ML20133G541
| ML20133G541 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 12/05/1996 |
| From: | NRC |
| To: | |
| References | |
| NUDOCS 9701160079 | |
| Download: ML20133G541 (113) | |
Text
Official Transcript of Proceedings NUCLEAR REGULATORY COMMISSION
$0-hufC
Title:
Comanche Peak Unit 1 Thermo-Lag Fire Barriers Docket Number: (not applicable)
Location: Arlington, Texas Date: Thursday, December 5,1996 Work Order No.: NRC-933 Pages 1-111 T;.~ . . , . _ . ,
i i NEAL R. GROSS AND CO., INC.
Court Reporters and Transcribers 1323 Rhode Island Avenue, N.W.
Washington, D.C. 20005 16000f1 (202) 234-4433 I
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1 1
! 1 UNITED STATES OF AMERICA 2 NUCLEAR REGULATORY COMMISSION ;
3 +++++
1 l
i 4 MEETING 5 ---------------------------------x 6 IN THE MATTER OF: :
i 7 COMANCHE PEAK UNIT 1 :
8 THERMO-LAG FIRE BARRIERS :
9 :
10 ---------------------------------x 11 Thursday, December 5, 1996 12 13 Region IV Headquarters v 14 611 Ryan Plaza i
15 Suite 400 16 Arlington, Texas i
l 17 1
18 l
19 The above-entitled meeting was conducted at 20 8:00 a.m.
21 22 23 24
/ \
( / 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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2 l 1 APPEARANCES:
l l f- 2 Dr. William D. Beckner t )
1 3 Director, Proj. Directorate IV, NRR 4 Linh N. Tran 5 Thermo-Lag Lead Project Manager, NRR 6 Timothy J. Polich 7 Project Manager, Comanche Peak, NRR 8 Ledyard B. Marsh 9 Chief Plant Systems Branch, NRR 10 Edward A. Connell 11 Senior Fire Protection Engineer, NRR 12 Amritpal S. Gill 13 Chief Electrical Engineering Section, NRR (V .
14 Ronaldo V. Jenkins 15 Electrical Engineer, NRR 16 Joseph I. Tapia l
17 Chief Reactor Projects Branch, Region IV l 18 Anthony T. Goody 19 Senior Resident Inspector, Comanche Peak 20 l
21 ;
22 1
23 I i
24
/O (j 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS l 1323 RHODE ISLAND AVE., N W. l (202) 234-4433 WASHINGTON, D C. 20005-3701 (202) 234-4433 l
3 i 1 P-R-O-C-E-E-D-I-N-G-S l
-, 2 (8:00 a.m.)
3 MR. POLICH: All right. Good morning, ladies 4 and gentlemen. This is a public meeting between the l
5 United States Nuclear Regulatory Commission and the Texas 6 Utilities Company.
7 The purpose of this meeting is to reach 8 technical resolution on Thermo-Lag Barriers at Comanche 9 Peak Steam Electric Station, Unit 1.
10 The issues were resolved for Unit 2 prior to 11 licensing, in February 1993. A few items remain open from 12 the safety evaluation on Thermo-Lag dated May 22, 1996. .
1 13 Specifically, the focus of this meeting is the seven items
[^\
'%s 14 in that safety -- open items in that safety evaluation.
15 The purpose of this meeting is to reach final i
16 technical resolution on these remaining items in the very !
i 17 near future.
18 And I would like everyone to introduce 19 themselves, and state their affiliation and whether i
20 they're reprenting the United State Nuclear Regulatory 21 Commission, Texas Utilities Electric Company, or members 22 of the public.
23 Also, would you please print your name and 24 title and affiliation on the sheets that we've been
( s 25 passing around, and also if you're a member of the NRC or
(_,/
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1
\
4 1 TU Electric, we'd probably need to get your phone number r~s 2 on another sheet that we need to send around.
3 Members of the public are reminded that this 4 meeting is between the NRC and TU Electric. This meeting 5 is being transcribed, and that transcription will be 6 placed in the Public Document Room.
7 And then after we go through introductions I'd 8 like to turn the meeting over tc Mr. Tad Marsh for opening 9 remarks, then we'll hear opening remarks from TU Electric, 10 and then we'll go back to making our -- side of the 11 issues, or the seven open items.
12 So if we start over here.
13 MR. COLLINS: Good morning. My name is Sam (3,
~' 14 Collins, for those of you who I haven't met. I'm the j 15 Deputy Regional Administrator here in Region IV. Region 16 IV is hosting this meeting. I'd like to welcome you all 17 to the office if you haven't been here previously. The 18 majority of you have, I suspect.
19 Also, members of the public and media who are 20 here, I appreciate your interest in the meeting and also 21 your cooperation for the conduct of the meeting.
22 The meeting is between the NRR Staff and the I
23 licensee. My role here is as an observer to the meeting, 24 and as host of the meeting, and I'm very interested in the l
(^ \
(_s)/ 25 issues, not only generically but also at TU as far as NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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I l 5 l 1 Comanche Peak, that's one of the plants here in Region IV.
l l l 73 2 So with that, I'd like to turn the following
( )
'J 3 remarks over to Ted Marsh. ,
I 4 MR. MARSH: Great. Before I get started, I'd 5 like to go around the room and make sure you all know who 6 we are, and we know who you are.
7 My name is Ted Marsh. I'm the Branch Chief 8 for the Plant System Branch in the NRR Headquarters, 9 programmatic responsibility for fire protection.
10 MR. CONNELL: My name is Edward Connell. I'm 11 a Senior Fire Protection Engineer, in the Office of i
12 Nuclear Reactor Regulation, Plant Systems Branch.
13 MR. BRADLEY: Biff Bradley, NEI, and I'm here fx.,
14 to observe the meeting.
15 MR. WALKER: Roger Walker, Regulatory and 16 [ inaudible] Manager, TU Electric. I'm here -- no. Let's 17 say I'd like to observe the meeting.
18 MR. TERRY: I'm Lance Terry, Group Vice 19 President of Nuclear at TU Electric.
20 MR. MADDEN: My name is Fred Madden, Technical 21 Support Manager at TU Electric, Comanche Peak.
22 MR. BECKETT: I'm Gene Beckett, TU Electric 23 Fire Protection Engineer.
24 MR. BHATTY: Obaid Bhatty, Regulatory Affairs.
G
) 25 I work for Roger.
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6 1 MR. WHITE: John White, Texas Utilities. I'm 7, 2 in electrical design engineering.
5 MR. GILL: Paul Gill, Electrical Engineering 6 Branch Section Chief, NRR.
7 MS. TRAN: Linh Tran, NRR. Thermo-Electric 8 Project Manager.
9 MR. JENKINS: Ronaldo Jenkins, Electrical 10 Engineer, Electrical Engineering Branch, NRR.
11 MR. POLICH: Tim Polich. I'm the Project 12 Manager for Comanche Peak, NRR. And at the back table, I 13 think if they could kind of like come up and -- or I could
/~
( )T 14 introduce, I think the people at the back table.
15 That's Phil Qualls, Fire Protection Inspector; 16 Joe Tapia is the Branch Chief for Projects here in the 17 Region; and Senior Resident Inspector Tony Gody. And --
18 MR. HENDERSON: I'm Breck Henderson, Region IV 19 Public Affairs.
20 MR. POLICH: And?
21 MR. BEDNAR: Mark Bednar, TU Electric Nuclear 22 Overview Department.
23 THE REPORTER: I'm sorry. I didn't hear you.
24 MR. BEDNAR: Nuclear Overview Department, Mark
() 25 Bednar --
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i 7 1 THE REPORTER: And what is your name? l fs 2 MR. BEDNAR: Mark Bednar, i \
3 THE REPORTER: Okay, thanks.
4 MR. MARSH: Thank you very much.
5 I have a few introductory comments which will l
6 set forth the context and the overall purpose of this 7 morning's meeting.
8 First, I want you to please recognize that we 9 have a rather large contingent here from headquarters and 10 from the Region, and I believe this represents the 11 Agency's continuing concern that the industry as a whole 12 promptly resolve their thermo-lag issues, as well as our 13 concern that you in particular are taking the appropriate r~s (s} 14 actions to expeditiously resolve thermo-lag at Comanche 15 Peak Unit 1.
i l
16 We've chosen this location to hold this 17 meeting in an effort to afford the public an opportunity 18 to attend. It's our belief that the public should be 19 given as much access as possible to meetings between i
20 licensees and the NRC, so they may be as well-informed as 21 possible. l 22 As Mr. Polich stated, and as described in our 23 November 22 letter to you, the purpose of this meeting is 24 to obtain your understanding of the issues surrounding the
() 25 resoution of thermo-lag at Comanche Peak Unit 1, and to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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8 1 reach a resolution of these issues.
-s 2 The NRC has engaged in verbal and written 3 dialog with you since 1993 in an effort to resolve these 1
1 4 issues. We are concerned that we have not yet reached l l
5 final resolution.
6 Through numerous telephone calls, meetings and 7 requests for additional information, we have expressed our 8 concerns and sought prompt resolution. l 1
9 Furthermore, on May 22, 1996 following l i
10 numerous conversations and attempts to close the open )
l 11 issues, we issued our Safety Evaluation with seven items ;
I 12 remaining open. Your response to this Safety Evaluation, 13 your October 24, 1996 letter, did not adequately address
\
14 all of the open issues.
15 Also, the new information provided in this l
l 16 response apparently had been available to you previously, '
17 and we want to understand why it had not been provided i
18 earlier.
19 Mr. Walker, on Tuesday, December 2 in a 20 telephone message to the project manager, Tim Polich, you 21 expressed your belief that our letter of November 22 was I 22 in error, and there had been misunderstandings between the 23 licensee and the NRC which have led to this delay.
l 24 Therefore, to minimize the chance for n
k,) 25 information discussed in this meeting to be misunderstood, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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9 1 we have elected to have this meeting recorded and es 2 transcribed, so that there will be no misunderstandings V)
(
3 and we have a complete and thorough record.
4 Now, shortly I'm going to ask Mr. Ed Connell 5 and Ronaldo Jenkins, the lead reviewers in this area, to 6 discuss with you our positions on each of the seven open 7 items, and our concerns regarding your responses to date.
8 Please allow the Staff to go through their 9 entire discussions, then ask the questions that you 10 choose, present your information, and engage in a dialog 11 with the Staff.
12 I would like you to discuss not only the 13 technical matters at hand, but also how you believe that
\~2 14 you are currently in compliance with your fire protection 15 licensing basis, and other regulatory commitments.
16 Furthermore, I would like you to focus your 17 discussions towards assuring us that you are taking the i
18 appropriate management actions to resolve the issues, and 1
19 how you believe your actions to date comply with Criterion l l
20 16 of Appendix B, to 10 C.F.R. 50 (phonetic] in terms of 21 taking timely corrective actions.
i 22 Following completion of the discussions, I'll 23 ask the Staff to caucus to develop any questions, 24 positions, or further information that we need.
i
( / 25 Any thoughts or questions? Roger, do you have NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W (202) 234-4433 WASHINGTON, D C. 20005-3701 (202) 234 4433
10 1 any opening comments?
-3 2 MR. WALKER: I thir.< Lance does.
/ \
3 MR. MARSH: Okay. Lance?
4 MR. TERRY: We appreciate the meeting. We do I
5 want to close the thermo-lag issue. I think if you look j 6 at the record, and -- no utility has been as aggressive as 7 TU Electric in trying to resolve the thermo-lag issue.
8 We were somewhat surprised at the tone of the 9 latest letter. However, we have reviewed recent l
10 correspondence, not looking at just one piece, just trying 11 to go back and look at the last several pieces of 12 correspondence, and review that correspondence.
l 13 It's obvious that there have been some i O
\~ / 14 assumptions made on our part, on familiarity with all the i
15 docketed correspondence that went before, and we have 16 not -- in some cases -- clearly laid out the exact trail 17 as to how we have resolved a specific issue.
18 I do want to put on the record that we have 19 done our testing and analysis to meet the October 29, 1992 20 acceptance criteria provided by the NRC that we used for 21 licensing Unit 2. We did in fact do additional testing 22 for Unit 1. That testing was done in late 1993.
23 And we completed all of our Unit 1 24 installations and upgrades to those tested configurations
(
(_)) 25 in -- by early 1994, and in fact put on the record in 1994 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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11 1 to the Commission that we in fact felt that we were in 2 compliance, and met our licensing basis. We still feel Ih
\'-l 3 that we meet our licensing basis.
4 In several meetings with the NRC since then, I 5 haver requested that we expedite the resolution of any 6 open issues on thermo-lag, and so I appreciate this 7 opportunity to try to understand what the few remaining 8 open issues are, and I do value hearing what those open 9 issues are so that we can better understand the issue.
10 It's obvious that we're -- you're asking 4
11 questions and we're trying to respond to those, and we're 12 not answering the right question, apparently. So -- we 13 need to understand what the question is.
O)(_ 14 Again, we thought we'd completed our action in 15 early 1994, we do want to bring thermo-lag to closure, so 16 I welcome the opportunity to meet with you today.
17 MR. MARSH: Thank you.
18 I'm going to turn now to Mr. Connell, and then 19 following that, Mr. Jenkins. Ed?
20 MR. CONNELL: Okay. Thank you.
21 Good morning. Of the May safety evaluation 22 issued by the Staff there were seven open items, and I'll 23 do the easiest one first.
24 The last one -- which was Item 7 -- related to r'
( ,}j 25 the use of Test Scheme 15-2, for cables smaller than 750 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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12 1 mcm. And the licensee's response, indicating that there 2 would not be any -- this application would not be used for 73 i' ,)
3 cables smaller than that size is acceptable, and we 4 consider that item closed. That's the easy one, and we 5 get that off -- the table.
i 6 Jump back to the first issue, the thermal l
7 mass. The performance of a fire barrier is significantly I 8 impacted by the thermal mass of the material which the 9 barrier encloses. This is well-recognized by the 10 industry -- as far as research goes, at least as far back l
11 as 1981, with the Underwriters Laboratory Test Standard 12 for Electrical Fire Barrier Raceway Systems.
13 And in the American Nuclear Insurers
(- 14 Guidelines for testing these type of fire barriers, which 15 is referenced in the Comanche Peak Engineering Report ME-16 067, that recognizes that the cable fill -- which is a 17 simplified way of determining thermal mass -- is an 18 important parameter that needs to be addressed, and that 19 cable fills that are less than the tested configuration 20 are not bounded by those test configurations.
21 This is an issue that's gone back with Unit 1 22 quite a ways. The licensee recognized this in an August 23 1992 meeting, that thermal mass was important regarding 24 some tests they've performed on small-diameter conduits,
.O
( ,) 25 and the importance of thermal mass was also recognized by NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W-(202) 234-4433 WASHINGTON. D C. 20005-3701 (202) 234 4433
13 1 industry during the Newmark , NEI- and TVA-sponsored 2 testing of thermal line barriers.
7S U 3 The information regarding the cable fill was 4 provided by TU Electric in the Engineering Report for 5 Unit 2. This information was deleted in the revision to 1
6 that report, that also included the fire barriers for Unit l 7 1, and no explanation was given.
8 This issue has been discussed, at least as far 9 as my involvement, back to June '94 when I advised the i i
1 10 licensee during a teleconference that they did need to 11 bound their barriers using the cable fill, and that cable
)
12 fills less than those tested were not bounded by the test 13 configurations.
