ML20136A672
| ML20136A672 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 02/28/1985 |
| From: | NRC |
| To: | |
| Shared Package | |
| ML20136A539 | List:
|
| References | |
| FOIA-85-59 NUDOCS 8601020237 | |
| Download: ML20136A672 (101) | |
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' MEETING BETWEEN TEXAS UTILITIES'AND THE 4
NUCLEAR REGULATORY COMMISSION REGARDING i
r COMANCHE PEAK STEAM ELECTRIC STATION 5
4 l
6 l APPLICANTS' PROGRAM PLAN 7
- TRT ELECTRICAL ISSUES l
8 f
10 Visitor's Center Auditorium 11 CPN Power Plant l
hf Texas Farm Route 201 12 g_
Glen Rose, Texas le 14 February 28, 1985 15 PURSUANT TO NOTICE, the above-entitled 16 matter commenced at 8:47 a.m.
17 18 PRESENT:
19 VINCENT S.
NOONAN NRC/ Comanche Peak Director l
J,OHN) BECK TUGCO 20 21 MARTIN JONES CRT s
n IVEN VOGELSANG
.TUGCO 23 SAM MARTINOVICE Gibbs & Hill 24 WOODY STROUPE W.
Stroupe & Associates
(_/
25 ANGELO MARINOS NRC h
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B601020277 851113 PDR FOIA CARDEB S-59 PDR 8
2 1
TERRY G.
TYLER ENERGEX/CPRT I
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2 BARSARA BOLTZ CASE t
34 JOSE CALVO NRC l
SPOTTSWOOD B.
BURWELL NRC/NRR/DL/LBH 4
I l
5 CHARLES J.
HAUGHNEY NRC/TRT i
l 6
L.
F.
FIKAR TUGCO 7
i C.
J.
HALE NRC/TRT 8
i D.
R.
HUNTER NRC/ Region IV 9
A.
S.
PHILLIPS NRC/ Region IV i
l D.
L.
KELLEY NRC/ Region IV/SRRI(O) 10 11 W.
F.
SMITH NRC/ Region IV/RRI(O) 12 JACK REDDING TUGCO 13 PAUL ARIEMO TPOL C3 14 T.
R.
VARDARO Gibbs & Hill 15 LIONEL BATES TERA 16 TONY BUHL ENERGEX-17 DAVID REED Dallas Morning News 18 19 20 5
21 22
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_P _R _O _C _E _E _D _I _N _G ~ S_
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8:47 a.m.
t 3
MR. NOONAN:
Good morning, ladies and 4
gentlemen.
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My name is Vince Noonan, the Director for 5
l 6
l the Comanche Peak Project.
t 7
I guess we are here this morning basically i
8 to listen to the Applicant tell us about his Program lPlansandhowhe is proceeding on what we call the TRT 9
10 i issues.
i 11 i
Today we will be addressing the electrical 12
- issues, 13 John, I think I'd like to just make one p
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14 statement to start out here.
I said earlier I am 15 going to leave here; I won't be here very long this 16 morning.
I have to take care of some business and 17 I'm going to use the residence trailer back of the 18 site.
19 But before we get there,.these next set 20 of meetings we are talking about here, the one today 21 and then next week, we are here to listen to your Zt Program Plan and what you plan to do about things and b
23 how you are going to proceed about it.
24 In reading the safety evaluations back in s
25 Washington, when I go through them, I look at some of 5
9
4 1 l the things the Staff has put in there, the various 2 l actions and some of the things we've put in there.
And e'
3 'I would like you to at least come back to us and tell i
us in some cases where you think there are better 4
i I
I ways, maybe a_better way of doing things or a more 3
I i
6 efficient way of doing things.
l 7
I guess I get concerned a little bit when lI read somewhere where.the Staff requires some certain 3
i Janalysis to be done.
9 10 That's fine.
If that's what is needed, 11 we'll do that; but I guess I'd like to address-that 12 that's really what is necessary.
There are other 1
13 ways to get into it.
14 Some of these analyses can get very long
! and they can't really be as conclusive as some other 15 i
16 course of action.
17 So whatever area we are talking about, I would like to have that open for discussion.
I'll 18 19 leave it up to you, your-prerogative.
20 If you think there's a better way of doing 21 it, then you ought to tell us about it.
Z2 Feel free to do that.
I know we are in a
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23 forum that.we don't like to operate in too well, the 24 NRC doesn't like to operate in too'well, because we i
s-25 like to have an open technical discussion.
We are i
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1j being recorded and we are being watched, and.that's
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2 fine.
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3 I would like to open it up, though, into-l' 4 4 what I call a normal discussion between us and.
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S t yourselves, and we'll discuss the pros and cons of l
6 these things.
7 with that, I think I'll let you go ahead 8
and start it.
9 MR. BECK:
Clearly, Vince, that's the i
!, spirit in which we are going to be making our 10 11 I presentations today and next week, is to provide a 12 full open exchange and a thorough ventilation of the 13 issues,.and your comments with regard to providing 14 alternatives to addressing some'of these questi'ons, 15 l we've also taken in good spirit and have in some l
16
! instances provided some options and alternatives that 17 ! we think, given the questions on the table, will get 18 at root causes and then subsequently to any generic
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19 implications that evolve from.looking at the specific l
20 set of questions.
21 Today we are going to be reviewing our 22 progress on the electrical TRT issues, as you indicated 23 earlier.
24 I'd like to give some background and 25 perspective, and especially relate today's meetings to t
6
Q 6
I 1
previous meetings that we've had, so that there's a 2p common thread established, particularly in the record.
3 I will be-introducing Martin Jones, our l Review Team Leader for the electrical area, who.will 4
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l 5
lead today's discussion.
l I
6 By'way of background, we received the.
7 first TRT letter addressing this particular issue on l September 18th,
'84, and submitted a Program Plan and
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8 I
action plans in early October.
9 i
10 We had public meetings in Bethesda on 11 October 19th and the 23rd to receive NRC comments.
As a result of those meetings, we modified 12 l
13 our Program Plan, the over-all guiding document for fallthe issue-specific action areas to add more 14 I.
15 objectivity, to place greater emphasis on root cause 16 and generic implication determinations, and to clarify 17 other aspects of the program.
18 The action plans.that will be discussed 19 today and at next week's meetings will reflect the t
20 following differences from those that you saw in 21 October:
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.First, we have reviewed-and revised with
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23 the new Review Team Leaders all the action plans.
If l.yourecall, previously we had assigned those individuals 24 e.
ss' 25 within the.TUGCO organization who were most familiar i
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1 1 i with the issues being discussed; and being responsive (S
2 to the question of objectivity, that's when we brought
- in the outside Team Leaders.
Martin Jones is only one 3
4 ) example.
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i We've also revised the action plans, and 6
1 they have been reviewed and approved by the recon-7' structed senior review team, once again adding third.
l 8
party outside people.
9 The action plans reflect consideration of 10
{ SSER-7, where it's applicable to the particular issues i
11 l in question.
12 They incorporate consideration of NRC 13 concerns expressed with the first versions that came O(
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14 in the October meetings, and then subsequently in the 15 January 24 letter from Staff.
16 They include. expansions that resulted from 17 our implementation process.
18 We committed to expanding samples when it was warranted by the results we found, and we have in 19 a
fact made such sample size expansions, particularly in 21
.the electrical. area.
n We've made substantial progress on many of
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23 the issues, especially those that were included in the 24 September 18 and November 29 letters, and you'll be
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25 hearing specific examples.of that progress.
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1 i
8 4
1 The Review Team Leaders, Martin Jones today,
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2
' and others later, will discuss their status on these i
3 issues.
4 I want to emphasize our ~ commitment to 5
thorough and objective reviews of all these questions.
6 What you'll hear today and next week is a 1
7 clear demonstration of the seriousness with which we
.8 view all of these concerns.
9-Turning now to today's presentation and i
10 i Martin ~ Jones,,our Review Team Leader for the electrical 11 area, Martin has over 25 years of experience in the 7
12 power industry.
