would
45 I
1 be to-confirm whether or not a pullby really did occur.
I
[K/
2 think we will find the numbers which were reducing.
3 MR. THIERRY:
How did you come to the 260 4
conduits?
5 MR. BROWN:
Right now there are 42 from our l
6 existing what we call Category D that have no data or 7
perhaps no sketch, one or the other.
There are about 120 8
that are from Category E which have no data or sketches 9
because they didn't meet the criteria.
It was legitimate 10 that those were never screened.
11 About another -- we are estimating 100 that have 12 either perhaps one piece of information -- say the data on a
()
13 cable or two cables on a conduit and a handful of sketches 14 that are missing from categories B, C or D.
Now, I will 15 give you a specific on that.
Conduit might have 20 cables, 16 and if they found the data on 19 of them and went ahead and 17 proceeded on the 19 and that was perfectly acceptable 18 because if they met the criteria of seven or more cr51es, 19 two or more pullbys, three with PVC jackets and so many 20 pullbys before August of 1984, then the fact that they had a 21 missing piece of data on one or two cables was really 22 irrelevant.
23 For our purposes, if we ar trying to assess the fs 24 forces in a conduit and understand the pullby groupings, 25 that is information that we need.
Yes, they may have had
46 1
missing information in B or C or D.
We have to go back and (k-2 capture it so we can do the calculations.
3 MR. THIERRY:
The questions is --
4 MR. BROWN:
That's how the 260.
It's about 40 5
from one category, 120 from another category, and another 6
100 from the last group, 260 total.
7 MR. THIERRY:
The 366 -
8 MR. BURZYNSKI:
That is an estimate.
If you 9
remember, we came up and talked to you in May and discussed 10 the LF over R ranking there, the conduits dropped out 11 because there were either no pullbys or because they were 12 long straight runs.
We are estimating that the pattern will
!l ()
13 continue; that if you took the 366, some of those will drop 14 out because they are long, straight runs.
15 MR. THIERRY:
That much.
16 MR. BROWN:
We also know that there are a number
]
17 of these that are under 20 feet.
You remember in the 18 original criteria there was no screen specifically in the l
19 first batch.
If you met seven cables or more you were in 20 Category E, and it didn't matter at that point in time j
21 whether you were five feet long or 105 feet long.
We know l
22 that some others will drop out on the basis of length alone 23 because they will be very short.
24 MR. BROWN:
Those numbers are just estimates.
25 MR. THIERRY:
I just wanted to know how you come l
t 47 1
up with that, if it's different than 366 and less than 400.-
-(";
k-2 MR. MARINOS:
For screen calculations the second 3
bullet, approximately 560 conduits, this. screening 4
calculation you haven't really defined.what they are, or is 5
it exactly what Browns Ferry did?
6 MR. BROWN; It would have to be an improvement on 7
what we did at Browns Ferry.
It will be a modification 8
somewhat, same general methodology.
If you remember, at 9
Browns Ferry we took length times fill divided by radius.
A 10 good reasoning for that, in that in sidewall bearing 11 pressure a simplistic version of the sidewall bearing 12 pressure calculation would be length times weight times
()
13 coefficient and friction divided by the radiance.
Since we 14 didn't know how the cables were grouped in any particular 15 pull sequence, we took the fill end said fill is related to 16 weight.
17 In a case of hot fill, I had a likelihood of large 18 pullby.
We made that kind of correlation.
At this plant, 19 rather than saying that, what I would like to do is, since I 20 know the pull dates I can go ahead and group cables.
21 Instead of using length times fill, perhaps I will use 22 length times weight of largest pullby.
Because I have a 23 sketch that shows distance between pull points, instead of 24 using the total length of the conduit I can use length 25 between pull points and weight of largest pullby, and I will
48 i
1 get a much more accurate --
l 2
MR. MARINOS:
What vehicle are you going to use to i
3 keep us abreast of what you are doing?
What you are telling 4
us now it is ret clesrly exactly what you are going to do.
5 What are you going to do to get NRC's feeling about or 6
reaction to what you are doing?
7 MR. BROWN:
I will cover that in the conclusions.
8 MR. BROWN:
Okay, fine.
9 MS. BLACK:
May I make one point here.
It seems 10 like if you use a better calculation you always end up with 11 less sidewall bearing pressure.
Therefore, Browns Ferry 12 rough calculations will bound all of Sequoyah.
1
()
13 MR. BROWN:
No.
Let me clarify something there.
l 14 At Browns Ferry we did two sets of rankings, a preliminary i
15 ranking that was based on sending everything through a 16 sieve, if you will, just to knock out consequential 17 conduits. Of the remaining group, those which were at the 18 top -- initially those 30 which were at the top, we went and 19 did rigorous calculations just like anybody in the industry 20 would-do.
We did rigorous calculations for sidewall bearing 21 pressure.
22 That didn't afford us the kind of correlation we 23 wanted between the preliminary CALC and the rigorous CALC.
There was a lot of shifting.
Number one became number 15, l
- O 24 25 number 15 became number one, et cetera.
We went back then l
3 e.
49 1
and-took the top -
I believe it was 59 -- 59 or 60 conduits O
(
2-that came up in the rough ranking and went and did 3
walkdowns, did isometrics, and did rigorous. calculations on l
4 all of those.
5 obviously, the accuracy of your ability to screen j
6 determines how much effort that you ne'ed -- how precise yon I
i 7
need to be in going out and doing walkdowns and rigorous l
8 CALC. - All I am trying to do here is say that if I can get 9
better correlation between the screening approach and the i
')
10 final' CALC, then I won't need to look at quite a large of a 11 family with the full blown isometric.
]
12 MS. BLACK:
This final calculation then, you will 13 be cog aring the same type of calculation?
14 MR. BROWN:
The same program, in fact.
Exactly l
15 the same program will be applied to both plants for that i
16 final calculation.
If nothing else, the next part of the 17 program --
. p 18 MR. NEWBERRY:
Let me just ask something.
When 19 you make that comparison, I guess I am just not clear with 20 Suzi's questions at least.
I guess I am still not clear I
21 what different things could happen as a result of that 22 comparison.
Suzi suggested one thing is that Browns Ferry 23 calculation results in terms of sidewall bearing pressures 24 could bound.
Another alternative is that they may not, 25 either small or large amounts, I don't know, i
l
- n 50 1
Should you come up with a new list of worst case j_g L
)
ss 2
cables -- conduits here.
What would you.do then,'what is-r 3
your intent there?
Before with.the 15 you went ahead and-i
-4 the objective, if I understand this, was to identify.
5 conduits for testing.
Is it your intent then to proceed e
6-with another test program or what?
7 MR. BYNUM:
We would really have to -- not knowing 8
.the answer to what it is going to look like -- it's hard 9
answer that.
Obviously, we will have to take that, and if 10 it's not bounded, we might have to come up with some 11
-mechanism to ensure ourselves that those cables are okay.
12' If that requires testing, that may be.
We really don't know
[ f.
13
-the answer to that.
n 14 MR. BURZYNSKI:
Testing is an option It may be 115 easier and cheaper to strip the cables out.
16 MR. BYNUM: To take the cable out and replace it.
17 MR. BURZYNSKI:
There is a couple of different 18 ways, and without know the results we just --
19 MR. NEWBERRY:
Suppose you -- let's say you are 20 bounded clearly, 100 percent bounded and let's take that 21 case.
Why is that fact -- or is knowing that you are 22 bounded by the Browns Ferry conduit and sidewall bearing
.23 pressures an adequate basis to go through that Sequoyah is 24 okay.
25 MR. BROWN:
What we undertook at Browns Ferry,
\\
J
]
51 1-when we were doing work there which we thought Sequoyah was j
-\\ -e 2
leadiej the pack and that Browns Ferry was following.
One 3-of the things.that we undertook a couple of years ago was to 4
do for Browns Ferry a review of their installation
[
5 practices, their plant configurations, their cable types, 6
their procedures and compare thosa with what we found at i
7 Sequoyah.
8 The idea at that point in time was to see if 9
Browns Ferry was enveloped by the successful Sequoyah test -
10
- which we thought at that point.and we had no reason to 11 question -- were not a full implementation of the criteria 12 as designed.