(
14 And just as a side note, licensee, in our 15 response to an RIA on Generic Letter Number 92-8 in 16 February '95 stated that the cable fill had been verified 17 and addressed, but didn't provide any additional 18 information.
19 So that's our position regarding the thermal 20 mass, and you know, you guys -- bring that up for 21 discussion.
22 MR. MARSH: Yes, my comments said we could go 23 through our entire presentation. Maybe it is better to 24 stop and discuss each topic as we go through --
/~T (s,) 25 (Discussion held off the record.)
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14 l
1 MR. WALKER: Yes, let's deal with them one at j g$ 2 a time.
U 3 Who wants to handle it? l 4 MR. BHATTY: I can handle it, sir.
5 MR. WALKER: Ah.
6 MR. BRATTY: I'm Obaid Bhatty. And 7 those cable fills -- we had intended to do that -- at that !
l 8 time when we revised the engineering report to Rev. 3, we 9 believed that what we thought or assumed -- like Lance i
4 10 already said -- that we had provided that information to l
l 11 you.
12 In the test reports, the cable fills are 13 there, and what we promised you -- we stated in our t\ ') 14 current response to your SCO [ phonetic] open items, we ;
15 said we will revise the engineering reports, and put those 16 cable fill numbers there, back again if that -- you know, 17 I think that should close the issue.
18 MR. CONNELL: Well, that's the information but 19 that doesn't bound the planned, installed configurations.
20 If you have raceways, conduits or cable trays that have a 21 lower cable fill than the tests that you're using to 22 qualify those as installed configurations, those 23 configurations are not bounded by those -- by that test 24 data.
25 MR. WALKER: Ed, can I ask a question?
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15
( 1 MR. CONNELL: Sure. )
i l 2 MR. WALKER: Back in -- when I was a child and ;
l (~s\ \
\ ) I 3 we started at this, we made commitments as to what we 4 would put in a test configuration with respect to our I i 5 tests. And in fact, the Staff insisted we do things in a i t
6 particular way.
7 MR. CONNELL: Uh-huh. ,
l 8 MR. WALKER: The Staff -- if my memory is 9 correct, and you guys stop me if I'm wrong -- the Staff i l
l 10 insisted that -- because originally we were not -- in our !
l l
11 original, the very initial ones, we did not have the )
i 12 configuration that the Staff wanted.
13 MR. CONNELL: That's correct.
5 s# 14 MR. WALKER: The Staff insisted that we put a 15 power cable, an instrument cable and a --
16 MR. BHATTY: Control cable.
17 MR. WALKER: -- control cable, and we agreed l 18 that was the appropriate configuration. That's how we 19 conducted our test, based on the Staff's telling us what 20 they wanted. So why -- we have difficulty understanding 21 is, you're asking us to go back and give you a test that 22 we didn't commit to, that we agreed to was correct in the 23 first place. That's our problem.
24 MR. CONNELL: Well, I think it's -- what's O( j 25 your question?
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16 1 MR. WALKER: The question is, we made 2 agreements on what constituted cable fill, and we lived up 3 to them, and now appear to tell us those agreements were 4 not adequate.
l l
l 5 MR. TERRY: Those were to be representative 6 cable fills, and the NRC wanted to see one of each type 7 cable in there as a representative cable fill. That's 8 what we did.
9 And the cable loading, at the -- varied, 10 depending on the size of the conduit as to what that 11 constituted for a loading within the conduit -- but that's 12 in fact the way the tests were set up, in an agreement 13 with the NRC that that's what we would test.
A w.- > 14 MR. CONNELL: For Unit 2.
15 MR. WALKER: And you know, you need to 16 understand that you told us also to do our testing for 17 Unit 1 as we did in Unit 2, in meetings that we -- went 18 to.
19 MR. CONNELL: Right. And if you'll look in 20 the Engineering Report for Unit 2, you'll notice that in 21 the appendix that addresses the cable fill issue, it 22 clearly defines in there which plant-installed barriers 23 are bounded by which tests, by percentage of cable fill.
l 1
24 So some conduits are from zero to such-and-l (#%
l t y ,) 25 such percent. Some cable trays are from 9 percent up to a NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W l (202) 234-4433 WASHINGTON D C. 20005-3701 (202) 234-4433 l
17 1 certain percentage. And all that information was used by I
j 2 the Staff for the Unit 2 review. All information was not
! (7,)
3 included, and the cape thermal mass wasn't considered by 4 the Staff for Unit 2 review.
l 5 Now, I did not do the Unit 2 review, but in 6 consultation with the lead reviewer, that information was 7 very important for the review, and that was part of the 8 basis for the acceptance of the Unit 2 configurations.
9 MR. WALKER: Maybe we're having a 10 communication problem. Are you looking for that same 11 correlation for Unit 1 as Unit 2, is that what you --
12 MR. CONNELL: What I am looking for is 13 confidence that the Unit 1 tests actually bound the plant-(\
- 14 installed configurations. That's what I'm looking for.
15 MR. BHATTY: We believe we can do that. We 16 believe we can do that, if we put those numbers back into 17 the engineering report, we still can say that they're 18 bounded --
19 MR. CONNELL: But, do they? Do they in fact ,
l 20 bound the configurations?
21 MR. TERRY: I don't know the answer to that 1
22 until we get it -- l l
23 MR. MARSH: And regardless of the agreement 24 that was made back by -- there may have been an
(%
( ,/ 25 understanding that the Staff had, that the tests that were l
l NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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I 18 1 done bound them to the condition, but maybe they don't.
l 7s 2 I mean, it's a legitimate question.
t 3 MR. TERRY: What we gave them was -- what we i 4 did was a representative cable loading. Okay?
l l
5 And I think, in the Unit 2 Engineering Report, 6 the engineering report we submitted for Unit 2, we did go 7 back and try to put together a correlation as to what 8 type -- how many -- what was the percentage fill for these 9 cables versus -- for these conduits versus these conduits 10 versus these conduits versus these can we put together a 11 similar-type chart for Unit 1?
12 MR. WALKER: Yes, we can, but does that --
13 MR. TERRY: But I don't know if it will bound.
[)
N' 14 It will show how we are as far as the representative 15 samples that we tested.
16 MR. MARSH: La you have this information 17 already, or is it something you have to develop?
18 MR. BHATTY: We were developing this in 19 response to this meeting, and we had told our management 20 that we can revise the Engineering Report as soon as they 21 tell us to do that; we can have that information.
22 MR. BECKETT: The proper response is there's 23 still some minor development work that requires 24 to complete that effort.
(~h
(_) 25 MR. POLICH: And what timeframe do you think NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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l i
19 l 1 that that -- is that going to be a long thing to develop, i
, ~g 2 or is that a short thing --
V 3 MR. WALKER: We were going to get to that, but 4 the bottom line is we probably will develop -- or take our 5 Engineering Report, because one of the things we feel is, 6 we need to update our Engineering Report to put more 7 detail in it, because of the long history of this.
8 This would be one of the things that we would 9 be modifying, and we are -- we had discussed it last 10 night, that we feel that if -- a reasonable because of the 1
11 Christmas holidays would be January 15.
12 Did I speak out of line? I haven't looked at 13 what day January 15 falls on, Tim, so --
O
\/ 14 MR. POLICH: The 15th?
15 MR. WALKER: Yes. Let me look and see what 16 date it falls -- if it's Sunday, maybe the 16th -- that's 17 our intention.
l 18 MR. MARSH: Is -- were you going to -- let's l l
19 see. Is the relationship to Unit 2 important to the 20 boundedness of these tests to the configurations?
21 MR. CONNELL: I'm not clear what your question 22 is.
23 MR. MARSH: Well, are you going to develop a 24 table that shows whether the tests bound the actual O
(_s/ 25 configuration for Unit 1?
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20 1 MR. WALKER: Did we say that?
f_ 2 MR. TERRY: I don't think we said whether they b 3 bound. I think what we said is we'll give you a table 4 similar to what we did for Unit 2 --
5 MR. MARSH: Okay.
6 MR. TERRY: -- that shows for this group of 7 raceways what is the loading --
8 MR. MARSH: That's correct.
9 MR. TERRY: -- because the tests that we did 10 were representative, and if we only have one cable in a 11 conduit, we were required to put three cables in a conduit 12 to do the test.
13 MR. MARSH: Okay. Let's jump downstream a
\-- 14 little bit. Looks like we accepted a relationship of 15 testing to representation for Unit 2. Right?
16 Now, if this table that you're going to 17 develop is out of line with that same relationship --
18 follow what I'm saying? -- then you should jump to the 19 next step, justifying that the representation that you're 20 using for Unit 1 is acceptable; that it's less -- that 21 would be the problem, that it would be less than there is 22 in Unit 2. l 23 Am I on the same wavelength?
24 MR. CONNELL: It's close. Of course, the 25 tests for -- that were accepted for Unit 2 had a lot more NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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21 1 margin as far as meeting the temperature acceptance 2 criteria than some of the Unit 1 specific tests. So it
()
3 was an important issue for Unit 2. It's a critical issue 4 for Unit 1.
5 MR. MARSH: Okay. What I'm trying to give 6 them is as much guidance as I can, to jump downstream i 7 after they've got this relationship. What more could they I i
8 provide to us with this table that would give us the j 9 assurance that we would need?
10 MR. TERRY: And specifically let me ask the 11 question: If in fact our representative cable loading i I
12 that we were told to put in is more than we have in a I 13 specific conduit, are you -- what do you want us to do
'~
,% 1 m 14 with that?
l 15 MR. CONNELL: Well, that would be that -- you 16 would have to evaluate whether that plant-installed 17 configuration is in fact bounded by your tested 18 configuration. I I
! 19 And if it is not, then you need to either 20 upgrade it or change it to one that is bounded or retest
! 21 that new configuration.
22 MR. TERRY: Even though that was the minimum 23 configuration NRC would let us test and get credit for?
24 MR. CONNELL: I'm not clear on what you mean
()
im 25 by, a minimum configuration.
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22 1 MR. TERRY: NRC said that we needed to put one
- 2 power, one control, and one instrument cable in every V 3 test --
4 MR. CONNELL: Well --
5 MR. WALKER: That was not our original 6 position --
7 MR. CONNELL: But that was for cable 8 functionality evaluations if you had exceeded the 9 temperature criteria, if I'm not mistaken.
10 MR. TERRY: That's what they want us to put in 11 the test set. So that's what we did.
12 MR. WALKER: That's what they defined for us 13 that they wanted in the test sample. That wasn't what we
(,
- 14 originally wanted to do.
15 MR. BECKETT: It was not limited to cable 1
16 functionality at that time.
17 MR. WALKER: We were asked to do it.
18 MR. CONNELL: Well, why else would you do it?
l 19 MR. BECKETT: To see what the impact 20 temperatures were on the exact cables in there, so that 21 you could -- with a visual inspection make a practical l 22 determination of the impact.
23 MR. CONNELL: So that is -- it's for cable 24 functionality, not barrier performance.
/~ 'N
( ,) 25 MR. BECKETT: Well, if your barrier does not NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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23 l
1 perform and your cables were damaged, then you could have l
t l ~s 2 a potential problem.
3 The integrity of the barrier is intended to l 4 prevent damage to those cables, and they wanted one cable l
5 type so that any potential damage that may or may not 6 occur was represented within that raceway, because it was 7 understood that because of the construction differences of 8 those types of cables -- and they're -- basically have 9 three different constructions -- that the fire's impact on 10 one type may be more severe than on another type.
11 And so therefore, the three representative 12 cable types gave you a good cross-section when you did 13 your visual inspections after the fact.
(,\
\2 14 MR. CONNELL: That's for cable functionality, 15 evaluations, to evaluate the functionality of the cable, l 16 post-fire. l l
17 MR. WALKER: I guess the point is, the test 18 configuration was defined for us, so the test was both for 19 cable functionality and for barrier performance. That's 20 our problem.
21 MR. TERRY: What the problem is, we had a 22 whole series of meetings like this to try to develop those 23 criteria. And we developed the criteria in October '92, 24 finally, and said that's what we will use for acceptance.
() 25 We were told to use the same thing on Unit 1.
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24 1 Now, that's what we've done. We've already done the r~s 2 tests. We've already done the installations. We've 3 provided you the information. We did not give you the --
4 same data in the Engineering Report. We will correct 5 that.
6 But to now go back and say we want to go 7 change the criteria looks like it's changing after we've 8 already done the work.
l 9 MR. CONNELL: Okay. I don't believe it'E 10 changing the criteria. Your commitment is to have one-11 hour barriers in the plant. So any barrier in your plant, 12 I should be able to tear it down, drag it down to San 13 Antonio, stick it in a furnace, instrument it, and it
(
\/ 14 should last for one hour.
15 MR. TERRY: That's correct.
16 MR. CONNELL: Now, if you have a particular 17 assembly -- let's say you have a cable tray that has no 18 cables in it, and you tested a cable tray that has a 50 19 percent fill, and the one with the 50 percent fill passed 20 with one degree of margin at the end of 60 minutes, the 21 chances of that cable tray with no cables in it passing is 22 small or nonexistent.
23 So that barrier would not be qualified as a 24 ene-hour barrier. That's the point I'm getting at. I O
k_) 25 mean, the laws of physics are strongly in play here. The NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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25 1 more material you have inside that barrier, the longer 2 it's going to endure a standard fire exposure. You
/-,T 3 understand that.
4 MR. TERRY: I understand -- what you're 5 saying.
l 6 MR. CONNELL: Okay. 1 7 MR. TERRY: I also understand that we did 8 not -- when we were making the initial determination as to 1
1 9 what the testing would be, we did not -- were not told to, 10 did not agree to, it wasn't even mentioned that we test 11 with no cables in at that point in time.
12 It was mentioned that we test with one of each 13 type cable. So that's what we did.
+ ,a e 1 kms / 14 MR. MARSH: The same was done for Unit 2.
15 MR. TERRY: Same was done for Unit 2.
16 MR. MARSH: Why don't you develop this 17 comparison, all right? And let's go from there. We're 18 not changing the rules. You know, I think we're 19 articulating what we think the rules were, and are.
20 MR. CONNELL: And that's consistent with the 21 generic communications we've send to all of the thermalite 22 [ phonetic] plants in December '94 regarding -- you know, 23 thermal mass; that that was an important criteria. So 24 you're not being treated any differently than any other
-s
! ) 25 termalite plant.
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26 t
2 (8:30 a.m.)
2 MR. TERRY: I understand, except recognize 1
(,.
' ') 3 that you developed those rules partly as a result of what
)
4 you had done with us, and those rules for us were j l
5 developed in October '92. That's when you gave us our -- '
6 MR. WALKER: And the testing was done before 7 1994 --
8 MR. BECKETT: Including all of our Unit 1 l l
9 tests. So we used the criteria that you had given us 10 consistently throughout the Unit 1 test, after we 11 approached the Staff to ensure that that methodology was 12 acceptable.
13 MR. MARSH: You've done the testing of Unit 1 t
\_/ 14 the same way you've done for Unit 2 --
15 MR. BECKETT: Yes, that's correct. )
16 MR. MARSH: -- and you believe that the 17 commitment was for you to do testing -- the same way, 18 as Unit 2.
19 MR. BECKETT: Yes, that's correct.
20 MR. MARSH: And you say that the Staff and you 21 agreed upon testing methodology for Unit 2 and Unit 1?
22 (No response.)
