ML20059H099
| ML20059H099 | |
| Person / Time | |
|---|---|
| Issue date: | 10/29/1993 |
| From: | NRC COMMISSION (OCM) |
| To: | |
| References | |
| REF-10CFR9.7 NUDOCS 9311090290 | |
| Download: ML20059H099 (98) | |
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LOCatiOD ROCKVILLE, MARYLAND i
dtO OCTOBER 29, 1993 2E9ES 76 PAGES
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COURT REPORTERS AND TRAWSCRISERS 1323 Rhode Island Avenue, Northwest Washington, D.C.
20005 I
(202) 234-4433 l
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DISCLAIMER This is an unofficial transcript of a meeting of the United States Nuclear Regulatory Commission held on October 29, 1993, in the Commission's office at One White Flint North, Rockville, Maryland.
The meeting was open to public attendance and observation.
This transcript has not been reviewed, corrected or edited, and it may contain inaccuracies.
The transcript is intended solely for general informational purposes.
As provided by 10 CFR 9.103, it is not part of the formal or informal record of decision of the matters discussed.
Expressions of opinion in this transcript do not necessarily reflect final determination or beliefs.
No pleading or other paper may be filed with the Commission in any proceeding 'as the result of, or addressed to, any statement or argument contained herein, except as the Commission may authorise.
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4 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION i
4 i
BRIEFING ON STATUS OF THERMO-LAG i
l PUBLIC MEETING i
J Nuclear Regulatory Commission One White Flint North Rockville, Maryland Friday, October 29, 1993 The Commission met in open
- session, pursuant to notice, at 10:00 a.m.,
Ivan
- Selin, 4
Chairman, presiding.
COMMISSIONERS PRESENT:
i IVAN SELIN, Chairman of the Commission KENNETH C.
ROGERS, Commissioner FORREST J.
REMICK, Commissioner E.
GAIL de PLANQUE, Commissioner NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W.
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2 STAFF SEATED AT THE COMMISSION TABLE:
SAMUEL J.
CHILK, Secretary l
KAREN CYR, Office of the General Counsel JAMES TAYLOR, Executive Director for Operations FRANK MIRAGLIA, Deputy Director, NRR l
l ASHOK THADANI, Director, Division of System Safety and i
Analysis, NRR STEVEN WEST, Division of System Safety and Analysis, NRR l
I WARREN MINNERS, Director, Division of Safety Issue Resolution, RES l
l l
l l
1 l
l NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W.
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P-R-O-C-E-E-D-I-N-G-S 2
10:00 a.m.
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3 CHAIRMAN SELIN:
This is an interesting l
i 4
talk this morning.
So much so I feel safe in drinking 5
decaf without worrying that our attention will lag 6
along the way.
7 COMMISSIONER REMICK:
No pun intended?
8 CHAIRMAN SELIN:
This morning we'll be 9
briefed on the staff's progress on the Thermo-Lag 10 action plan and the fire protection task action plan.
i 11 I should say this, to be frank about it.
i 12 The charts might give you the impression that this is f
13 just another quarterly or routine update, but it 14 really isn't.
I feel and the Commission feels that we 15 are at a crossroads in this program..
It's been a 16 longstanding program.
There have been a lot. of 17 problems.
It is possible that a solution to the fire 18 barrier problem is in the offing in the near future, 19 but it's not at all clear exactly where we stand and 20 how we get to this point.
So, we're looking forward 21 not only to the update but really to what I hope will 22 be quite a definitive discussion of the extent of the 23 problem, the staff's current assessment of where we 24 stand and what will be done, what has to be done and 25 what actions, if any, should be taken so that this i
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serious resource problem, safety problem, performance f
2 problem can be resolved properly for one and for all.
i 3
Well, at least for awhile.
i 4
The Thermo-Lag action plan addresses'the f
i 5
technical and programmatic issues related to the use l
a j
6 of the Thermo-Lag fire barriers by nuclear reactor t
7 licensees and there's also a fire ' protection task l
8 action plan which is more generic and the staff is to 9
9 be commended on undertaking this activity which i
2 1
10 addresses implementation of the recommendations made i
11 and the NRC reassessment of the fire protection i
12 program.
1 I
j 13 As I started to say, the. failure of the
+
i 14 Thermo-Lag fire barriers has identified concerns with i
l 15 the process used to identify potential problems at the
=
16 reactor site and so it's of utmost importance that we 17 address not only the Thermo-Lag problems, in fact not 18 only the fire barrier problems, but any underlying
]
19 problems in this process to correct all the problems t
l 20 that have been identified.
These two plans between
.)
1 21 them have the Intent to do just that.
I~
i 22 Commissioners, do you have any --
i i
l 23 Mr. Taylor, would you proceed?
24 MR. TAYLOR:
Good morning, sir.
25 With me at the table are the people from NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N.W.
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?
1 NRR responsible for this operation, as well as Warren 2
Minners from the Office of Research.
As you know, at 3
the request of the Commission, the possibility for 4
rulemaking, more performance-based rulemaking in this 5
general area is being examined by the Office of 1
6 Research and. I asked him to join us in case there were 7
questions in that area.
i f
l 8
Before turning the meeting over-to the 9
staff, I'd like to note to the Commission that there f
I 10 has been an exchange of letters between myself and Mr.
j l
11 Colvin of NUMARC with regard to NUMARC testing, which 12 you are aware of and which the staff will provide more l
[
l 13 information on.
The concerns that I've had=is.that i
l l
(
14 there be agreement by staff with the various j
15 parameters and requirements in those tests which the 16 first phase has been done, but-there's an extensive 17 second phase of testing of Thermo-Lag configurations, i
18 placement of thermocouples and what I'll call.the l
19 controlling features of the test.
There's not been 20 agreement between NUMARC and the staff on that subject 21 and it's been my purpose to try to resolve those 22 differences before the tests are done so that the 23 value of the tests are recognized and accepted by both 24 NUMARC for the industry, and most importantly by the 25 staff who have technical responsibility.
That's our NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W.
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own staff.
2 So, my last exchange was a letter to Mr.
l 3
Colvin which I signed yesterday which noted the l
4 differences still remaining between the NUMARC people 5
who are controlling these tests and the NRC staff and i
6 suggesting a prompt series of meetings so we. can i
7 resolve these differences. They are not yet resolved, I
l I
8 I regret to say, but we must do it.
i i
i 9
So, with those few notes from my --
l 10 COMMISSIONER ROGERS:
Just before you t
i 11 leave that letter question, Mr. Taylor, I wonder if a
12 there's just one little point that you could throw a l
13 light on
- there, whether there's just a
total
)
14 disagreement on something or whether there is another i
15 issue here about what we're talking about.
l 16 In your letter, at the bottom, you said on j
l 17 the first
- page, "The currently proposed staff 18 acceptance criteria are essentially in agreement with l
19 the proposed ASTM standard for fire tests, raceway
)
20 barriers through Revision 14.
In Mr. Colvin's letter, I
21 on page 2.3, he said, "Our proposed thermocouple 22 placement approach is consistent with draft ASTM 23 standard E-5-11, standard test methods for fi,re tests 24 and fire resistant barrier
- systems, electrical 25 components."
l NEAL R. GROSS l
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Is this just a total disagreement on 2
something or --
3 MR. TAYLOR:
We'11 address it.
We will 4
address it.
5 DOCTOR THADANI:
We place to specifically I
6 address that issue.
i i
7 COMMISSIONER ROGERS:
Okay.
1 l
l 8
MR. TAYLOR:
As part of our --
l l
9 DOCTOR THADANI:
What the issues are and 10 what's meant by what draft and the scope of 11 information that goes into it.
l l
12 MR. TAYLOR:
If you don't mind, we'll hit 13 it --
14 COMMISSIONER ROGERS:
Fine.
15 MR. TAYLOR:
-- as we proceed.
16 COMMISSIONER REMICK: One thing that might 17 be helpful in the presentation, if you have some kind 18 of a sketch which would show what cable tray rungs are 19 and this question of where a thermocouple should be 20 placed.
21 DOCTOR THADANI:
Okay.
We will see if we 22 can't get --
23 MR. TAYLOR: We can probably have somebody 24 draw on in the back room while we're starting the 25 presentation.
We'll do that.
The staff is here.
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I'll ask Doctor Thadani to continue, l
l i
2 please.
j 1
I 3
DOCTOR THADANI:
Good morning.
4 CHAIRMAN SELIN:
Good morning.
l 5
DOCTOR THADANI:
(Slide)
Could I have 6
slide number 2?
There it is.
7 I'll briefly go over the status, the 8
action plan and then Steve West is going to give you 9
not only the status of where we stand, but also what 10 the significant issues are in each element of the I
11 program plan and where we're headed.
12 (Slide)
May I have the next viewgraph, 13 please?
i 14 Well, as a result of the many issues that 15 were identified, concerns that were identified with 16 the Thermo-Lag material, we did prepare a plan laying l
17 out the technical work that had to be done and the 18 schedule by which we hope to resolve this issue.
We 19 briefed the Commission last November on this matter.
20 Since then, we have completed two parts of this action 21 plan.
Part 2 is completed.
That is the small-scale 1
22 testing, not only of the Thermo-Lag material, but also 2
l 3
i 23 of the other materials that are used as fire barriers.
j 24 We also have completed, as the Chairman 25 noted, the fire protection program reassessment. This NEAL R. GROSS 1
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is the introspective look at our own activities, as 2
well as some of the issues that were identified in the 3
IG report that came out last year.
4 As we have-gone through our evaluations as 5
significant issues have developed, we have kept the 6
Commission informed. Some of the examples are, again, 7
Comanche Peak issues as they were developing, as well l
8 as some of the information we got on some materials j
9 other than the Thermo-Lag material.
10
- Now, as the Chairman
- noted, the 11 reassessment report was quite extensive and there were 12 a significant number of recommendations for action, as 1
13 well as for further study.
At that time we decided 14 that we needed to factor those issues in and develop 15 a plan as to how we were going to get those behind us.
16 Now we have two action plans basically.
So, we have 17 the Thermo-Lag action plan that deals with issues l
i 18 related to Thermo-Lag material and the fire protection 19 action plan that relates to other materials as well as 20 the generic issues that were identified in this 21 reassessment report.
22 We have completed a number of other 23 activities, including issuance of some generic letters 24 to get information from the industry on specific 25 issues and the actions that we have taken as a result NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W.
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of information coming from some of the small-scale 2
testing that we've done.
We keep the Commission 3
informed on a quarterly basis as well through our 4
status reports. The most recent one was provided just 5
about two weeks ago.
1 6
Our plans for this morning were to go 7
through each of the major issues, major activities and 8
what are the significant problems and how we hope to 9
resolve those problems, and that requires -- either we 10 know what the answer is, or at least the process we'll 11 have to go through to resolve the issues.
Steve West 12 is going to go through all of that.
13 Steve?
14 MR. WEST:
Thank you.
15 Good morning.
16 (Slide)
Next slide, please.
17 I plan to cover this morning the major 18 activities that we've either accomplished or are well 19 along the way on since the November briefing.
We'll 20 talk about the Generic Letter 92-08 which we issued 21 shortly after that briefing, our acceptance criteria 22 which are near completion, the NIST test that we did 23 on Thermo-Lag and other barrier materials, the plant-24 specific programs that are either completed or 25 underway at this time, the NUMARC test program and NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W.
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then we'd like to conclude the discussion of the 2
Thermo-Lag action plan with a discussion of the 3
schedule and where we see ourselves in industry going.
j l
4 And then following this discussion of ~ Thermo-Lag 5
action plan we'll touch briefly on the fire protection 6
task action plan which we've also started some work 7
on.
I 8
(Slide)
Next slide, please.
l 9
We last briefed you in November and a 10 month later we issued Generic Letter 92-08.
This was
]
11 the generic communication that specifically identified 12 the staff's concerns with Thermo-Lag fire barriers.
13 It was the result of the work completed by the special 14 review team and then later by-the staff following up 15 on those concerns that were identified.