What we found was a consistency in materials.
.p 4
1 13 Tnere is no reason that the materials at Browns Ferry or
.w) 14 Sequoyah, one or the other, should be more or less
-15 susceptible of pullby damage.
16 We found that the plant configurations were 17 commensurate one with another in the respect'of having-the 18
-absence of excess degrees of bends between pull points, 19 having the absence of large numbers of overfill conduits, et 20 cetera, and we found no indication of adverse craft practice 21 which would be something which would demarche Browns Ferry 22 from Sequoyah or Sequoyah from Browns Ferry.
23 We found that there was a consistency between 24 those two plants that we could rest on.
Now, by virtue of l'
25 the findings at Watts Bar which drove us back to do the
52
-1 testing at Browns Ferry, we find ourselves in a rather i
A-2 strange situation of going just theLopposite direction and 3
banking on Browns Ferry for the. sake of-Sequoyah.
If the-4 analysis was good before that the two are consistent in i
5 terms of practice and configuration, I still feel that it'is 6
still a valid -- we feel that there are differences between 7
the Browns Ferry and Sequoyah plant from the Watts Bar Plant 8
which set them apart, and leaves us confident with the 9
earlier.
10 MR. MARINOS:
A comparable statement is made in 11 documents that you submitted to us on Watts Bar that compare 12 Watts Bar to Sequoyah favorably and similarly to Browns
!.p l_ ( j 13 Ferry.
There is a three ring circle here.
You have 14 Sequoyah compared to Watts Bar, Sequoyah compared to Browns 15 Ferry, Browns Ferry compared to Watts Bar and the whole 16 thing is a circle.
17 If you were to take credit for the success of 18 Browns Ferry, you have to reconcile the failures of Watts 19 Bar with regard to Sequoyah, because there is plenty of 20 information that you have made and documented, similarities
'21 between the two plants, Watts Bar and Sequoyah.
So, how to 1
22 reconcile those similarities that you have drawn.
23 MR. BROWN:
The purpose of our March 28th 24 submittal I believe it was, to look specifically at Sequoyah 25 in light of Watts Bar.
Our conclusion was then of course, l
b 53 1
and still-is now, that we do see some significant k>
2 differences in their either practices or plant configuration i
3 which.give Watts Bar a greater measure of. jeopardy that we 4
don't see at Sequoyah.
Plus, it's an und6niable or 5
undisputable fact that we do have'a large body of conductors 6
out at Sequoyah which have been verified by tests.
7 What we are seeing now is they may not be the 8
number one through 15 when we come through all this, but we
[
9 certainly have gone through it as sequoyah the test program 10 in the industry of greatest magnitude followed next by the 11 one_at Browns Ferry to validate low voltage cable.
In other 12 words,-there is some paper evidence and then there's some
.(
)
13-plant evidence.
We feel like yes, we saw something at Watts 14 Bar that is certainly analogous in terms of that parachute 15 cord and the practices and overfill and degrees between pull 16 points, et cetera.
We don't see that here.
.17 If I simply made a paper analysis between the two, 18 people could still ask questions.
I have almost 1,000 19 conductors that have been tested at Sequoyah which does lend 20 I think a real strong credence to what we have done and 21 concluded there.
22 MR. MARINOS:
Are you going to look at them more 23 specifically on the failure mechanisms identified at Browns 24 Ferry or cable damage comparable to Sequoyah.
25 MR. BROWN:
At Browns Ferry, of course where they
?
?
54 l'
found their problems, they had to prepare CAQR's.-
Those A
2.
CAQR's are flushed through our system.
What I.can say for j
3 instance with the PN cable -- the cable type where we have a 4
single conductor polyethylene with a nylon jacket.
I am 5
going to speak'a little bit from memory.here, but my memory 6
is that is not used in safety-related circuits at Sequoyah.
7 MR. MARINOS:
I thought I misunderstood you.
8 MR. BROWN:
I was saying --
9 MR MARINOS:
In your testing at Browns Ferry you 10 identified cable damage through another mechanism and not 11 pullby.
12-MR. BROWN:
Yes.
(
)
13 MR. MARINOS:
Since you are making a comparison 14 now,-the favorable is also Browns Ferry.
Are you going to 15 transfer the unfavorable results of Browns Ferry to Sequoyah 16 in your evaluation or are you going to decide on those?
17 MR. BROWN:
Again, just the very fact that they 18 occurred forced us to write that CAQR, our condition adverse
-19 quality report.
A generic review at the other plant is 20 necessary.- It will be done.
What I can say in that regard 21 is, I am sure we could go back and look at the 1,000 22 conductors that were tested at Sequoyah and you are going to 23 find some that go through fire seals, et cetera.
There is
.(~g 24 some basis that exists for Sequoyah to already evaluate it O
25 but, yes, it has to be evaluated.
55 1
MR. MARINOS:
All right.
f~T 2
MR. HAYES:
Let me see if I can summarize ~it in my 3
mind..What you are saying is that several years ago what 4
you did was, you identified the 15 worst cables at Sequoyah 5
and based on identifying and testing in those cables --
6 excuse me -- testing those conduits, that there was a
~
i 7
certain confidence that all of the cables -- none of the 8
cables have been damaged when they were installed in 9
conduits.
10 Is this 95 percent that we were talking about, was 11 that docketed number?
12 MR. BROWN:
Yes.
(
13 MR. HAYES:
Okay.
It was 95 percent confidence.
14 Now what we are saying is that based on the analysis here,
-15.
about one-half of those -- seven or eight of those conduits 16 were not the worst case.
Now.that we don't know what your
'17 confidence level is anymore about the amount of damage or 18 possibility of damage at Sequoyah; is that correct?
19 What this program is intended to do is, rather 20 than try to go back and recreate that confidence level, you 21 want to attack it from a different one.
22 MR. BROWN:
Yes.
23 MR. HAYES:
And compare it with Browns Ferry or 24 Watts Bar.
25 MR. BROWN:
Yes.
If you think back at the initial
56 1-
- Browns Ferry approach was supposed to occur -- their
'O's!
2' confidence was going to be an extrapolation of what was done 3
for-Sequoyah.
What we are proposing in essenceLis a -
4 perturbation of that same thing.
We have turned it around -
5 we have results on Browns Ferry, we have evaluated the.
6 similarities and the differences between the two, and we are 7
saying if possible -- that's if possible -- if we are truly 8
bounded, then we would want to take credit for it 9
supplemented by the fact that we do have 1,000 successful 10 tests in our pocket that certainly give credence to the fact that we don't have a pervasive problem at the sequoyah 11-4 12 plant.-
-( )
13 MR. THADANI:
Let me go back to the basis for 14 continued operation and let me postulate two cases here.
15 Case one is you take six to eight weeks to complete Phase I, 16 and everything goes well.
Assume that the program is good, 17 the results come out very well, and it's a success story.
18 That's option or alternative one.
19 Alternative two, there are some questions about' 20 Phase I.
The results don't come out too well and your Phase 21 II questions still remain about the situation at Sequoyah.
l 22 Can you characterize for me in terms of safety why is it 23 okay to continue the operation of these facilities -- is the 24 risk so small, the questions pretty insignificant and risk 25 so small that it's okay for "x" months or years to continue
i I
57 1
to operate or, is there appreciable risk but we are talking rx.
Lf I'
K/
2 about.Very short time period and therefore it's okay.
3 Put it in those terms.
I can't completely.
4 understand safety-significance of this.
If you can help me 5
on that.
6 MR. BURZYNSKI:
Let me take a shot at it and 7
address it from three points of view.
First, given what we 8
know about Sequoyah and what we know about Browns Ferry and 9
Watts Bar, the potential for pullby damage is much lower at 10 Sequoyah.
It looks much more like a normal industry plant.