23 MR. MARSH: Okay. I'm hearing it. Let's go 24 on. I want you to develop that table that we talked (O) 25 about, the representation, and --
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i t 27 1 MR. GILL: Ted?
,_ 2 MR. MARSH: Yes.
+ i 3 MR. GILL: Also, I think we would want them to 4 identify what configurations are not bounded. At least we 1
5 would know -- which ones are bounded and which ones are 6 not. I would think that information would be helpful.
7 MR. MARSH: Okay.
8 MR. WALKER: We need to understand something.
9 MR. MARSH: Yes? i l
10 MR. WALKER: Well, the reason I'm doing this, 11 I want to make sure we're in total communication when we 12 leave.
13 MR. MARSH: Right. '
n
-- 14 MR. WALKER: When he says, to tell them which 15 ones are unbounded -- what --
16 John?
17 MR. WHITE: John White. We -- do have 18 conflicting criteria here, and now when the electrical 19 guys begin to talk about what's bounded, I'm going to --
20 I'm assuming you're talking about from a cable 21 functionality standpoint. Am I correct?
22 MR. GILL: I was basically following up in 23 terms of additional information that would be helpful 24 to -- you know, go beyond that point, to see what
/~N t, j 25 configurations are bounded or not bounded.
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28 1 MR. WHITE: Well --
,-s 2 MR. GILL: I wasn't thinking so much of
\' ] 3 functionality, which we -- would follow later on.
4 MR. WHITE: -- ultimately, what we're 5 concerned about is cable functionality. If we don't have 1
6 cables in these raceways -- you know, we don't have !
7 anything to protect. And in the May 22 letter, Sandia 8 National Labs and the Staff took the position that there 9 are competing requirements here.
10 When you increase the thermal mass, yes. You 1
\
11 are going to increase the ability of the cable in that l l
12 configuration to dissipate heat. However, you're also 13 increasing the metal-to-cable surface contact, which is l p
\> 14 actually going to give you a higher temperature profile 15 measurement than the increased thermal mass will.
16 So even though --
17 MR. CONNELL: Where are you going to get a 18 higher temperature profile?
19 MR. WHITE: Well, because we have --
20 MR. CONNELL: No, where? Where? Not why, 21 where?
22 MR. WHITE: At the individual hot spot 23 locations. The temperatures -- on the cables --
24 MR. CONNELL: You're talking about the
/s
( ,) 25 temperatures on the cables.
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- 29 l
l 1 MR. WHITE: Right.
l t
l rx 2 MR. CONNELL: Not on the raceway, on the side 1
1 (\~s) 3 rails, or on the conduit's surface. Those --
l 4 MR. WHITE: On the cable itself.
5 MR. CONNELL: Right. Those cemperatures are 6 going to be higher, with a lower cable fill.
7 MR. WHITE: Okay. But --
8 MR. CONNELL: And you're telling me about a 9 mechanical property, where you're putting mechanical 30 pressure on the cable-jacketed insulation, versus the 11 thermal properties of the enclosed raceway.
12 MR. WHITE: Right.
13 MR. CONNELL: Okay.
k- 14 MR. WHITE: And the way we had performed our 15 functionality evaluation is based on the -- I guess 16 mutually agreed upon -- criteria that a composite analysis 17 is the best to do this. So we're taking segments of the 18 cable, and looking at individual hot spots.
19 MR. CONNELL: But these are for cables --
20 you're looking at cables for barriers that have -- did not 21 meet the temperature acceptance criteria.
22 MR. WHITE: Correct.
23 MR. CONNELL: So they've already failed the 24 temperature acceptance criteria; the barrier's already l
l
(T
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30 l
1 high, so the thermal mass issue is no longer a factor. !
1
_ 2 So when you talk about the mechanical I 3 concerns, that's after the fact that the barrier has 4 already failed to meet the temperature criteria. It's 5 opened up, or whatever has happened to it.
6 So I don't see how they're conflicting. The 7 thermal issue is -- the thermal mass drives it until that .
8 barrier opens up, and then the mechanical concern comes 9 into play downstream for doing your cable functionality i
10 evaluation.
11 So they're really not competing; they're 12 really in series.
13 MR. WHITE: Okay.
[
\# ~ 14 MR. TERRY: Is that true? That's not my 15 understanding of what you've described to me. My 16 understanding of what you described to me was that the 17 more loading you have in a particular raceway, the least 18 points of contact that you will have with the actual 19 conduit itself, and therefore the more hot spots that 20 could potentially develop, and that's why they're saying 21 that there would be a more significant effect with the 22 higher loading. Whether or not it opens up the barrier.
23 MR. WHITE: Right. I'm going to be -- the way 24 the May 22 letter was worded, was that as we increased the
/x
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I 31
! 1 and that's going to give us -- and identify hot spots
,_ 2 better. So the configuration that we're looking at is
(' ') 3 going to identify the hot spots better, even though the 4 average temperature of the whole entire run may go down.
5 MR. JENKINS: This is Ronaldo Jenkins. In 6 terms of the hot spots, the hot spot issue I have to agree 7 with Ed, comes up after you have a barrier that basically 8 does not meet the acceptance criteria.
l 9 You're talking about a marginal barrier, and l l
10 the cable functionality evaluation is used to justify the 11 marginal -- performance of that barrier. And so at the 12 time that you have the burn-through, you have now -- you 13 have to be concerned about the fact that there may be i
/~N I km 14 local hot spots developing, and you have to evaluate those j 15 indications.
16 So it -- comes after -- I think Ed's issue 17 really is more generic in terms of bounding the 18 performance of barriers that you would have in the plant, 19 with respect to their nominal performance; whether they 20 are -- in fact one hour barriers.
21 The -- you're not -- the cable functionality 22 argument only enters in when you're talking about, Now I 23 have a barrier that's a marginal performer. Is it okay to 24 use that barrier or not?
() 25 MR. CONNELL: Right. And you're not doing NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W (202) 234-4433 WASHINGTON, D C. 20005-3701 (202) 234-4433
32 1 cable functionality evaluations for barriers that met the 2 temperature acceptance criteria. So the mechanical Os V 3 concerns are -- you don't even consider those, because if 4 it passed the temperature criteria, that's -- you know, 5 acceptable to the Staff as is; no further evaluation is 6 necessary.
7 VOICE: Okay.
8 MR. TERRY: Lance Terry. Let me just clarify 9 one more thing. When you caucus, we will also caucus and 10 we will provide you the table, and we will talk about 11 whether or not we have actually identified the specific :
12 ones that would fall below the representative loading we 1
13 have. l (V 14 MR. MARSH: All right.
1 15 MR. TERRY: We'll talk about that and get back l I
16 to you.
17 MR. MARSH: You should also discuss the 18 testing that you've done on Unit 1 and Unit 2 and how they 19 are the same, and if it is true that your perception --
20 your understanding is that there was agreement made with 21 the Staff that you were supposed to test them this way, 22 and then no other way.
i 23 And where is that docketed, and where is that i
i j 24 understanding written down? I'd like to reference where C 25 that understanding is.
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l 33 1 MR. WALKER: I think it's in correspondence, 2 but it also would probably be in meeting notes --
73 3 MR. MARSH: I'd like that -- I'd like you to 4 find that --
5 (All speaking at once.)
6 MR. MARSH: -- where you say we've agreed to 7 this. We're going to be doing the same thing.
8 Okay. Well, let's see. That took us about a 9 half an hour to go through one issue. That's --
10 MR. WALKER: Two.
11 MR. MARSH: Okay. Right. One closed, one 12 open.
13 MR. CONNELL: Okay. Next issue is, Hose
~s
\- 14 Stream Test Performance, specifically to Test Scheme 11-4.
15 As you're aware, barrier material was dislodged from the 16 bottom of the enclosure, exposing the bottom of the tray 17 following the fire exposure test.
18 The hose stream part of the fire barrier 19 qualification has been around for about 70 years. It's 20 supposed to be representative of an impact, cooling, 21 erosion that might occur to the fire barrier during and 22 immediately following a fire exposure.
23 TU Electric, in their September 24, '94 letter l
(
24 committed to perform the hose stream test. They also
, O)
(_ 25 committed to obtain a NRC Concurrence for Deviations from NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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34 1 the Acceptance Criteria, prior to declaring a testing 2 configuration acceptable. They did not do this with O
V 3 regard to Scheme 11-4.
4 The NRC letter that followed that September 5 '92 submittal, the October 29, '92 submittal, reiterated 6 the hose stream test. A -- for Unit 2, a similar scheme, 7 Scheme 12-2, opened up during a hose stream test. This 1
8 particular configuration was upgraded in the plant from l 9 the testing configuration to resolve that issue prior to 10 being accepted by the Staff.
11 In the most recent, October 24 submittal, the 12 licensee associated the hose stream tests with a visual 13 inspection of thermal damage, and of course there was no O
N'# 14 correlation between the hose stream test performance and j i
15 thermal damage.
16 So I'm not sure what that correlation is 17 intended to meet. So basically, you know, the hose stream 18 test is part of the acceptance criteria. It's been part I
19 of the acceptance criteria. You agreed to it. And for 20 this particular test scheme, it did not meet that criteria 21 and you haven't done anything to resolve that issue.
22 MR. BECKETT: Jim Beckett.
23 We went back and reviewed the tapes of that 24 test to satisfy our curiousity. Those enclosures i
(~N l
1
(_) 25 basically stood together for almost the entire duration.
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l 35 1 We do agree with you, the enclosures did open -- it
~~ 2 appeared to open due to some extenuating circumstances.
t' 3 It opened right at the tail end of the Hose Stream Test.
4 Those items notwithstanding, those enclosures 5 were provided with additional upgrade. The tested 6 configuration had a simple stress skin stapled overlay 7 which had proven successful on most of the configurations, 8 but we have also tested commodities with relatively large 9 spans, and we singularly tested them with what we call a 10 stitching, which I'll describe for you briefly.
11 The thermal-lag has got a steel reinforced 12 dress skin on the backside, and you penetrate two adjacent 13 boards; you run wire, and you hard-couple those together t i k# 14 where they cannot move relatively. As a result, the fire i 15 hose stream -- we used that method to upgrade these i 16 enclosures, plus we also included the stress skin that was 17 in those -- tests.
18 So those enclosures have been double-19 reinforced.
20 MR. MARSH: When were they double-reinforced?
21 MR. BECKETT: During the installation; prior 1
22 to the completion of the job in '94.
23 MR. MARSH: In other words, since -- l l
( 24 MR. TERRY: They were never --
7x i
(,) 25 MR. BECKETT: Yes, it was part of that test --
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36 l
1 MR. TERRY: As a result of that test, we did l
, 2 that stitching --
t i k' i 3 MR. BECKETT: I don't think we addressed your 4 specific question. My understanding of your specific 5 question was, because of the fact that the barrier opened 6 up during the Hose Stream Test, you're saying that we had 7 to do a cable functionality, and we didn't do it --
8 MR. CONNELL: No, no. Cable functionality has 9 absolutely nothing to do with the Hose Stream Test. The 10 cables are not going to fail -- following the impact of 11 water.
I 12 What we were looking at was a -- the Hose 13 Stream Test is simulating an impact erosion, cooling of 1
,O
(_/ 14 the barrier assembly during and following the fire 15 exposure.
16 If the barrier fails to meet the hose stream 17 performance criteria -- and I think this was specified in 18 a lot of the generic communications that went out -- then 19 the licensee has to evaluate the performance of the 20 barrier during the Hose Stream Test, and evaluate each 21 specific plant and solid configuration that's using that 22 tested configuration, to determine if the performance of 23 the barrier during the Hose Stream Test is significant to l
j 24 the expected performance during a fire in the plant.
r%
( ,)
25 And that has not been done. We've ask for it NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W (202) 234-4433 WASHINGTON, D C. 20005-3701 (202) 234-4433
i 37 1
l 1 several times. And I've gotten basically saying that,
- 2 Well, we did a cable functionality evaluation, and cable
~
3 functionality, and looking for thermal damage on a cable, 4 there's no correlation with the Hose Stream performance.
5 The Hose Stream performance was strictly 6 testing the barrier. It had nothing to do with the cable.
7 MR. MARSH: Furthermore, they're saying 8 something different than I think we understood --
9 MR. CONNELL: Yes. They've never -- told us 10 that the barrier was upgraded. I specifically -- on the 11 original RAI that I wote a couple of years ago, I did 12 mention that the Unit 2 Scheme, 12-2, was upgraded and 13 basically said, you know, What is your proposal for i
k- 14 addressing this particular Unit 1-specific scheme, and got 15 a response saying that -- you know, it didn't apply or 16 something. It really wasn't very clear.
17 MR. WALKER: We apologize for that --
18 MR. CONNELL: But if in fact -- this -- the 19 plant-installed configurations they're using, Scheme 11-4, 20 have been upgraded so that they're -- you would expect, 21 based on an engineering evaluation -- that they would not 22 fail during the Hose Stream test, that would be i 23 acceptable. It would have been acceptable two years ago.
l 24 MR. WALKER: I think -- this one was. I think q,) 25 all along, our people read what you were looking for was l
l NEAL R. GROSS
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! 38 l
! 1 to evaluate the cables, because you -- of your concern on 1
1
- 2 the fire barrier. That's what we did.
('~/
3 You are asking us for something that maybe we 4 didn't perceive you asked for. We --
5 Did we perceive that he was asking to evaluate 6 the barrier performance?
7 (No response.)
8 MR. WALKER: And that's our problem. We did 9 not do that because we never perceived that that was what 10 was being asked. Maybe we don't know how to read or 11 understand English; that's possible. But that's what -
12 MR. CONNELL: I think it was -- thought it was 13 pretty clear.
14 MR. TERRY: Well, when we upgraded the Unit 2 15 and we did that upgrade on Unit 1, we'll got back and 16 confirm that, but that's -- that was installation after 17 that, was to tie those large spans --
18 MR. CONNELL: I mean, the question that I 19 asked back in May '94 was with regard to thermo-lag box 20 assembly tested in Scheme 11-4:
21 " Provide a technical basis for accepting this 22 configuration concerning the performance of the assembly
. 23 during the Hose Stream Test. When barrier material was 24 dislodged, exposing the bottom of the cable tray, and O)
(, 25 considering the decision by TU Electric to reinforce the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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l 39 l
1 attachments for CPS Unit 2, assembly tested in Scheme 12-2
-s 2 based upon its performance during the Hose Stream Test.
us 3 "This Scheme is listed in Appendix C," blah, 4 blah, blah, and there are some other, minor, trivial 5 issues there.
6 MR. WALKER: You're not going to believe this, 7 but to me that meant provide cable functionality. And 8 that may be because --
9 MR. CONNELL: Cable functionality wasn't in 10 anything I just read --
11 MR. WALKER: I understand. But its bearing on 12 the six or so years we've been listening to this, that
,. 13 would have come across to me is, he felt we failed the
' 14 barrier and needed a cable functionality. That may be 15 wrong, may be right, but that's the way it would have come 16 across to me.
17 MR. TERRY: But, bottom line. We can provide 18 that information?
19 MR. BECKETT: Yes, we can. We've actually 20 already confirmed the plant installations. We do 21 understand what you're saying, and we can provide that.