I
)
)
16 Probably the most significant thing I
17 well, we recognize that there were quite a few plants 18 that use Thermo-Lag and the generic letter certainly 19 confirmed that.
We found that there were 79 units 20 that use Thermo-Lag fire barriers to meet NRC fire 21 protection requirements. What's significant abcat the 22 responses in our minds is that of those licensees at 23 least 70 are waiting for the results of the NUMARC 24 program before they affect any corrective action 25 programs.
So, really, we're in a position now of NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W.
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waiting for the NUMARC program to be completed and 2
we'll talk about what the elements of that program are 3
so you'll understand what our interaction has been 4
with NUMARC.
l 5
There were a couple of licensees that have 6
actually removed their Thermo-Lag from their plant'.
7 These are a couple of plants that had minimal amounts l
8 and they were either able to reroute cables or in some 9
cases use another fire barrier material to actually j
10 replace it.
So, there are a few licensees out there,
[
l 1
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11 about six, that either are or will shortly be out-of l
12 the woods.
)
13 We are continuing to review the responses f
1 14 that we've received on the generic letter and we're 15 replying back to each licensee and the final ultimate 16 close-out action for the Thermo-Lag problem will be an 17 inspection at each plant by the staff and that's still j
18 sometime away, but we'll talk a little bit more about 19 what we're doing to prepare for that as we go through 20 the presentation.
21 Another very significant activity has been.
22 the preparation of clarified fire endurance test 23 acceptance criteria.
We have been working for some 24 time on this.
We recognized shortly into the Thermo-25 Lag review that the existing staff guidance could use NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W.
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some refinement and clarification.
There was -- the l
2 special review team and later the staff identified i
3 that there was confusion within the industry despite e
4 the staff's previous efforts to put forth guidance.
i 5
We have been working on that and we had. recently l
6 published the proposed criteria in the Federal 7
Reaister for comment.
We've received those comments i
i 1
8 and we have responded to all those comments and have 9
finalized the proposed acceptance criteria which are L
10 currently under final management review.
)
11 I want to just point out quickly before I 12 move on that the fundamental regulatory requirement 13 that a licensee install a one'or three hour barrier 14 depending on the other fire protection features to 15 meet Appendix R has not changed in any way.
Also, the 1
-16 scope of this criteria which are included and will be i
17 included in this supplement to Generic Letter 86-10 18 are still within the broad scope or bounded by the l
19 existing staff criteria.
The only change which has 20 been discussed extensively with the Commission, 21 Chairman Dingle and the public and NUMARC and 22 everybody has been this hose stream business where we 23 have utilized other existing NRC guidance for hose 24 stream testing and are allowing licensees at their 25 option to apply it to the Thermo-Lag fire barrier or NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE N.W.
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any raceway fire barrier in the future.
1 2
Okay.
I said we've received comments.
3 We've probably got about 80 comments in response to 4
the generic letter and they focused on hose stream 5
testing, thermocouple placement, allowing an option of 6
testing raceways without cables installed, which we 7
had previously approved for TVA and which is a part of 8
the ASTM and UL standards.
We have included that in l
9 our guidance.
We felt that --
l 10 CHAIRMAN SELIN: Could you just -- I'm not 11 familiar with the issue of whether the cables are in 12 the raceway or not when you do the testing.
What's 13 the effect of not having the cables --
I 14 MR. WEST:
Well, when you build one of l
15 these test assemblies, be it a conduit or a cable tray 16
- assembly, if you add cables to the test assembly l
l 17 you're adding a heat sink which helps improve the 1
18 performance of the fire barrier system itself.
19 There's two schools of thought.
One is that if you --
l 20 because in-plant configurations typically have cables, 21 you should be able to take advantage of that thermal 22 performance.
The other school of thought is that 23 since you're really looking to see if the fire barrier 24 itself is qualified, you should not try to take 25 advantage of the heat sink provided by cables.
i l
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1 The NRC will, in the criteria, allow 2
either option.
There are slightly different 3
methodologies that you would apply, depending on which 4
option you followed.
But the --
5 CHAIRMAN SELIN:
Does that mean in l
6 practice that people generally will test with cables r
7 and --
8 MR. WEST: Well, in the two plant-specific l
I l
9 programs which were recently done, Comanche Peak chose 10 to use cables and TVA chose not to use cables.
I 1
l 11 think from the standpoint of truly testing your fire 12 barrier and qualifying it, the preferred method would
)
13 be without cables, particularly if you're going to be 14 trying to apply your results generically.
It's a lot 15 easier to apply -- do a plant-specific test and apply 16 the results with cables to a specific plant because 17 you're using plant-specific cable configurations, 18 plant-specific equipment types of cables and you can 19 do functionality testing that will apply.
i 20 MR. TAYLOR:
There are varying degrees of 21 loading in the trays.
So, your cable load is within 22 the specs.
l 23 COMMISSIONER de PLANQUE:
But in allowing 24 either option you're still keeping the test criteria 25 the same?
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1 MR. WEST:
Yes, the basic criteria would 2
be the same where you're measuring a temperature rise 3
on the unexposed side of the barrier.
In either case 4
there are options for demonstrating cable 5
functionality if you need to.
6 MR.
MIRAGLIA:
I think the key point 7
that's being made and Mr. Taylor's response to Mr.
8 Colvin more recently, and it bears on the issue of 9
thermocouple placement, amount of cable that's in 10 there, the real concern is the applicable of the test 11 configuration to the install conditions within the 12 plant.
13 In Comanche Peak's case, they chose to 14 pick configurations that were representative of their 15 plants, the cable loadings were consistent.
So, the 16 applicability of those tests to Comanche Peak, while 17 they had concerns, they were bounded.
We evaluated 18 those.
19 In TVA's case, they're taking, as Steve 20 has indicated, the broader perspective, rating the 21 barrier clearly and then if they have two percent 22 cable or 100 percent cable, it's applicable.
23 The standard, as I understand it, that's 24 under consideration in draft form and it's probably 25 two years away to final adoption has that as a NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W.
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1 preferred option.
So, the thermocouple placement, the i
i 2
amount of cables is what is the applicability of the i
3 tests to what we have.
The key point is we have 70 4
licensees waiting for the NUMARC test.
If we have l
t l
5 5
questions relative to -- gee, it was 15 percent cable l
l l
6 and the thermocouple was on this side of the rung
\\
l 7
versus the other side of the rung and there's 8
temperature differences.
It raises questions then as l
9 to the broadness or the applicability of that test to l
10 a large amount of configurations out there. The focus i
11 of our concern relative to temperature placement and 12 applicability is we need to try and run these tests so j
i 13 there is as fewer questions that get raised.
So, when 14 we try to apply it to the broad range of 15 configurations out there, we can cover the waterfront 16 because it's a very, very resource intensive kind of 17 effort.
To the extent that we can increase the 18 applicability of these tests in a generic way, the l
l 19 easier our job is and the easier the industry's job 20 is.
l l
21 That's really the focus. They're going to 22 run some tests with thermocouples and it will say is 23 it 15 degreen or is it 40 degrees.
But that will be
{
24 something that we'll have to evaluate an issue and 1
25 say, "Well, it was 40 degrees with 10 percent cable.
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Now we have this tray here, we have -- what would it 2
be with five percent or ten percent?" It raises those 3
kind of issues.
4 So, really the issue is the applicability.
5 It's well stated in Mr.
Taylor's letter, is the 6
applicability of this test on a generic basis so we 7
can get on with the resolution of the issue.
8 COMMISSIONER de PLANQUE:
I understand 9
your problem with applicability, but if you use the 10 same criteria, whether or not you have cables in 11 there, how much conservatism is then built in when you 12 test without cables? What's the dif ference between no 13 cables and the minimum amount of cables you're likely 14 to find in any given situation?
15 MR. MIRAGLIA:
I think there would be 16 differences, but what we're saying then is if it's a 17 plant-specific application, then that temperature rise i
18 that you see is the same.
In other words, without i
19 tests, there's probably more conservatism in a test j
20 without cables than a test with cables.
But in either i
21 case --
22 COMMISSIONER de PLANQUE: Yes. Of course.
23 MR. MIRAGLIA:
But the real question has 24 always been the functionality and then the temperature 25 rise is a surrogate for that.
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CHAIRMAN SELIN:
Can I try this question 2
a little differently? The Appendix R and the generic 3
letter basically are saying in a opecific application 4
there should be no more than a certain temperature l
5 rise and that would include specific configurations, 6
including specific amounts of cable. What it's trying 7
to do here is take generic results so that nobody has j
8 to test each configuration from scratch, that there be 9
a reference base.
10 If I understand it correctly, what you're 11 asking is that NUMARC do the test without cable or at 12 least a --
l 13 DOCTOR THADANI:
As an option, yes.
l 14 That's an acceptable option.
15 CHAIRMAN SELIN:
And then when a
16 particular utility comes in, then they have to show us 17 to your satisfaction that the effect of the cable 18 would be so much and therefore a generic test can be 19 evolved with correction based on real configurations 20 with real cables.
But if the generic tests are run 21 with a lot of cable, then you don't know how to scale 22 up.
23 DOCTOR THADANI:
That's exactly correct.
24 I know we're going to get into a lot of specifics 25 later on, but there is a lot more behind this issue.
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\\
1 We're going to have a hard enough time, I think, when 2
we get down the road after the tests are completed to 3
make sure that the licensees that use this information 4
have adequate basis to say that the tests are, in I
5 fact, applicable so we don't end up into yet a whole l
l 6
new set of tests later on because we leave some questions unanswered.
This is just one part of that 7
8 process that we'll have to go through.
1 9
There is some good thinking behind the l
10 preferred option of measuring temperature on the cold 11 side of the barrier because the loading may be 12 different on the cable trays, there may be sagging 13 involved, there may be contact involved between the 1
1 14 barrier and the cables. There are a number of issues.
15 I think we can get into a lot of that later on, but a 16 number of issues that say if we were to go forward and 17 have either no cables present or have bare copper wire 18 as close as possible to the barrier itself, then I 19 think we would have avoided some of these questions 20 that are bound to come up.
21 CHAIRMAN SELIN:
Let me just go into 22 something.
The barrier will not pass or fail the 23 NUMARC test.
It's not a test in a sense of a pass or 4
24 fail, it's a test to establish a base set of data
. i 25 which can then be used in specific configurations.
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I l
21 1
So, if they run the test with a thermocouple on the 2
cold side of the barrier, you expr et more of a 3
temperature rise than if they ran the thermocouple 4
where the cable would be.
l 5
MR. MIRAGLIA:
That's right.
j 6
CHAIRMAN SELIN:
But we're not passing or 7
failing the material based on that. We're saying this l
8 is a more invariant baseline to be used in a specific l
9 analyses, so please run this in the least variable way 10 so that when the individual utilities come in they l
11 will have the best information.
12 DOCTOR THADANI:
Exactly. That's exactly 13 what we're trying to do.
14 CHAIRMAN SELIN:
Is that correct?
15 DOCTOR THADANI:
That's correct.
16 COMMISSIONER de PLANQUE: My question will i
i 17 still stand in the end.
What degree of conservatism, 18 therefore, is built into that compared to a much more 19 likely real situation?
20 DOCTOR THADANI:
Yes.
There is -- we'll 21 get into it again later on, at least one test that i
22 NUMARC is planning to conduct where they will have 23 bare wire on both sides basically to see what the 24 ef f ect is.
At this stage, one would expect that there 25 would be some dif ferences and they may be dependent on NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W.
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i 22 l
1 the loading in the barrier.
I suspect there would be.
2 COMMISSIONER de PLANQUE:
So, the 3
temporary answer is we really don't know the answer to 4
that question yet.
[
5 DOCTOR THADANI:
That's correct.
l 6
MR.
MIRAGLIA:
At least in terms of 7
magnitude, you expect the conservatisn there.
8 COMMISSIONER de PLANQUE:
Right.
Yes.