11 From that standpoint, I can tell you it's relatively low 12 risk.
()
13
. Secondly, the majority of the items that we looked-14 at and where we think based on those kinds of numbers there, 15 the majority of the conduits that would be affected by 16 pullby points are outside of containment.
They tend to see 17 pullby actions where things come together.
They come 18 together where your instrument cabinets are, and the access 19 cnannels through the auxiliary building and in the control 20 building and the auxiliary instruments.
21 In fact, the 15 we tested I think 12 of them were 22 in the control building and three were in the auxiliary 23 building.
So, you don't see them subject to harsh
/"'s 24 environments.
You have much less of a threat.
Their (j
25 expected operation would be no different than their normal
58 1
operation today.
j%
's-)
2~
Third, there is all that we know in addition to 3
testing that was done at Sequoyah, the kind of calculations
~4 that we have done on conduits already and comparing numbers 5
to Browns Ferry reinforce that.
The three ways to 6
characterize it is that it'is probably a low threat.
7 MR. MARINOS:
You alluded to Watts Bar.
How do 8
you relate to Watts Bar?
9 MR. BURZYNSKI:
In Watts Bar we see programmatic f
10 problems that increase the potential for pullby damage.- The i
11 programmatic problems are overfill violations, violations of 12 length and bends, and the use of the parachute cord.
Those t( )
13
-three tend to say Watts Bar is rare likely to have cable 14 pullby damage.
l 15 What you see at Sequoyah is general conformance to l
16 fill, to pull points -- in fact, the TER and the 17 observations of the NRC consultants was that we had a lot of 18 pull points, more so than typical that they saw.
The number i
l.
19 of boxes and conduit fittings that we have looked into l'
l 20 through the test program and through the modifications _that 21 we went through in this last outage, we don't find problems 22 in looking at it.
We don't see parachute cords, we don't l-23 see missing bushings, we don't find damaged cables.
24 MR. MARINOS:
Did you look for missing bushings at
("N ls 25 Sequoyah?
\\
l
59-l' MR. BURZYNSKI:
Not particularly, not k-2
-programmatically.- Browns Ferry did,.but by virtue of the 3
fact that we have opened these things up, part of our normal 4
practice is that when you have problems you put them in the 5-fix it systems through CAQR's.
So, we don't see stuff 6
coming out of those programs saying things aren't built 7
right.
8 That's why I say Sequoyah is different than Watts 9
Bar, and that's the evidence that we base it on.
t 10-MR. THADANI:
Let me still stay on the issue'of 11
. safety significance.
Can I take --
12-MR. BURZYNSKI:
One other point.
n
-13 MR. THADANI: -Let me ask you though.
Can I take 14 comfort from the thought that there is redundancy in systems 15 required to-deal with breaks outside containment that there 16 would be separation, that there is some probability that you 17 won't affect both our multiple trains.
Is that something l
18 that I should count on or ont?
L l
19 MR. BURZYNSKI:
That's true, but I don't know how 20 you could quantify that.
I certainly can't.
I don't know l
21 generally how our conduits are run for redundant trains.
22 The separation criteria for electrical separation that is 23 typically applied is not the same as for Appendix R.
In 24 Appendix R you get much greater spacial separation.
In some l
25 cases --
n 60' l'
MR. THADANI:
On Sequoyah I can't1 count on the
.,jj
" i >)
2 separation of cables --
s 3
MR. BURZYNSKI:
I'think to some extent you can, by l
4 virtue of Appendix R approach.
That is typically safe 5
shutdown as opposed to accident mitigation.
I tnink for 6
purely accident mitigation it would be just simply can't 1
7 quantify spacial separation beyond one physical separation.
8 MR. TRUDEL:
The redundancy is certainly there.
9 That is part of the depth theory, i
10 MR. LAINAS:
Haven't you completed at Sequoyah l
11 high energy line break analysis.
l l
12 MR. BROWN:
The high energy line break analysis 1
/~3 13 has been completed and certain' modifications'to reach that g
j v
14 have occurred.
h 15 MR. TRUDEL:
The other-thing is, of course, having 16 tested the 2,000 conductors on a random basis if there was a 17 programmatic problem with something like bushings we would 18 have expected that would have showed up much the way it did i
19 at Browns Ferry.
20 MR. THADANI:
In your own decision making process, l
21 how do you decide how long it's okay to continue to operate 22 with this question hanging?
23 MR. BYNUM:
I think Mark walked through it.
We l
'T 24 basically don't think we have a problem.
We don't have any
(
s l
25 reason to think that Sequoyah has a cable problem.
All of
/
x~
61 l'
the evidence that we have so far really points in that 2
direction.- We have done.the testing.
Even though at the 3.L and there was a redistribution, we have.done again' based on 4:
the distribution the four worst, _and seven of the 14 they 5-have been tested.
6-We really know more about that cable than most 7
people who basically have had the same cable practice as we 8
have.
We really don't have an indication that there's a 9
problem.
In Watts Bar there are some specific attributes at 10 Watts Bar that we have addressed that we don't think 11 applies at Sequoyah.
That is the basis.
12 MR. BURZYNSKI:
One point that I didn't make 13' earlier when I went through our reasoning and one I guess 14 that is-important in your understanding of this is, at Watts 15 Bar there were very specific allegations.
There were none 16 at-Sequoyah.
The Sequoyah program was a result of a generic 17 application of the Watts Bar concern because they were TVA 18 plants and could possibly have the same programmatic 19 problems that might have led to the allegations.
At the 20 time that was a reasonable hypothesis not knowing any more.
21 Today, we know much more about the conduit 22 configurations that tend to give us some confirmation.
The 23 reason we didn't have allegations specific at Sequoyah.is 24 because the practices appeared to be okay.
25 MR. MARINOS:
Mark, how do you know the
62 1
configurations if you don't have specific isometrics to
.,,) -'
2 really make the comparison of where you stand?
(n\\-
3 MR. BURZYNSKI:
We do have isometrics.
Understand 4
a couple of things, one is, that we went through the 5
evaluation of our test program and we compared conduits to 6
our definition of an easy pull.
Many -- in fact all of the 7
category D dropped out because they were considered easy 8
pulls.
The observations we-have of physically walking 9
around and looking support that, although they are not-10 quantified quantitative assessments by people that are 11 considered experts in that -- tend to support that.
The 12 observations of the consultants that NRC brought in to look
)
-13 at Watts Bar and Sequoyah specifically on the cable issue, i
14 they documented the better appearance of the Sequoyah 15 conduit configurations.
16 MR. MARINOS:. You are correct, appearance.
They
-17 can only do so much.
p 18 MR. BURZYNSKI:
We are talking about a quantum 19 leap in our minds between Watts Dar and Sequoyah, with 20 Sequoyah looking -- in fset, they make the statement in the 21 TER that we have more than the typical amount of pull l
22 points.
I mean, that was their assessment looking at it 23 physically and we walked them down all over the plant, 24 wherever they wanted to go.
L 25 It's those kind of pieces that come together that l~
1 1u
'0; 1
d) 63
- .y 1
tell us..
!f ]
Lk 2
MS. BLACK:
On the seven that were tested, how 3
many of those were wet tested versus dry tested, the seven 4
out of 14 in the worst case?
5 MR. BURZYNSKI:
The 3-B's were the wet ones, and 6
those still remain.
7-MR. TRUDEL:
They still remain as tested and still 8
remain as B.
The wet conduits,. testing hasn't moved.
9 MR. BURZYNSKI:
It is difficult in the sense you 10-are trying to prove that negative, that you can't ever prove 11
-in your work.
We are testing whether something might be L
L 12 there.
It makes it much more difficult to write a JCO in 1
,]m -
13 the usual sense.
l']
l 14 MR. BYNUM:
There is considerable amount of 1'
15-evidence to date based on testing in isometrics that we do 16 have on the different looks.
You take all of that 17 information and put it in a basket, our basic conclusion is 18 there is not a problem.
There-is a lot of_information that 19 supports that, and it's not like we don't know anything 20 about what is out there.