22 MR. TERRY: Well, one thing we do need to make 23 clear. I think one of our problems up front is, we never l
24 felt that the barrier failed, in actuality. That's 25 what --
l l
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40 1 MR. BECKETT: The video actually showed the l
fs 2 thing opening up after the fire test, after the hose i \
U 3 stream was effectively done --
4 MR. TERRY: Yes. And independent of that, we 5 can go back and provide what you're asking for. We didn't 6 interpret it that way. And that's maybe an honest error, 7 maybe we're just stupid. But we didn't interpret it that 8 way.
9 MR. BHATTY: Let me another question: There 10 was a response to your first questions that you just 11 read --
12 MR. CONNELL: Yes.
13 MR. BHATTY: -- we did provide it, on June 16, 10 k-) 14 1994.
15 MR. CONNELL: Yes.
16 MR. BHATTY: In there, I think I tried to go 17 back over there and talk about the hose stream analysis.
18 I went back again to cable functionality --
19 MR. CONNELL: Right.
20 MR. BHATTY: -- okay.
21 MR. CONNELL: Which has nothing to do with it.
22 MR. BHATTY: The logic that we provided, does i 23 that not satisfy the hose stream analysis?
24 MR. CONNELL: No, because your logic is
/~N i
i ( ,) 25 looking -- and it's reflected in the most recent letter NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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l 41 1 following the SER, which I have.
2 MR. BHATTY: The October 24?
7- t
\
V 3 MR. CONNELL: It says, " Based on" -- we were 4 talking about the Scheme 11-4, as tested -- " met the 5 requirements contained in the NRC letter dated October 29, 6 1992." It does not -- it failed the Hose Stream test. So 7 that was wrong.
8 It says, "The barrier opened during the Hose 9 Stream Test. However, a visual cable inspection revealed 10 no apparent thermal damage to the conductor insulation."
11 As stated before, you would expect thermal 12 damage as a result of failure of the Hose Stream Test.
l 13 That's related to its performance in the furnace. It had l G
- 14 nothing to do with -- a hose stream isn't going to cause 15 thermal damage.
16 So that's -- you know, why I think you guys --
17 I don't know what you were doing, but it was clearly --
18 MR. BHATTY: Well --
19 MR. CONNELL: -- off base of what was I l
20 intended.
21 MR. BHATTY: -- now, that's not true --
22 MR. CONNELL: Okay --
23 MR. BHATTY: -- because we basically go back i
l 24 and tell you, in our June submittal, that given the nature
) 25 and location of that barrier opening -- okay? --
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42 1 significant damage to contents in such barrier 2 configuration would occur.
l /~'\
3 But, you know -- so it satifies the intent of l
4 the hose stream. So we tried to analyze it. We didn't 5 write down big letters in front of it, that this is the 6 analysis of the Hose Stream Test. But we did give you a 7 justification -- )
8 MR. CONNELL: Do you have an engineering 9 evaluation for each place in the plant where this 10 particular test scheme is used to justify configurations?
11 MR. BHATTY: Since we did the upgrades, I 12 don't think we need that, but --
)
i 13 MR. CONNELL: No, you don't. l p
ks 14 MR. BHATTY: Okay.
15 MR. CONNELL: But I mean -- so you don't have 16 an engineering evaluation.
17 MR. BHATTY: 3o, tying this letter -- okay.
18 That's where we made our mistakes. We were not tying 19 every letter together. What we did was, in this letter we 20 gave you the analysis. You may call it, Engineering 21 Analysis for the Hose Stream Test.
22 And then we cama back and said, However, we 23 upgraded --
l j 24 MR. CONNELL: Well, you never told us you
/~
is ,N) 25 upgraded it.
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43 1 MR. WALKER: Well, did you -- the resolution 2 of this issue appears to me that we go back and justify --
fS 3 MR. BHATTY: I thought we did that -- -
4 MR. WALKER: -- that. We --
5 MR. CONNELL: If you've provided an upgrade 6 that -- and you have confidence, based on an engineering 7 evaluation if you went and actually tested this thing 8 again, it wouldn't fail during the Hose Stream Test, that 9 would be acceptable.
10 MR. WALKER: Okay.
11 MR. TERRY: Does subparagraph (d) in our 12 October response -- that tells you we did the upgrade.
13 MR. CONNELL: But it doesn't say what that (N'
14 means. Was that where it failed, the additional stitching 15 and stress skin?
16 MR. BECKETT: These boxes have been double-17 reinforced throughout the entire box assembly, so that 18 they would not be subject to any weaknesses that we could 19 perceive might transpire --
20 MR. CONNELL: But none of this information was 21 in the Engineering Report, Rev. 3 of the ME-067. Right?
22 MR. BHATTY: No. But we will revise --
23 MR. CONNELL: Which is what the -- my SER was 24 based on.
(Q
'(,/ 25 MR. WALKER: I understand.
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l 44 1
1 MR. CONNELL: Okay.
I 7-~ 2 MR. WALKER: But we -- well, we intend to put
.]
3 in an update of the Engineering Report, and submit it by 4 January 15.
5 MR. CONNELL: Okay.
6 MR. WALKER: We can get by this issue. I just 7 want to -- I think, technically the result of it --
8 MR. CONNELL: Okay.
9 MR. WALKER: I think you would agree that if 10 we did that, we'd get by this issue.
1 11 MR. CONNELL: Yes. I agree that if you made l 12 upgrades so that you have reasonable confidence this thing 13 would stay together following the Hose Stream Test, then i l i s
NJ 14 that's acceptable.
15 MR. WALKER: Okay.
16 MR. CONNELL: As it was for you to do.
17 MR. WALKER: And if we did not provide that 18 information -- up front, I apologize.
19 MR. CONNELL: Yes. Plus Unit 2. Okay. See, 20 this goes to -- sorry.
21 MR. COLLINS: Let me ask a quick question: Do 22 we agree that it's failed the Hose Stream Test.
23 MR. BECKETT: Well, that was questionable, 24 according to the video, when we went back, and --
,s t )
(_/ 25 MR. COLLINS: No, we say --
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45 1 MR. TERRY: -- you don't agree we failed --
7_.s 2 and I'm hearing, we for some reason think it failed. No.
i 3 We say that it did not pass because when we did the 4 inspection, it was opened up. So -- we're saying that we 5 needed to go do an upgrade. And we did.
6 MR. WALKER: I think, Sam' -- originally, I 7 think our technical people did not believe it, but we've 8 come to that conclusion, so --
9 MR. COLLINS: We -- I'm not sure on what 10 basis. The letter appears to be written based on the fact 11 that upgrades are needed, but those upgrades are 12 enhancements.
13 MR. WALKER: That's the original way we
'A
\~)\ 14 approached this; those upgrade standard -- ;
15 MR. COLLINS: Whereas, I think where we were 16 coming at it -- was that the test was a failure.
17 MR. WALKER: Yes. And I understand it.
18 MR. TERRY: Sam, if you look at this chart, 19 here -- part of our confusion was, okay? If you look at 20 that chart, and this is what we worked with for a long l I
21 time in '92 to get -- the acceptance criteria.
1 22 This would say that if we had burn-through -- j 23 and if it failed on the post test, that was also ;
l 24 considered burn-through -- thet if it failed that, then l l
("%
q,) 25 you needed to go to -- it was considered a failure of the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE , N W.
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46 l'
l 1 test, and you needed to go to cable functionality.
g_ 2 Probably part of the confusion that we've had
! (
\ %J 3 all along is to the' fact that you were saying, It opened 4 up, therefore you need cable functionality. And we've 5 been trying to answer that question; you've been asking us j 6 a different question than that. l I
7 MR. BECKETT: You see, we did not interpret -- l 1
8 MR. CONNELL: It didn't open up during the 9 fire insult. It opened on the Hose Stream Test --
10 MR. TERRY: And we agree with that. And --
11 but we did go in, and we recognized that we needed to j l
12 reinforce that scene when that one opened up, and went in I 13 and we made part of that installation be, that -- to put
(_/ 14 stitching in there, that issued a distress signal.
15 MR. BECKETT: I would like to add to that, 16 that apart from the opening of the enclosure, that that 17 test -- thermodynamically went very well --
18 MR. CONNELL: Yes.
19 MR. BECKETT: -- the temperatures inside were 20 very mild --
21 MR. CONNELL: And I wrote that in the safety 22 evaluation --
23 MR. BECKETT: -- it was a very good test, and 24 we all are aware of that. And the cables were in
( 25 excellent shape as well, from the visual --
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47 1 MR. CONNELL: Yes. That's why cable g 2 functionality wasn't an issue for this particular test,
'~
3 the temperature acceptance criteria; but it did not meet 4 the Hose Stream acceptance criteria. And they are 5 separate criteria.
6 MR. BECKETT: Okay.
l 7 MR. CONNELL: Let's close it. Move on -- l 1
8 MR. WALKER: I think we just want to --
9 MR. CONNELL: -- to the next one. Great.
10 Okay. The next one is Thermo-Lag Fire Stops. And this 11 one has been -- what I perceive as a lot of different 12 information.
13 In the -- Rev. 3 of the Engineering Report ME-14 067, Scheme 4 is listed, and tested as a Thermo-Lag Fire 15 Stop. Now, this test scheme was never provided to the 16 Staff for review.
17 Appendix E of that same Engineering Report 18 references Scheme 4 as applicable to fire stops installed 19 at Comanche Peak Unit 1. A TU letter dated June 16, '94 20 states that Thermo-Lag was used for fire stops at Unit 1.
21 That same letter also stated that Scheme 4 22 demonstrated that Thermo-Lag 330 is acceptable for fire 23 stop applications.
24 And in the recent, October 24, '96 letter, the
/~N
() 25 licencee states that Scheme 4 was not used, and that an NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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l l 48 1 electrical standard, MS-38H requires silk on elastymer l
t
,f S 2 [ phonetic) fire stops.
, \ )
'~'
3 And as a correction to the October 24 letter, 4 Scheme 11-2 was not included in the Supplementary Safety 5 Evaluation Report 26, as stated in your letter.
6 So the bottom line for this is, did you use l 7 Thermo-Lag as a fire stop material, where a barrier is not 8 continuous into walls, or didn't you?
9 MR. BHATTY: I'm going to let Gene go ahead 10 and answer that one. Okay? But the first portion, I'm )
11 going to go ahead and answer that. That we did not use 12 Scheme 4. i 1
13 We made an error when we were revising O
k/ 14 Engineering Report ER ME-067, from Rev. 2 to Rev. 3, and 15 somehow the other -- we made an error and put that in 16 there.
17 We indeed used three schemes to certify the 18 fire stops, and Gene would get into that -- the different 19 configurations of how we did that; how do we use silk on 20 foam, or elastymer. But that was an error on our part:
21 when we revise the Engineering Report in the next 22 revision, it will clearly state that Scheme 11-5, 14-1 and 23 11-2 were used to certify fire stops.
24 MR. CONNELL: And those are all silk on 1
[~h
!q,) 25 elastomer --
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49 1 MR. BHATTY: They are. Some of them are silk fx 2 on elastomers, and some of them are silk on foam. And I \
3 they are acceptable tests --
4 MR. TERRY: I want to point out that there is 5 an error in this -- the specs that -- to use elastomer, 6 there were several applications where there was a design 7 change to the spec, on -- alterize [ phonetic) the 8 engineering document that we used silicone foam with 9 Thermo-Lag, and that was not caught when this was put l
10 together, and I want to be up front that there is an error 11 in this response, and -- I 12 MR. BECKETT: Yes --
13 MR. TERRY: -- Gene, why don't you ahead and h !
14 address it.
15 MR. BECKETT: We have two tests, Ed. We have 1
16 Fire Test 11-2, that included silicone foam as the fire I 17 stop material. That was a successful test for that 18 application.
19 We have also used First Test 11-5, which has )
20 silicone foam in it. And Fire Test 14.1 uses elastomer ,
21 fri a tire stop material. We wanted to ensure that both .
l 22 types of foams were adequate for fire stop applications 23 and fire barriers.
For Unit 2, you've indicated -- you've been I 24 (D
(_) 25 shown a familiarity in your document. Basically, on Unit NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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50 1 2 we used elastomer, but when we ran the Unit 1 fire test, 2 we switched over to the silicone foam, to also gain
('l 3 approval and ensure that it was appropriate for use in 4 this test commodities.
5 Thermo-Lag itself is historically not used as 6 an internal fire stop, where it might be put somewhere 7 within the barrier.
8 We -- where cables exit, certain 1
9 configurations were considered fire stops; it's very 10 similar to the protruding item of extension. We do use !
11 some Thermo-Lag for that, and we do use -- we consider 12 that as a fire stop on some cables where they do exit.
13 And those were included in the test commodities.
(3 k/ 14 But we looked at our words, and went back with 15 an open mind to see what we had said earlier, and when we 16 make reference to foam and Thermo-Lag -- and it might be 17 confusing, so I want to make -- take a moment to clear up l
i 18 any potential confusion that has or may arise in that.
19 Normally, when we put our fire stops, let's 20 say that we're running protected cable down a tray, they 21 go sa a T, and take a different direction. We'll go down 22 a ways and we'll terminate that tray beyond the protected 23 cable.
24 And we may have -- you'll have other cables O
d 25 continuing up, but we will put a fire stop in that. The NEAL R. GROSS COURT hEPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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i 51 1 object of the test was to ensure the silicone foam and I
_ 2 elastomer both were adequate in the depths that we tested,
\#
3 that -- would turn out to be adequate, and normally, 4 though we would go ahead and take that enclosure, and cap l 5 off with a Thermo-Lag panel on the end.
i 6 So there are some references as to foam, l l
1 7 Thermo-Lag interface, and I don't want that to cause any 8 confusion in our response. )
9 MR. WALKER: Gene, I don't want to put words 10 in your mouth, but I hope you will agree with me that all 11 our fire stops we have out there are configured consistent 12 with tested configurations --
13 MR. BECKETT: Absolutely.
O)
\s / 14 MR. WALKER: -- yes, we may have the wrong 15 references, and we need to correct those --
16 MR. BECKETT: That is correct. I don't know 17 how it happened. The only thing I can figure -- is that 18 maybe we started to make a reference to 14.1 for some 19 reason, and it would up as a typo -- maybe the -- it was 20 garbage, and we just missed it on the back check.
21 But we'll put the proper references, and we'll 22 bring that up to date.
23 MR. CONNELL: Okay. What is the acceptance 24 criteria we used for these fire stops? Is it the same as
( -)
s_
25 what was agreed to in the October '92 criteria? Same NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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i l 52 1 temperature criteria?
l l 2 MR. BECKETT: Yes, sir.
l l
l j
Q 3 MR. CONNELL: Okay. So there's no -- you're 4 not using the I-EEE-634 penetration --
5 MR. BECKETT: No.
6 MR. CONNELL: -- that was referenced in 7 several of your engineering reports.
8 MR. BECKETT: That was a poor attempt on our 9 part, too, because we used a penetration seal design out 10 of our penetration seal program, that -- while that 11 penetration seal was governed by that particular standard 12 in the tested wall configuration, that notwithstanding, we 13 needed to test that configuration in the barrier to make l
(~
14 sure that it also quaiified under our agreements with the 15 NRC, on proper testing and temperature limits for the 16 barrier itself.
17 MR. CONNELL: Okay. Because as I stated in a 18 previous, RAE, you know, that our position was that the 19 fire stop is an integral part of the barrier. It is not a 20 penetration seal similar to what you would have with a 21 floor or a wall, or something like that.