9 MR. MIRACLIA:
And how significant -- you j
10 know, one position that NUMARC says is that it's not 11 going to make that much of a difference.
And these 12 tests will give us some insights into that question.
4 13 COMMISSIONER de PLANQUE:
Right.
i 14 CHAIRMAN SELIN:
But the objective is to l
I i
4 15 determine both sort of a reference IcVel that is 1
16 extensible to each case and then a set of scaling 17 factors.
18 MR. TAYLOR:
That's right.
19 MR. MIRAGLIA:
That's exactly right, sir.
20 COMMISSIONER REMICK:
Two questions.
In 21 the case where tests are conducted with cables, are 22 the cables energized or not?
23 MR. WEST:
No.
24 COMMISSIONER REMICK:
The other question 25 is what's the significance of bare cable versus NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W.
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insulated cable?
2 MR. WEST: During the tests the cables are l
l 3
not energized.
They're just laid in the tray, 4
installed in the same fashion as they would be in the l
i 5
plant or in the conduit.
l l
-l 6
COMMISSIONER REMICK:
So they are a sink t
l 7
in that case.
Energized they may or may not be much l
l l
8 of a sink.
l 9
DOCTOR THADANI:
That's right, they're a l
10 sink.
l 11 MR. WEST:
They are a sink.
They're just i
l 12 at ambient temperature at the start of the test.
i j
13 There's no energy applied.
The theory behind l
14 measuring the temperature from a bare copper conductor
~
15 is you attach the thermocouple directly to that and
~
l i
16 run it on the underside of the rungs in accordance l
17 with our criteria.
That copper conductor just serves 18 as a good heat sink so that the thermocouple will read i
i 19 the temperature.
It's shown that that temperature is 20 more representative of the actual temperature within 21 the enclosure than if you taped the thermocouple, for-22 example, to a cable jacket.
23 COMMISSIONER REMICK: But if the cable was 24 jacketed, the conductor would be running at a lower j
25 temperature, right?
In other words, it would be i
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS cm2) 2:pM ASH N TON D C 2 (202) 2WM i
24 1
1 insulated from the fire source --
2 MR. WEST: Yes. The bare copper conductor 3
is just a way of trying to make the thermocouple 4
reading as efficient as possible because the cables i
5 would be whatever insulation is to be used.
6 COMMISSIONER REMICK:
But your real 7
concern is melting of the cable, the conductor, right?
l l
8 DOCTOR THADANI:
That's right.
That's 9
right.
10 MR. WEST:
Cable damage.
11 COMMISSIONER REMICK: Without insulation, 12 it's going to be running at a hotter temperature than 13 it would be if it was insulated.
Am I correct?
14 MR. WEST: But the bare copper wire is not 15 representative of the cables.
16 DOCTOR THADANI:
It's just to place 17 thermocouples.
18 MR. WEST:
It's just to make sure that --
19 it's just a wire to assure heat conduction to the 20 thermocouples.
21 DOCTOR THADANI:
Right, because of its 22 content.
23 MR. WEST:
It's just a way of attaching 24 the thermocouples inside the enclosure.
25 MR. TAYLOR:
Go ahead.
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1 MR. WEST:
Okay.
In any event, we have i
2 received and reviewed and responded in a document to l
3 all the comments that we received from the draft l
4 proposed staff criteria,- and what's left to do ie 5
complete the internal management review, show it to f
l 6
CRGR again and then provide it to the Commission for f
7 a
look-see.
We plan, hopefully, to issue that
{
I' 8
criteria through the generic letter before the end of 9
November.
10 One of the tasks that we completed in the j
i l
11 action plan was the small-scale test that we did of i
12 Thermo-Lag to give us a better understanding of the
{
13 thermal performance.
These were-done sometime ago.
t i
14 I think actually we gave you preliminary results in i
15 November when we met with you.and really events have 16 really overcome these tests.
They did show that i
1 17 there's some problems with Thermo-Lag material itself j
18 and that upgrades would probably be needed in quite a 19 few configurations.
So, unless there's any specific 20 questions on that, I'm anxious to move along.
21 There have been a couple of series of 22 plant-specific tests. Texas Utilities did a series of 23 tests for Comanche Peak Unit'2. We briefed you on the-24 results of those tests in February during the-25 licensing review and we ended up approving all of the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W.
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26 1
Comanche Peak configurations.
They use only one hour 2
barriers in that plant and they have actually i
3 installed all those barriers, completed all their 4
evaluations and all those barriers are operable.
So, 5
it may be one of the few units around that has the 6
Thermo-Lag barriers that doesn't have fire watches.
7 TVA has also completed fire tests for the 8
barriers that they plan to install in Watts Bar, 1
9 Their tests were limited to one hour conduit tests and 10 they planned to rely on the Comanche Peak Unit 2 tests 11 for their cable trays. We have those test reports in-12 house and they're under review right now. We observed 13 all these tests and we don't think there's any l
14 particular problems.
Again, they're one hour tests.
i 15 Comanche Peak recently completed another i
16 series of tests for Unit 1.
They decided to take the 17 high road and not wait for NUMARC, so to speak.
So 18 they expanded their original test program a bit to 19 test some Unit I
configurations.
These barrier 20 designs were probably not quite as substantial as the 21 Unit 2 barrier designs.
Unit 2 was going in as a new 22 installation. There were certain design features that i
23 they could incorporate that are not readily 24 retrofitted, such as internal banding which helps 25 provide support to the barrier from inside the raceway NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N W.
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I
l-27 l
l 1
and they didn't have quite as good results.
They did 2
experience some high temperatures and some burn l
i 3
throughs and as a result of this they had some visual 4
cable damage. The criteria we have allows for them to 5
evaluate that damage and see if it will have any j
i 6
effect on cable functionality.
Texas Utilities is
{
i 7
doing that now.
So, we would expect to be reviewing i
8 in the near future their cable functionality l
l 9
evaluations.
I 1
10 Okay.
If we could talk about the cable l
11 tray configuration first and then maybe move into the i
\\
I 12 NUMARC test program, it may help, explain -- help us l
l 13 describe some cf the issues we're talking about.
We 14 have hard copies.
I don't know if they'll be able to i
t 1
15 come up on the monitors.
But on the first page, this 16 shows a typical -- the first page shows a typical test 17 assembly, side view of a cable tray.
Basically the 18 dark line across the top is the test deck itself and 19 then this tray is hung from the deck and there's two 20-steel channels that serve as supports.
So you're 21 testing two radial band to straight run and then a 22 radial band. This looks like probably from the NUMARC 23 program.
24 Then what you do is you have this assembly 25 on this test deck and you lower it onto a furnace.
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28 1
Then they turn the fire on in the furnace and they 2
follow a standard time temperature' curve and burn it 3
for one or three hours, depending on the rating you're i
l 4
looking for.
l 5
(Slide) The next picture or drawing shows 6
a cable tray.
If you were to look at the first one 7
and kind of look up underneath it and it shows the 8
side rails would ten along the top and bottom there, 9
and then the rungs are shown going up and down.
The 10 cables would lay --
11 COMMISSIONER REMICK:
Not like the run of 12 a ladder then.
13 MR.
WEST:
- Well, it's very similar 14 looking, but it's different.
The cables, of course, 15 lay across the rungs. Now, some trays also have solir!
{
16 bottoms and solid tops, but the rung configuration is 17 pretty common.
18 (Slide)
The next slide just shows the 19 same thing looking from the end, and the last slide is 20 a 3-D view and that gives you a pretty good idea of 21 how the runs are.
When we talk about the cable fill, 22 it would just be laying inside this tray on the rungs.
23 Typically they're tied down with the wire ties.
24 The NUMARC -- get into the NUMARC program j
25 while we have the picture.
The NUMARC program uses i
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for their cable tray test specimens a 15 percent cable 2
fill nominal.
What that basically is would be one 3
layer of cables completely across the tray.
So, the 4
entire tray would be covered --
5 COMMISSIONER REMICK:
Volume entry 15 6
percent or load 15 percent?
7 DOCTOR THADANI:
I believe it's load 15 8
percent.
9 COMMISSIONER REMICK:
Load.
10 MR. WEST:
Any questions on the drawing 11 itself?
12 COMMISSIONER ROGERS:
Now, the Thermo-Lag 13 material now surrounds this whole --
14 MR. WEST:
Right.
After you build the 15 tray, assemble the tray, put in the cables if you're 16 going to use cables, you would install the Thermo-Lag 17 barrier around this in the same way you would using 18 the same construction techniques and installation 19 details.
20 COMMISSIONER ROGERS:
Those cables don't i
21 extend out beyond the Thermo-Lag.
In o,ther words, in 22 the ends.
23 MR. WEST: Well, the cables would run from 24 here.
They'd be chopped off up above the test deck 25 and run down and be chopped off on the other side of l
l NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W.
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30 1
the test deck.
They usually have about -- in the case 2
of Texas Utilities who chose to do -- use cables and 3
do functionality testing before and immediately after 4
the fire, they had about a 20 foot lead so they could 5
do their anchor testing or cable insulation resistance 6
testing.
The NUMARC is not doing any functionality 7
testing.
So I think theirs just chopped off up above 8
the test deck.
9 We've been working for quite some time 10 with NUMARC on the issues.
The special review team 11 completed its work in February '92 and we met with 12 NUMARC at that time and discussed the issues and 13 requested that they consider coordinating an industry 14 response to whatever came out of the special review 15 team report.
Ultimately they agreed to do that.
So, 16 we started working with them in February of 1992 and 17 about a year ago in September, October time frame, 18 1992, they submitted some proposed test programs which 19 we rejected.
Then there was a period of time where 20 they regrouped and they undertook an industry survey 21 which was quite a
significant effort.
I can 22 appreciate what they went through to try and identify 23 all the different types of raceways and Thermo-Lag 24 barriers and configurations and construction and 25 installation techniques that exist in industry.
From NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W.
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31 1
that survey they went on to develop their test 1
l 2
program.
What they did was from that survey develop l
3 some baseline barrier configurations that they wanted 4
to test.
And the first phase of the test was a series 5
of tests of baseline configurations that had been l
6 upgraded in some way.
So, they chose to test upgrades i
7 before they test pure baseline barriers.
8 They planned to do seven tests and they 9
actually did six of those and deferred one because one l
10 of the early tests, the results weren't very good and 11 the second assembly was an aluminum tray 3:ntead of l
l 12 steel, so they didn't see the point of running that l
13 test right away.
14 Of the tests they did in phase one, 15 probably only one we would agree is fully successful.
16 Now, we don't have to use the term " pass and fail,"
17 but we typically say successful or unsuccessful 18 because we do have a set of criteria and the idea is 19 that if you meet the criteria you're successful, if 20 you don't you're unsuccessful.
In some cases if 21 you're unsuccessful in one area you can compensate in 22 other areas. For example, if the temperature exceeded 23 the acceptance
- criteria, you may then go into 24 demonstration of cable functionality.
So, although 25 the test itself did not meet the criteria and was not NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N W.
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~
32 1
successful, the NRC staff position or criteria would l
2 allow you to deviate from the criteria if you could 1
3 demonstrate cable functionality.
There's several 4
examples of areas where you can deviate and still 5
justify your barrier.
1 6
COMMISSIONER de PLANQUE:
Which test 1
7 criteria now are we referring to?
l 8
MR. WEST:
What I just described is what 9
is allowed by the staff criteria.
10 MR. MIRAGLIA:
But the terms of success I 11 think Steve is using the temperature.
12 MR. WEST:
Right.
13 COMMISSIONER de PLANQUE:
Okay.
14 MR. MIRAGLIA:
If that's your question.
l l
15 COMMISSIONER de PLANQUE:
Yes.
But you l
16 were already admitting there are several draft 17 standards out there and we need to know which ones 18 we're talking about.
19 MR.
WEST:
- Well, there are several 20 initiatives. ASTM has a subcommittee who for the past 21 ten years has been workirg on a standard for fire 22 tests of raceway fire barriers.