There's a large amount of 21 information out that.
22 That information basically supports the case to 1
23 date.
We are willing to go and get more information and do l
24 more with it, and that is fully our intent.
)
25 MR. HAYES:
Let me ask you on this intent.
You
1 64 1
said in a week it's going; to be August.: The September Y
2
' outage for Unit four begins early or' late --
3 MR. BURZYNSKIs September,:early.
4 MR. HAYES:
He's talking: about how much you have 5
to do between now and then, you are going to compare 6
Sequoyah values to Browns Ferry values.
As I understand it, 7
-based on the results, if you decide to test or replace 8
cables if necessary.
9 MR. BURZYNSKI:
Those are two options.
10 MR. HAYES:
There.is not a great deal of time, 11 particularly for Unit two.
The outage is in November /
12 MS. BLACK:
Also, you have to walkdown the ones
()
13 that are excessive too.
14 MR. DONOHEW:
Has Phase I started?
15 MR TRUDEL:
Yes.
16 MR. HAYES:
Wait a second=.
17 MR. DONOHEW:
The six to eight weeks, when do you 18 expect the eight weeks to end?
19 MR. TRUDEL:
Eight weeks from today.
20 MR. DONOHEW:
The six to eight weeks from today, 21 so that would be around October 1st.
22 MR. KIMSEY:
We are expecting right now the six to 23 eight weeks that we estimated is based on the fact that we 24 will screen the data we can talk about.
Right now we have 25 people coming in and being trained, and hopefully, that will
65 1
all occur in time.
- (
W \\~
2 MR. TRUDEL:
People are coming in today.
3 MR. DONOHEW:
I understand.
I think the thing l
4 with eight weeks, what you are talking about is the end'of 5
September -- I will use the word hopefully -- Phase I would ll 6
be completed and you would have the ranking of the cables L
L 7
that you are able to walkdown.and that you have been able to L
8 correlate your sidewall bearing pressure with the selection 9
criteria.
10 I just wanted to make sure that we all understand E],
11 that your estimate is about the end of September.
12 MR. TilIERRY:
One question I have is the pullby --
A)
';1 13 jamming and vertical, when are you due for those?
m 14 MR. BURZYNSKI:
In particular on jamming, the 15 selection calculation has been prepared:by TVA people.
It 16 has not been formally issued.
That will be included within 17 Mr. Lumpkin's review covering two aspects.
Is it n
18 technically adequate and programmatically why wasn't it I.g 19 issued.
20 In terms of the vertical, that is covered by l.i 21 Appendix 6 or attachment 6 of the calculation here, that was 22 not prepared or checked.
We have done a review of that i
23 information, technical review and have found no 24 discrepancies.
25 MR. MARINOS:
That portion can be easy you say and
66 1-to the NRC as accurate information.-
(
Y sN/
2 MR. KIMSEY:- We have done a sample of ten, and 3
want to continue to verify that.
The first ten that we have 4
looked at we have no problem with.
5 MR. BROWN:
It is even simpler than what we 6
described to you for the pullby.
We do recognize that we 7
have to attest to its validity and we have to do something 8
with it in-terms of issuing it in some fashion.
9 MR. BURZYNSKI:
In understanding the chronology of' 10 thic we started off with an administrative problem, and then.
11 we had indications of an allegation against the pullby i
12 ranking.
So, we went and checked that and found problems.
J
(
)
13 Once we found that we started branching out in these other 14 areas'and really haven't gotten that far.
We did a quick 15 sample there.
l 1
16 The other CALC on the jamming, we just put it into 17 the.QA audit round and just said go and look at it.
If it 18 comes up with problems we will obviously have to develop a 19 program, but we just aren't that far.
20 MR.-THIERRY:
The reason I am asking is that the 21 vertical drop transfer for Sequoyah will Browns Ferry take 22 credit.-
23 MR. BROWN:
Browns Ferry does not take credit for
/"'N 24 the vertical drop portion of it.
I 25 MR. THIERRY:
The jamming.
67 i:
1-MR. BROWN:
They will for the jamming, that is
[
'. A - )-
2 correct.
3-MR. BURZYNSKI:
We still have some work to do 4
there, and we are not overlooking it. ltt just is not far 5
enough down the road to tell you much more than that.
6 MR. BROWN:
Relative to the jamming, if the 7
calculation is technically adequate we'would suggest no.
We 8-haven't established that there is any problems or not with 9
that CALC, we haven't seen them.
10 MR. BROWN:- With respect to the vertical drop i
11 issue, Browns Ferry did not have the silicon rubber cable 12 which was present at Sequoyah so they had to go out and l
I J
13 assess their own worst case conditions and establish a test 4,
4 l
14 program, and have successfully completed the test program 15 for their vertical drop problems.
It also is separate from 16 the Sequoyah analysis.
I:
l 17 MR. ROSS:
You mean they took credit for the work?
l l-l 18 MR. BROWN:
Yes.
In that arena they simply 19 compared their configurations -- combinations of materials 20 and cable sizes, et cetera to those which were successfully l
'21 tested at Sequoyah.
The kind of impact would be less l
22 assumed that all the Browns Ferry ones were bounded by 23 Sequoyah.
If that is true, it's really not important
(~}
24 whether those are the worst at Sequoyah or not, just that
(__/
25 they are bounded.
68-1 There is a degree of impact.
o r
-\\~s 2
MR. ROSS:
How long do you expect it to take to 3
resolve that?
I 4
MR. BURZYNSKI:
I think we need to get to.the next 5
part of the presentation which is --
6 ER. MARINOS:
Before you go to the next part, I 7.
Want to go back to the point I made about the Browns Ferry 8
cable damage that has been discovered as a result of the i
9 pullby damage situation.
Browns Ferry is branching into new 4
10 test programs to assess the overall implications of those 11 failures.
12 What kind of urgency are you going to-place on.
'rN
, 1(,/
- 13 Sequoyah with the known damage from those mechanisms 14 identified to Browns Ferry?
15 MR. BROWN:
Let me answer part of that.
That.
16' started a while ago and stopped and went in some other 17 direction.
Let's take specifically the case of the missing 18 bushing with the PN cable.
The PN cable is 30 mils of 19 polyethylene with a four mil nylon jacket.
We had a grand 20-total of about -- correct me if I am wrong on the numbers --
21 about seven cables of that variety and safety-related 22 service at Browns Ferry as one of our older varieties.
As 23 you can imagine, that's a very thin jacket, seven mils of 24 nylon.
It is like transparent paper over that jacket.
)
25 There was a case where there was a bushing which
69 1-had become' disengaged.
During the pulling process they had j_
3 ~c} -
o.(
2 hit the end of the conduit, that unprotected end of the 3
conduit had significantly gouged the cables where the L
4 insulation was violated at a single point on each of several 5
conductors to get the total number.. What we did is, having i
-6 assessed -- to assess the damage mechanism and then decided 7
to find out -- since we were already aware at Browns Ferry 8
of one truly missing bush - a disengaged bush -- we decided 9
to go and.look elsewhere to find out wherever there was a PN 10 cable look and assess that there was always a bushing in 11 1 place.
Plus, we went into the program to look close enough L
12 to find out if this really were a problem.
j) 13 Some tests have precipitated from that.
Our 14 commitment was whether-there was a missing bush would we do 15 tests.
The thing that so distinguishes.Sequoyah from Browns 16 1 Ferry in that regard is that the PN cable varieties are not 17 used in Class 1-E service.
That has, if you will, the 18 jacket type that affords the least protection.
At Sequoyah 19 in contrast, I would expect that minimum jacket difference 20 we would find would be 30 or 45 mils, much tougher material 21 and something on the order of hypalon or BBC or something in 22 that regard that will withstand dragging or impact or either 23 one better than will the nylon.
24 I think that is the thing that will ultimately 25 distinguish the two plants.
701 1
1; MR. MARINOS:- You essentially made,an evaluation 2
now,=at least to us right now about the dissimilarities.of 3'
.the two plants.with. regard to the missing bushing. - What--
4 about the other damage as a result of the RTV removal-'for 5-
.the boundary'at Browns Ferry, how would you assess that 6-relative to Sequoyah?