13 For the last five years, Martin has been a 14 private consultant to the nuclear industry in the 15 electrical and QA/QC areas, i
Previously, he held various positions with 16 i
4 17 South Carolina Electric & Gas Company, including 18 Quality Control Manager for the Virgil Sumner Nuclear 19 Project; and subsequently, he was the company's 20 Manager of Construction.
21 Mr. Jones' nuclear experience began in n
1959 with the Carolina - Virginia Tube Reactor, where f
23 he was the staf f electrical engineer and instrumentatior, 24 supervisor.
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25 He will be leading today's discussion of 6
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I 9
i 2
1
- action plans and the results in the electrical area.
I 2
i We would like this to be an open discussion s
i 3 l of the action plan itself and our results.
Feel free to interchange as the presentatior.
4 I
5 goes forward.
It has been structured so that it will l
l accommodate that kind of active involvement.
6 7
i If there are no further questions, I'll
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8 turn it over to Martin and he can get started.
9 MR. NOONAN:
There's just one other thing.
10 When-I was making my opening remarks, one thing I 11 didn't mention that also I would like you to come back 12 to us on.
13 This is in regard of certain things we 14 talk about, whether they are safety-related or not 15 safety-related.
16 As you start to see more and more of the 17 SER's, you will see in there that there's a number of 18 things the NRC Staff looked at that were not safety-19
~related equipment.
20 Under the normal course of doing business, 21 the NRC Staff would not even have looked at these 22 things.
23 We would have turned them back to you and 24 ! said they are more of an economic impact on you than s-25 they are -- they are of no safety significance to us, e
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and more of an economic impact on you.
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These things are in here. I'm not sure 2
lin this particular area there are any of those, but 3
4 in.some of the areas there are those kind of things.
I 3
I think you need to look at those and you~
6 need to come back to us.
If we say something has l safety significance and you disagree, you have to tell 7
8 us, because you know your plants a lot better than we 9
do.
10 You know, we are in Washington.
We are 11 regulators, and we look at the regulations.
12 It's always the utility that makes the 13 decision of what's safety-related and what's not s
14 safety-related, and we look at it from an auditor's l standpoint =.
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15 16 We usually concur in those decisions or t
17 I we might hava some questions of some certain things 18 we think should be on that list.
But clearly, it's 19 your list to maintain and to' determine.
i 20 so I think as we go through it, particularly
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21 for the next few days, if those kind of' things are in i
22 error, we ought to bring it out on the record and show I
23 that these are non-safety-related items we're talking 24 about here.
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25 The Staff can explain why they. looked at i
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it, and we can go from there.
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MR. B C T.K :
Good.
I apprec? ate that input.
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h, MR. CALV0:
Just for the record, I guess 4
Mr. Noonan forgot to' it.^ roduce the other two members of I~
5 the Nuclear Regulatory Staff.
l 6
i I'm Jose Calvo.
I was the group leader i
7
' for the electrical ir.s trumentation review at Comanche
!I Peak.
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8 9
Here to my right is Angelo'C. Marinos, t
10 who is also working with me in the electrical in-i I
11
. strumentation group.
i 12 That's all I have to say.
13
'MR.
BECK:
Thank you.
14
' Martin, would you do your thing.
15 MR. JONES:
Okay, thanks, John.
l 16 We are going to go right ahead and get 17 into the specific action item plans.
We are going to la use the viewgraph and we've got just a couple of 19 slides that we are going to show as well.
20 Again, as John has said, please feel free 21 at any time just.to ask questions.
We'll be glad to n
stop whenever you like.
If there are any questions,
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23 we 'll be happy to address them as we go.
24 The first thing I want to cover is the
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25 issues which have been assigned to us, that is, 6
12 s
i particularly to me.
There are nine in all.
1 2
1.A.l..regards the' heat-shrinkable cable e-(
3 insulation sleeves.
4 1.A.2.,
inspection reports on butt splices.
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i l.A.3.
is butt-splice qualification.
5 6
1.A.4.
is agreement between the drawings 7
and field terminations.
That is, are the conductors
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8 j terminated as shown on the drawings.
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1.A.S.
involves the nonconformance reports, 9
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10 specific nonconformance reports which were written it on vendor installed AMP, which is a brand-name, 12 j terminal lugs.
i 13 1.B.l.
regards the use of flexible conduit i
14 in the control panels to maintain separation.
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13 1.B.l.
is flexible conduit to flexible 16 conduit separation; and related to that is 1.B.2.,
17 which is flexible conduit to cable separation.
Is Again, we are talking about separations in the panels.
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19 Item 1.B.3.
is regarding conduit to cable 20 tray separation; and Item 1.B.4.
regards barrier 21 removal.
The barrier was a barrier in the control
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Zt panels which have been removed, i
5 23 I'm going to discuss with you Items 1.A.l.
24 through 1.A.S.,
and Item 1.B.4.
25 Items 1.B.l.,
2.,
and 1.B.3. will be r
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1 discussed with you by Sam Martinovich, who is a Gibbs &
1.
I 2 l Hill engineer on this particular issue.
3f I-will go through'them in the order which 4
you have just seen.
A couple of them will be combined, 5
, that is, 1.B.2.
and 1.B.3.,
the butt-splice qualifica-6 tions are sort of intertwined, so I will discuss those fas one subject..
7 i
1 8
Item 1.A.l.'is the Nuclear Heat - Shrinkablo i
l Cable Insulation Sleeves.
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A little background on this:
The sleeves l
11 are in most cases provided by the RayChem Company, 12 the ones.that are under discussion here now.
13 They are insulation sleeves which are
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slipped over terminations or joint splices and which i
13 can be shrunk tightly around.the cable conductors to i
16 provide both insulation and environmental seals.
They l
1 17 are used particularly where there are harsh environ-I j
18 mental areas.
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j 19 In this particular instance, the issue 20 involves a lack of awareness on the part of the QC j
21 inspectors as to where the heat-shrinkable cable
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Z2 sleeves were required to be installed and where the i
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23 installation was required to be witnessed by the QC 24 inspectors.
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I 1 ) involves the following.- It's divided into two parts.
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2i The first part.was that we would review the x
3 QC, that is, the inspection procedures, and the instal-llationprocedures, and to make revisions to better 4
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'5 define where these inspections were required and what 6
. the actual installation requirements were for these l
7 l things.
8 In looking at some of the documentation 9
reviews that we 're going through now, it's becoming I
to even more apparent to us now that we need to even 11 further improve those procedures.
We need to clarify 12 them even more.
13 So we are in the process of doing that 14 now, and I think when we are finished with the program, 15 we are going to have a very useful set.
16 Part two of the program involved a sampling 17 plan, which was based on the 95 percent confidence 18 level that no more than five percent of the inspection 19 reports would be defective.
N That is, in reviewing the inspection 21 reports, make sure that these inspections were witnessed..
It so we have identified in this program a f
23 little over 1100 places in Unit 1 where the heat-shrink 24 installations were used.
That is, of motor terminations,
s 25 connections between cables and electrical penetrations
I 15 and in areas of that type where they were actually 1
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' used.
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3 Those cables were identified in the 1
4 { sampling plan, samples from those 1100.
To get the 5
95/5 confidence factor, we selected 60 out of those which had an acceptance of zero, with an expandable i
6 1
l factor in there to expand it to 95 in case there was
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!' one failure.
9 Any more than that, above the -- out of to that 95 requires, using this statistically-based ilsamplingplan, a hundred percent reinspection, a ti 12 review of all those, a hundred percent review of all 13 those inspection reports.
14 Based on the first 60, and going through 15 it the first time, and reconciling all the things I that need to be reconciled -- for example, what 16 17 revision of the procedure was in use at the time that inspection was made, what inspection report was is that 19 required at that time, and going through the whole i
20 thing trying to reconcile them with those things, we I
21 felt at that time that there was a failure that we n
could not reconcile.
I 23 We expanded it to the next 35.
In re-4 24 reviewing that, we are still reviewing that one failure, k) 25 and we are not positive that it was a failure to 9
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16 1 l actually witness the splicing, maybe a failure of s
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something else.
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But we are still looking at this plan, but i
4 we have gone to the second 35.
We are in the process
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5, of reviewing those now.
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We hope that we'are going to be able to t
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! reconcile all our findings.