That subcommittee is 23 now up to draft 14 of their standard and that is a 24 standard that NUMARC wants to take some credit for and 25 the staff wants to take credit also for its criteria l
l NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W.
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l 33 I
being very close to that standard.
2 COMMISSIONER de PLANQUE:
So which ones 3
are we talking about in this case, the phase I NUMARC 4
tests?
5 MR. WEST:
In phase I we're talking about l
6 the criteria that NUMARC has proposed to demonstrate 7
success or no success.
As we mentioned several times I
8 in the - briefing, there's still disagreement about j
j 9
those criteria that we're trying to work out with 10 NUMARC.
11 So, if you look at the NUMARC criteria and 12 look at their test
- results, there was one' f
13 configuration, a one hour multi-conduit configuration 14 that we would agree met their criteria and I don't 1
15 think we have any problems with that either in the --
~
i 16 in the conduit configurations they don't use cables 17 and thermocouple placement use of cables and all that 18 is not an issue.
So, we would agree with that test.
19 Based on our observations -- we haven't reviewed the 20 test report yet -- that it appears to be a successful 21 test.
22 There was one other test of a three hour,_
23 24 inch wide cable tray where the tray itself appeared 24 to meet the NUMARC criteria. We do have some problems l
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~
34 1
configurations that NUMARC has proposed and with the 2
use of cables principally because we think it's going 3
to limit the plant-specific applicability of the test 4
results.
So that one we could say the cable tray met 5
the NUMARC criteria, but we have problems with the 6
criteria.
7 Okay.
We met with NUMARC recently.
They 8
went over these test results with us and discussed 9
also some of their plans for phase II.
They have 10 another phase of tests planned.
This will be eleven 11 tests and in this series they're planning to test some 12 other upgrade techniques and also test some baseline 13 barriers.
In other words, a barrier that they think 14 is installed in the plant, they want to test it and 15 see how it performs without any upgrades, j
16 Probably -- I guess the most disappointing l
17 aspect of phase I is the performance of three hour 18 barriers.
None of them really performed that well.
19 They were all upgraded significantly from what the 20 vendor would recommend for a three hour barrier.
21 In some cases, they took like a three hour 22 barrier, built it the way the vendor says with some 23 conservatisms in the direction of not being 24 substantial and then they actually enclosed it in like 25 an upgraded one hour barrier and they still had NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W.
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l 35 l
1 problems with burn-throughs and openings and high 2
temperatures and hose stream damage, even with the 3
lesser fog nozzle hose stream.
So I think the staff 4
and NUMARC and probably industry are a little bit 5
concerned about the three hour barriers.
6 CHAIRMAN SELIN: They all exceeded the one 7
hour time period in this three hour barrier?
8 MR. WEST:
The three hour barrier would 9
last for one hour.
10 CHAIRMAN SELIN:
How feasible or
)
11 infeasible is it to have sprinkler systems or other 12 fire suppression systems in these plants where --
13 MR. WEST:
Where there are none now?
It i
14 would depend on the plant area.
I would imagine in 15 some areas you could do it.
In some it would be more 16 difficult.
i 17 I think the problem may be, if you take a 18 plant like River Bend or WNP 2 where they use three 19 hour2.199074e-4 days <br />0.00528 hours <br />3.141534e-5 weeks <br />7.2295e-6 months <br /> barriers extensively throughout the plant, you'd 20 be talking about significant expense and probably l
l 21 operational problems to retrofit sprinklers in those l
22 areas.
In some areas it may be very easy if you have 23 a pump cubicle or something where you had a conduit 24 running through it.
25 Okay.
I'll just go on to describe the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N W.
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E
~... -.
36 1
rest of the NUMARC program and then I'll get-back to 2
the disagreements between the staff and NUMARC on 3
their program.
4 During the meeting we had earlier this 5
month with NUMARC, they advised us that they are going 6
to conduct a second industry survey to get additional 7
information on in-plant configurations and raceway and 8
they're going to use that to help them finalize phase 9
2.
And they also mentioned that as a result of the 10 performance of the phase 1
assemblies they're 11 considering a phase 3,
which would be additional i
12 testing.
13 They're also looking at upgrades. All the 14 upgrades we've seen to date have been taking a Thermo-15 Lag barrier and adding more Thermo-Lag or more TSI 16 products to it.
They're now considering upgrades 17 where you would take an existing Thermo-Lag barrier 18 and maybe put some other fire barrier over it, cable i
1 19 or what-have-you.
Again, I don't want to speak for 20 NUMARC on this.
They haven't given us any definite 21 ideas or proposals, but they mentioned it's something 22 they're looking at.
23 When NUMARC has completed their test 24 program they plan to develop -- actually it's under 25 development now, but they'll issue to industry a test NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W.
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l
I 37 1
application guide.
That's the guidance that an
~
f 2
individual licensee would use to evaluate the test 3
results and make judgments as to what would apply to j
i 4
its plant configuration, the plant conditions, and i
I 5
decide whether or not it could use a particular test l
6 to either declare an in-plant barrier operable based 7
on its current configuration or whether upgrades were 8
needed. The application guide will use both the tests 9
actually sponsored and conducted by NUMARC under this 10 program and any other. tests that they can identify 11 that maybe have generic or. industry applicability like 12 the Comanche Peak or Watts Bar tests.
13 I would like to mention just quickly too 14 that NUMARC has submitted a methodology for evaluating 15 the combustibility hazard in-plant and we got that a 16 couple of weeks ago and we'll be reviewirq that also.
17 CHAIRMAN SELIN: Before you go on, why are l
18 they being so stubborn about -- you know, basically 19 anything they do has got to pass muster with us, so, 20 if you just take a look at it from a cynical point of 21 view as opposed to a scientific point of' view, it 22 really doesn't make sense for them to run some tests 23 that we're not happy with because no matter how 24 effective they might be to a third party they would 25 have indications that they would have trouble passing NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS I
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.w--.
1 a--r w ur y
38 1
the staff review.
That's about the most' agnostic way 2
I can put it.
3 So, why are they being so stubborn about 4
not trying to accommodate what the staff wants?
5 MR. TAYLOR:
I'll turn to my colleagues.
6 I find it not quite fathomable personally, but I'll 7
ask Steve or Ashok.
l 8
DOCTOR THADANI:
I can't answer that 9
question.
10 MR. MIRAGLIA:
I think the best answer, 11 Mr. Chairman, would be to examine the responses to the 12 inquiries of the staff Mr. Taylor has sent to NUMARC.
i 13 I think there is an honest technical disagreement in
'1 14 that they don't see the bare thermocouple wire and the
]
15 placement as being a significant issue. They may have
~
16 some views that the 15 percent is representative of a l
17 large number of configurations out there.
)
18 CHAIRMAN SELIN:
I stipulate all that.
19 Let's say that they have world class talent in this 1
20 area and all this talent comes in and tells them that 21 they're right and the staff is being foolish and 22 silly, et cetera, but they still have to pass the same 23 staff.
I mean, in a sense, yours are the court l
24 appointed tests.
So if they can't talk you out of 25 these tests or resort.to some third party, they're NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W.
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39 1
going to eventually have to come pass.
2 I mean, is it so much more expensive to 3
run the tests the way the staff wants them run or is 4
it --
5 DOCTOR THADANI:
No, no.
6 MR. TAYLOR:
It's not cost.
7 CHAIRMAN SELIN:
Is there some threshold 8
that says that these differences in where you put the 9
thermocouples will have a
huge difference in
{
10 performance?
I mean, is it likely that they'll be 11 satisfactory with one thermocouple replacement and not 12 another one?
13 MR.
MIRAGLIA:
I think any test that 14 proves acceptability of performance would be a useful 15 test and the concern would be what's the generic j
j 16 applicability of it.
l l
17 DOCTOR THADANI:
If I can just -- just the 18 narrow
- issue, and I
think the placement of 19 thermocouple is a narrow issue in itself, but there's 20 a broader issue of applicability of NUMARC testing l
21 program because there are other variables which may be 22 much more important when one goes to apply these 23 things.
But as to this narrow issue is concerned, I i
l 24 did at the last meeting we had with NUMARC about 25 October 18th, I believe, I asked exactly the question l
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that you're asking us.
2 The response I got was, "Well, this is l
3 just adding an additional conservatism and we don't 4
want to do it, basically.
We will do one test just to 5
see what it means."
I just can't tell you any more.
6 That's the best understanding I have.
7 COMMISSIONER de PLANQUE:
But there's no 8
data out there on any of these kinds of tests that 9
would indicate what degree of conservatism this is?
10 Nobody's done a test with the thermocouple inside and i
11 the --
12 MR. MIRAGLIA:
They've moved forward on 13 that point, Commissioner de Plangue, in that they've 14 agreed to run one or two tests with the bare copper 15 wire to get a feel for it.
16 COMMISSIONER de PLANQUE: But all the work 17 in developing the ASTM standard, isn't there any i
18 information that can even suggest what magnitude we're 19 talking about here?
i 20 MR. MIRAGLIA:
As I understand it, Steve, 21 and you can correct me, the standard would say no 22 cable on cold side.
23 MR. WEST:
Right.
24 COMMISSIONER de PLANQUE:
Yes, but there 25 must have been work that went into the basis for that.
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MR. WEST:
Well, there's a fundamental 2
disagreement between the staff and NUMARC.
3 The staf f 's criteria has always been, ever I
4 since we specified fire barriers to meet our 5
requirements, to measure the -- during these tests to 6
measure the temperature on the cold side of the 7
barrier off the cold side surface.
That's why our 8
criteria specifies the location of the thermocouples 9
underneath the cable rungs.
10 NUMARC is saying, "You're asking us to 11 measure temperature in an area where a cable cannot be 12 located and that's a flawed methodology."
13 COMMISSIONER de PLANQUE:
I fully l
14 understand these distinctions, but what I'm asking 15 for -- when people get together and they develop a 16 standard there's usually scientific research data 17 that's brought to bear on how you set up a criteria.
18 Is there no evidence out there anywhere that tells you 19 what the difference is going to be, measurably?
20 MR. WEST:
There have not been any tests 21 or experiments to give you the number you're looking 22 for.
23 COMMISSIONER de PLANQUE: Or not even a --
24 MR. WEST:
There's plenty of qualitative 25 arguments that will tell you that, if you take a NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE N W.
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42 1
thermocouple in the location the staff recommends j
2 underneath the rungs and you move it to the location i
3 NUMARC is using up in the cable bundle, you're going 4
to see differences in temperature.
5 COMMISSIONER de PLANQUE: Right. Logical.
6 MR. WEST:
Now what our criteria says is 7
that, if you do it the way the staf f specifies and you 8
meet the temperaturized criteria, you're home free.
9 You don't have to do anything else.
You're okay.
10 COMMISSIONER de PLANQUE:
But we're back 11 to the Chairman's argument.
Why is there a big 12 resistance to the --
13 MR. WEST:
I don't know why there's a big 14 resistance.
You'll have to ask NUMARC that.
15 CHAIRMAN SELIN:
My question is not an 16 academic question and it doesn't stop there. What I'm 17 really getting down to is it appears from this 18 presentation, and I think we should invite NUMARC in 19 very quickly to make their presentation, but it 20 appears to me that there's a course of action going on 1
21 that is not converging at a solution to the problem.
22 The fire watch, this whole set of points, was based on 23 the assumption that within a reasonable amount of 24 time, and that reasonable amount of time is pretty 25 long already, that we would get to some answers.
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l 1
None of t.s is very comfortable with the 2
At least, I'm not very comfortable with 3
the fire watch.
Apart from the expense that the j
4 plants have and the temptation to short-cut it, people 5
walking back and forth are not as reliable as some 6
technical solutions.
7 If now the Commission is faced with the j
8 prospect that either it will take longer or we can't
)
I 9
even put a time on when this will be converged, I 10 think we have to consider a different course of 11 action.
So what I'm really asking you is are we to 12 the point where you have significantly less confidence 13 than you did when you came in with the original plan 14 that there's an industry course of action that will 15 lead to a resolution of these problems within a 16 reasonable amount of time one way or another or do we 17 have to -- do you have to consider and do we have to 18 review a quite different course of action from the one 19 upon which we are currently embarked?