22 MR. BECKETT: And we totally concur with your 23 position --
24 MR. BHATTY: We concur with the position.
( /i
(,,/ 25 It's just how our pencil just kept on going with I-EEE-NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W (202) 234-4433 WASHINGTON. D C. 20005-3701 (202) 234-4433
53 1 634. Sorry about that.
73 2 MR. CONNELL: Well, I mean, you know what you 1
3 have. And you have tested -- test data that meets the 1
4 October ' 92 criteria for temperature and hose stream, et i
5 cetera. You know, that would be acceptable.
6 But the information that I got, you know --
7 led me another way.
8 MR. BRATTY: And we --
l 9 MR. BECKETT: You're going to have to clear !
1 10 that up. '
11 MR. BHATTY: -- in our revision to the RME-067 12 would correlate that, and what type of -- the 13 configuration, what -- and we can even provide you with s- 14 some additional information on what types of fire stops we l 15 have, and which test is applicable to that test.
16 MR. CONNELL: Well, that's --
17 MR. BHATTY: Okay.
18 MR. CONNELL: -- what's required. And I think 19 that's true for the silicone foam fire stop issue as well.
20 MR. BECKETT: On Item 4 --
21 MR. CONNELL: Yes.
22 MR. BECKETT: -- so effectively, we've 23 addressed both items.
I 24 MR. CONNELL: That's right. And that -- yes,
! A
(_,) 25 that finishes the open issues that I was responsible for.
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54 i
l 1 Ronaldo has the cable functionality issues.
i p 2 MR. JENKINS: Okay. And hopefully, that's k'
3 going to go along fairly quickly.
4 MR. WALKER: Can I ask a question?
5 MR. CONNELL: Sure.
6 MR. WALKER: Item 3 and Item 4 were connected.
7 Can I assume we just talked about Item 4 --
8 MR. CONNELL: Yes --
9 MR. JENKINS: He said that.
10 MR. WALKER: -- oh, I'm sorry. I didn't -- I 11 missed that.
12 MR. CONNELL: -- fine.
13 MR. JENKINS: Okay. Going on to Item 5, the k2 14 Test Scheme 9-3, involving one and -- one and one-and-a-15 half inch, and the two-inch conduits.
16 In the SSER 26, dated in February '93, the 17 Staff reviewed Scheme 9-3 for Comanche Peak Unit 2, and 18 determined that the configuration deviated from the 19 acceptance criteria.
20 Subsequently, the licensee submitted this 21 scheme for Unit 1 application, along with several other 22 test reports and schemes.
23 The Staff looked at the reports and the 24 evaluations, and we deve].oped an REI which raised O 25 questions regarding cable self-heating, barrier burn-l t
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55 1 through damage, and the use of -- surface cable
- 2 temperatures for IR -- or insulation resistance N] 3 determination.
4 In the TU Electric response dated 8/8/94, 5 essentially licensee said that the cable self-heating be a 6 concern for power cables only, and that the use of no 7 temperatures was overly conservative.
8 The letter also talked about acceptable l 9 reasons for observations of burn-through for other test l l
l 10 schemes, not for Test Scheme 9-3. I 11 In our SER, we reviewed the evidence on Scheme 1
12 9-3, and determined that it had not -- that that l 13 information did not demonstrate that the barrier would
(~)
k/ 14 be -- provided cable functionality in light of the burn-15 through evidence, the hot spots indications, and the 16 unacceptable IR values.
17 Lastly, we've gotten a letter back from the l
18 licensee which contends that the LBDs and radical bends l
l 19 have been upgrade to mitigate the barrier damage, a new 20 temperature profile shows acceptable estimated IR values, 21 and that cable self-heating is not a concern to 100 22 percent capacity margin for the applicable cables.
23 Now, that's -- as we understand it.
24 MR. WHITE: That's correct.
/3
( ,) 25 MR. JENKINS: Okay. So did -- j l
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56 1 MR. WHITE: Yes, you've summed it up just
_ 2 about as well as I could have. Do you have any additional
'-) 3 questions, or do you concur with this, or --
4 MR. JENKINS: Well, the questions on -- we 5 have separate questions on the response, but I think we 6 need to -- I went back over the record, and we need to 7 clear up what the ground rules are; the use of the cable 8 temperatures.
9 I looked repeatedly in your responses back to 10 us; you consistently use the surface temperatures, cable 11 surface temperatures as the basis for acceptability of 12 cable functionality.
13 And the Staff has disagreed with that since
/D i
s/ 14 '92. The acceptance criteria, 10/29/92 acceptance 15 criteria stated that the cable tray side rail and external 16 conduit temperatures would be used to determine the 17 temperature acceptance of the fire barrier system, and 18 that in addition, your staff agreed that the cable 19 trays -- to also use -- the cable surface temperatures to 20 supplement the higher -- what would be expected, higher 21 raceway temperatures.
22 MR. WHITT : Okay. I'm -- back in -- well, I 23 guess one thing that -- you know, we're trying to look at 24 this from an overall standpoint. And we're using these --
O)
(_, 25 the cable surface temperatures right now, I guess for one NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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57 1 of two reasons.
2 One, it's the best data we have to accurately
/f'N V 3 ascertain what the cable performance is going to be. And 4 in the response that was sent, I guess before this one, 5 but Sandy also had input into -- in the original 6 functionality evaluation that we sent to you, we had used 7 the average temperature over the entire assembly to do the 8 functionality evaluation with.
9 And in that memo, you -- came back and told i 10 us, no, you don't need to use the average temperature.
11 Since you thermocoupled the cable at the six-inch 12 locations, those are the actual temperatures that you need l 13 use for your functionality.
(~\
k_ 14 And so we were -- in our response from that 15 point on, we were attempting to do that, because that data l
16 was available.
17 And you know, with regard to the opening of 18 the barriers, again I have to apologize for this; there is 19 so much information going back and forth that all of the 20 areas where we experienced burn-through were at the LBs 21 and the radial bends, and all of those were upgraded.
22 So we're not going to even see this severe a 23 thermal profile when --
24 MR. WHITE: When were they upgraded?
(~N
( ,) 25 MR. JENKINS: I guess from the day that --
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I 58 l
l 1 MR. BECKETT: They were upgraded during the i ,3 2 original installation, because some of the earlier tests
! )
3 on Unit 2 showed that for certain orientations of box-l l 4 outs, around LBDs, tha the LBDs were aggressively attached l
5 by fire, and in certain orientations they could loosen, i
6 and cock [ phonetic], and potentially open at the edge.
l 7 So we adopted at that time, for Unit 2, an 8 upgrade method of overlaying stress skin and reinforcing 9 the connection between the LBDs and the conduit protection l
l 10 together, and we tested that configuration successfully.
11 Also involved in some of the earlier 1
12 experimental tests, we also noticed that the radial bends l 13 also took a considerable aggression from the fire test,
/
\ ,
\- 14 and that they needed to be reinforced. So when we went 15 into our November test program for Unit 2, we did 16 successfully test all of those upgraded configurations.
17 And we have utilized the reinforcement of 18 those commodities on Unit 1 as well.
19 MR. TERRY: Let me correct one thing you 20 said -- we're talking Unit 1.
21 MR. BECKETT: Yes.
22 MR. TERRY: And you said, that was in there 23 since the initial installation. It was not on Unit 1 on l 24 the initial installation --
(D 25 MR. BECKETT: Oh, yes.
l ( ,/
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59 1 MR. TERRY: -- when we went in and did the 2 backfit on Unit 1 in late 1993, we in fact upgraded the (g) ,
'~' '
3 pull boxes and the radial bins.
l 4 MR. BECKETT: Oh , yes. Thank you, Lance. I l 5 didn't mean to --
6 When we completed -- it was done in the 7 upgrades that were completed in '94. That was an integral ,
l 8 part of the upgrade work. I l
9 MR. BHATTY: And here was another example of 1
1 10 what we thought we were giving you, and we did not -- when l 11 we submitted it, the different schemes, what we were going 12 to test we did write down -- in Scheme 13-2 that was
,_ 13 applied for Unit 2 -- we did do the upgrades on two-inch k- 14 conduit, and tested that. And the tested configuration -- l 15 I mean, test, was acceptable.
16 MR. JENKINS: And of course that --
17 MR. BECKETT: For 13-2?
18 MR. BHATTY: 13-2.
19 MR. JENKINS: 13-2 on Unit --
20 MR. BHATTY: Unit 1.
21 MR. JENKINS: Okay. Well, we're talking about 22 9-3.
l 23 MR. BHATTY: I understand. He's talking about 24 the upgrade methodology used for 9-3.
>O
(_) 25 MR. JENKINS: Okay. So essentially, you had a NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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~. __ _ _ _
60
')
' L 'st that you performed on 9-3, we had these obsevations I
, _s 2 and indications, and you subsequently upgraded using the l f
V) 3 methodology that was acceptable for 13-2.
4 MR. BRATTY: Right.
5 MR. WALKER: But beyond that, I think that 6 you're telling them that we tried to do what they wanted 7 with respect to the analysis.
8 MR. WHITE: Right Yes. And you know -- and 9 I guess we -- I never married these issues together well 10 enough for you. We were asked to do a functionality 11 evaluation, we were proceeding, we were doing a l l
l 12 functionality evaluation based on the numbers that -- we I 13 hadn't upgraded anything. l
( ) J
\/ 14 MR. JENKII!S : Right. And that was our 15 assumption, that you hadn't upgraded anytLing, and --
16 MR. WHITE: When in fact we had.
17 MR. WALKER: So was it John's when he was 18 doing the analysis, by the way.
19 MR. JENKINS: And I think -- the important i
20 point is that the way we looked -- the SER developed the I l
l 21 approach list to look at the metal temperatures first, 22 determine what schemes -- whether they pass or fail. And .
1 23 then if they failed, then we would look at the other )
I 24 evidence that would be available, such as hot spot
) 25 indications, and burn-through, and then make a NEAL R. GROSS COURT REPORTERS AND TRANSCRIBE'tS 1323 RHODE ISLAND AVE., N W.
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61 1 determination based on that.
,_s 2 MR. WHITE: Right.
I i sj 3 MR. JENKINS: And under that, that's why 9-4 3 -- for the conduits failed, and also 11-2, the two-inch 5 air drop, also failed, which is the next item.
6 MR. WHITE: Yes. Correct. But we have -- but 7 we feel like that the functionality evaluations indicate 8 that even with this worst-case temperature profile, the 9 cables will still perform their intended function.
10 MR. JENKINS: Based on the metal temperatures, 11 or based on the -- I l
1 12 MR. WHITE: Based on the surface temperature 13 of the jacket. Which we also feel is conservative, r
- 14 because what -- we're really not concerned -- from a
]
15 functionality standpoint -- about cable jacket surface j 1
16 temperature. What we're concerned about is the 17 temperature of the insulation itself.
18 MR. JENKINS: Right.
19 MR. WHITE: And so -- I know I don't have to 20 explain this for the guys on this end of the table, but 21 when we have a cable construction, we have a copper 22 conductor that has an extruded insulation over that, 23 and -- on the other case it has an extruded jacket over 24 the top of that, which is -- in our case, is normally
/'s
(_) 25 always Hypolon [ phonetic], or chlorosulphanate [ phonetic]
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62 1 polyethylene.
2 That's a very good thermal insulator. So I
' 3 we're taking the surface temperatures on the outside of 4 the jacket -- which are going to be much more severe that i
5 the insulation it's actually going to see -- because 6 you've got another 30 mils of thermal barrier there.
1 I
! 7 MR. JENKINS: Well, I think part of the l
l 8 confusion is in the way you've gone about the process of 9 explaining that -- I mean, you've jumped immediately to i l
l 10 the end conclusion without necessarily developing the !
I 11 beginning argument. l 12 If you're going to say okay on the metal 1
1 13 temperatures -- if I use the metal temperatures using the l
/N I 5ss 14 composite IR approach that we all agree on, it failed. )
i i
15 Okay? It did not meet the acceptance criteria. Step two, J 16 then you look at, what are the other indications that j l
17 support or -- basically caused us to think that it did not i 18 provide functionality.
19 And what you're saying is, in using the cable 20 surface temperatures to supplement, that we believe that 21 that -- those cables are functional --
22 MR. WHITE: Yes.
23 MR. JENKINS: -- given the upgrades that have 24 already been performed.
l l [
( ,) 25 MR. WHITE: Well, actually even without the j i
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63 1 upgrades. We have upgraded; make no mistake about that.
2 But the cables -- the algorithms basically indicate 7-s V 3 acceptance levels that -- and we're assuming that the 4 upgrades were not performed for the purpose of this 5 analysis.
6 MR. JENKINS: Based on what?
7 MR. WHITE: Well, based on -- those are the 8 only numbers that we have available. The only cable 9 numbers for the temperature profile I have are based on 10 the 9-3 Scheme. That's what the functionality evaluation 11 originally started.
12 MR. JENKINS: Okay. But isn't that -- metal 13 temperatures available? I think you -- your position in (D
\-- 14 another letter said that they're unreliable, and therefore 15 you can't use them.
16 MR. WHITE: Right.
17 MR. JENKINS: So in effect, you just threw the 18 metal temperatures out.
19 MR. WHITE: Yes, I -- correct me -- there was 20 _ problem with the way a liquid bled out --
l 21 MR. JENKINS: Right. There was some l 22 failures --
l l 23 MR. WHITE: -- a superheated --
24 MR. JENKINS: -- right. There were three O( ,/ 25 thermocouples, I believe that --
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64 1 MR. BECKETT: Water gets driven into the l 2 inside, and it shorted out the thermocouple so that the t
73 a
?
Q 3 readings were unreliable.
4 MR. WHITE: Right.
1 l
5 MR. BHATTY: In this particular case -- in 9-6 3, yes. And we couldn't use the surface temperatures.
7 MR. JENKINS: Okay. So your acceptance 8 criteria, then is based on the cable --
9 MR. BECKETT: See -- unless the cables are 10 instrumented every six inches throughout -- continuously 11 from one end to the other.
12 MR. GILL: Is your jacket bonded to the 13 insulation?
I
\ In these -- cases, I don't believe 14 MR. WHITE:
15 they are. I'm not -- specifically -- you know, I'm not 16 going to say if we don't have any bonded jackets. But for 17 instrument cables, they're certainly not going to be 18 bonded; for control cables, they're not going to be 19 bonded.
20 And the bonded jackets which we included in 21 the fire test were double-jacketed cables. You had a 22 conductor that had an insulation jacket on that, and then 23 an overall jacket over the three conductors.
24 Those are the ones that you have the jacket 25 balloon and stuff, and the water got trapped in because of NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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65 1 the glass-break tape. So in the case where we had bonded
_ 2 jackets in the test, we had an extra jacket on top of the
(_) 3 normal cable Jacket.
4 MR. GILL: Okay, because that's going to be 5 important in terms of the functionality, whether it's I
6 Donded or not.
7 MR. JENKINS: Well, in August '94, you said l
8 that the cables with bonded jackets were utilized in the j l
9 glass within the fire barriers in Unit 1?
10 MR. WHITE: Yes. And we did not have any case i 11 there where the -- where jacket damage precipitated and 12 extended damage down through the insulation, or at all.
13 All of the jacket was limited to a few metals [ phonetic].
(~x
\ ')
14 MR. MARSH: Why -- you're not relying on this 15 any longer. You've upgraded the material. Now, why is it 16 important for us to agree or disagree on the functionality 17 aspect based on the cable temperatures?