'7 MR. BROWN:
I can't speak to.that one.
8 MR. MARINOS:
We found damage there, so what i.
9 urgency is TVA going to place on that kind of damage that 10 may potentially exist at Sequoyah since the plants are 11' similar?- Mark, do you have an answer to that?-
12-MR. BURZYNSKI:
No.
a(
13 MR. MARINOS:
We are going to wait for you to tell 14 us then.
You need to-tell us.
15 MR. BURZYNSKI:
I personally don't understan'd the 16 RTV issue, so I. don't think I can speak..to it.
l
' 17 '
MR. MARINOS:
Okay.
p l'
18 MR. BROWN:
In terms of TVA's documentation et lI L
19 cetera, again, CAQR's -- the generic process will require I
20 that Sequoyah and Watts Ber both address both issues, L,
21 formally address both issues and the potential for impact in 22-those plants.
+
l L
23 MS. BLACK:
What is the limit on that for this l
24 generic applicability -- 30 days?
l 25 MR. TRUDEL:
It's 30 days and corrective actions
71 1
from the previous plant, which-_is a 30 day process.
w 2
MR. MARINOS:
The other. potential problem.in the 3
justification regarding the pull points that you have, more 4
pull points at Sequoyah.
Therefore, it made the pull points 5
easier, assuming that the pull points.are utilized.- Region 6
II just issued a violation to Browns Ferry for bypassing 7
pull points right now.
8-So, how much weight are we going to place on this-9 argument for'the past?
1 l
10 MR. BURZYNSKI:
I don't know.
We placed quite a 11 bit on that.
=12 MR. BROWN:
It is clear even from the inspection
. O) 3 13 that the consultants did at Browns' Ferry, they even assessed 14 that that had not'been a' normal practice.
It was obvious to 3
115.
them, because-they found slack at-pull points.
i l
16-MR. MARINOS:
That's Browns Ferry that we are i
17 talking about?
18 MR. BROWN:
Yes, sir.
I understand.
L l
20 MR. BROWN:
You mentioned Browns Ferry and the l'
21 issue there.
What I am saying is that on the basis of the 22 review that has been done at this point either by us or by 23 your consultants, it would clearly seem to be the case that 24 what we are talking about is an anomaly rather than the
('Ng V
25
-normal practice.
j 72 1
MR. MARINOS:
It was also done at Watts Bar
-1 C
2 Acently.
3 MR. BROWN:
You are talking in the man holes.
4 MR. MARINOS:
Right.
There is so much that we can 5
do, and we can extrapolate so much on the basis of the data 6
that we see but don't completely hold us to it.
The plant 7
has to prove itself, number one.
8 MR. BROWN:
You remember, that was exactly why we 9
included in the original criteria a desire to find two 10 condolets, two 90 degree condolets, the feeling being there a
11 that if 90 degree condolets were present but were not used 12 a pull points -- if you pulled around the corner with the
)
13 extremely small radius that-is existent in such a fitting, 14 sidewall bearing pressures would be enormous and cables 15 would be rapidly deployed under a pullby process.
16-That was part and parcel to our criteria, and we 17 do have tests from approximately 900 conductors, and did not 18 find that to be a mechanism of failure in any of those.
The i
19 kinds of sidewall bearing pressures that would be generated, i
20 if you pulled around the corner in a condolet are going to 21 be astronomical and whether it's the number one conduit on 22 your ranking or the number 15 or 20.
It's the question of 23 infinity or infinity plus a few that is a one-eight inch 24 radius in there.
The radius goes directly into the U(~N.
25 denominator of that equation so that sidewall bearing
.)
l 73' 1-
-pressure are going to go up rapidly when you put one-eight
[~
L'
-2 of an-inch in there.
3 ~
MR.. IIAYES:
Excuse me, Mr. Brown.
I didn't hear 4
your answer to this gentleman's question when he summarized 5
the conditions concerning the 95 percent confidence factor.
.t 6-Ne asked you whether you agreed or disagreed and I missed l
7 four answer to that.
8 MR. BROWN:
I believe someone else answered that i
9 one.
10 MR. HAYES:
Did you agree or disagree, I'm sorry, i
11 I missed that.
12 MR. BURZYNSKI:
Did I agree or disagree with --
f-(
13 MR. HAYES:
This gentleman's summary, a
14 MR. BURZYNSKI:
I don't know what you mean by --
15-MR. HEDFORD:
Let me address the point.
From the 16 absence of other data what ana have identified in - our 17 Investigation would cause you to say that probabilities --
18 certainty of that work has decreased.
If it was a 95 19 percent probability before confidence, it is something less 20 today.
But we aren't absent other data.
21 We have done a substantial amount of additional 22 testing at Browns Ferry, and programmatically Browns Ferry 23 and Sequoyah are fairly similar.
In other words, there was
(~
24 a point made earlier that they are different and, in fact, Q}.
25 Browns Ferry is better.
The only way that I know Browns
l I'
74 i
'l Ferry is better is that Browns Ferry tends to have shorter N- )
{
2 runs and shorter runs yield in general, lower pullby forces.
- 3 Both of those go into the calculation of sidewall 4
bearing pressure; i.e.,
you take the length of the run or l
5 the. length of the pull in either case.
So, if we have lower 6
runs at Browns Ferry that makes absent any other 7-differences, that makes the numbers lower there.
We have l
8 done the calculations at Browns Ferry and we have compared 9
for a hefty population at Sequoyah including the ones l10 thought to be most susceptible to pullby, 11 We have compared those with Browns Ferry results-12
.and demonstrated that they are bounded int the Browns Ferry
- 7-wg 13 results. - Just to kind of summarize that long and rambling
( j.
14 discussion, I would agree with what Bruce said earlier 15 absent the Browns Ferry information.
I think coupled with 16 the Browns' Ferry information, I think-we have more I
17 confidence today that we don't have a pullby problem at L
18 Sequoyah than we did when the calculation was originally 19 done.
l 20 MR. HAYES:
So, you are saying that it is better than 95 percent confidence?
MR MEDFORD:
That's correct.
I am not a statistician.
That is a gut level feel.
We have more
/
24 testing results -- we have a heck of lot more testing V) 25 results, so that's why I say it's better.
75
?~-
1 MR. BURZYNSKI:
The only thing that I would add to Os-C 2
thatiis, I am~ aware that there are some people that have 3
- challenged the 95 percent number and the statistical 4
f ormuihtion.
Not being a statistician, I don't know if 5
that's correct er incorrect, s
6 MR. LAINAS:
On Sequoyah, how many tests passed 7-
'and how many failed?
4 8-MR. MEDFORD:
There were 15 conduits tested with 9-over 900 cables.
10 MR. LAINAS:
Conductors.
11 MR. MEDFORD:
Right.
For a pullby.
There were 12 other tests done on other conduits for other reasons.
(?-
13 MR. LAINAS:
Let's take the pullby. -How many of 14 those were tested.
15 MR. MEDFORD:
Three of the 15 conduits were 16 tested.
17 MR. LAINAS:
What was your pass / fail rate on that?
18 MR. MEDFORD:
For pullby, they all passed.
19 MR. LAINAS:
None failed.
20 MR. MEDFORD:
On pullby, they all passed in the 15 21 conduits.
22 MR. BROWN:
Are we ready to move on?
I guess the 23 last part of the program is Roy Lumpkin, the Site Quality 24 Manager will tell you about TVA's plans to both look at O~/
25 calculations as to what did or didn't go on and, also, the
1
'?
76 1
1
.ind of activities and QA involved in our forthcoming 2
effort.
3 MR. LUMPKIN:
Two parallel quality assurance 4
activities are now underway, forward look and the look back.
5 The first will' provide an ongoing coverage and independent-6 verification at the very beginning on this activity of
'{
t-7 readjusting to a calculation on problems that we have 8
identified.