20 DOCTOR THADANI:
One is a clear case.
l l
21 That is, the whole process has certainly been delayed 22 by at least, I would say, a period of about eight l
23 months because of delays in testing..
l i
24 CHAIRMAN SELIN:
That's where we stand 25 today with the original approach?
l NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N.W.
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44 1
DOCTOR THADANI:
Exactly.
2 CHAIRMAN SELIN:
That's kind of a
3 baseline, the thermocouple on the cold side of the 4
debate, so to speak?
5 DOCTOR THADANI:
No, no.
Last November, 6
if you recall, when we went through the whole issue 7
and we said we've developed this action plan and this 8
action plan is based on completion of various 9
activities by date X and so on, we had hoped that the 10 generic testing would be ccmpleted earlier this year.
11 MR. MIRAGLIA:
By the end of this year.
12 DOCTOR THADANI:
And now we 're already 13 seeing that's not happening and it's not going to 14 happen, assuming that the course we're on is in fact 15 an appropriate course of action, so there's number 16 one.
i 17 CHAIRMAN SELIN:
So we have a translation 18 of eight months?
19 DOCTOR THADANI:
Eight months as a
20 minimum.
21 The second issue is this applicability 22 issue.
We want to meet with them and NUMARC has 23 agreed to meet with us and discuss this guide that 24 would be the technical basis for how to apply the 25 generic data to plant specific configurations and we NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS
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45 I
hope that that would proceed as we expect.
2 So the only then issue remaining, i
3 technical issue remaining that we know of today, is 4
the placement of thermocouple. And as Mr. Taylor said 5
earlier, we have elevated the importance of this whole
{
6 matter.
We are expecting to meet with NUMARC in the 1
7 next few weeks before the construction of the phase 2 8
assemblies is completed.
If this issue does not get 9
resolved, then clearly we --
{
10 CHAIRMAN SELIN:
We're in deep trouble.
11 DOCTOR THADANI:
-- we have a problem.
12 CHAIRMAN SELIN: We have not only an eight 13 month delay, but we have a course of action.
14 Now let's get on to a third point.
If 15 there isn't the information that Commissioner de 16 Planque has so patiently but persistently asked for, 17 what would you do if you had the information that 18 we're talking about?
You wouldn't have the gradings 19 to say how do you extrapolate from a base case, 20 conservative or not, to specific installations with 21 specific configurations.
Or is it expected that this 22 set of tests will also produce the gradients as well 23 as the base information?
24 MR.
MIRAGLIA:
As we understand the 25 proposal for the next phase, they're going to run some NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W.
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46 i
I 1
tests with the bare copper vire that would at least i
2 give some dimension to the conservatism with respect I
i 3
to that.
4 CHAIRMAN SELIN:
- Well, it's not just J
5 conservatism.
Let me make it clear.
" Conservatism"
.j i
6 makes it sound like'it's a pass-fail test.
I don't l
?
7 much care if the base information is with thermocouple 8
one place or a second place if they're equally l
I 9
invariant.
i 1
10 The real question is, no configuration is
[
I j
11 going to be exactly the same. as the reference i
4, 12 configuration and therefore, even if you and NUMARC-13 agreed on what the reference configuration would be, I
l t
14 you need the factors.to say how do you extrapolate l
15 from the reference configuration to any --
i 16 MR. MIRAGLIA:
That's right.
17 CHAIRMAN SELIN:
And I understand Mr.
18 West's answer to say we don't have those factors 19 today.
I mean, if we don't know the degree of 1
20 conservatism, then we don't know the difference 21 between a temperature. measurement at the cold side 4
l 22 and --
l
}
23 MR. MIRAGLIA:
That's true in part in 1
1 24 terms of broadness, to make the test as broadly 25 applicable, but, if one supposes that they run tests NEAL R. GROSS I
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47 1
with thermocouple placement, with loading, and they're 2
" successful," that at least would set a datum as to if 3
you have configurations that you can demonstrate are i
4 reasonable configured like this.
We have an answer 5
then for a percentage of the configuration out there.
l 6
CHAIRMAN SELIN:
That's only one point on 7
a continuum, Frank.
8 MR. MIRAGLIA:
That's right.
9 CHAIRMAN SELIN: I mean, the basic concept 10 of having a test case is that you then know you have 1
11 quantitative f actors, not just polarities, on how you 12 extrapolate to dozens and dozens of different physical 13 configurations.
14 COMMISSIONER de PLANQUE:
But the dilemma 15 is this.
There's one situation that obviously sounds 16 like it's easier to extrapolate to more situations and 17 that's putting it on the cold side.
But if that is --
18 let's be ridiculous and say ten times more 19 conservative than doing it in a realistic situation, 20 you need to know that, and then maybe the criteria are 21 unrealistic if you're doing your test that way.
It 22 seems to me that's --
23 DOCTOR THADANI:
I think we're in total 24 agreement on that, absolutely.
25 COMMISSIONER de PLANQUE:
But nobody has NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W.
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48 1
the answer to that yet.
2 DOCTOR THADANI:
And if we had a plant 3
specific configuration, plant specific information on 4
the
- loading, the types of
- cables, the type of 5
insulation material, et
- cetera, we had all the 6
information on thickness, geometry and all of that, it 7
would certainly be a
lot easier to understand 8
placement of thermocouple as an example.
9 COMMISSIONER de PLANQUE: But that scaling 10 or that extrapolation is a problem no matter what you 11 use as your reference case.
12 DOCTOR THADANI:
That's true.
13 COMMISSIONER de PLANQUE:
One may make it 14 easier, but it's still a problem.
15 DOCTOR THADANI:
Yes, it is.
16 COMMISSIONER de PLANQUE:
The range of 17 configurations that you have out there in the plants.
18 DOCTOR THADANI:
It's still an issue with 19 a number of variables.
This is just one, clearly.
20 CHAIRMAN SELIN: Commissioner de Planque's 21 point, in the taxonomy I gave you, is actually a third l
22 point which is the reference case is too far from the 23 center of gravity.
The real case is then it wouldn't
. l 24 even be a very good reference and without being able 25 to measure that -- but, even if one grants that these NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N W-l (202) 2344433 WASHINGTON, D.C. 20005 (202) 2344433 l
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l i
i 49 t
i 1
are small differences that ycu're talking about, you 2
still need both of these sets.
I l
1 3
Now what do actual licensees do?
Don't t
b 4
they come in with a specific analysis that goes beyond 5
just the measurements? You know, "We had better cable l
6 than you had in mind.
It's less combustible," or "We 7
have a lower probability that there.'d be a fire."
I 8
mean, don't they come in with a specific configuration 9
and argue on specific grounds that it's safe from a l
l 1
1 o
10 fire --
i l
\\
l 11 MR. WEST:
If we could go back, you had 1
l 12 mentioned this earlier about the testing - without 1
(
13 cables.
If you test a configuration and you do not 14 use cables and you measure the temperature from the 15 unexposed side and it is below the temperature rise l
16 cut-off for success or nonsuccess --
17 CHAIRMAN SELIN:
You're finished.
j 18 MR. WEST:
-- you're finished..
19 CHAIRMAN SELIN:
But that's just a
l 20 surrogate.
21 l
MR. WEST:
And what cables you have is 22 immaterial.
You don't even have to consider it any 23 further.
So the problem comes in where you're going 24 to get into these analyses, is when the 80 units come 25 in with 250 types of cables and try and use the data NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W.
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4 50 1
that was generated using the cable NUMARC has used and
,1 2
equate that to their in plant configuration and it's 3
not clear how that is going to work.
These are l
1 4
questions we 've asked N1' MARC. How is that temperature 5
profile that you generate during the test, even if 6
it's successful, how is that going to apply to another 7
plant configuration or somebody else's configuration?
8 So the conservatism we're looking for is 9
not so much, you know, are you this good or this good 10 if you use cables or do not use cables.
It's how do 1
]
11 you apply the data from one test to 80 plants.
12 CHAIRMAN SELIN:
That's fine, except if
- 1. 3 the material can't pass those tests.
I meari, the idea 14 of having a surrogate which is conservative enough to 1
15 say if you pass the first test you don't have to go to l
16 the second or third, that's very attractive.
But if 17 it's so conservative or if the material is so 18 defective, either way -- let me go on, if I might, to 19 another related -- we've been arguing about rather 20 esoteric questions of standards and tests.
Now what 21 do we find out about the material itself, as opposed 22 to the fact that it doesn't pass some specific tests?
23 Does it burn?
Does it not bond when you add more i
24 Thermo-Lag to existing Thermo-Lag?
25 MR. MIRAGLI A:
I think what we have now is NEAL R. GROSS court REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N W.
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51 1
a range of real test data now, Mr. Chairman, that 2
indicates that the performance of this material is 3
very configuration dependent.
It's very subject to 4
how it's installed, the quality of installation, and 5
it has been demonstrated in some cases to be able to 6
perform, but the performance at that level is at a 7
significantly higher enhancement than exists at plants 8
today.
So, as is it would not be expected to perform 9
at the one hour --
10 CHAIRMAN SELIN: With all due respect, Mr.
I 11 Miraglia, that's a pretty mushy answer.
I mean, what 12 do we know?
I mean, do we find where you double up 13 the thickness of Thermo-Lag and it doesn't do much 14 good --
15 MR. WEST: The Texas Utilities and the TVA 16 tests of one hour barriers have shown that the 17 material can be upgraded to work.
Like I said during 18 the discussion of the NUMARC --
19 CHAIRMAN SELIN:
That's Comanche Peak 2, 20 right?
21 MR. WEST:
Yes, sir.
22 CHAIRMAN SELIN:
But they didn't just --
23 as I understood, they didn't just stick in the 24 material.
They went in and they bound the --
25 MR. WEST:
No, that's with upgrades.
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the upgrades for the one hour barrier appear to be 2
workable.
Like I said, f or the unit 1 tests that they 3
did they backed off a little bit from the unit 2 4
upgrades and the results weren't quite as good, but 5
even that showed us that there is some cutting edge 6
where you can probably achieve success.
7 The NUMARC tests for the three hour l
8
- barriers, as I
mentioned, were much more 9
disappoir. ting. Regrettably, the results were not that 10 good.
11 CHAIRMAN SELIN:
Comanche Peak 1 and 2,
12 both one hour, did they have fire suppression --
13 MR. MIRAGLIA:
They were all one hour 14 barriers, sir.
15 DOCTOR THADANI:
They were one hour j
16 barriers, right.
17 CHAIRMAN SELIN:
So they don't illuminate 18 the three hour problem.
19 MR. WEST:
No, and TVA as well. The first j
20 three hour tests that we've seen since the problems 21 have been identified and reviewed by the staff in i
22 detail have been the three hour tests conducted by 23 NUMARC in the last couple of months.
As I've said, 24 they've been disappointing because they've been 25 significant upgrades and the results have not been NEAL R. GROSS CoVRT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W.
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that good.
2 The one 24 inch wide tray, three hour, was 3
not too bad.
But again, it was upgrade.
I think what 4
that shows is that we've been calling the three hour 5
barriers indeterminant, but probably they're just --
6 a three hour barrier installed the way the vendor 7
recommends today in a plant probably won't last three 8
hours.
9 CHAIRMAN SELIN: Extrapolating, given that 10 you've had these upgrades to the point that you have 11 serious doubts that brute force upgrading will meet --
12 even with brute force upgrading, they'll still be 13 unable to meet -- I'm sorry, triple negative.
Will 14 they still be unable to meet the three hour barrier 15 even with serious upgrades -- I mean, the three hour 16 standard?
17 DOCTOR THADANI:
Given the information we 18 have today, that's the way it looks.
19 MR. TAYLOR: That may say that where three 20 hour2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br /> barriers are necessary they're going to have to 21 go back and potentially put in suppression --
22 DOCTOR THADANI:
Spray or some kind of --
23 CHAIRMAN SELIN:
Which means it wouldn't 24 require three hour barriers.