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MR. MARINOS:
Martin,-can-I interrupt you i
9 l a minute?
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l' 10 MR. JONES:
Sure.
11 MR. MARINOS:
This one failure that you j
12 mentioned, is that failure to document or failure in 13 the actual physical installation?
What was the nature 14 of the f ailure ?
13 MR. JONES :
That reject that's listed 16 under Page 1 right the re, in fact, had to do with I
17 the termination, not with the heat-shrink installation l
l 18 itself, and that's why we still have a question as to i
i 19 whether that was actually a failure of somebody to i
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witness the heat-shrink installation.
21 MR. MARINOS:
But the documentation was 1
M there that it had been performed?
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l 23 MR. JONES:
There was some documentation
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2d that it was witnessed, verified.
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25 MR. MARINOS:
Ve rif ied?
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MR. JONES:
Verified, right.
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2 MR. CALVO:
You say that the total number i
3 of cases with the heat-shrinkable sleeves used 4 I were 1100.
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5 MR. JONES:
Over 1100.
l MR. CALVO:
What is important to know, 6
l 7
i you've got to know what the total population is.
I 8
MR. JONES:
That's right.
9 l
MR. CALVO:
So based on that total i
10 population, you say you picked up 60 records?
11 MR. JONESt. Sixty records.
12 MR. CALVO:
It looks to me that that is 13 kind of low.
14 MR. JONES:
That's to give us 95 percent i
15 confidence that no more than 5 percent of those will 16 not have that record.
17 MR. CALVO:
But that was based on what 18 kind of a population, over 11007 19 MR. JONES:
Over 1100.
20 MR. CALVO But as the population increases /
21 then the sample also would increase?
%2 MR. JONES:
It would also increase, if
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23 that's the case, yeah.
24 Mn. MARINOS:
Sixty gives you a 95 percent 25 i confidence level with no f'ailure s ?
18 i
1 MR.' JONES:
Five percent failure; five 2
per cent.
3 MR. MARINOS:
Who has determined the 60?
4 I
i 4
- That is statistical basis?
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MR. JONES:
Yes.
We have a statistical i
l 6
censultant on board with us almost full time that l
7 works here, and this was based on his reccamendation j
's as to how we came up with it.
1 9
MR. MARINOS:
That's something that I l
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10 l.would have to ask our statisticians.
I'm not a 11 statistician, so I 1
1 12 MR. JONES:
Neither am I..
13 MR. MARINOS:
So 60 is the number that l
14 would give you'that confidence level?
15 MR. JONES:
That's right, 95/5.
i 16 MR. MARINOS:
I was under the impression J
17 it was a larger number.
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18 MR. JONES:
Not in this case.
i 19 MR. MARINOS:
What'do you mean, "not in f
20 this case"?
j 21 MR. JONES:
We'll get to one on the i
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Zt terminations where we have a 9'S with only one' percent l
I 23 rejection f actor, which does give you a much - higher 24 number.
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25 MR. MARINOS:
Well, in terms of how many, 1
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1 l what is the sample, how large a sample you need in forder to get this confidence level of 95 percent, I
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that is a larger number 3
was under the impression that i
4
- you would have to inspect in order to get this con-lfidence I-5 level of 95 percent.
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6 l
I thought it was in the hundreds.
It's 7
l something I'll have to check with our statisticians.
I 8
i MR. JONES:
Okay.
Fine.
We'll be glad to I
'9 lgooverthat.
10 MR. MARINOS:
On various subjects, not 11 I just terminations, but other things that we do to 12 determine the confidence level.
13 MR. JONES:
Sure.
14 MR. CALVO:
But again, you answered to 15 say "over 1100."
That is not the correct answer.
16 The answer is, "We have so many of these cases," and 17 based on how many cases, you pick out a sample to give 18 you 95/5.
Okay?
19 MR. JONES:
Exactly.
20 MR. CALVO:
Based on that sample, then you 21 find what the rejection criterion is, at 5 percent.
22 So you've got to know -- for us to check 23 it to see if you are correct, we've got to know how i
lmanyrecords 24 do you have, how many cases.
Then i
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%s 25 based on that, the cample hed been selected.
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MR. JONES:
That's exactly right.
Precisely.
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MR. BECK:
Jose, if I can interject, i
3 { because we are using a sampling approach, we are very i
4 l sensitive to making certain from a statistical stand-l point I-5 that it's a properly structured piece, because l
i 6
l we are doing it in more than one instance.
I 7
The consultants that we have brought in i
8
! in this regard are absolutely topnotch and the action i
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9 plans as they specifically address samples will i
l reflect that constant input.
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11 l
They are assisting across the board with j
i 12 all the issue team leaders as they encounter these, l
13 and the written documentation will reflect very
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14 precisely what the bases were, what the sample sizes 15 were, what the criteria are.
16 I think you'll find it sound.
t 17 MR. JONES:
What you say is absolutely 18-right.
You have to know the exact 1128.
19 MR. CALVO:
The other thing, I think, we 20 l talked about at a meeting in Bethesda on this same 21 subject.
Z2 Once you start with the sam $le that you
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23 are going to take, you should concentrate on those 24 systems which, upon their failure, they give you the
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s-25 greater probability for potential risk, you know, a
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potential problem of core melt-down in the reactor.
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So whatever the sample, if you only come e'
F 3[out with 60, I think it will re of interest to everybody 4
where you are concentrated, with the diesel generator, 5
or are you concentrated with the emergency core cooling system, whatever.
6 I think that's interesting.
7 MR. JONES:
I think when we get into 8
i 9
termination you will see exactly how we address what 10 your concern is there.
i I
MR. CALVO:
Okay.
33 MR. JONES:
So the status of this 12 particular item is right now that we have reviewed 90.
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13 we are still in.the status of review.
j, We have not yet determined that we will 15 have to expand that sample in this particular area.
16 That is the status, and we are almost, 17 in this case, on this one, practically at the end of 18 our work and at the end of our review on 1.A.1.
j, 20 Okay.
These butt s'plices -- and as I mentioned earlier, I'm going to combine the discussion 21 of 1.A.2.
and 1.A.3. on' butt splices.
22
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This is an area where we have had a 23 24 number of problems.
We want to discuss them with you.
I3r 25 I think there's certainly some negative e
6
1 22 l
1 l aspects to it, but there's some positive aspects to it, 2
too.
3 The concerns that TRT found with the butt 4 l splices included:
That inspection reports did not i
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indicate that the witnesses of the splice installation l was done; the drawings did not reflect the location of 6
l 7
all the butt splices.
8 We were concerned that the butt splices 1
9 ! were not qualified for the service conditions which 10 they were used.
11 That the butt splices were not staggered; 12 that is, they were not adjacent to each other and i
13 not touching one another.
I 14 And that there was a lack.of provisions in i
the installation procedures, and that should also
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15 i
16 include the inspection procedures, to verify the 17 operability of those circuits where those things were t
la e used.
t 19 I would like to give you a little background i
3 on butt splices.
21 A couple of years ago it was recognized 22 that there were a number of changes that were going k
23 to be required in some of the control panel wiring.
24 These were for a number of reasons.
They
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25 were primarily in the control and spreading room panels,
9 l
23 1
In some cases they were in other areas.
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These were either due to logic changes, or I
3 I there were some other reasons, human factors, for l
4 I example, maybe TMI changes, or in some cases it was
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simply to better re-arrange the train cables in the 6
panels.
7 But for whatever reason, the AMP pre-s insulated environmental seal butt splices were 9
selected, which is a butt-splice sleeve which has the I
to l insulation as sort of an integral part to it.
11 We've got a slide which shows this.
An 12 FSAR amendment was submitted to provide for the use of 13 these.
f.
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14 I think that was Amendment 44.
It was 13 submitted to allow for the use of these splices in 16 ;
the panels.
17 Could we have that first slide, please.
18 These drawings were taken from the AMP It installation guides that were used here on the project.
20 The left-hand side is the acceptable 21 method of using it.
The right-hand side shows one, n
for example, where the insertion depth is not -- if f
23 you'll look where it's marked No.
6, for example, on 24 there shows that it's not inserted as far'as it is on n
25 No. 6 on the left-hand side, all the way to the wire
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i
!l 24 l
1
- stop.