18 MR. WALKER: Good question, Ted. I was having 19 the same question in my mind.
20 MR. JENKINS: But did -- have you tested your 21 upgrades?
22 MR. BECKETT: We did. We tested the two-inch 23 upgrade.
24 MR. MARSH: Have you provided that to us?
N
{j
(_, 25 MR. BECKETT: Yes, we did.
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I l 66 l
l 1 MR. MARSH: Okay. Well, this argument doesn't l 2 bear on anything else in the plan -- Unit 2, or anything 3 else?
4 MR. BECKETT: No.
i 5 MR. MARSH: See, I'm not sure we're ready to 1
6 buy -- and it may have generic implications if we buy this 7 argument too. And it's not really important for you, 8 so -- I'd like to not argue it until --
9 MR. WALKER: Well, Ted --
10 MR. BECKETT: Well, we were not applying this 11 in the context that the Staff would accept this on a 12 wholesale of generic application basis, or -- as an 13 application industry-wide. This analysis is specifically fD
(.) 14 for the cables that Comanche Peak uses, to show that the i 15 conductors themselves within the cable are quite capable 16 of performing their function, even with the interior 17 temperatures that they saw in Fire Test 9-3.
18 We have tested -- like I said, we have tested 19 the two-inch -- Test 13-2, for the two-inch, with the 20 upgraded LBDs and radial bends. We did not test the one-l 21 and-a-half inch -- I can tell you that we have looked at 22 fire tests, and basically one-and-a-half inch and two-inch 23 sizes perform in a fire very similarly.
24 We did not test the one-and-a-half-inch; you im l i 25 know, we did not want to run the risk of having anything NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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67 1 hanging loose that was unsupported by a proper analysis.
2 MR. JENKINS: Okay -- I guess I don't
()
l -
\~
3 particularly know where we would go with this, other than 4 the fact that if your upgrades would have mitigated the 5 barrier damage, then that would be -- an issue -- that 6 would be an approach that we would work with.
7 MR. MARSH: And they have.
8 MR. JENKINS: Well, that's going to have to be 9 substantiated.
10 MR. WALKER: Can I suggest that, in our 11 Engineering Report of January 15 -- this is becoming an 12 ominous date -- that we provide again how we did our 13 analysis, and our assumptions -- because I think you said (D
's-)
14 before that we needed to start out with an argument why 15 the outer -- the --
16 MR. JENKINS: Raceway.
1 i MR. WALKER: -- raceway temperatures, yes, 18 were not applicable; and then provide that we did our 19 analysis, this is what our results is -- which we've 20 already done somewhat in this piece of paper -- and beyond 21 that, we've upgraded in the following fashions, and here's 22 the testing that was done, associated to support those.
23 That is what we're going to do. Right?
24 MR. JENKINS: I just want to make clear that O
( ,)
/
25 surface temperatures, by themselves, do not support the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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68 1 cable functionality argument that you're -- proposing.
f- 2 Because that's basically inconsistent with the Staff
\ i
%/
3 position.
4 MR. WALKER: What we will do is, provide --
5 using surface temperatures, our analysis says this, but 6 beyond that we've upgraded --
7 MR. MARSH: Why do you need to even do that?
8 What's the point? Because you put us in the position of 9 having to refute something, that we're relying on.
10 MR. WALKER: I think --
11 MR. TERRY: Well, if you don' t need i t; if you 12 can -- accept the upgrade that we did, based on the 13 additional testing we did on the two-inch, then we're okay
(
Y/ 14 on that.
15 MR. MARSH: See -- what could happen, if you 16 put this in your engineering report, and we're silent on 17 it in our safety evaluation -- or let's suppose that we're 18 not silent on it; let's suppose that we say something 19 about it in our safety evaluation, but we don't like it.
20 Sometime downstream, you may find yourself 21 with a degraded barrier, for some reason, and you may say, 22 It's degraded but I'm functional, because look at this 23 evaluation that I've gotten.
24 Now'we're back into an inspection mode or N
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69 l
1 didn't approve of; and the record is not clear. l
! I l g- 2 MR. WALKER: I think Lance is right. If you l
(_) 3 guys don't feel you needed to accept it, and you can 1
j 4 accept the configurations we have based on -- the testing l
S- that we just explained to you, then we don't need --
6 MR. TERRY: The upgrade that we've done, and 7 the testing that we would explain to you. I l
8 MR. BECKETT: Actually, 13-2 is mentioned in j 9 this response, on page 39 of Enclosure 2, and the Staff 10 has already acknowledged that that upgrade test was i
11 successful. There was a high temperature -- i l
12 MR. CONNELL: For cable functionality j i
13 purposes. It did exceed the temperature criteria.
7
/
]
i
' 14 MR. BECKETT: Right. I 15 MR. GILL: Are you saying 13-2 and 9-3 are I I
i 16 very similar?
17 MR. BECKETT: No. I'm not saying that.
18 MR. GILL: So how are those upgrade -- how are 19 you --
20 MR. BECKETT: 9-3 did not have the LBD and the 21 radial bend upgrades. 13-2 did have them.
22 MR. GILL: Not, but other than that, they 23 were -- you know -- I'm trying to correlate 13-2 with 9-3, 24 because you did not test 9-3; you tested 13-2, for two-
- k. ,/ 25 inch.
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70 1 MR. JENKINS: I guess I want, once again to f- 2 make sure that on this magic date that comes in, we don't
\)
3 come back with another round of questions --
4 MR. BHATTY: So do we.
5 MR. JENKINS: The hot spot indications, where 6 you had deltas -- you know, 100-and-some degrees between 7 the -- even the surface temperatures. That has to be 8 addressed, in terms of your upgrade. If you upgrade, fix i
9 the problem, that's fine.
10 MR. BHATTY: See, we don't have to address 11 that. If we utilize and take the reference for two-inch 12 conduit, and say 13-2 is acceptable for two-inch 13 conduit -- okay? Put in on a matrix; then we don't have
\- 14 to talk about the surface temperatures.
15 MR. JENKINS: No, but what I'm saying is that 16 if I look at the data, and I look at this thermocouple {
17 here, at this point; and your upgrade is over here. Then 18 that's going to raise a question, as well as the upgrade 19 would have in fact mitigated the damage.
20 MR. BRATTY: I don't follow that. If I'm I
21 giving you a two-inch conduit upgraded in 13-2 and saying, 22 This passed the acceptance criteria for October 29, 1992, 23 and I don't mention 9-3 two-inch conduit, why do you have 24 to go back over there and review the previous -- because O
\ ,) 25 I'm not taking credit for it.
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71 l
1 MR. JENKINS: Oh, you're not going to take l I
2 credit for 9-3? l 3 MR. BHATTY: I'm not taking credit for it.
4 I'm just proposing that right now.
5 MR. JENKINS: Okay. But --
6 MR. BHATTY: I don't know; I'm going to let 7 these guys talk about it -- )
l l
8 MR. TERRY: The reason why we think that we l 9 need to do the engineering analysis here of the cable 10 functionality evaluation is because of the one-and-a-half I
11 inch only. Because we had one-and-a-half and two that we 12 were doing the cable functionality test on. Okay? In 13 Test -- 13-2, we only had the two-inch with the upgrade.
()\
's_ 14 We didn't have the one-and-a-half inch. Okay?
15 We think, based on our analysis, that the one-16 and-a-half and the two-inch upgrades, we did them both, we ,
1 17 did them the same, and we did that based on what we saw on 18 Unit 2.
19 And the two-inch passed with no problem on 13-20 2 --
21 MR. JENKINS: So are they identical? Is that 22 what you're saying, that the two-inch conduit and the 13-23 2 --
24 MR. BHATTY: Yes --
p I
q,) 25 MR. TERRY: Except for the upgrade.
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72 1 MR. JENKINS: So you're saying that they're l
j 2 identical.
7-i 1
% J' 3 MR. BHATTY: They're two-inch conduit. Let's 4 put it that way. !
l 5 MR. JENKINS: Okay. Well, I'm talking about 6 the barrier.
l 7 MR. TERRY: Except for the upgrades. The i
8 upgrades, we put in 13-2. They were not in 9-3.
9 MR. JENKINS: Okay.
10 MR. WALKER: And one last thing: The one-and-l 11 a-half-inch we have to assume, performed the same as the 12 two-inch.
13 MR. CONNELL: Did it in 9-3? Did it perform l 7
's/ 14 the same in 9-3? You tested one-and-a-half in 9-3?
15 MR. WALKER: Yes.
16 MR. CONNELL: So that's what we're talking 17 about -- did you get the same results? For the one-and-a-18 half and the two-inch conduit?
19 MR. TERRY: Similar results.
20 MR. CONNELL: What does that mean? I mean, 21 it's perfectly acceptable -- you know -- to have an 22 engineering evaluation that's -- a sound technical basis 23 for -- you know, bounding something that's -- you know, 24 not exactly testing, and you have a basis for that, and f)T q, 25 you can say, Hey, look. We tested the two different sized NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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73 i
1 conduits in 9-3 and it performed -- you know, so close it l I
f~s 2 doesn't matter -- that you might have a reason for making
! ) i 3 that extrapolation to the 13-2 performance.
4 But the difference is significant between 5 then, that argument with no water --
6 MR. BHATTY: I'm saying, we did not do a 7 temperature thermocouple-thermocouple comparison with 8 those. Okay? All we did was look at the peak points.
l 9 The peak points appear to be similar; we had j 10 not gone back over there, so --
11 MR. WALKER: We need to do it, and if it comes 12 out different, then we need to deal with it.
13 MR. JENKINS: Right. So once again then, the
/'s
! i
\/ 14 proposed text should address the burn-through, and also 15 the hot spot indication.
16 MR. GILL: In the two schemes.
17 MR. JENKINS: Yes. This --
4 18 MR. GILL: For 9-3; we didn't use 13-2. To 19 resolve 9-3, and I'm saying 9-3, for two inch, for 9-3 you 20 have the issue of a hot spot where you saw this big 21 depression between two thermocouples.
22 And I think you need to explain that, that 23 it's -- that your upgrades -- that this is the result; you 24 know, based on your data for 13-2. Otherwise, you know,
(] 25 we have more questions on it.
(_/
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74 3 MR. JENKINS: I think they understand.
f3 2 MR. GILL: Okay.
t 4 LJ Essentially, it's 3 MR. JENKINS: Scheme 11-2.
4 the same -- type of concerns as 9-3, except that you 5 didn't address any fix to the cable damage issue. So 6 now -- so I don't know what you're going to do about that.
7 The one part of it I think that failed was the 1
1 8 power cable; with the charring on the power cable. l 9 MR. MARSH: Ronaldo, why don't you kind of 10 walk us through.
11 MR. JENKINS: Okay.
12 MR. MARSH: Just some of the documentation -- l 13 this is the same kind of a case as before.
I,_h 14 MR. JENKINS: Right. In essence, we had --
15 Scheme 11-2, two-inch air drop deviated from the 16 acceptance criteria, as stated in the 10/29/92 letter to 17 the licensee.
18 The Staff REI dated 6/15/94 raised questions 19 regarding cable self-heating, barrier burn-through, cable 20 damage and the use of surface cable temperatures for 21 instrument -- for insulation resistance determination.
22 A TU Electric letter dated 8/8/94 contended 23 that cable self-heating will only be a concern in power 24 cables, and the use of metal temperatures is overly --
(_ 25 conservative.
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75 1 Licensee stated that the burn-through 2 observations for other schemes were acceptable for various
{O 3 reasons.
4 The Staff developed an SER dated 5/22/96, and 5 found that Scheme 11-2, the two-inch air drop, did not 6 demonstrate functionality in light of the cable damage 7 evidence, hot spot indications, and unacceptable IR 8 values.
9 Licensee submitted a letter dated 10/24/96 10 which contends that a new temperature profile shows 11 acceptable estimated IR values and cable-self heating is 12 not a problem due to that 100 percent capacity margin for 13 the applicable cables.
, U 14 Licensee did not address efforts to mitigate 15 cable damages.
16 MR. MARSH: Or the upgrades, or anything of 17 that sort. j l
18 MR. JENKINS: Right.
19 MR. WALKER: I'm sorry. What did you say, 20 sir? i 21 MR. MARSH: That is, the upgrades or any other .
1 22 things -- efforts you made to mitigate the damages.
23 MR. WHITE: Right. And they're -- and to cut i 24 to the chase, there were upgrades done on those also.
/3 Q 25 MR. WALKER: Did we inform them of that?
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76 1
1 MR. WHITE: I don't believe we did here. j 2 MR BHATTY: When were these done? Do we l 3 know?
4 MR. BECKETT: They also were included in the 5 '93 '94 upgrades. The hot spots or hot spot, I should 6 say, was at the top of the air drop, plexi-blanket bundle 7 at the transition point.
8 We went back and looked at the Unit 2 tests, 9 and what we had done on Unit 2 was, we had increased the 10 thickness of the material, which for the majority of the 11 air drop the thermocouple temoerature profiles were pretty 12 good, except for that one transition was on up near the I 13 top, which we could see was being impacted by the p
(-) 14 aggressiveness of the fire more than any other place.
15 So we utilized the Unit 2 upgrade method for 16 the transition area, which gives better mechanical 17 protection for the joint itself, but what it does is, it 18 provides additional thickness of Thermo-Lag; you've got a 19 stress skin reinforcement for both mechanical, and that 20 also does help thermodynamically, and we've got an overlay 21 over that.
22 So that we've added the equivalent of about 23 another layer of plexi-blanket, and extended that down 24 beyond the transistion area, so that now you have a much i
O
(_) 25 larger volume, at that point.
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77 1 We've tested this material enough to know that 2 that improves the heat transition away from the attacked G 3 area, because Thermo-Lag is a pretty good thermal )
i 4 conductor; it's about one-third that of steel. And that 5 and mechanical and the thickness, we are very comfortable 6 that the two-inch air drops will perform properly in the 7 plant.
8 MR. JENKINS: Just so we're clear: What 9 you're stating is that the upgrades, the fixes would have 10 in fact prevented --
11 MR. BECKETT: Mitigated the hot spot.
1 1
12 MR. JENKINS: Well, not just the hot spot l 13 indications, or indication, whatever that may be, but also U 14 the surface char that was noted on the power cable, l 15 approximately 12 inches above the top of the cable tray 16 horizontal section, as stated in the Omega Point 17 Laboratories test report.
18 MR. BHATTY: Yes. I think we could probably 19 justify --
20 MR. WALKER: Wait a mindt . I don't think 21 that they know without -- you even remember where that 22 char was, Gene?
23 MR. BHATTY: Sure. It was -- okay, Gene. Go 24 ahead.
O 25 MR. BECKETT: No. Go ahead --
()
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78 l
l 1 MR. BHATTY: It was two inches below the l l
1
14 MR. WALKER: Well, is there a way -- I'm 15 not --
16 MR. GILL: I mean, if there was enough margin 17 in your IR values, I would then -- okay, tend to explain 18 away why I don't need to use cable self-heating 19 temperature impact.
20 MR. WALKER: Yes. I --
21 MR. GILL: Okay? But here, I don't think we 22 have that much effect margin, and I think you need to 23 explain or you need to include that effect.