25 MR. TAYLOR:
That would be yes, and NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W.
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54 1
that -- or another --
2 MR. WEST: That's one reason other options 3
using other fire barrier materials are being explored.
4 CHAIRMAN SELIN:
May I continue in this 5
line?
i 6
COMMISSIONER REMICK:
Sure.
Oh, sure.
l 7
CHAIRMAN SELIN:
Okay.
Let's go a step 8
further.
I don't want this problem with NUMARC to 9
obscure what seems to me to be a much more fundamental i
10 problem, which is at this point we really have no 11 confidence that this brute force approach, at least in 12 three hour barriers, is going to lead to solutions.
13 We also have an untenable situation out there.
We 14 have 70 some power plants that are operating in a 15 fashion that is acceptable at the most for temporary 16 course of action.
What alternatives are available?
1 17 Are we going to have to require more detailed case by 18 case analyses?
Are we going to end up, as Mr. Taylor 19 suggests, saying that people have to put in fire 20 suppression systems if they don't have them where 21 separation is called for?
Are we going to set some 22 kind of time deadline and say, "Here's a set of 23 options to choose from, but you've got to do some of 24 them within a given amount of time."
25 This is just very serious situation. Here NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N.W.
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55 1
we are years some af ter we started paying attention to 2
it and we're really no closer to a solution, at least 3
for the three hour situation, than we perceived that 4
we were when we started, to be fair about it, or am I i
5 over -- please, if I'm overstating the case, this is 6
the time to tell me this.
j 7
MR. MIRAGLIA:
Well, there has been the 8
concern from the very outset of this and relative that 9
we've tried to put the safety significance into 10 context and we're saying the compensatory measures 11 that buys us time to consider those.
The options that 12 you have articulated, Mr. Chairman, are all potential 23 options.
These tests we're hopefully going to 14 illuminate, put further illumination on those issues.
15 The next phase would provide that kind of information 16 for us to make that judgment.
17 The three hour tests have not performed.
4 18 They've been on the range of two hours plus.
)
i 19 CHAIRMAN SELIN:
Let me put the question 1
20 a little more even if you settle tomorrow with 21 NUMARC all these questions about degree of cable and 22 thermocouples and stuff, we're still very, very far 23 from a solution on the three heur answers.
Is that 24 right?
25 DOCTOR THADANI:
The current information NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W.
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says exactly that.
They are planning --
2 MR. TAYLOR:
I think it's appropriate to 9
3 look and I
don't have the answer here today.
4 Typically in a plant a one hour barrier is much more 5
widespread than a three hour barrier --
6 MR. MIRAGLIA:
Yes.
Yes.
7 MR. TAYLOR:
-- because you get the other 8
factors of Appendix R, separation, fire loading and so 9
forth.
Is that not correct?
10 MR. MIRAGLIA:
That's correct.
11 DOCTOR THADANI:
Yes.
12 MR. TAYLOR:
So, I can't look you in the 13 eye and tell you it's 80 percent one hour in a plant 14 and 20 percent three hour in a plant.
If you go 15 through the plant, you will find the one hour barrier 16 with a much wider application.
Where the spacial i
17 separation of the redundiunt cabling and control cables i
18 is not very good and where the fire loading is higher 19 you hit the need for a three hour barrier.
But it is 20 a much more defined population.
21 CHAIRMAN SELIN:
Let me follow up on the 22 implication of that.
The issue is not really what's 23 the characteristic of Thermo-Lag, the question is what 24 do we do for fire separation protection in the power 25 plants.
Therefore, it seems to me that you might s
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consider a branch course of action, one that follows 2
along where we're going towards the places where the 3
one hour barrier is deemed to be adequate because we 4
all seem to believe we're in the ballpark there.
I 5
wouldn't say we're quibbling, but we're getting --
6 MR. TAYLOR:
Getting closer.
7 CHAIRMAN SELIN:
Getting closer.
You're 8
down to how much more buttressing is necessary to meet 9
the span and how do you measure it.
On the three hour 10 barrier -- and one thing I'm sure you'll provide very 11 quickly is really some -- how much of the problem is 12 one hour and how much is three hour.
There, even if 13 you had a complete settlement with NUMARC tomorrow, 14 the results to date don't give any confidence that the j
15 approach being followed will, in fact, produce a 1
16 solution, namely better installation and more stuff.
17 There you might seriously consider that it's time to 1
18 look at another -- at least an additional course of I
19 action like suppression or like mandatory rerouting or l
20 something short of just saying, "We will go on however i
I 21 long it takes until we find out how much Thermo-Lag it 22 takes and so on.
I l,
23 MR.
MIRAGLIA:
And as Mr.
Taylor has 24 pointed out, there are other considerations with l
25 respect to suppression and things of that nature.
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58 l
1 think we could also go back and look. My recollection l
2 would seem to say that even where they had less than 3
three hours without barriers, the rule, Appendix R, 4
allowed for a deviation to an exemption process and we 5
may have even approved --
6 CHAIRMAN SELIN:
Upon meeting some very 7
good criteria.
8 MR. TAYLOR:
Yes.
9 MR. MIRAGLIA: Yes, sir, and we 'll look --
l l
10 CHAIRMAN SELIN: It doesn't say, "Well, if 11 you can't do three hours, how about two and a half?"
12 MR. MIRAGLIA:
That's exactly right.
It 13 has to be looked at and evaluated in each case to rule l
14 out for that and there may be some situations out like l
15 that and we could look for those.
l 16 DOCTOR THADANI:
You need technical --
17 MR. MIRAGLIA:
So there is a range of 18 options on how to deal with the issue.
19 MR. WEST:
I'd like to, just so it doesn't 20 look like all bad news with three hour barriers, point 21 out that the baseline three hour barriers that NUMARC 22 started with before they upgraded it were very 23 conservative in the direction of -- I mean weakness.
l i
l 24 They used the dry fitting methods where the trowel 25 grade didn't seal the joints completely. They ran the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W.
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ribs the opposite way of what the vendor recommends, 2
which doesn't give you the structural stability.
3 There may be three hour barriers out there that if l
4 they were more robust and upgraded in the same fashion 5
would, in fact, pass.
So, we don't really have that 6
information yet.
l 7
In fairness to NUMARC arid what they're l
8 doing, I think it should be pointed out that the i
l 9
baseline barriers were very weak.
1 l
10 DOCTOR THADANI:
The important element is j
11 that's the information we have today, but NUMARC, as 12 I understand, we haven't seen the scope of their 13 planned testing for phase II.
But I believe they j
14 would be -- with some changes would be doing some 15 additional testing in the phase II to see if there 16 aren't ways one can deal with the three hour issue.
l 17 But we don't have the information yet to be able to 18 tell you exactly what they planned to do.
19 CHAIRMAN SELIN: Commissioner, do you have 20 comments before we go on to the more broad fire 21 protection test --
22 Mr. Taylor?
23 MR.
TAYLOR:
- Steve, do you want to 24 continue?
25 MR. WEST:
Yes.
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i 60 1
We had a slide 10 on the schedule for the 2
Thermo-Lag and we kind of touched on all the points 3
that are going to result in what we think will be a 4
delay from the date we gave you in November of -- May 5
of 1985 for total completion.
There have been some 6
slippages and we're estimating now it could be eight 7
months to a year longer if things continue along this 8
path and assuming things go well.
9 COMMISSIONER ROGERS:
I did have a
10 question I probably should have brought up.
On the 11 inspection -- the TI inspection document.
12 MR. WEST:
Yes, sir.
13 COMMISSIONER ROGERS:
Where do you stand 14 on that? That's supposed to be done about now in this 15 quarter, issued for comments.
Has that been issued 16 now yet?
17 MR. WEST:
That temporary instruction has 18 been through several draft stages and we have given it 19 to -- it hasn't been widely circulated for comment, 20 but we are giving it to Region IV to use for a pilot 21 inspection at Comanche Peak Unit 1 since they will be 22 the first plant to actually complete their upgrades.
23 From the lessons learned of that inspection, we would 24 probably revise it again and then circulate it for 25 comment.
Because of the delays in the overall NEAL R. GROSS COURT HEPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W (202) 234-6433 WASHINGTON, D C. 20005 (202) 234-4433
61 1
schedule, getting the TI completed and issued is not 2
considered to be a critical path item right now, 3
although there may be some plants that don't have 4
extensive amounts of Thermo-Lag, say they just have 5
one hour conduits where there are probably upgrades 6
readily available.
7 COMMISSIONER ROGERS:
Well, it may not be l
8 a critical path item for wrapping up the Thermo-Lag l
l 9
question, but it does seem to me it's an important 10 document to have out there for guidance, isn't it?
11 MR. WEST: No question about that. That's 12 why we are -- that's why we've drafted it and given it 13 to Region IV.
We would expect that inspection to 14 result in a final document from the lessons learned.
15 COMMISSIONER ROGERS:
I see from your 16 GANTT chart that you expect to have a workshop after 17 you've issued the final TI.
I'm just a little puzzled 1
18 by that.
Why a workshop after you've issued the final 19 TI?
Why not before you issue the final TI?
20 MR. MIRAGLIA:
It's very similar to the l
21 question and comment and interaction since it is a 22 staf f ef fort and it's a verification, the staff would 23 like to develop a criteria, have a position on it and l
24 then interact outside and get comments.
Inspection 1
25 and that kind of decision making, we feel, should rest NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N.W.
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with us to develop that criteria and put that out 2
there.
If there are concerns and comments that come 3
with that, we can deal with it.
't's very similar to 4
what we've done with the maintenance inspection and 5
it's that same approach that we're intending to use 6
here.
7 MR. WEST:
If I could expand on that just 8
briefly, the real expertise in these fire barriers 9
rests within Headquarters here. What we have planned, 10 what our intention was with the workshops was to take 11 the Headquarter's employees out to the regions or have 12 the regions come in here and really do a data dump on 13 them and bring them up to speed to where they can l
14 conduct these inspections.
So, we'd want pretty much t
15 a final TI set up.
I'm not saying there may not be 16 some fine tuning if we got some good comments out of 17 the workshop, but really the idea is to pass the 18 information along to the people that are good 19 inspectors but don't have the expertise.
1
)
l 20 COMMISSIONER ROGERS:
Okay.
I guess I 21 just didn't understand what the purpose of the l
22 workshop was.
I see.
It's really how to apply it.
23 MR. WEST:
Right.
It would be for the NRC 24 staf f that will actually be performing the inspection.
l 25 COMMISSIONER ROGERS:
All right.
Fine.
I l
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DOCTOR THADANI:
And part of the process 2
does call for comments during the development, 3
comments from each of the regions.
4 COMMISSIONER ROGERS:
Yes, I saw that.
I 5
just didn't understand what the purpose of the 6
workshop was.
Please go ahead, Steve.
7 MR. WEST:
Okay.
So, that's all I wanted 8
to say about the Thermo-Lag action. We can move along 9
to the fire protection task action plan.
10 As the Chairman mentioned, we did develop 11 an action plan to implement the recommendations that 12 came out of NRR's reassessment of the reactor fire j
13 protection program.
It's an extensive and 14 comprehensive action plan.
We recently gave you the second -- I guess the first update of the action plan.
15 i
16 Basically the action plan is broken up along the lines 17 of the reassessment report where the reassessment 3
18 report had recommendations for action.
In other 19 words, things that we should be looking at near-term.
20 Then there were also some recommendations for further 21 consideration and then some confirmatory issues.
So 22 the action plan itself is split along those lines.
23 (Slide)
We wanted to talk today about 24 some of the recommendations for action.
Slide number 25 12 lists all of those recommendations and I don't want 4
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i 64 1
to necessarily go through the list one by one today.
l I
2 There are some I want to focus on in the next slides.
l 3
COMMISSIONER ROGERS:
Are you going to 4
talk about the fire barriers other than Thermo-Lag?
5 MR. WEST:
Yes, sir.