{N 2
We have spent a lot of time on this and 3
a lot of effort.
We'd like to go into that in some 4
detail, if you'd like.
5 We have one more slide that shows where 6
these splices -- an example of where these splices were 7 l used.
8 This is the inside of one of the control 9
panels.
This particular one is CR-13.
It's a little 10 difficult to see the splices.
They are small.
n This is just an example of the kind of 12 Panel =nd the type of wiring where these are encounterect.
13 In this particular panel there are quite a 14 few of them.
I'm sorry the slide is not a little bit j3 clearer, but if you look closely, they are visible.
16 They are not very much bigger than'the conductor 17 itself.
18 Okay.
As I mentioned, the FSAR Amendment 19 44 was submitted to allow for the use of these, but in 20 using them the issue of staggering was not included in 21 that amendment to the FSAR.
22 So it was recognized shortly, I guess, after
(
23 the TRT inspection that staggering had neither been 24 included in the procedures nor had it been accomplished (s
23 when the splices were made.
6
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l So it was recognized early on that that 4
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2 I type thing had to be corrected.
.i.k I
j 3l I'd like to also point out that the sleeves lthatwarsusedareverysimilartothe
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4 AMP, which is I
jl the l'
5 same menufacturers who manufacture most of the I
6 terminals that are used in those panels and elsewhere i
i j
7 throughout the plant.
i 1
l l
j 3
So in the process of doing this, there l
9 were a number of these control instrumentation cables to spliced and reterminated and they were primarily in i
i ti these cabinets.
i l
i 12 To date we have identified 615 of those i
2 f
13 splices.
That's in these panels in the cable and 14 spreading room and outside, including a few that are J
i' 13 in some other control centers and other places.
16 Could I have the next?
i l
17 MR. CALVO:
Excuse me.
This is from Unit 1 j
13 or Unit 2 only?
i I
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MR. JONES:
We're talking about Unit 1 g
right now.
I think we're doing the best to not use
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21 them at all in Unit 2.
n The fact is that Unit 2, before that in i
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23 fact, not all that work has been done yet, if'I'm I
l 24 correct, and they recognized these modifications and 4~
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25 changes that needed to be made before those cables were I
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l 26 1
put in to begin with.
So it hasn't been the same sort fofprobleminUnit (S
2 2.
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3f MR. CALVO:
So the question, then, any I
systems in there that are shared be tween Unit 1 and 2 4
(
5 where you may have bad splicas; that's what I'm asking.
l 6
MR. JONES:
I suppose it would include 7
Unit 1 in common in what we've already looked at..
1 s
I will say specifically, we have not 9
looked at Unit 2 at this point, anyway, just at Unit 1 10 in common.
11 So far, here are the initiatives we've takert, 12 and I'm going to discuss these in phases because it kind 13 of in a logical manner falls into these phases.
14 In Phase 1, these were the things that we 15 recognized from the beginning:
That the cables had 16 to be retrained so that the butt splices would not 17 touch one another.
Is We realized that we needed to revise the
~
19 procedures, the installation and the quality control 20 procedures for tighter control.
21 We agreed with you that we needed to --
Z2 that the butt-splice sleeves needed to be qualified b
23 for the service conditions in which they were used:
24 and this is based primarily on the manufacturer's
()1 25 information on those.
4
_ ~ _._._
I 27 1
And we agreed, also, that we needed to i
2 i review additional inspection reports for witnessing
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3 j the splices.
L i
j 4
I During this period of time when the TRT
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j 5
was.here, I think you looked at about 12 inspection 4
I 6
reports and found some problems with those inspection I
i i
i j
7
- reports.
8 And then prior to, at least, the i
9 restructuring of the SRT, TUGCO folks had looked at 1
10 12 additional ones, but not based on any statistical 4
I 11 i sample or any, really, scientifically based sample, 12 but just sort of a random sample that they had done.
1 t
13 Phase 2 was predicated on failures in
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14 Phase 1 which occurred.
15 In addition to that, I think your comments l
16 on the original action plan had requested that Phase 2 i
17 be conducted regardless of any outcome of Phase 1.
I i
is So in any case, for whatever the reason, l
)
19 we have proceeded to Phase 2 in the butt-splice l
20 inspection.
o 21 Phase 2. consisted of a third party f
Z2 inspection of the butt splices in the panels; that is, i
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i
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23 physical inspection of the butt splices in the panels 24 to see that they were in conformance with the drawings, l
. b 25 that they were properly terminated, that the right f
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28 1
i
! sleeves were used, that the right crimp was used and I
2 l the right tool was used, the things of a normal in-4 3 l spection nature which take place during any installa-i 4 l tion.
(
l 5
Phase 2 was also to update and correct the 6
design documents.
Primarily, that is that the~ drawings l
7 j correctly reflect the location of splices within those
.g panels.
9 Phase 2 would also correct the hardware 10 i deficiencies that were found; that is, bad splices for 11 whatever reason.
Any hardware deficiencies that 12 needed to be corrected, they would be taken out, 13 replaced or whatever.
14 It would'also include a third party review 15 of all the inspection reports; that is, inspection 16 reports of all the cables covered by these butt splices, 17 the 600 conductors, however many cables that was.
la okay.
I'd like to give you just a summary.
19 We are still reviewing this and I'd like not to be 20 pinned down on these exact numbers, but I want to give 21 you some numbers on the things that we found during 22 this inspection.
23 The physical inspection is complete.
We 24 are still doing the documentation reviews and we are (i
25 still reconciling some of these things.
29 i
Let me give you some numbers of things we p
2 l found.
s.
l There were 26 cases of plain unauthorized 3
l butt splices being made.
That is, there was not a 4
I 5
design change authorization.
6 And, again, if you don't We are still 7
reviewing the numbers, but I want to give you an idea 8
of what they are.
Please don't' pin me down to them.
9 There were in excess of a hundred splices 10 on the drawings which were not found in the field, and
)wemayneeda little explanation on that.
11 12 I think the best explanation for that is i
13 that the field requested that splices be authorized 14 in looking through and seeing what cables were going 15 to have to be moved.
And I think probably what 16 happened in this case was when + bey actually had to 17 move the cables, they found that the conductors indeed 18 were long enough to reach.where they needed to be 19 reached, but the glitch was in not getting back to the 20 engineering so that they correctly reflected it in the 21 drawings.
22 There were 23 crimps, that is, the
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23 impression on the butt splice, where the wrong tool 24 was used.
That is, the manufacturer specifies for (i
25 each sleeve size and type what tool should be used.
+-
30 1
In 23 cases the wrong one was used.
i r'
2 l
In eight cases the wrong sleeve was used.
t 3 l'That is, the wrong size sleeve was used for a 4
particular conductor size.
(
5 In ten' cases the insulation, the integral 6
insulation to the sleeve had been split.
Whether it t
7 was caused by the tool or maybe by heating it, over-I h' eating when it shrunk, it was split.
8 i
9 In three cases we found strands curled.
10 i That is, all of the strands in the conductor didn't 11 get inside the barrel.
12 And in fourteen cases there was an 13 improper crimp.
Generally, this means that the tool 14 wasn't placed in.the correct location on the butt splice.
13 when it was found.
16 In addition to that,.we found other 17 deficiencies -
I' won' t give you any numbers on those --
18 where at least there was a termination error or there 19 were drawing errors.
There was no visible dot code M
on the splice.
When you squeeze these with the right 21 tool, it leaves a little tiny det impression and Z2 indent so that you can go back and later see that the I
23 right tool was used, either one dot or two dots.
24 In this case.you just couldn't see it.
.I t doesn't
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25 necessarily mean it was bad, but you couldn't see i t..
8 6 49.-
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31 1
The stagger was certainly not what it 2
should have been, and that has been or is being i
3
! corrected.
f Either wrong color or the wrong size w za 4
1 5
was spliced on.
We are still looking into that.
6 And then outside of Jhd.. a specified in 7
! our inspection procedures, what we asked the inspectors i'
8 to specifically look for, we also asked them to 9
notice other things.
f These included damaged insulation that 10 1 they ran across.