We will be independently verifying the 9
calculation assessment that Kent earlier described to you.
10 We will move forward quickly from there.
That is
~
11 underway now.
We will move forward quickly from there'into 12 real time, online verification with each of the steps that
()
13 were' identified in the current activity plan that is shown 14_
in the sketches in the scheduling.
That it the forward 15 look.
16 We will have some monitoring reports'available at i
17 each of these steps along the way, and a summary report will 18 be issued within two weeks after the completion of Phase I 19 of those current activities.
We cannot at this moment 20 predict what Phase II will be, and we will await our 21 planning of that phase until the result of Phase I is in.
22 This particular activity of forward look will be 23 conducted by my Site Quality Staff.
We will have 24 specialists competent in this field assigned with us as 25 necessary from the corporate office of engineers, quality l
l
I, A.
,,m 77 1
assurance office.
The other activity will be a look back.
2 We will be using programmatic auditing as a means for 3
accomplishing this look back.
This will be conducted the 4
Corporate audit staff under Dave ".alone's auspices.
These 5
people that were assigned to QA tht.' used to be in the 6
engineering assurance field that are familiar with this type 7
of work will be performing this particular programmatic 8
audit.
9 We will be determining why this specific cable 10 selection calculation was not reviewed.
This will be our
.1 first efforte in that regard.
We already have interviews 12 underway.
We will be looking at the past program 13 requirements for calculations and for activities of this 14 variety, which is kind of an unorthodox calculation if you 15 please.
We will be looking to see if the present program 16 compares with it or has been changed, if it is providing the 17 information that we need to have in our program, the 18 requirements u..:.
se need to have in our program that will 19 allow us to move forward with more comfort in the future 20 than we now feel comfort in as a result of this past.
21 These evaluations -- all of the data from those 22 types of activities will be assembled and evaluated with an 23 intent of determining if we have an isolated c m here or is 24 this a qaneric implication that needs to be explored 25 further. I fully expect this recond look back activity to be
o, 78
+
1 finished and the audit report available September 7th.
If 2
ve run into things that indicate that we neod more time, ve 3
will immediately inform you so that you can make the proper 4
notification of that date change.
5 I think that the aspects associated with the look 6
forward and the Browns Ferry connection, if you please, the 7
return to the crossroads and deciding to take a pass 8
somewhat different to justify the adequacy.
Finally, the 9
cables at Sequoyah will merit some special attention, 10 especially as it regards to the completeness of work at i
11 Browns Ferry and as it regards the vertical runs supports
~
12 and the jamming issues that is underway at Browns Ferry
()
13 right now and the review of their calculations.
14 We will tie those together in our forward look 15 report, so that NRC will have a complete report and a 16 complete understanding of that circumstance.
Further in 17 regards to several of the questions dealing with the 18 probabilities of adequacies of Sequoyah, we will pay some 19 attention to that with the nuclear engineering staff in 1
20 order to bring forth all of the information that we have at 21 our dispor in a positive frame to support our confidence 22 at the end of this road in this program if that is at all 23 possible.
24 I will be hers as an independent verifier and, 25 hopefully, I will be able to do that.
Are there any l
79 1
questions?
?
/
\\_/
2 MR. DONOHEW:
Has there been any other 3
calculations like these were, the CALC's being discussed?
i 4
MR. LUMPKIN:
To my know) edge, no.
But we are 5
approaching that as well right now.
T9ople are looking at 6
that right now.
7 MR. DONOHEW:
When you say no, you mean excluding 8
the two at Browns Ferry?
9 MR. BURZYNSKI:
Two at Browns Ferry and this one.
l 10 at Sequoyah.
There is also the jamming calculation that we 11 talked about that was prepared in Knoxville as opposed to 12 United Engineers.
There was an additional one that was
' ()
13 prepared by United that documents the basis for the 14 selection of the wet testing conduits that is also not --
15 that we have found at Sequoyah that has not been issued.
16 The 009 that we have discussed here extensively 17 and +'
the one on the jamming, and the one that documents 18 the decision making -- the wet testing.
19 MR. 'IARINOS :
This is documented somehow but has 20 not been issued.
21 MR. BURZYNSKI:
Has not been issued.
22 MR. LUMPKIN:
Issued, prepared and checked.
23 MR. MARINOS:
There are two calculations at Browns 24 Ferry.
Can you tell us, are they electrical calculations?
)
25 The Browns Ferry, you said there were also two calculations l
80 1
but data were not assigned.
Didn't you just mention that?
/x
's-]
2 MR. LUMPKIN:
No.
I think the jamming 3
calculations at Browns Ferry --
4 MR. MARINOS:
Okay.
5 MR. LUMPKIN:
Are there any questions?
6 MR. HAYES:
I have some questions.
You say that 7
you have started your review at this point?
8 MR. LUMPKIN:
Yes, sir.
9 MR. HAYES:
Have you done any interviews at this 10 point?
11 MR. UUMPKIN:
I had two incerviews last week.
One 12 was with Tony capozi and one was with Dave Malone.
Those
()
13 were both individuals on our engineering assurance 14 organization in 1987 when this activity was being performed 15 by Nuclear Engineering and their contractors.
From that, we 16 have gathered information as to what we are interested in, 17 in terms of the criteria that engineering assurance was 18 going to use to decide which celculations they may put in 19 for independent verification.
20 Also from that we found some information regarding 21 individuals that were involved, and we have new established 22
-- as of this moment I have seven interviews scheduled and 23 seven more besides those -- eight or nine more.
I can name
/~'*g 24 them and give you the dates if you like.
y 25 MR. HAYES:
Do you plan to develop any type of
81 1
audit plan or something, or is that the process you are tk/
2 going through now?
~
3 MR. LUMPKIN:
The audit plan in draft form was 4
handed to me Friday afternoon, and I have several comments 5
and additions to make to it.
You can see from the list that 6
four or five objectives listed on the front page, detailed i
7 plans for the activities, the type of interview 8
questionnaire that we are planning to use, et cetera.
Each 9
of these pages and then, of course, the interview program l
10 that I have already initiated.
11 MR. HAYES:
Is it your current practice during the I
12 interview process that you intend to undertake, do you 1 ()
13 maintain your notes and draf t reports and draft interviews 14 of those interviews?
15 MR. LUMPKIN:
Yes, sir.
In this particular case, 16 when we feel a programmatic breakdown has occurred of this 17 nature, we will have two parties at each interview and one l
18 will be espec.ia? ?y aimed at trying to keep the notes proper.
i 1
19 We are trying to structure our questions so'that we ask them 20 the same way with each party each time, et cetera.
That's 21 the best we can do.
22 If we get down to the point of identifying the 23 issues associated with the program, a QA can deal with that.
/
24 If anything else arises, we will turn it over to the 25 appropriate management.
82 1
MR. HAYES:
Is it yous intentions at this point to
{}
(~ '
2 interview employees who are no it ager with TVA that may have 3
information bearing on this?
4 MR. LUMPKIN:
Yes, sir, it is.
Two trTt we know 5
of, and after that we will have to see who else surfaces.
6 MR. HAYES:
Is it correct to assume then that if I
7 in three months you have done your work and you have j
8 collected your data and you have issued your report and wha't 9
have you, then you would have all the documentation 1
10 necessary in a file that would support your audit reports 11 includir.g your notes and memorandum and questionnaires and 12 who you interviewed, who was there, who interviewed them and A( )
13 their answers, et ceterat am I correct?
14 MR. LUMPKIN:
Yes, sir.
15 MR. HAYES:
Thank you.
16 MR. BURZYNSKI:
We have come et the conclusion 17 slide.
We will briefly just go through the key points that 18 we think we have made.
First, our review might.dentify 19 substantial problems with the selection count tl.at was 20 utilized for identifying conduits to be tested for the 21 pullby program.
As a result of that, we are Jeevaluating
~
22 the Sequoyah cables utilizing screening calculations similar 23 to Browns Ferry, and then performing detailed sidewall
(~'
24 oearing pressure calculations to top ranked conduits.