6 (Slide)
So, slide 13.
l 7
One of the recommendations, just briefly, l
G was that NRR management should look at the resources 9
they've placed on the Thermo-Lag action plan and the 10 fire protection issues in general and ensure that 11 adequate resources are being applied.
That has been 12 completed.
One of the actions that we've taken in 13 response to the recommendation was to add another I
14 senior fire protection engineering staffer to NRR and 15 we're very close to filling that position.
So, that 16 recommendation has been completed.
17 Another one that involved the ccoperation 18 of NUMARC, and I'd like to say they were very prompt 19 and efficient in their response, was to review the 20 fire-induced vulnerability evaluation methodology 21 that's commonly referred to as the five methodology.
22 That's a screening technique for evaluating fire event 23 sequences and it's the methodology that most of the 24 plants are using for their IPEEE reviews and 25 submittals.
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65 1
There was a weakness identified in that 2
methodology.
We pointed that out to NUMARC and they 3
worked through EPRI to clarify that very promptly.
l 4
So, that's been completed.
5 The other recommendation that we've been l
l 6
expending significant effort on since the -- actually 7
we started before the FP-TAP, as we call it, is a 8
review of other fire barrier materials.
We've done a 9
couple of things.
We have done similar testing of 10 these materials at the National Institute of Standards 11 and Technology as we did with Thermo-Lag.
In other i
12 words, small scale scoping tests to help us understand 13 something about the thermal properties and the fire 14 resistant performance of these materials.
1 15 So, we've tested all of these and we don't 16 see anything that's caused great alarm.
Thermally 17 they appear to perform fairly well.
One of the 18 materials, if you look at just the temperature rise 19 across the cold side of the material, if you look at 20 the raw test data, it looks kind of high.
It doesn't 21 look successful in terms of looking at the criteria.
22 But the system itself has built into it, if you were 23 to install it on a raceway, an air gap, a frame you 24 build around it and then this material which results 25 in an air gap, which is an integral part of the system NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W.
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66 1
itself which we could not model in the tests we were 2
doing.
So, that's kind of an anomaly we're looking 3
at.
1 4
But all the other materials in terms of 5
just our thermal performance, nothing of great alarm 6
came out of it.
I'll just point out that these are 7
the fairly severe tests because it's just a the 8
pure material itself subjected to the standard time 9
temperature fire.
There's no raceway, so there's no 10 thermal enhancement that would be normally provided in 11 full-scale tests.
There's also pads between -- the 12 thermocouple is attached between the material and a 13 pad, which is a heat sink.
So, you probably see a 14 higher temperature there than you would in a full-15 scale test.
On the other hand, it's not enclosed.
l 16 It's open to free air.
So, there are tradeoffs.
17 COMMISSIONER ROGERS:
- Now, those 18 materials, does that include Flamastic?
Is that one 19 of the materials?
20 MR.
WEST:
No, it doesn't include 21 Flamastic.
Flamastic is usually -- is a mastic that's l
22 sprayed or troweled onto cables directly.
We haven't 23 looked at that.
It's not really considered within the 24 scope of the fire barrier problem.
It's an entirely 25 different material.
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.-,.m--
, - -. - ~ J
67 1
CHAIRMAN SELIN:
Is it possible to -- I 2
mean if somebody had a Thermo-Lag installation and 3
weren't up to snuff and were faced with quite a large 4
- cost, is it possible to use one of these other 5
materials for the enhancement or do you pretty much i
6 have to stick to --
7 MR.
WEST:
There are some independent i
8 efforts underway by some of the other fire barrier i
9 vendors to use their products as an upgrade of Thermo-l 10 Lag barrier.
A couple have come in and talked to us 11 informally and I believe some are talking with NUMARC.
12 Like I said, NUMARC is planning in phase II possibly 13 testing some of those.
It seems feasible to the staf f 14 that that may be an approach.
15 CHAIRMAN SELIN:
I'm sorry.
Thank you.
16 MR.
WEST:
Okay.
Based on our early 17 reviews of some of the other fire barrier materials, 18 we did identify some technical concerns and they led l
19 us to issue a couple of information notices just to 20 get the information quickly out to industry.
We sent 21 those to you with a Commission paper at the time.
We 22 also have asked each vendor a series of questions and 23 they have submitted to us their responses and test 24 reports and that kind of thing.
So, we're kind of 25 going into the same type of review we did initially NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W.
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i 68 l
1 with the Thermo-Lag fire barriers.
We're kind of 2
starting at ground zero looking back through what the 3
vendor or what utilities have done, what has the staff 4
done, have we looked at this material before and that 1
5 kind of thing.
So, those reviews are all underway and
{
6 we're still on schedule to complete that early next 7
year.
If we identify anything, depending on the l
8 significance, of course, we may send out another 9
information notice or bulletin or what have you, but l
i 10 we'll probably plan to summarize the results of all 11 that and put it out maybe in a generic letter or 12 something later.
13 Were there any specific questions on any 14 of the other materials?
15 CHAIRMAN SELIN:
We probably should plow l
16 ahead unless you actually get the question.
17 MR.
WEST:
- Well, I'm down to my last 18 slide, just a summary of the -- well, before I get to 19 the last slide I'll just mention that one of the other 20 things that we're working on is with Office of 21 Research on the performance-based fire protection 22 rule.
It's kind of in its infancy.
We've had a 23 couple of meetings.
In fact, we met with -- had a 24 good exchange of information with NUMARC yesterday on 25 some of their thoughts on how a performance-based rule NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W.
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should go.
Research has the lead for that, but of 2
course we're supporting it and very interested in it.
I 3
So, that's underway also.
4 (Slide) The final slide is just a summary 5
of the schedule for the fire protection task action 6
plan.
As you can see it's kind of a drawn-out 7
schedule.
It goes through 1997.
8 CHAIRMAN SELIN:
But these are looking 9
f o'r, identifying and resolving new issues.
They're 10 not like the Thermo-Lag for a known existing acute i
11 problem.
Is that right?
12 MR. WEST:
Some of the issues were -- this i
13 is an issue you should look at just to give yourself 14 a warm feeling that there's no underlying problem and 15 some were applying a lessons learned kind of approach 16 to other programs to see if there may be some other 17 program within NRR we want to look at closer.
l i
18 CHAIRMAN SELIN:
Do you know of any l
19 problem even of a smaller scale like Thermo-Lag in the 20 sense that we have an acute problem today and it's l
l 21 going to take three or four years to work it out?
22 DOCTOR THADANI:
No, we don't know of any 23 such major issues.
24 MR. WEST: That concludes my presentation.
25 CHAIRMAN SELIN:
Before I turn to my NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N W.
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70 1
colleagues, I'd like to say three things.
First, I 2
think on a tactful basis you've done a first rate job.
3 You've been thorough, careful, tough, rigid where 4
called for.
You thought out what you want to do and 1
5 you certainly haven't bought a bill of goods or i
6 anything like that.
There's no implication in my 7
remarks of anything like that.
8 The second is there are clearly some --
9 from a I wouldn't even say methodological point of 10 view, but from a test point of view, as Commissioner 11 de Plangue points out, there are a number of other l
12 things that would be necessary.
But the third thing, 13 my point is that occasionally one has to sit back and 14 say not what do we do next, but are we going to get to 15 where we have to get in a reasonable amount of time?
16 It's my opinion that this is the right time to ask 17 that question and not just look at this as an 18 undifferentiated problem.
Again, it's not a Thermo-19 Lag problem, it's a 70 power plant problem.
4 20 So, we'll get to what to do about Thermo-21 Lag and TSI in a dif ferent area.
Here the question is 22 how do these people in a not unnecessary, uneconomical 23 way, but quicker than we're getting now get up to 24 meeting our standards and that has to, I think, 25 probably be broken down into a number of sub problems.
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My suggestion is that it's time to consider that I
2 question as well as how do we keep as close as 3
possible to the original course of action.
4 Commissioner Rogers?
5 COMMISSIONER ROGERS:
Well, yes.
I guess just my own thoughts are a little bit 6
I would l
7 different from that, just really a concern about how--
l l
8 thought it through quite what you might do about it, 1
l 9
but a concern about how long this is taking to get i
l 10 resolved.
I really think that it is taking much too 11
- long, particularly the number of plants that are l
12 susceptible here and liable.
I think that something 13 has to move more rapidly towards closure.
I'm 14 uncomfortable about some of these dates and slippages 15 and so on and so forth.
I just don't think that 16 they're really tolerable.
I think that I don't 17 understand why really it's taking so long.
I'm not 18 blaming staff or anybody, but I think somehow it's 19 just to move more rapidly.
20 What's the situation with European 21 reactors?
Do they have to satisfy similar kinds of 22 fire protection, fire barrier requirements to the ones 23 that we're imposing?
If they do, what materials are 24 they using?
Are they using other materials than are 25 being used in the United States?
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l 1
MR. TAYLOR:
Are you in a position to 2
answer that?
3 DOCTOR THADANI:
I'm not.
4 MR. TAYLOR:
Let us take a look at that.
5 DOCTOR THADANI:
We need to look.
6 MR. TAYLOR:
I should note that even when l
1 7
Appendix R was passed there was a great debate about 8
the backfit issue in the United States in 1980, I 9
think it was.
It was a very tough decision because it was known that the plant configurations didn't reach 10 l
I 11 what was necessary by separation alone, which is the 12 ideal way.
I know a lot of the European designs have l
13 gone to separation, those that were in a design state.
l 14 So, we'd have to look more at the older plants.
15 COMMISSIONER ROGERS: Well, I'm not asking 16 for an extensive research project in here, but just a 17 feeling of whether there's anything that suggests i
18 itself from looking at those situations that might be i
19 applicable.
20 DOCTOR THADANI:
Yes.
In fact, next 21 month --
l 22 MR.
MIRAGLIA:
With respect to the 23 circumstances here
- though, there is all the 24 information we have is shared in the international 25 community.
So, our information is our generic NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N W.
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letters.
So, the concerns that have been raised here 2
are at least known.
3 DOCTOR THADANI: There's a planned meeting 4
next month, I believe it is, December, in December 5
when Mr. Madden is meeting with a number of countries 6
on trying to understand what they are doing on this 7
issue.
We will get the information to you.
8 COMMISSIONER ROGERS:
Thank you.
l 9
CHAIRMAN SELIN:
Commissioner Remick?
l j
j 10 COMMISSIONER REMICK:
I must admit I'm a 11 little surprised to hear that the staff and the i
12 industry are apparently at loggerheads on some of the 13 technical questions.
I have enough experience to know l
14 there are always two sides to any story and I
15 certainly support the Chairman's suggestion that 16 perhaps NUMARC should come in.
i 17 But another thought that goes through my 18 mind, have you vented this difference with ACRS where 19 both parties are there at the same time 61d both sides 20 are given and somebody listens to both
- sides, 21 technical arguments and tries to be helpful?
22 DOCTOR THADANI:
Not so far, but there is 23 a meeting planned with the ACRS.
I just don't i
24 remember what the date is.
We are planning to meet 25 with the ACRS.
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i i
1 COMMISSIONER REMICK:
And on the delays, 2
I'm certainly disappointed that it's taking more, but l
3 in a way I'm not necessarily surprised.
Is it due to t
i 4
lack of diligence?
Is it just taking longer than we 5
had estimated in our plan? I once again quote General l
l 6
Eisenhower who
- said,
" Plans are meaningless and 7
planning is everything."
I don't have to go back too 8
far in time to realize that many times when we specify i
9 things for others to do it always takes longer than we l
10 estimated that it would take.
But is it lack of i
11 diligence?
Is it just that there are problems, that 12 to build test equipment it takes time?
13 MR. MIRAGLIA:
Commissioner Remick, we 14 started the dialogue, as Steve indicated, early in 15
'92.
Industry came to an agreement that they would 16 consider a program in mid
'92.
Our expectations were 17 when we came to see you a year ago that we'd be well i
18 along the line to having the test completed and 19 knowing what the fixes were by this time.
We 20 developed criteria.