They identified some separation 11
)
12 problems.
13 There were improper support.
That is, in L.
14 some cases the bundle might then pull it down against 15 the termination lugs.
You know, it's not properly i
16 supported.
17 One of the problems that we are looking 18 into further was that there's a possibility -- if you 19 will recall the first slide that we saw -- that there 20 was not complete insertion of the conductor into the 21 sleeve; and that is one that bothers us because it's Z2 not something you can determine from outside inspection
(
23 of it.
So we are looking into that.
24 We are going to consider all these things, 25 but.what may be most significant, what we feel the I
ame sse o y
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1, most significant of these, and that is where the wrong i
(7 2
crimp tool was used, where there was an improper crimp, 3
where we u' sed the wrong sleeve or the wrong wire size, 4
either case, where there was improper insertion depth,
'l 5
if that is the case.
Those are'the four items with I
6 j which we have our primary concern.
7 The actual safety significance, that is, l
8 i the over-all' safety significance as it applies to the 9
operation of the plant will be determined in each j
10 case where we have a bad crimp, looking back at the 11 function of what that particular conductor was and I
12 whether it may or may not have functioned in that plant.
13 So that's part of our ongoing work, is to 1
look into the safety significance of those particular 15 things.
16 Could I have the next chart on that, 17 please?
Okay.
Is I would like to say that the documentation 19 review, that is, the inspection reports, that's been 20 started.
1 21 I think they have turned in initial 22 findings on that.
h.
have not reviewed those and 23 that is in progress.
24 So all.these are going under review.
(r 25 There's.obviously a need for a Phase 3.
Phase 2 is 4
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l 33 l
1 j not going to resolve all the problems that we have.
Phase 3,
I said, we will need to evaluate
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i Am j
3- ; the safety significance in those specific areas.
i' 4
We need to investigate related areas.
I 5
That is, this is not limited to butt splices, if 6
l there are other things that are related to that that 7
! may also be affected by the things that we find wrong 8
here.
9 The first thing you would think of would to be, say, terminations or the drating change' control, 11 things of that nature.
12 We don't feel-the terminations are, but 13 there may be other areas and we are going to look into 14 those.
15 l
We are going to determine the root cause, 16 how did.this all come about and why is this situation 17 existing.
18 We are going to look at the OA and QC 19 implications of what we've found.
20 And then we are going to take long-term 21 corrective action.
Z2 Okays What we've tried to do is to 23 summarize the concerns that'we found with butt splices 24 and what we're going to do a~s far as the over-all
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25 corrective action goes.
e 4
34 1
The first three concerns, for example,
(*5 2
i the wrong crimp tool was used, wire strands were l
3 ! curled or the insulation was split or improper shrink, l whatever, in those cases, certainly, the short-term 4
5 action is going to be replace those things.
In order to do that and before we replace
~
6 7
them, what we're doing now is making sure that the t
8 proce'dures that we use are --
9 MR. MARINOS:
One point of clarification.
10 These determinations were made on a 11 hundred percent inspection of all the butt splices i
12 that you were able to find.
13 MR. JONES:
Yes.
14 MR. MARINOS:
So the specific deficiencies, 15 wrong crimp tool or wire strands is on specific ones?
16 There is no hidden ones?
17 MR. JONES:
No.
There's no statistical is
, analysis or anything like that.
These are specific i
19 ones where we found a specific problem.
That's correct.
3 Before we can replace them, certainly,- we 21 need to look at the procedures.
We need to make sure n
that'the electricians that are going to do this work
'I 23 are adequately trained, and that the inspectors are 24 also adequately trained to do this.
()
25 The procedures are in the process of review l
l l
l 35 1
now.
I've looked at them; other folks have looked at
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2 them; outside third-party people have looked at them.
3)
Next week the AMP training trailer or 4
truck or whatever they have is going to be down here I-5 l to specifically talk to the people who are going to do
~
I fthiswork.
We are going to have the factory people 6
i 7
come in and make sure that they are adequately trained, 8.
both the ins pe ctors and the electricians, before we 9
start this work again.
10 Those would apply to the first three.
11 We are going to correct, certainly, any 12 unsatis f actory terminations.
In doing the butt splices 13 we also inspected the terminations associated with 14 that butt splice.
~
We looked at the butt splice and went to 15 16 the end of the cable and looked at those terminations.
17 And this is added --
In looking at these terminations - -
18 when we get to 1.A.4. we will discuss this a little 19 bit more,-but it's added to the number that we looked 20 at under terminations.
21 We further improved our confidence in those zt by looking at these.
We found one where the white and
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23 the black wire were rolled.
The function was still 24 okay.
It was still in contact and it still worked (I
25 okay, but we are going to correct that.
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We feel like that was an isolated incidence I
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and no long-term corrective action is needed in this i
3 case.
4 Where inspections were inadequate,
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l 5
- certainly I would have to say, and I don't think there 6
would be any disagreement, that in finding the number 7
of things that I've listed for you today, that inspec-
~
8 tions were not adequate either.
9 So we've got to'go back and look at 10 training and certification requirements.
We've got to 11 look at the procedures, and we've got to do some 12 inspector retraining-for this particular thing.
13 The next concern --
14 MR. MARINOS:
But as far as butt splices 15 are concerned, you have made a hundred percent 16 inspection, so you have it narrowed down to the 17 specific ones that are of question.
18 MR. JONES:
Yes.
~
19 MR. MARINOS:
They may be adequate, but 20 nevertheless in question.
So you can repair those 21 one way or the other, and this whole' issue could be 22 put to bed.
(
23 MR. JONES:
But we want to make sure that 24 the repairs are done.
-25 MR. CALVO:
We started on the premise in t
I 37 1
this'whole effort that butt splices shall not be
('N 2 ! permitted in the installation of a nuclear power plant.
~.
g 3
i We accepted --
At the time it was 4 - l determined it would have been counter-productive to
(
5 rip all the cables and put the new ones in to satisfy 6
the requirement.
i 7
I think from the standpoint of safety it i
P woul4 be the wrong thing to do.
So we had to find out, 9
see what you had there and determine if what you had i there had been accomplished in the right manner.
10 11 I think it will be -- and, again, keep 12 in mind that we only accepted what you had on a 13 limited basis, and maybe 600 may'be'conside' red to be 14 a limited basis, but I think i't would be of interest' 15 to all, and to you, too, is where those splices are 16 and on what kind of systems they participate.
17 To me, that's the most'important safety 18 significance.
I 19 MR.. JONES:
You are exactly right, exactly 20 right.
21 MR. CALVO:
Because if these splices are 22 associated with unrestricted windows, alarms or
(
23 associated with lights, as oppossa to control signals, 24 that becomes.very significant.
/
25 Depending on theisystem where that.is O
38 i.
1 l butt spliced, if it's a control system, then we are i
('N 2
l going to assess in those cases whether it's worth the l
v 3 lwhile to have a butt splice or do something else, 4
especially in there, because of the significant impact I
5 or the failure of that splice would have on the safety 6
of the plant.
7 i
Suppose we found a butt splice associated 8
with the diesel generators.
If that one failed, we 9
! coul'd end up losing all the diesel generators.
Maybe 10 we should look at those particular cases very closely.
11 If all the butt splices are associated 12 with lights and alarms, then the inportance to safety 13 is not --
-Y-14 MR. JONES:
They are not.
No, they are 15 not.
16 MR. CALVO:
So I guess what I'm getting at, 17 to put this whole butt splices in perspective, I would 18 like to know as soon as you could, maybe at the front 19 end of your plan, which circuits and which systems are 20 those splices associated with and what impact those 21 splices will have in the event of a seismic event or Z2 when you challenge them against all the design basis I
23 events.
24 MR. JONES:
We have not identified the I
v 25 functions of the splices which we have considered to be 9
i
39 1
acceptable splices.
We are only doing that where we
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2 j have determined --
3 MR. CALVO:
You may want to consider --
MR. JONES:
'We may want to consider --
4 5
MR. CALVO:
You may want to consider that, i
i l and, also, depending on the role they play to the 6
i
~
7 safety of the plant, you may say, "I want to handle 8.
this a special way, and I can handle this in a special 9
way."