24 MR. WALKER: Is there a reasonable way -- I
,m L.p_) 25 can't argue with you, because you guys are a whole lot NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W, (202) 234-4433 WASHINGTON. D C. 20005-3701 (202) 2'8 433
86 1 smarter than me, and like always -- I'm not trying to --
ps 2 what I'm trying to do is just find a reasonable way --
( /
'~#
3 MR. GILL: I'm using -- just common sense, I 4 would think --
5 MR. WALKER: -- we're taking a 90 degree 6 penalty, and that was your concern.
7 MR. WHITE: Well, we're taking a 40 degree 8 penalty --
9 MR. WALKER: 40 degree penalty. And that was 10 your concern. Is there a reasonable way that we can deal 11 with the fact that we have ours, a 100 percent margin in 12 ours, and get a value that --
13 MR. GILL: Right. I tell you, you need to
.\
\m- 14 look at your loading and see what the cable self-heating 15 effect would be. It may not be 40; it may be 10, 20. I 16 don't know what it is. You know your cables and how 17 well -- you know, what kind of margins you have, and for 18 power cables I think you need to include that.
19 MR. WHITE: Okay. Well, let me ask this then:
20 If we go in and perform calculations, say, which show that 21 if I decrease my ampacity by 50 percent, that corresponds 22 to a 10 degree C --
23 MR. GILL: Right. There is a formula, and then 24 we can calculate.
t' %
'( ,) 25 MR. WHITE: -- and then we can -- take the 40 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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l 87 l
! 3 degrees we . art with, and subtract from that.
l 2 MR. JENKINS: Yes. You can reduce O)
\
'~'
( 3 that penalty, the 40 degree C. We took the 40 degree C as l l . i i
4 a max -- as a worst case. That's the only reason that we l 5 used that, and I guess the self-heating question came up i l
1 6 back in '94, 6/94. And so -- you know, that's another l 7 question is -- you know, why -- is this information coming 8 out now, at this point?
9 MR. WHITE: I can perform those calculations. I 10 And I will do those for you, and --
11 MR. JENKINS: Okay.
12 MR. WHITE: -- get the information to you, l l
13 and --
N- 14 MR. WALKER: We would propose to put them in 15 the January 15 outline, and then couple that with the fact 16 - t at we have done upgrades, describe those upgrades --
17 MR. JENKINS: Okay.
18 MR. WALKER: -- and say this is the answer to 19 this question.
20 MR. GILL: I think that that would be the 21 right thing to do.
22 MR. JENKINS: And I guess the other -- I mean, 23 the cable self-heating issue, then -- you know, given that 24 if the temperature rises, you know it's much smaller --
O)
(, 25 I've got no problems with --
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88 1 MR. WHITE: Okay.
2 MR. JENKINS: And you can show what that
()
g 3 heating would be.
4 MR. WHITE: Okay.
5 MR. JENKINS: Because I don't think it's going 6 to make that much difference. Going back to '93, the --
7 we developed a peak -- based on peak surface temperatures, 8 IR values. And what I'm trying to ascertain is what --
l 9 how you arrived at a different value.
10 I guess that's -- before we get into the cable 11 self-heating, that's how I was attempting to do that. And 12 when we picked the peak temperature for each cable type -- !
13 and so what you're saying is, what you did was, you picked ;
i i
(~)h
's 14 the peak temperature irrespective of the cable type.
15 MR. WHITE: Right. And applied it to all.
16 MR. JENKINS: And applied it to all of them.
l 17 MR. WHITE: Right. And that is where there 18 was some discrepancy, or would have been discrepancies in 1
19 the numbers, because I took a worst-case scenario.
20 MR. JENKINS: And looking at the different 21 values, they are -- roughly the same, except there are 22 some -- differences with respect to -- I mean, if you look 23 at the numbers that you have, and you look at the table, 24 okay? There's like two orders of magnitude difference.
, [h j ( ,) 25 Do you see?
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89 1 MR. WHITE: Well, now, I'm not real -- what (g
t J 2 page are you looking at, because --
%./
3 MR. JENKINS: 18 of the Sandia National Labs 4 report.
5 MR. WHITE: Okay. The --
6 MR. JENKINS: So, if you look at -- do you 7 have that table? It's called Table 4.2 -- l l
8 MR. WHITE: Yes. 4.2. j i
9 MR. JENKINS: -- okay. And if you look at the 10 9-3, the one-and-a-half inch power cable, you have 1.9 MIG I
11 [ phonetic), okay? And we have 1.3 even at three.
12 MR. WHITE: I --
_ 13 MR. JENKINS: And that's -- what I'm referring
('-) 14 to. We're going to need an explanation, so why -- these 15 values are so far off.
16 And then of course you have an even bigger 17 difference on cable -- when you look at their Table 2, 18 your letter -- the October 24, 1996 letter -- for the two-19 inch air drop, you have a power cable with a value of 20 three raised to the -- fifth MIG, okay?
21 And when you look at our determination, our 22 value for the power cable, it's 5.2, tuned to the three.
23 MR. WHITE: Yes. I -- again, I apologize. I 24 wasn't prepared to go into this much detail, okay --
(
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I 90 1 either, but I think it's important to understand what your
, 2 analysis is going to be, because the numbers are the same.
1 3 MR. WHITE: Well, what I -- I do know that I 4 did resolve that issue. Those three numbers I've 5 highlighted here, and I highlighted them as I was able to
( 6 reproduce the Sandia National Labs value. Because their 1
7 calculations weren't provided to us in this memo. So I l
8 kind of had to take their numbers, play with the numbers l
9 and back-fit.
10 So -- but I did do that --
11 MR. JENKINS: And that's what I'm saying. We 12 need --
13 MR. WHITE: Right. And so --
O Esl s 14 MR. JENKINS: -- when you get your response to I
15 this question, we're going to have to go back and compare s16 it to what our lab -- our contractor developed.
17 MR. WHITE: Okay.
18 MR. MARSH: Is this going to be an acceptable 19 methodology they're using with all that? I mean, this 20 technique of using --
21 MR. JENKINS: Well, we'll have to look at the 22 details of the analysis, but it's certainly -- if it's 23 more conservative, we have got no problems with accepting
{
l 24 it provided that once again, fixes -- the structural l
I
(( jD 25 fixes -- are acceptable to -- you know, plant systems l
l NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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t 91 1 range.
7- 2 MR. MARSH: The upgrade. So --
- k. j 3 MR. JENKINS: The upgrade. So it's a two-4 part -- answer.
l l 5 MR. MARSH: And you're accepting a little bit l
6 less information on the upgrades than you want, which is a 7 tested configuration -- you're accepting a little bit less 8 than a -- methodology than you really want --
9 MR. JENKINS: In fact, that was the approach 10 we used in the SER. We -- okay, where the metal 11 temperatures show that you have failure of that 12 configuration, we said, Okay. What other evidence do we 13 have out there.
/~N
{ \
\/ 14 In some cases there were -- 1 think 11-5 was 15 the hot spots. There were no -- the hot spot IR value, 16 the highest value showed that it was acceptable. There l
17 were no indications of burn-through, and there was no 18 indication of high deltas between thermocouples, even )
l 19 using surface temperatures.
20 So with the positive evidence, we could accept 21 even the fact that the metal temperatures' IR value was 22 unacceptable. So we used the balance of the evidence that 23 was available to us to accept that.
l 24 MR. WHITE: Oh, okay. I'm sorry. I remember i ("N 25 I'm sorry -- you need to -- excuse me for
(_) what it is.
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92 1 interrupting. I'm over here working in my own world.
-s 2 The number that he provides you on the table,
~
3 the 1.3E to the three, is based on an ohms per 1,000 feet.
4 MR. JENKINS: Right.
5 MR. WHITE: Now, while we'll agree that that's 6 a good mechanism to compare an individual test --
7 MR. JENKINS: Sure. Right.
8 MR. WHITE: -- the October 29 letter asked us 9 to evaluate our instruments and our cables on a specific 10 basis. So the numbers that I've provided to you are a 11 composite insulation resistance value based over the 12 length of cable in the test chamber.
13 MR. JENKINS: Yes, and I think we discussed i
\~ / 14 that in the -- in this contract we discussed that approach l 15 as being somewhat non-conservative, to use that type of 16 approach.
17 MR. WHITE: Well, it's the only way that we 18 can assess how our instruments are going to function. You 19 know, the ohms per 1,000 feet doesn't correlate well to an 20 instrument error, or how a particular power cable's going 21 to function, because your hot spots are going to be 22 limited in size.
23 And -- but if we removed the self-heating, all 24 of the cables end up passing his minimum acceptance gS
( ,) 25 criteria, 1,000 ohms per 1,000 feet.
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93 i 1 MR. JENKINS: Right.
I 2 MR. WHITE: So we feel like we meet both O 3 criteria. We're just providing different stuff. On the l
4 one-and-a-half inch conduit, under the hot spot, our hour 5 value, we had 1.13 ohms there, and that's the same number 6 that's provided on Column 1 --
7 MR. JENKINS: Can you provide both, then? If 8 that's not a problem?
9 MR. WHITE: Oh, no. And -- I believe I've 10 done that in the Table 1. I have the composite IR in ohms 11 per 1,000 feet, and the composite IR value beside it.
12 MR. JENKINS: The composite IR value in Table l
13 2, is that ohms per 1,000 feet? i O
'-- 14 MR. WHITE: No. The composite IR value there 15 is just meg-ohms, per --
16 MR. JENKINS: Right. Actual length?
17 MR. WHITE: -- of -- yes, of the actual 18 length. And the ohms per -- the hot spot IR, in ohms per 19 1,000 feet is the same numbers that he used over here.
20 And those do correspond to the numbers that he has on page 21 18.
22 MR. JENKINS: For the hot spot?
23 MR. WHITE: Right.
24 MR. JENKINS: Yes. I said that initially, g,) 25 that the hot spots agreed.
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94 1 MR. WHITE: Right.
('
G' 2 MR. JENKINS: Okay. But I guess the -- well, 3 we can do the conversion --
4 MR. WHITE: Yes. He didn't provide -- I don't 5 believe -- information on his table which would have --
6 that was similar to our composite IR value. That was an 7 additional piece of information that we provided.
8 MR. JENKINS: Right. And the reason that he 9 did not provide it was that -- the -- and I'm looking for 10 this report. The final estimated IR values were -- are 11 not normalized, ohms per 1,000 feet.
12 And once again, he's looking to compare it 13 to -- compare the test results that may have -- the tests
'-] 14 may have different lengths of cable, and what you're 15 trying to do is compare it to a standard.
16 MR. WHITE: Right. And that's why we did j 1
1 17 include those in our report also. But we didn't know to ;
l 18 what extent you'd want to -- perform an evaluation, so 19 we've included the others, also.
20 MR. WALKER: We can clarify that.
21 MR. GILL: Well, are we clear on what 22 temperatures are we using, metal -- cable surface, or 23 jacket surface, or what? !
l 24 MR. JENKINS: Well, they clearly failed the b'/
(,
\
25 metal temperatures.
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95 1 MR. GILL: Okay. l 2 MR. JENKINS: That's not what we're talking
,7-
\) .
3 about. Now, we're talking about the upgrades -- use of l l
4 the upgrades to mitigate the damage. Plus now, the 5 composite IR --
6 MR. GILL: Of the jacket surface temperature?
7 Is that what you're using --
8 MR. JENKINS: Yes. They're using surface --
9 MR. GILL: -- it's not the conductor; it's the ,
l 10 jacket.
.i 11 MR. J3NKINS: Right. They would fail the 12 conductor.
13 MR. MARSH: Have we accepted this kind of t
/~S '
\~/ 14 approach before? Do you know?
15 MR. GILL: On Unit 2, we did.
16 MR. JENKINS: On Unit 2 -- no, no. No, we 17 didn't.
18 MR. MARSH: But we accepted this approach, 19 that they're making on another plan. That is, an upgraded 20 configuration, not fully tested, plus composite 21 temperatures for IR values, when they have failed metal 22 temperatures?
23 MR. JENKINS: No, in fact it -- you know, in 24 8610, Supplement 1, another plant came in and said, We're i"
(%,) 25 going to use cable functionality, we would base it on the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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i 96 1 metal temperatures, l
i ,~ 2 MR. MARSH: Well, you know we need to leave l
%J 3 ourselves some room here. Because -- well, I'm not sure l 4 we're going to accept this approach that they're l
5 proposing. Okay?
1 6 MR. WALKER: I've -- never doubted that we --
1 7 this -- you need to review it before we get a decision, 8 and we're not --
9 MR. MARSH: Yes. And you need to think about 10 all three of these as well.
11 MR. WALKER: We do want you to understand, 12 that's the approach we're going to take --
13 MR. MARSH: To -- it sounds like this approach D) i k- 14 has been discovered today, by you. Correct? l 15 MR. WALKER: Well --
1 16 MR. MARSH: It sounds like you've just learned !
1 1
17 that the thing was upgraded, and so -- you're going to 18 make a coupled argument now. Which troubles -- i l
l 19 MR. WALKER: -- yes. We're going to couple 20 the argument on the --
21 MR. MARSH: But that you had discovered this 22 in this meeting is a bit troublesome to me.
23 MR. WALKER: No, no --
i j 24 MR. MARSH: Okay.
25 MR. WALKER: We just didn't communicate it to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS I 1323 RHODE ISLAND AVE., N W.
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(
l 1
97 1 you.
,_ 2 MR. BECKETT: One comment I'd like to make.
5 3 There's been a lot of discussion across the table as -- in 4 regards to thermocouples on the cable versus thermocouple 5 temperatures on the metal, and one of the items that are 6 involved in this is in Item 6, and that's a two-inch air 7 drop, and there is no metal involved in that.
8 All the thermocouples that are run in there 9 had to be run in on the conductors within the drop. Okay?
10 MR. BHATTY: I think they understand that. I 11 think they were just talking about the inch-and-a-half 12 conduit.
13 MR. BECKETT: I understand.
\
(~l (s 14 MR. MARSH: Okay. Why don't we press on.
l 15 MR. JENKINS: Okay. Going to the last --
16 item, because I think we're clear on what we need for the 17 previous two open items. This is Scheme 15-2, flexi-18 blanket wrapped power cables. No metal involved.
19 Scheme 15-2, 750 mcm wrapped power cables 20 deviated from the acceptance criteria as stated in the 21 10/29/92 letter to the licensee. The Staff REI, on 22 6/15/94, raised questions regarding cable self-heating, 23 barrier burn-through, cable damage, and the use of surface 24 cable temperatures for insulation resistance IR
(%
( ,) 25 determinations.
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98 l
1 The licensee letter dated 8/8/94 contended i
s 2 that cable self-heating would only be a concern in power 1 l \
(j 3 cables, and the use of metal temperatures is overly l
4 conservative. Licensee stated that burn-through 5 observations for other -- test schemes were acceptable for 6 various reasons.
7 An NRC SER dated 5/22/96 found that Scheme 11-8 2, the two-inch air drop, is acceptable only for cables 9 750 mcm or larger based on several inherent conservatisms.
10 Open Item existed for the smaller cable size I
11 applications.
12 The TU Electric letter dated 10/24/96 states 13 that Scheme 15-2 found a unique configuration. Licensee ,
l'% l
'\w-) 14 does not intend to use that test scheme to certify ,
1 15 configurations that are smaller than 750 mcm.