There was discussion about 21 criteria, should they move before our criteria was 22 finalized, after, and so those are all factors.
23 So, I think the answer is and the short 24 answer is all of those are factors into the equation.
25 We all hope that even with the tests starting in NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N W.
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75 1
September, had this phase I presented the path for l
2 solutions, we'd have been fairly close to being on 3
schedule.
The tests that ran did not produce that 4
result.
So, it's a long answer to a --
5 COMMISSIONER REMICK:
So, it sounds as if e
6 it's just taking longer than we had expected because l
7 there are complications.
Am I correct?
8 DOCTOR THADANI:
- Yes, I think that's 9
basically it.
I hope we're not leaving you with an l
10 impression that NUMARC is not pushing aggressively.
11 I think they are.
I think their recent information 12 that they developed is, I think, not what they had 13 expected or we had expected.
Therefore, it's no time j
14 to sit back, as the Chairman said, how do you proceed.
15 There's some tough issues.
16 COMMISSIONER REMICK:
Well, I certainly 17 urge that we forge ahead, but it sure appears like 18 it's a complex question.
It appears that we don't 19 have all the answers.
As I say, I'm a little more 20 surprised that we still have technical differences, 21 but I certainly would want to hear more about it 22 before I came down one side or another on why there 23 are still those technical differences.
These are 24 complex matters, but they always end up taking more i
25 time and all I
have to do is look at BWR NEAL R. GROSS court REPORTERS AND TRANSCRIBERS i
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76 1
instrumentation, level instrumentation.
It always 2
takes more time than we think it will take and people 3
actually have to carry these things out.
4 I appreciate the information that you 5
provided today and the job that you are doing.
6 CHAIRMAN SELIN:
Commissioner de Planque?
7 COMMISSIONER de PLANQUE:
Yes.
I guess 8
I'm still surprised that there are arguments over the 9
criteria and the testing methods.
If there aren't 10 data out there already to help resolve that, maybe 11 some of the tests should be aimed at resolving those 12 issues rather than randomly -- not randomly, but j
13 selectively testing configurations per se, but aim the 14 tests at settling the disagreement about what the j
15 criteria should be.
16 I have nothing further to add other than 17 I agree with most of everything that's been said.
18 CHAIRMAN SELIN:
Thank you very much.
19 MR. TAYLOR:
Thank you.
20 (Whereupon, at 11:36 a.m.,
the above-21 entitled matter was concluded.)
22 l
l 23 l
1 1
24 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W.
(202) 2344433 WASHINGTON. D.C 20CK6 (202) 2344433
CERTIFICATE OF TRANSCRIBER This is to certify that the attached events of a meeting of the United States Nuclear Regulatory Commission entitled:
TITLE OF MEETING:
BRIEFING ON STATUS OF THERMO-LAG PLACE OF MEETING:
ROCKVILLE, MARYLAhT l
l DATE OF MEETING:
OCTOBER 29, 1993 t
vere transcribed by me. I further certify that said transcription is accurate and complete, to the best of my ability, and that the transcript is a true and accurate record of the foregoing events.
62/L v
g Reporter's name:
Peter Lynch i
i i
e NEAL R. GROS 5 cover eseoems me inAnscenens 1913 eMODE ISLAMS AVD8ME, N.W.
(30r) m WAmee01000. SA 2000$
(70r) 2324000
. ~ -
THERMO-LAG FIRE BARRIERS AND FIRE PROTECTION PROGRAM REASSESSMENT 1
4 STATUS REPORT ASHOK THADANI, DIRECTOR DIVISION OF SYSTEMS SAFETY AND ANALYSIS i
AND STEVEN WEST, CHIEF SPECIAL PROJECT SECTION OFFICE OF NUCLEAR REACTOR REGULATION i
OCTOBER 29,1993 l
SLIDE I
l AGENDA e
BACKGROUND THERMO-LAG ACTION PLAN e
FIRE PROTECTION TASK ACTION PLAN i
I 4
SLIDE 2
BACKGROUND NOVEMBER 1992, LAST COMMISSION BRIEFING ON THERMO-LAG ACTION PLAN e
e PART I - TECHNICAL ISSUES NOVEMBER 1994 PART ll - NRC SMALL-SCALE TESTING COMPLITED: SEPTEMBER 1993 e
PART lil - INSPECTION PROGRAM MAY 1995 PART IV - FIRE PROTECTION PROGRAM REASSESSMENT COMPLETED: FEBRUARY 1993 e
e PART V - PLAN MANAGEMENT COMMISSION INFORMED OF SIGNIFICANT ISSUES AS THEY ARISE e
- STAFF APPROVAL OF COMANCHE PEAK BARRIERS
- PROBLEMS WITH OTHER FIRE BARRIERS FIRE PROTECTION PROGRAM REASSESSMENT-----> RECOMMENDATIONS RECOMMENDATIONS----> FIRE PROTECTION TASK ACTION PLAN e
OTHER MAJOR ACTIONS (GL 92-08, SMALL-SCALE TESTING OF OTHER FIRE BARRIER e
MATERIALS, ETC..)
ACTION PLANS UPDATED QUARTERLY (LATEST OCTOBER 8,1993)
THIS BRIEFING WILL FOCUS ON MAJOR ISSUES, ACCOMPLISHMENTS, AND PLANS e
?
SLIDE 3 3
THERMO-LAG ACTION PLAN e
GENERIC LETTER 92-08, THERMO-LAG FIRE BARRIERS e
GENERIC LETTER 86-10, SUPP.1, ACCEPTANCE CRITERIA e
NRC SMALL-SCALE TESTS e
PLANT-SPECIFIC TESTS e
NUMARC TEST PROGRAM e
COMPLETION SCHEDULE i
SLIDE 4 j
GENERIC LETTER 92-08 "THERMO-LAG 330-1 FIRE BARRIERS" e
IDENTIFIED SPECIFIC TECHNICAL CONCERNS e
70 UNITS AWAITING RESULTS OF NUMARC PROGRAM l
e 2 LICENSEES PROPOSED APPENDIX R EXEMPTIONS e
3 LICENSEES PROPOSED ALTERNATIVE COMPENSATORY MEASURES STAFF PLANS TO CLOSE OUT THERMO-LAG BARRIER ISSUES BY INSPECTION i
i l
i SLIDE 5
GENERIC LETTER 86-10, SUPPLEMENT 1 ACCEPTANCE CRITERIA CLARIFIES FIRE ENDURANCE TEST ACCEPTANCE CRITERIA j
e NUMARC, LICENSEES, UL, VENDORS AND INTERVENORS COMMENTED e
DOMINANT COMMENTS FOCUSED ON
- THERMOCOUPLE PLACEMENT
- HOSE STREAM TEST METHODS l
- TESTING ASSEMBLIES WITHOUT CABLES l
PLAN TO ISSUE NOVEMBER 1993 l
i l
l 1
SLIDB 6 l
l NRC SMALL-SCALE TESTS l
ASSESSED THERMO-LAG MATERIAL THERMAL PERFORMANCE e
TWO 1-HOUR AND FOUR 3-HOUR PANEL TESTS e
MAXIMUM TEMPERATURE RISE OF 250 F EXCEEDED e
TESTS INDICATED THAT THERMO-LAG MATERIAL NEEDED UPGRADES TO ACHIEVE FIRE RESISTANCE RATINGS e
TESTS INDICATED THAT THERMO-LAG MATERIAL EXHIBITED COMBUSTIBLE PROPERTIES TESTS DID NOT ASSESS PERFORMANCE OF ASSEMBLIES l,
1
]
SLIDE 7
PLANT-SPECIFIC TESTS e
TEXAS UTILITIES FOR COMANCHE PEAK UNIT 2
- STAFF APPROVED TEN UPGRADED BARRIER DESIGNS e
TENNESSEE VALLEY AUTHORITY FOR WATTS BAR NUCLEAR
- TESTS OF UPGRADED CONDUlT BARRIERS
- RESULTS OF TESTS UNDER STAFF REVIEW
- WILL USE COMANCHE PEAK CABLE TRAY TEST RESULTS e
TEXAS UTILITIES FOR COMANCHE PEAK UNIT 1
- BARRIERS WITH LIMITED UPGRADES
- TEXAS UTILITIES ASSESSING CABLE FUNCTIONALITY 1
SLIDE 8
NUMARC TEST PROGRAM e
PHASE 1 - SEPTEMBER / OCTOBER 1993 1
- VENDOR-DESIGNED UPGRADED THERMO-LAG FIRE BARRIERS
- SIX FULL-SCALE FIRE ENDURANCE TESTS - ONE TEST DEFERRED
- MOST TESTS DID NOT SATISFY ACCEPTANCE CRITERIA
- THERMOCOUPLE PLACEMENT
- PLANT-SPECIFIC APPLICABILITY OF RESULTS 4
e PHASE 2 - JANUARY 1994 l
- ELEVEN BASELINE AND UPGRADED FIRE BARRIER DESIGNS e
INDUSTRY TEST APPLICATION GUIDE e
COMBUSTIBILITY METHODOLOGY SUBMITTED OCTOBER 1993 i
SUDE9 i
THERMO-LAG ACTION PLAN i
COMPLETION SCHEDULE e
COMPLETION SCHEDULE WILL BE IMPACTED BY:
- NUMARC TEST PROGRAM SCHEDULE l
f
- TIME NEEDED FOR LICENSEES TO ASSESS TEST RESULTS 4
FOR APPLICABILITY
- TIME NEEDED FOR LICENSEES TO TEST OR ANALYZE UNIQUE CONFIGURATIONS I
j
- TIME NEEDED FOR LICENSEES TO EFFECT CORRECTIVE i
ACTIONS l
- TIME NEEDED FOR NRC TO INSPECT ALL PLANTS l
SLIDE 10
w FIRE PROTECTION TASK ACTION PLAN e
RECOMMENDATIONS FOR ACTION l
e COMPLETED AND ONGOING ACTIONS i
e REMAINING ISSUES e
SUMMARY
STATUS i
i i
i i
I l
SLIDE 11 1
RECOMMENDATIONS FOR ACTION ASSESS RESOURCES NEEDED FOR ACTION PLAN REVIEWS
- i l
l e
REASSESS THE FIRE-INDUCED VULNERABILITY EVALUATION METHODOLOGY e
REVIEW FIRE BARRIERS OTHER THAN THERMO-LAG i
i e
REVISE NRC FIRE PROTECTION REGULATION (APPENDIX R)
DEVELOP INTEGRATED INFORMATION MANAGEMENT SYSTEM l
e EXPAND STUDY OF FIRE-RELATED ELECTRICAL LOAD MGT i
e DEVELOP TRAINING PROGRAM FOR NRC STAFF e
COORDINATE FIRE PROTECTION AND SYSTEMS REVIEWS l
e REEVALUATE SCOPE OF FIRE PROTECTION INSPECTIONS i
L l
SUDE 12 l
COMPLETED AND ONGOING ACTIONS ASSESSED ACTION PLAN RESOURCES e
CLARIFIED THE FIRE-INDUCED VULNERABILITY EVALUATION METHODOLOGY THROUGH NUMARC e
EVALUATING FIRE BARRIERS OTHER THAN THERMO-LAG
- ISSUED TWO INFORMATION NOTICES
- CONDUCTED SMALL-SCALE FIRE TESTS AT NIST e
DEVELOPING PERFORMANCE-BASED REGULATION CONSISTENT WITH COMMISSION REO.UEST R
SLIDE 13
FIRE PROTECTION TASK ACTION PLAN
SUMMARY
STATUS MAJOR RECOMMENDATIONS FOR ACTION SCHEDULED COMPLETION: FEBRUARY 1996 e
RECOMMENDATIONS FOR FURTHER STUDY SCHEDULED COMPLETION: NOVEMBER 1995 i
l i
e CONFIRMATION ISSUES l
l SCHEDULED COMPLETION: MAY 1997 LESSONS LEARNED i
l SCHEDULED COMPLETION: DECEMBER 1994 l
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