\\
f 25 Pursing this approach to expedite resolution of
83 1
the cable issue, it avoids having to have further
\\_ /
2 discussions on the material question; it gets to some 3
criteria that we are comfortable with and that you are 4
comfortable with; and, it's work that we feel that we can 5
estimate fairly well.
6 We plan to docket revised program plan in early 7
August.
This submittal will address the findings, summarize 8
that information for completeness.
It will describe the 9
revised engineering program and the basis for it.
At this 10 point you will get the final ranking or screening criteria 11 and why it was selected.
It will address the schedule 12 issues.
It will also address the programmatic review plans
()
13 that we have for the quality assurance organization so that 14 you can understand how we are proceeding to evaluate any 15 programmatic issues.
We plan to docket that in early 16 August.
17 As you are well aware, we notified you early last 18 week of the findings, and have since pursued the JCO 19 submittal putting this presentation together, estimating the 20 program and understanding the findings ourselves.
So, some 21 of the estimates are preliminary.
We discussed that l
l 22 earlier.
We figure by putting the submittal in by the 23 second week of August, we will have some time to figure out 24 whether our assumptions are appropriate and modify the 25 program as necessary and inform you in a timely manner so
(
l l
84 1
that we have on the docket what we think is the right
,)
\\_/
2 program.
The schedule may change a little bit and the scope 3
may change a little bit, depending on what we find in the 4
next two weeks when we are looking it it.
5 That is the reason that we proposed that.
In 6
addition, we have to finalize what the ranking criteria will 7
be.
That is our general plan right now.
We expect that the j
8 revised plan will be a substitute for the selection tcst f
9 program that had been previously identified as a restart 10 program.
We are shifting away to different criteria and 11 different approach, and we intend to utilize Browns Ferry 12 testing results to the extent that we can reasonably bound i( )
13 Sequoyah with those.
14 MR. THADANI:
Will it include the two alternatives 15 that you described in case the results aren't favorable when 16 compared to Browns Ferry?
17 MR. BURZYNSKI:
I think we can discuss those as 18 two options. I don't want to close the door on any others, 19 but those are certainly two that we can identify as options 20 that we have discussed internally.
21 MR. MARINOS:
The testing or removing cables to 22 observe them.
23 MR. BURZYNSKI:
Yes.
24 MR. MARINOS:
Has been also described.
\\
25 MR. BURZYNSKI:
Yes.
There may be some other
85 1
approach to that, and I don't want to preclude another good 2
idea. Right now those are the two that we have identified.
3 We will certainly address them.
4 MR. MARINOS:
I have a quick question technical, 5
just for information.
Kent, do you happen to know how many 6
conduits are accessible right now from the population in 7
question while the plant is operating?
8 MR. BROWN:
No, sir.
9 MR. MARINOS:
Any guess anyone, what number of 10 conduits.
11 MR. BURZYNSKI:
Probably 80 percent, something on 12 that order.
13 MR. BROWN:
That is similar to what we found when 14 we did the LF/R ranking previously.
I 15 MR. MARINOS:
I am talking about would you be able 16 to get in the area and look at what population of those 17 conduits are easily accessible without shutting the plant 18 down.
19 MR. BROWN:
I guess one way you could approach 20 that is previously we wanted to look at -- what was it 366, 21 and we were able to look at everything except for 15 or 14, 22 the 14 ALARA conduits.
That was a pretty high percentage 23 that we were able to look at before.
24 MR. MARINOS:
You alluded about 80 percent of the 25 770?
That's a pretty large number.
I 86 1
MR. TRUDEL:
We would probably get to that many.
2 We have a large -- we haven't tried to bound it yet.
We 3
think we would get a large percentage.
4 MR. MARINOS:
Better than 50 percent of the 5
conduits.
6 MR. TRUDEL:
Better than 50 percent, yes.
4 7
MR. BURZYNSKI:
We certainly believe that the 8
majority of them will be accessible.
Are there any other 9
questions?
10 MR. HAYES:
I have one question.
When you say up 11 there you are using the calculations similar to Browns 12 Ferry, in your opinion is that program more stringent or
()
13 less stringent than the original criteria of a couple of 14 years ago that was presented to the Commission?
15 MR. BYNUM:
It's really different.
As far as the 16 stringency -- and it's hard to say it's really looking at 17 some different.
It is looking at it in a different way and 18 giving weights to different aspects of it.
It's really hard 19 to say which is more stringent, it's different.
20 MR HAYES:
Is it your view then that using the 21 Browns Ferry data, that the result under your new program 22 will be more accurate, more assuring?
Il MR. BYNUM:
No.
I think it covers a broader 24 aspect probably than the original criteria.
25 MR. BROWN:
It might be well at this point to very
87 1
briefly discuss how we went from the materials screening 2
process to looking at sidewall bearing pressure.
It was at 3
Watts Bar that we went through this inadvertant process of 4
evaluating employee concern with regard to welding near a 5
conduit that Mark described earlier.
We found our initial 6
pullby damage.
7 It happened to be in a conduit that would not have 8
been included in the worst case when defined by materials 1
9 screening.
That said to us one of two things at Watts Bar.
10 Either our materials screening criteria was not a good one 11 or we had damage which possibly extended beyond just the 12 worst case category.
()
13 When we went and confirmed damage in the material 14 sensitive population at Watts Bar, that said we had damage 15 in both sets of populations.
We said if this is true, then 16 in developing a program for Watts Bar we said we need to 17 focus on something other than just materials because we are 18 finding it in areas that materials were sensitive in and in 19 areas that they weren't because of Watts Bar specific 20 practices.
21 It was then that we conceived the notion of 22 evaluating with respect to the forces in that conduit, the 23 forces that the cables would see.
That was not particular to the types of materials that would be resident.
When we O,,'
24 25 went to Browns Ferry, we carried the same thought process l
1 n
1 1
88 1
over.
We said start with the whole populations, find those
)
,_\\
\\
i k- /
2 where the forces may have been extreme and zero in on that.
3 As we go back to Sequoyah now, that is what we like to do 4
is, go back and start with the broad population so as not to 5
inadvertantly screen something out that has seen a high 6
force and go after it.
7 MR. BURZYNSKI:
I think another way to approach B
that is to look at our criteria.
You hsve material 9
parameters here that says all things being equal, a more 10 susceptible material would be damaged first.
I think that's 11 prer.ty straightforward.
We get that force indirectly here 12 through that configuration.
The Browns Ferry approach
()
13 focuses on this parameter and quantifies it in a way, but it 14 excludes the material.
15 So, you can surmise that I have high forces but I
\\
16 might have more resilient material is that really worse than 17 lesser forces would -- a more susceptible material.
The 18 trouble is, if there are more parameter it's easier to come 19 up with an easy rank and say I filed number one.
You can 20 find families that are more susceptible.
21 We think this approach has merit to Browns Ferry.
22 The make some different assumptions, but they are both valid 23 and define a target population.
Again, the starting 24 criteria are really different.
You can't really say that 25 one is more rigorous than the other.
It makes an
89 1
assumption.
p,
)
i_/
2 MR. BRADY:
The new Sequoyah criteria or criteria 3
that you don't use at Sequoyah will be heavily dependent on 4
the computerized cable routing system.
5 MR. MEDFORD:
That goes back to one of the earlier 6
points that Kent mentioned, and that's to test the accuracy 7
of the database.
Remember on one of those slides that he 8
used, that first bullet on that was that we assure the 9
adequacy of the data that we start with.
10 MR. BRADY:
Isn't that what you will be using to 11 determine the fill?
12 MR. MEDFORD:
It doesn't use the cable, the r"N
(
)
13 compute 11 zed cable routing system, i
14 MR. BRADY:
What are you going to use, just pull l
15 tickets?
16 MR. BROWN:
It does, to the extent that you say, 17 how many have seven cables or more and what are those 18 cables.