10 l
MR. JONES:
Okay.
We'll certainly J
I 11 consider that and be glad to talk with you more on i
l 12 that subject.
Sure.
13 As I say, though, the safety significance b
(
14 to date that we have considered has only been for 15 those where we feel that there's been a problem and 16 not where they have been acceptable.
17 But we will certainly --
18 MR. CALVO:
Even the ones that you feel 19 are a hundred percent correct, you've got to put them.
N in which system, what role they play in that system 21 and what is the significance if that splice' fails.
22 I guess it goes back again, when you say
(
23 that it had to be properly qualified for the service
~
24 conditions.
-Now, what do you have in mind there when 25 you say " service conditions"?
What did you consider?
1 40 1
1 I'm asking the question, what things do I
~
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2 j you consider when you say that you are going to be i
3 sure that they are going to be qualified for the 1
4 t service conditions?
I l
5 MR.. JONES:
Primarily what we have 6
considered in qualifying for service conditions has 7 l been atmosphere; that is, you know, on the accident l conditions, the atmosphere for them.
Not its function, 8
lbutwhere it is as opposed to what it does, if you 9
l 10 follow me.
11 MR. CALVO:
But I guess what we had in i
12 mind when you try to qualify a piece of equipment, a 13 splice, a cable, to a service condition, the service i4 condition all the' design basis events.
15 I guess one thing of interest will be 16 what happens when you shake -- if a seismic event in 17 some kind of way shakes those things up, if it will 18 come loose as a result of that.
19 This is the kind of service conditions 20 that we had in mind.
21 MR. JONES:
I think that's covered under 22 qualifications, but we'll be glad to go over that h
23 with you in detail.
We do have the qualification 24 reports.
25 MR. CALVO:
Okay.
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41 1
MR. JONES:
We will be glad to get into lfurther detail with you on that.
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2 I
3 l
MR. BURWELL:
My name is Spottswood Burwell I
d ; of NRC.
I wonder if copies of these slides will be I
l 5
- made available.
6 j
MR.. JONES:
We are going to give them to 7
her as part of the transcript, as I understand.
I 8
believe that's right.
9 Our next concern is with the and I think 10 we need to spend just a little bit of time talking i
11 I about it is the insufficient conductor penetration 12 depth.
13 We can't tell that.from looking at it.
14 What caused the concern is the little splices are 15 translucent, and if you look with a light behind them, 16 you can see whether the insulation is seated all the 17 way.
18 You can't tell whether the conductor is 19 seated all the way, but you can see where the insulation M
is in all the way.
21 We have found some where there's a gap Z2 that shows that the insulation is not in all the way, 23 which means one of two things:
Either it was stripped 24 too far back from the end of the cable or the whole P.(s 25 thing wasn'.t pushed in far enough before it was crimped.
42 1
So we have identified some of those and
(
2 we are going' to do some testing.
We are going to use I
particularly the ones that we have to remove.
3 l
4 To date ve have. identified about 77 that t
S-i we know are going to have to come out.
So we are going I
l to use those particular ones to come out; we are going 6
l l
7 l to run some tests on those.
a We have identified some that have two hits.
9 They had to be removed for some other reason, and, 10 also, you can see that there's a little conductor gap.
11 These will be destructive tests.
12 We've also done some X-raying.
I think 13 we are going to find that a satisfactory X-ray will 14 show us whe ther we 've got the penetration or not.
I is believe the guys that have done that said that it's 16 even possible te do it on the ones that are in place 17 in the control room.
18 So we are going to do further investiga-19 tions.
We are going to do some pull tests when we 20 are evaluating safety significance, for-example.
One 21 that has been pulled out for the wrong crimp tool, 22 for example, we are going to run pull tests on those I
23 in accordance with the UL standards to see what might 24 have happened if we hadn't discovered what was wrong.
(-
25 So we've got a small testing program that
43 1
we're in the process of outlining now.
I think it
,r't 2 ! will resolve all these things and tell us exactly which s-i ones have to be removed and exactly which ones can be 3
4 kept and for what reason.
(
5 Let me summarize, not just from the l
I 6
standpoint of butt splices, but from the standpoint 7-of our whole Program Plan that we've got here in the 8
electrical area and in the other areas, to kind of 9
rei'terate to you how we got to where we are.
I think to the butt splices is a pretty good example of this.
11 The Program Plan that governs the actions 12 that we work under, that is, that the SRT works under, 13 is shown in this as sort of an evolution of what's
(
14 happened to the butt splices.
15 First, there was recognition at the 16 beginning, I think, that installation should be 17 improved through retraining the electricians, through 18 retraining the inspectors, and that we needed to 19 separate the splices in accordance with the NRC's 20 guidelines.
21 We agreed that the. splices need to be 22 qualified for the environment used in.
We recognized f
23 that the procedures need to be tightened up, both in I
24 installation and for the testing procedures.
1
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25 Stage two, as I look at it, was recognition
l 44 ll that the docume'ntation that you guys looked at didn't 1
Il meet the witnessing requirements.
That was just a
.i 2
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i 3
small sample, but we recognized that they didn't.
l As a result of that, we went into a third 4
(
5 party reinspection of all these butt splices that 6
we've identified in control panels, where these splices 7
were made in these control panels.
We reinspected them 8
l all.
i 9
And we also recognized in the second phase lo that the design drawings need to be made to match 11 correctly the as-built condition.
12 Then we went to stage three, which was 13
. recognition -
that's where we are now -- that the 694(
14 installation requirements had not been met in all 15 cases, and that there will need to be corrections of 16 immediate concerns.
17 That is, under the requirements of the 18 TUGCO program, we had to correct those immediate 4
19 concerns.
a We had to evaluate the safety significance 21 of what we found, and we have to determine the need to 22 expand what we found here into other areas.
23 As part of that, also, we need to define 24 what the long-term corrective action is.
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25 So this has been the three stages that
.*-e we M-
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l 45 1
. we have come through in this thing.
Throughout this
/'s 2 ! whole process, what we've also recognized in addition
-(.
3 is the need to coordinate what we've found with the 4
other QA/QC concerns that have come out in subsecuent I'
5 letters, and to maintain communication with our other 6
SRT disciplines, that is, civil, mechanical, whatever, 7
testing, so that they have access to the things that 8
, we've found so that where it is applicable that they 9
can apply those lessons that we've learned to the 10 l areas-where they are working.
11 l
If there's commonality.of the problems, 12 we want to know about it throughout, no matter what 13 discipline it is.
It makes no difference to us.
b(
I 14 We want to.make sure that where we have 15 found that there is some commonality of problems, 16 that everybody understands-them.
17 But I think that what we've done in this 18 is indicative of the breadth and the depth to which we 19 have gone in these action plans.
20 This is from the standpoint of finding 21 things that are wrong, kind of a bad example, but I
[
Z2 do think it gives you a better understanding of the
(
23 way that we are approaching these' problems.
That is 24 that we are not simply addressing your immediate 25 concerns you found with the TRT and putting that away 6
m,
46 i
1 l or fixing that immediate thing.
But we want to get to I
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2 j the root of it.
We want to correct all of
't.
We
('
3
! want to make it better.
i i
4 l
We want to make sure that the work that
(
5 goes on in the future in related areas is done 6
{ adequately, and that where else this might apply 7
throughout the plant it is also applied.
s I think'that this particular area has 9
been a good example.
10 That concludes all I had on the butt 11 splices.
We can go on to terminatiori.
12 MR. CALVO:
I would like one more question.
13 MR. JONES:
Sure.
14 MR. CALVO:
Are you going to consider the 15 verification of circuit operabilfty?.
~
16 MR. JONES:
We've looked into that,.both 17 from the standpoint of -- I tP'.nk the procedure is now 18 requiring conductivity checks, that is, conductivity 19 checks before put into service.
The operations-also require 20 they 21 determinate and run their own conductivity checks, in 22 addition to the function of the tests that they
(
23 subsequently run on those circuits after they are 24 reconnected a's part of the start-up testing program.