16 And I guess I'm surprised at that item -- but 17 the item is considered closed.
18 MR. MARSH: Okay. Do you need any 19 clarification on that?
20 MR. JENKINS: No. I don't need any.
21 MR. MARSH: Okay.
22 All right. So we've gone through the items 23 and we've got a lot of information. I would ask to 24 caucus, unless you've got any more questions you want to l
(O) 25 ask, or information to gain before we caucus, for --
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99 1 MR. CONNELL: I just want to -- this is Ed
,f-2 Connell again. I wanted to just note that in the
() 3 licensee's October 24, '96 response, he talked about t
l 4 combustible loading and equivalent fire severity, and
)
5 stuff like that as part of the basis for the acceptance of 6 some of the test schemes that -- didn't meet the 7 temperature criteria and were being evaluated on cable I
l 8 functionality. l l
9 And you know, I wanted that clear that that 10 has absolutely nothing to do with the performance of the l
11 fire barrier. Your commitment is to have one hour 12 barriers, and equivalent fire severity less than one hour 13 is not really acceptance criteria for the barriers.
\/ 14 MR. BECKETT: In no case do we attempt to, nor 15 are we attempting to take credit for a -- combustible 16 loading as not having to require a full one hour. It is 17 our intent to meet the full requirement.
18 MR. CONNELL: Okay. Because the statement 19 here is typically what I see for people that want to 20 somehow do a fire hazard analysis approach for justifying 21 barriers that are less than one hour, and it's not 22 applicable to your particular case.
23 MR. TERRY: Yes.
24 MR. CONNELL: Okay.
l '( , 25 MR. TERRY: We understand that our commitment l
l NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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l
100 1 is to have a one hour fire barrier. We -- as we told you 2 in early '94 -- think that our tests and our evaluation O 3 did that. We appreciate the comments that came in here 4 today, and you know, we're going to go try to resolve the 5 issue.
6 MR. MARSH: Great. Why don't we do this, if 7 it's okay to you. We're going to break off, and decide --
8 you know, how we're going to kind of sum it up. I'd like 9 you to do the same thing.
10 MR. BECKETT: Okay.
11 MR. MARSH: And if you don't mind, I'd like 12 you to go through these items, and give us your 13 understanding of the item. That is, what you think you o
s 14 owe us, and how you think the item ends up. Okay?
15 And I asked at the beginning for you to tell 16 us how you think your compliance with your licensing 17 bases -- where are you with respect to timely corrective 18 actions of Appendix B. And I'd like you to tell me where 19 you are on those, too.
20 You said a little bit about it in your opening 21 comments. I want you to recap that for me, having gone 22 through all of this. Okay?
23 And we're going to caucus if we can.
24 (Whereupon, a short recess was taken.)
( ,
( ,/ 25 MR. POLICH: Okay. We're bock -- can we go l
l NEAL R. GROSS COURT REPORTERS AND TRANSCF'JBERS 1323 RHODE ISLAND AVE., N W (202) 234-4433 WASHINGTON, D C. 20005-3701 (202) 2344433 j
101 1 back on the record.
2 MR. MARSH: Okay. Jus; a couple kind of (G
/
3 reopening comments. I want to reemphasize for you and for 4 everybody that may be reading this transcript the 5 importance of Thermo-Lag and the Commission's intent that 6 it be resolved and be resolved expeditiously.
7 And the growing concern that we have that the 8 industry in general is not treating these Thermo-Lag 9 issues in an expeditio~us manner; so we intend on doing --
10 as we've been doing today -- and more, to try to get i
11 timely resolution of these issues. l 12 The good news is, I think this has been a good 13 meeting. I think it's been important, it's been O
._ 14 instructive and it's s . informative.
i 15 And I guess the bad news is, we learned maybe 16 too much today. Okay? We learned things that we really l l
17 should have known before. And we've learned about all of 18 the modifications that have been made to the plant, and 19 the Thermo-Lag configuration.
20 We learned about some information that was not l 21 perhaps accurate, in the record, and some mistakes and l l
l 22 things of that sort.
23 And while that's good, that's also -- causes 24 us pause, and should cause you pause too, for the kind of G
( ,) 25 information that you've been providing to us, and the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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i 102 l
1 accuracy and completeness of it. Okay?
2 So that's the good and the bad news. I would 7-b 3 encourage you to go back and look at your documentation l
4 associated with this issue, and make sure that it is i
! 5 complete and thorough and accurate to the extent that it 6 can and should be.
7 I want to go back and emphasize again putting 8 things on the docket and on the record that you do not 9 need, that you are not relying upon for compliance with 1
10 the regulatory requirements. Okay? l 11 I don't want us to be in a position of you 12 having something submitted to us, and the industry may 13 think that it is an approved approach just because it's
/~'T k~s/ 14 been on your docket. That's not an acceptable mode, and 15 it's caused us confusion and it's caused the industry 16 confusion.
17 Things -- they'll open up the docket for Texas 18 Utilities, find something submitted and think, Ah ha.
19 Here's an approved approach, or here's an approach that's 20 being used by you. Please don't do that. It confuses the 21 issue, it confuses the docket, it confuses the industry.
22 With respect to test configuration, and cable 23 loading. We asked you to go and check where it was 24 committed to, what the agreements were. That's important, fs
(,)
25 because we don't think that that was an agreement. We're NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W (202) 234-4433 WASHINGTON, D C. 20005-3701 (202) 234-4433
103 1 going to go back and check as well, but we're not sure 2 that that was something that explicit.
7~-
~
3 Ed's done research on this, and he doesn't 4 think that it was something that was explicitly agreed to.
5 And we need to come to closure on that.
6 We do expect this response that you've 7 discussed on January 15 -- and that's important -- to come 8 to the timely resolution on this.
9 And I encourage you to work as diligently as 10 you can on the closure on this. We've -- lasted too long, 11 on this. We've got increased pressure from our bosses, 12 and from Congress, and from other forces to get on with 13 this thing. It causes me pause, when we hear about the O
k/ 14 information flow and the lack of communication between us 15 on some of these things. I think that's contributed to 16 the stretching out of the issue, and we need to move on.
17 Your turn.
18 MR. TERRY: Okay.
19 I also thought this was a worthwhile meeting.
20 It's -- I appreciate the effort and the time that you put 21 into it, bringing these people here so that we could make 22 sure that we understand the issues. Because if we don't 23 understand the issues, it's very difficult to get to the 24 resolution of the issues, p)
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104 1 your comment concerning wanting to timely close the s 2 Thermo-Lag issue. I have to say for the record, I don't 3 think anybody's tried harder than TU Electric to close the 4 Thermo-Lag issue. And we will continue to do that.
5 I acknowledge your comments concerning the 6 amount of information that's flowed between the -- TU l
7 Electric and the Nuclear Regulatory Commission. There has ,
)
8 been a substantial amount, and sometimes that -- when we 9 wrap up with a new document, we don't include everything 10 that was in the previous document.
11 There were clearly some cases where we did 12 some upgrades that you were not aware of. That should not 13 have happened. And the fact that we had an error in one i
t
\ -) 14 of the letters, we will correct that letter as part of our l 15 corrective action coming out of this. And I agree with l
l 16 you, that does cause us pause, and we will re-look at that 17 issue also.
18 Let me go through what I think are the things 19 that we owe you, coming out of this, and -- we do owe you i
20 an upgrade to our Engineering Report, and we have 21 committed to get that upgrade in by the 15th of January l
l 22 1997.
23 For Item Number 1, we owe you a matrix similar 24 to what was in the Engineering Report for Unit 2, ss 25 concerning cable loading. There was one question that we NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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105 1 had as to whether or not you were talking all raceways or 3 2 just conduits?
3 MR. CONNELL: All raceways.
1 4 MR. TERRY: All raceways. We will identify 5 those raceways which have less than the representative 6 samples, and we will identify the documentation that we 7 see where we have agree to the testing methodology, as 8 well as the cable loading on Unit 2 and subsequently Unit 9 1.
10 On Item Number 2, we owe you an upgrade in the 11 Engineering Evaluation which shows what we did in the way 12 of an upgrade, and why that upgrade makes our applications 13 in Unit 1 acceptable, wherever it was used in Unit 1. And l f~% 1
\'- ) 1 14 that will be included in the Engineering Evaluation. l 15 Item Number 3, first of all we will correct 16 the errors in the letter. Secondly, we need to correct 17 the references. This will be put into the Engineering 18 Report as t o what our basis is for acceptance of the 19 applications.
20 You asked us a question as to whether or not 21 our acceptance criteria was the same as the October 29, l
22 '92 letter and I think we told you that it was, as far as 23 we're concerned.
24 Item Number 4 was the same as Item Number 3.
r
(,,x) 25 Item Number 5 was a little bit confusing, but NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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106 1 let me tell you where I think we are on it. I think where 2 we are on Item Number 5 is that we are going to attempt to 3 close Item Number 5 without having to rely on cable 4 functionality.
5 We will provide you with the data, a close 6 correlation of the data in Test 9-3 concerning the one-7 and-a-half and the two-inch conduit. We will then try to 8 correlate that to the test data that we saw on the two-9 inch conduit on Test --
10 MR. CONNELL: 13.
11 MR. TERRY: 13-2, and presuming that we can 12 make that engineering evaluation such that the one-and a-13 half and the two-inch, with the upgrades that we applied n
l m- 14 to both of those, is acceptable then we should not have to 15 fall back on cable functionality for Item 5.
16 If that one-and-a-half inch case cannot be 17 drawn, then we may still have to fall back on the cable 18 functionality for the one-and-a-half inch, and we 19 understand that if we do this, we have to resolve the 20 self-heating of the cable issue, and that will be part of 1
1 21 the Engineering Report. I 22 Item Number 6, the two-inch air drop, we did 23 some upgrade on that. We need to tell you about that 24 upgrade and we will do that in the Engineering Report. We O 25 will still do a cable functionality on Item Number 6, and
(,)
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107 1 we will include in that cable functionality the self-2 heating effects.
7 V 3 That's what I think we owe you on the specific 4 items, and Item Number 7 is closed. Is there anything 4
5 else that you think we owe you on any of those items?
6 MR. MARSH: Yes. Back to 6, that's the two-7 inch air drop. I want you to also be aware that we may 1
8 not accept that approach to cable functionality, and I'd 9 like you to consider testing as an alternative, as another 10 approach. That's something that -- be aware of or 11 consider, or -- put into your plans.
12 MR. TERRY: I don't think that we would do 13 additional testing on it. If we had to do anything, we'd
/~N
- 14 just go back and put a Unit 2 installation on it. And 15 that would -- be an easier fix that going and doing 1
16 additional testing. {
17 MR. MARSH: All right. The same issue for 18 Issue 6 -- well, that's the one where you may have to rely ,
1 l
19 on the functionality.
20 MR. TERRY: On 5, you mean?
21 MR. MARSH: On 5, I beg your pardon.
22 MR. JENKINS: Yes -- the only thing I would 23 say is that, you're in cable functionality space. Okay?
24 If you mean, you don't rely on the cable -- on the surface (A_) 25 temperatures of the cable to perform your evaluation and NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS l 1323 RHODE ISLAND AVE., N W. l (202) 234-4433 WASHINGTON, D C. 20005-3701 (202) 234-4433 l
108 1 using the composite IR, that's fine.
2 But so that -- I mean, you're saying you don't t
V 3 rely on cable functionality, in fact you -- do not meet an 4 acceptance criteria, so you have to rely on cable 5 functionality, you know, to demonstrate the acceptability 6 of the barrier.
7 MR. TERRY: My understanding, in -- you i
1 8 talking 5 now, or 6?
9 MR. JENKINS: Well, 5. Yes.
10 MR. TERRY: In 5, my understanding of what we l
11 were requested to do was to go in and justify that we have 12 upgraded the barriers such that we don't need to rely on 13 cable functionality.
0 V 14 MR. JENKINS: Right.
15 MR. TERRY: If we can do that, we will do 16 that. If we have a problem with that, then we may still 17 come back to the cable functionality issue, recognizing 18 that you may have a problem with that.
19 MR. POLICH: You're going to correlate the 9-3 20 with the tested upgrade, 13-2. And that's going to be 21 your first approach.
22 MR. TERRY: That's correet.
23 MR. CONNELL: And 13-2 relied on cable 24 functionality evaluations; 13-2 did not me,et the i n.
l (V 1 25 temperature criteria.
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i 109 1 MR. TERRY: Right. So we'll still use the l
- 7% 2 cable functionality.
- q,]
3 MR. POLICH: Right. I'm just clarifying the 4 terms.
l 5 MR. TERRY: Anything else?
6 (Ik) response.)
7 MR. TERRY: Now, in regard to the -- whether 8 or not he are in compliance with our licensing basis, we 9 did our testing in the '93 timeframe. We felt that we had 10 in fact tested to our licensing basis at that time. We 11 did our upgrades to those tests, submitted those to the 12 NRC in early 1994.
~, 13 That notwithstanding, we have continued to t i
\ 14 maintain our fire watches, even though we felt we were in 15 full compliance with the -- one-hour fire rate, one-hour 16 rated fire barriers. Therefore, we feel that we are in 17 complete compliance, and have always been in compliance 18 with our licensing basis.
19 As far as Criterion 16 concerning effective 20 corrective actions, we think that we aggressively went 21 after the Thermo-Lag issue. We went into testing early, 22 early before that was even attempted by others. We found 23 out some significant lessons learned.
24 We made corrections based on those lessons
[)
( 25 learned, and developed what we still feel is an adequate NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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110 1 one-hour fire barrier, which is the last issue that we're
, 2 trying to resolve right now, and we feel that we have b,s, 3 certainly taken appropriate corrective action, although I 4 do feel that we need to resolve these last few issues so 5 that we can get this behind us.
6 MR. MARSH: Okay. Any other comments from us?
7 Tony?
8 MR. GODY: Yes. I'm not clear on one point -- I 9 MR. MARSH: Can you maybe come up a little 10 closers.
11 MR. GODY: Tony Gody. I'm not clear on one 12 point. With respect to cable functionality, are -- is 13 there additional information needed on the justification
(~\
\ ~-) 14 for where the temperature was measured, or where the 15 temperature is assumed? There was a discussion esrlier 16 about cable tray temperature versus cable jacket 17 temperature --
18 MR. TERRY: Let me try to answer that. If we 19 have to, in Item 5, go to cable funcrianality, at least 20 based on the 9-3, I'm not -- I'll nave to look at the date 21 on 13-2.
22 If we cannot use the conduit temperature 23 because of the faulty -- of the failure of those 24 thermocouples, we'll say that in the engineering report so p
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A 111 f 1 rather than just jumping straight to the jacket l
g 2 temperatures, which is I think what you're concerned
(') 3 about. For the air drop, since there is no metal on the 4 rail, we'll go straight to the jacket temperatures.
5 MR. MARSH: Okay. Good. Comments, questions?
6 (No response.)
7 MR. MARSH: Good. Thank you very much.
8 (Whereupon, at 11:15 a.m., the meeting was 9 concluded.)
10 11 12 13
/ 14 15 16 17 18 19 20 21 22 23
'E 24
(%
k) 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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l l
1
)
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CBRTIFICATE This is to certify that the attached proceedings before the United States Nuclear Regulatory Commission in the matter of:
Name of Proceeding: COMANCHE PEAK UNIT 1 THERMO-IAG FIRE BARRIERS Docket Number: N/A Place of Proceeding: ARLINGTON, TEXAS were held as herein appears, and that this is the original transcript thereof for the file of the United States Nuclear Regulatory Commission taken by me and, thereafter reduced to typewriting by me or under the direction of the court reporting company, and that the transcript is a true and accurate record of the foregoing proceedings, bhfM/A W
' SUNNY fER' Official Reporter Neal R. Gross and Co., Inc.
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