From then on you go directly to the pull records.
l 19 At that point you have to -- for instance, if there are l
20 wholesale discrepancies and the computer is going to any 21 there's 10 cables and you get there and find seven tickets,
{
l 22 obviously if we run into those k{.k?_ of problems we will have 22 to take action.
The computer routing system at Sequoyah has 24 been challenged in the past.
There have been reviews to 25 assess that back in the 1987, 1988 timeframe.
I am not
}
90 l
1 privy to all of those results', but it was challenged.
As I
('M K-)
2 understand it, it successfully past the sampling that was i
3 mutually done.
4 MR. BURZYNSKI:
Are there any further questions on 5
the conclusions slides?
6 MR. THADANI:
Yes.
Going back to the JC0 what you 7
sent in, I guess it was yesterday or the day before, is it l
8 your intention to amplify and provide additional bases in 9
light of today's discussion?
10 MR. BURZYNSKI:
We had no plans to, but if you 11 feel that you want additional information we would be happy 12 to provide it.
[)
13 MR. THADANI:
It probably would be helpful, if you v
14 would.
15 MR. BURZYNSKI:
What type of information?
16 MP. THADANI:
I think there are two issues that I 17 need to talk to my staff about -- we owe you.
We need to 18 get back to you fairly promptly I think.
Two issues are 19 still not very clear in my mind.
20 Issue number one is, exactly how long is that we 21 are discussing time period, two months?
The results may 22 come and indicate that you need to go beyond.
of course, 23 you then have your plants during next outage, both Units one i
l ()
24 and Two.
That's issue number one.
V 25 Issue number two is, as I said earlier, in the I
91 1
context of safety.
I think Tom sort of touched on it.
He 3
(s 2
sort of touched on it, I thought, in terms of what is the 3
biggest concern.
It may be that it is high energy line 4
break or moderate line energy line break outside containment 1
5 and what kinds of cables are involved.
What is the chance 6
of having situations which could lead to some releases.
7 I can't get that out of the write up.
Maybe it's S
in there, and maybe people who have been involved in this 9
issue much longer than I have can comment.
I think it would 10 be very helpful if you cast what the work you have done and 11 somehow your conclusion be based on why you believe there is 12 no safety concern.
Is it two months, six months, four
()
13 years, I'm not sure.
14 MR. BURZYNSKI:
Right now the JCO really deals 15 with our evidence and our reasoning that says the 16 possibility of cable pull by damage is rather low.
l l
17 MR. THADANI:
I understand what you are saying.
l 18 MR. BURZYNSKI.
Beyond that to say what are the 19 consequences should it be tostulated to be there.
20 MR. THADANI:
Right, that's the part.
I think he 21 was also talking in terms of confidence.
A was the 22 confidence, B is if you have -- let's say some reduced level 23 of confidence now, then what are the consequences.
If you l
, ~N 24 say the consequences are trivial, one might have one l
(
25 reaction.
But if consequences are serious, then you need to
j 92 address the point.
1 2
I am a little uncomfortable.
I read this and I 3
must admit that I didn't know if this meant it was okay or l
4 not okay.
j 5
MR. BURZYNSKI:
We understand that.
From our end, 6
we are trying to prove a negative which is really 7
impossible.
We are put in a position of having to prepare a 8
JCo that goes down that road.
There are additional things 9
that we could add that are more qualitative than what we 10 currently have in here, our approach here was realli to 11 stick to things that we had specifics on.
12 The consequences, you get into a more qualitative.
( )
13 We have some basis for our reasoning there, but it is 14 certainly not as rigorous as what is there.
We could take a 15 look at that.
At the time we wrote it, on Monday we 16 identified the discrepancies.
On Tuesday we were asked to 17 have a Jco in, and on Wednesday, Thursday and Friday we were 18 developing our corrective action plan.
When we wrote it, we 19 weren't sure how long it was going to be in force.
i 20 Right now we are still not sure, depending on the j
21 nature of what we find, we may want to utilize it.
Is it 1
22 reasonable to just include that with the submittal we plon 23 in August.
24 MR. THADANI:
I thought that was in the middle of 25 August is what you said?
93 h
t 1
MR. BURZYNSKI Yes, the second week of August is g) t
- J\\m/
2 what we are shocling for.
3 MR. THADANI:
I think you should get back to us 4
sooner than that.
I would --
5 MR. BURZYNSKI:
You want the JCO earlier than 6
that?
7 MR. TRADANI:
Yes, I think so.
Two things.
One 8
is, if you can get back to us on JCO, I think we need to get 9
back to you very promptly on this proposal.
We will do that 10 in the next day or two.
We won't take much time.
I do 11 think you need to get back to us fairly quickly on the JCO t
12 though.
What is a reasonable time for you?
Friday?
()
13 MR. BURZYNSKI:
Friday it is.
14 MR. THADANI:
Okay, Friday sounds good.
-1 15 MR. MEDFORD:
I would put a little caveat on that.
16 I think we can address what we have heard here today and i
17 give you a JCO that goes to consequences to the extent
.d possible and addresses the Browns Ferry concern which we 19 didn't in our letter.
What I want to guard against is if 20 you will take a couple days and say it's Wednesday or 21 Thursday and we receive a letter from you that goes beyond i
22 this meeting and asks a lot of additional questions, we may 23 or may not be able to include that in something that we send 24 you on Friday.
{~N I
25 MR. DONOHEW:
Before we end the meeting, I want to i
94 1
offer Angelo the chance to go through -- he had some 2
concerns that he had on the JCO also.
I want you to go s-3 ahead and --
4 MR. MARINOS:
They have gone through what was 5
representative of my questions.
They are going to revise 6
the JCO by Friday.
I understand that you will submit a new 7
JCO, a revision of the JCO, and you will take into account 8
the remarks made here through your presentations.
9' I think essentially that will answer those 10 questions.
11 MR. DONOHEW:
Of the concerns that you have raised 12 internally, did you want to address those in --
(
)
13 MR. MARINOS:
It might be simpler if I hand them 14 to them, the remarks.
15 MR. THADANI:
I would be -- a lot of them have 16 been discussed one way or another.
17 MR. MARINOS:
I can hand them.a copy of 18 preliminary evaluations.
19 MR. BURZYNSKI Can we have a copy before we 20 leave?
21 MR. THADANI:
Yes.
22 MR. DONOHEW:
It is a preliminary evaluation.
Are 23 there any other questions that anybody would like to bring
(g 24 out?
This ends the meeting.
You hnve stated that you will V
25 hava a revised JCO and letter.
Did you say that also in the
95 1
letter that you were planning to send to us Friday that you i
)
(~/
2 were going to discuss the programs that you set out?
i 3
MR. BURZYNSKI:
No, that will be the second week 4
of August.
5 MR. DONOHEW:
That will be in the second week of 6
August.
l 7
MR. BURZYNSKI:
That will contain all of the 8
schedule information.
Since those are really back of the 9
envelope estioNces, we want to have a little bit of time to 10 see if we are on the right track.
i 11 MR. DONOHEW:
Okay.
12 MR. BURZYNSKI:
And, keep you fully informed of
()
13 how well we are meeting the estimates that we see right now.
14 MR. DONOHEW:
We will get back to you after we 15 receive the revised JCO.
It will be probably by the early 16 part of next week.
At least it will be by phone and 17 probably by letter.
18 That ends the meeting.
19 (Whereupon, at 3:44 p.m.,
the meeting concluded.]
20 21 22 23 25
( j'~'.
REPORTER'S CERTIFICATE N~J This is to certify that the attc hed proceed-ings before the United States Nuclear Regulatory Commission in the matter oft NAME OF PROCEEDING:
Sequoyah Cable Testing DOCKET NUMBER:
PLACE OF PROCEEDING:
Rockville, Maryland were held as herein appears, and that this is the otiginal transcript thereof for the file of the United States Nuclear Regulatory Commission taken by me and thereafter reduced to typewriting by me or under the direction of the court report-ing company, and that the transcript is a true and accurate record of the foregoing proceedings.
fu r
(
Mary C.
Larkin Official Reporter Ann Riley & Associates, Ltd.
9
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