(/
25 MR. MARINOS:
Do you mean continuity tests?
r 9--.-_.p..4..-
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e c- - -
i 47 1
MR. JONES:
Continuity tests, right.
g 2
MR. CALVO:
I guess I'll just reiterate r
1 I said before.
We'll be very interested, h; what 3
l 4
- everybody, in the front end of it, what circuits these 1
5 butt splices are associated with.
MR. JONES:
Okay.
We have not to date 6
I 7 l looked at what the functions are for all 600 of those S
circuits, as I have mentioned.
9
. We will be grad to get into that and have l some further discussions with you about it.
We have 10 I
11 l not done that to date.
12 1.A.4.,
the title is called, " Agreement 13 Between Drawings and Field Terminations," and this is
(<
selected field terminations, cable terminations were 34
' looked at by the TRT and it was found in several of 15 16 the cases that there was not. agreement between the 17 location of the terminals in the field and what was 18 shown on the drawings.
~
19 Our initiative in this area has been to 20 conduct a statistically based random sample of the 21 safety-related terminations in the control and cable 22 spreading room, and we have provisions there, if 23 necessary, to expand that sample based on the results.
24 To get back to what you said, Mr. Calvo, a e.
(>
25 little earlier about limited to the safety related and
]
48 l
1 critical uses, this sample that was selected was I
('
2 l comprised of a population of ---- I believe it was 3,000, fl a little over 3,000 terminations which we had determined 3
1 4 i were associated with circuits interfaced with the
(-
5 alternate shutdown panel.
That is, these were critical circuits to 6
l l being able to shut the plant down in accident conditions 7
8 and to prevent the core damage that I think you had 9
- previously considered.
10 So that's where this population in this 1
11 { particular case was s ele cted from.
The number -- I'm 12 sorry, I don't have it right now, but I think slightly 13 over 3,000.
@(
14 In this case we d dn't feel like five
.15 percent was adequate.
In this case, statistically 16 based, 95 percent confidence that they are less than 17 one percent, that there will be less than one percent 18 errors in the entire population, based on the sample 19 that we found.
l 20 This required -- okay,-I'm sorry.
Here's 21 the numbers.
Thirty-eight hundred and twelve, thr'ee 22 thousand eight hundred and twelve was the number.
9 f
23 To get the one percent required that we 24 inspect three hundred with zero rejects, zero exceptance 25 So this was the numbers that were used.
.-..mn
--.n
49 1
i MR. MARINOS:
What are the expectations to
/~N 2 l locate termination problems during a pre-operational l
3 i test?
Would they expect, if you didn't look at them 4
all, that there are some wrong terminations?
5 Is the pre-operational test comprehensive 6
enough to locate those?
7 MR. JONES:
I would say, and this is purely
~.
8 opinion, Angelo, that where they are critical, there's I
a very good expectation that they would.
9 10 MR. TYLER:
Terry Tyler, the Comanche I
11 I Peak Response Team.
4 12 The pre-operational test program, the 13 prerequisite testing did verify the terninations, 14 circuit continuity, et cetera, and also, the logic 15 tests have been reperformed to verify total logic 16 circuitry functionality, both initially and then 17 again the second go-round of testing.
18 So to answer your question, yes, the
~
19 pre-op tests are very comprehensive and would pick up N
those problems.
1 21 MR. JONES:
So to date, what we have found, n
we have compared these 300 terminations to the f
23 drawings.
2d We have also, in doing this, looked also
(
25 at the crimps, the other inspection attributes, the o
l m,, -,
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i 50 1
connections to the terminal blocks, whatever else you
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2 can tell in an after-the-fact inspection.
That is, s
{that they were identified properly, the right colors, 3
i 4 l all that kind of thing.
(
l 5
l We did find some minor problems, such as 6
there was some difficulty in identifying a blue
~
7 conductor because of the shade of what was used.
8 They identified one terminal that looked as 9
if the conductor was not inserted far enough into the 10 sleeve.
However, an NCR had previously been written on 11 that and it had been covered.
12 There were a couple of drawing errors.
13 There were some spares that weren't shown on the C..
14 drawings, for example, and weren't tagged.
15 But in all cases, in all cases, as Terry 16 mentioned, the function of all these terminations was 17 correct.
Is In addition to that, we added the 600-plus 19 that we did under the butt-splice inspection into this 20 pot, and they are distributed 'not just to the interface 21 with the alternate shutdown ~ panel, but for whatever they n
happened to be used for.
(
23 We also, in conjunction, when we looked at 24 the butt splices, we looked at the termin,ations j
25 associated with those butt splices, which trip' led our e
.-~
r l
i 51 l
]
1 sample size, basically; and, again, although there
}
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i i
j
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2 j
were some minor concerns we found --
For example, f
rs 7
t 3
in this case we found a rolled pair of leads, a black i
4 wire and a white wire were rolled.
They went to a l
I r
5 contact, which the function was correct.
i l
f i
6 We found a loose screw on one of the i
f 4
7 I terminations, and, also, in doing it, where it first i
8 appeared that the termination did not match the i
i 9 ! drawing, in fact there was a design change in progress, l
l I
i 10 that when it caught up to the end of the design change, i
j 11 it actually showed the terminations as they were in 12 the field.
t i
13 So all in all, we feel very good about
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l a
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14 terminations.
i f
15 MR. CALVO:
You say you selected the I
16 alternate shutdown system.
The alternate shutdown i
17 system, before your inspection, was that alternate 18 shutdown system checked out by *he~ pre-operational i
~
19 people?
M MR. JONES:
Oh, yes.
I would say i
21 probably, and I don't have any numbers or anything to I
i 22 base this on, but most of these-terminations, I would 4
I 23 guess, had all been checked two or three times, one f
l 24 way or the other, before we got around to looking at f%
V.
25 them.
i a
i e-e, 1
52 1
I would suspect that after you looked at l
(i 2
them, that there had been a number of them reinspected, 3 l for whatever reason, subsequent to the time you looked 4
at them until the time we got around to looking at i
5
. them, for whatever reason that there might have been.
6 MR. CALVO:
So far as that system is 7. concerned, nobody is going to touch that system any l
8 6 more?
It's finished.
9 MR. JONES:
Operations has to do that i
i 10 under their maintenance procedures.
11-MR. CALVO:
Okay, but as far as the 12 construction aspects, that system has been done.
13 MR. JONES:
That system has been done.
14 MR. CALVO:
They are not going to be 15 disturbed.
16 MR. VOGELSANG:
We might have some rework 17 on the butt splices on that system.
18 MR. JONEc :
Right.
Le t me s ay now, if 19 there was a butt splice in that system, in accordance N
with the procedures that they use, it would have to be 21 turned back to construction; is that right, Iven?
It Redone by construction, turned back to f
23 them, and back-through their whole testing system-the 24 whole testing program again before it was found to be
(
25 acceptable.
53 1
MR. CALVO:
It will be done within a lcontrolledmanner.
rw 2
I 3
MR. JONES:
Yes, absolutely.
l So we feel good about the terminations.
4.
- There's no question about that.
5 I
1.A.S. was a disposition of some noncon-l 6
1 7
formance reports on vendor-installed AMP again, the 8
same. vendor -- terminal lugs.
l 9
The issue that was found was that the NCR's which di' positioned bent vendor-installed AMP 10 s
11 terminal lugs.
That's kind of a mouthful, but the 12 vendor has installed terminals within these items of 13 equipment which had been bent or twisted.
l The disposition -- The NCR's had either 14 15 been improperly dispositioned or closed.
16 Initiatives that we've taken on that 17 and I think the problem that was found was they had 18 accepteo the lugs that were bent more than 90 degrees
' 19
'or they were twisted, and the basis for that acceptance 20 is what was in question.
21 To date, the NCR's have been redispositioned Z2 in accordance with the AMP guidelines.
I have talked
(
23 to the guy on the phone, other people have talked to 24 him on the phone, but in addition to that, we've gotten (d'
25 your comments.
I believe it was i~n your comments or e
e emm
54 1
either.in the NCR, but I believe-in your comment's, was
(~'
2 ! that you would like to see a formal written AMP analysis s-l 3
l or test results or whatever that they needed to go ahead.
i 4
and verify that.
I 5
So in order to go ahead and take that to 6
its conclusion, TUGCO has issued a purchase order to 7 l AMP to conduct specific tests on these specific lugs 8
under these conditions that we're talking about here, 9
and to give us a written report.
10 That will cover the problem, both the 11 bending, whether to 90 or to 120, and the question of
^12 twisting which -- I guess the twisting was an un-13 fortunate selection of words.
It's not exactly a twist, 14 but I would have-to describe it as being bent upward 15 and to the side at the same time, more than as if you 16 went straight at it and twisted it.
That's my 17 understanding of the problem.
18 AMP has that.
We are expecting something 19 possibly at the end of next week from AMP on their N
actual physical tests on these lugs.
+
21 At that time, what we plan to do is to Z2 revise those NCR's to'specifically include the results f
23 from AMP when we go back out~there and look at those 24 again.
25 MR. CALVO:
I think the concern at the time 6
no w-6 e e me-em =aem m p
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f l
55 i
1 l was the fact that in the NCR, there was not sufficient t
i
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2 l justification in there why that thing was accepted.
s i
3 We are saying if there was a good reason 4
for doing it this way, maybe the NCR should have
(
l addressed that good reason 5
j for it.
l l
i 6
j That was our findings at the time.
~
7 MR. JONES:
Yes.
8 MR. CALVO:
Let me go back again, if ycu l don'tmind, 9
to the terminations again.
10 You know, you have looked at our Safety 11 Evaluation Report.
12 MR. JONES:
Yes.
13 MR. CALVO:
And we cited some samples in
(
14 here of things that we found wrong.
15 I think it would be appropriate, at least i
16 from the standpoint of the public record, for you to 17 look at those things up there, whether you agree or
'18 disagree, so we have some' kind of way to establish l
i.
19 whether we were correct or something else has supersedect 20 this, that the thing has been corrected.
21 That would be very helpful to us, to put Z2 that in proper perspective for the future.
23 MR. JONES:
We are doing that exact thing.
24 I have to say we don' t always agree with you.
I 25 MR. CALVO:
That's all right.
l 56 i
MR. JONES:
Okay.
So that is the status of l the AMP lugs.
(3, 2
w 3
That concludes.the first part of my i
4 presentation on the 1.A.'s, that is, l. A.' l. through 5
1.A.5.
6 Do you have any questions on those? If lyoudon't, I'd like to go next to the 1.B.l.,
l.B.2.,
7 I
8 which are the flexible conduit to flexible conduit and 9
flexible conduit to cable separation issues.
10 Sam Martinovich.from Gibbs & Hill, who is 11 the engineer who has been specifically doing the 12 analysis on this, is here with us today.
13 I would-like to ask if Sam would go ahead bS()
i4 and give us his presentation on these two issues, if 15 that's okay.
y Let's take,a five-minute recess before i
17 he starts.
18 (Re ce s s t aken. )
f 19 MR. JONES:
We are about ready to start 20 again, please.
Okay.
\\
21 The next two issues that I mentioned will 3
be discussed together are the 1.B.l.
and 1.B.2.,
which
( ~
are the flexible. conduit to flexible conduit and 23 24 flexible conduit to cable separation.
()
As'I mentioned before the break, the lead 25 i
l i
k 57 1
engineer from Gibbs & Hill is' Sam Martinovich, who has 1
2 primarily been doing the work for us on this, and I'm 3
going to ask Sam if he will address those issues for 4
us.
I 5
MR. MARTINOVICH:
Yes.
As Martin mentioned, 6
we are addressing.two issues that were established-s 7
during the TRT audit last year.
1 8
Some background, during the TRT review, 9 l.the NRC in reviewing the internal wiring separations 10 inside the control boards, they found that flexible 11
-conduit was used in some cases as a barrier where six
~
12 inches could not be maintained between redundant 13 safety-related or safety and non-safety-related wiring.
hNI
(
14 They questioned the use of this flexible 15 conduit and that.gave rise to basically the issue that 16 no analysis was performed to allow the use of flexible 17 conduit.as a barrier in control room panels, and that 18 where used, some flexible conduits containing these t 19 redundant train cables were separated by less than one 20 inch or were actually touching.
21 That ir Qe essence of the first issue.
It The b.eki rcund to the use of the flexible f
23 conduit is that it came about because of the needs 24 found during construction on certain devices on the r%
(a/
25 control board, namely hand switches, which required 9
~
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50 1
cable s1'ack in installation for removal, serviceability, I
(~'
2 main te n an ce.,
adjustments; and because of that slack, 3
l removal tended to change existing separation and 4
increase the likelihood of them possibly coming into 5
contact.
6 Discussions with the control board-7 manufacturer of the problem resulted in him recommend-8 ing a cervic-air flexible conduit as a fix to be used 9
as a barrier where the separation could not be i
l maintained.
10 11 After also investigating with-the flexible 12 conduit manufacturer the seismic qualifications of
- 13 the material and the environmental qualifications of 14 the material, at~that point the design. change was i
15
. implemented to use the flexible conduit.
16 The next issue, cables in control panels 17 which were in direct contact with the conduits 18 containing redundant train cables.really represents a 19 construction deficiency.-
M This was not a design basis to have cables 21 installed in that manner, and that is not being 22 analyzed.
That is being corrected as part of post-I 23 inspection verification.
24 In response to the issues, if we can go to I
25 I the next slide, the initiatives taken were to provide e
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59 lanalysiswhichwouldsupport the use of the flexible 1
rs
'2 conduit ~
a barrier.
as 3
The scope of this analysis will address the 4
l suitability of the flexible conduit to be used as a k
(
5 barrier.
It will consider specifically types of circuits in the control board, low level control 6
l instrumentation.
7 l
8 It will consider cable failure modes, with 9
' emphasis on cable construction and potential for i
10 i electrical ignition and propagation of fire.
11 It will 1~ook at the available energy, 12 maximum short-circuit levels on these circuits.
13 It will address the over-current short-b
~
(
14 circuit protection provided in the plant design.
15 And lastly, it will also take into 16 consideration the location of the panels in a
.17 controlled environment, the control room.
18 Supplementing -- or as a result of the 19 analysis,.we will have prepared an inspection criteria 20 for an-independent third-party reinspection of the
~
21 panels.
Z2 This reinspection criteria reinforces and
(
23 is required to make sure that the objectives of the
.24 analysis are carried out, that the design basis is,
,'~s (s
25 l carried out in the installation.
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l 60 1
This is a 100 percent reinspection of all
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2 i the panels.
I guess I've really gone into the third-
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l I
3 party reinspection.
4 MR. CALVO:
If you are going to perform 5
some analysis to demonstrate the adequacy of the 6
flexible conduit as a barrier, the prior slide is still 7
i saying that you are going to fix those cases where 8 l flexible conduit is touching each other.
9 So you say you are going to justify through 10 analysis that flexible conduit can be used as a I
11 barrier, but you are still going to maintain the one-12 inch separation between flexible conduits from 13 redundant divisions?
i'o 14-MR. MARTINOVICH:
Let me clarify that.
15 The analysis is designed to establish in 16 which cases touching, for instance, would be permis-17 sible, as opposed to cases where it may not be 18 permissible.
19 The point I made about the construction 20 deficiency has to do with exposed cables external from 21 the flexible conduit which are in contact with the flex 22 of a different train.
(
23 MR. CALVO:
Okay.
So then you are saying 2d under th6se conditions, also, you may prove your
- 25 case that --
9 ga***
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q 61 1
1MR. MARTINOVICE:
May prove it's acceptable,
)
2 ) but it's not a design basis.
I 3
MR. MARTINOS:
And the analysis would 4
include what kind of criteria for acceptability.
(
5 MR. MARTINOVICH:
That's right.
The 6 l analysis contains the acceptance criteria.
7 MR. MARTINOS:
What are the acceptance 8
i criteria?
Do you know it now?
What are you~ going to 9
try to do?
4 MR. MARTINOVICH:
Well, we've tried to 10 l
! define --
11 12 MR. MARTINOS:
Like you say, short circuit 13 is one analysis to-see what kind of currents are b
( -
14 going to go through and whether you are going to start 6
15 a fire.
16 Is that one of the criterion you are going 17 to use?
18 MR. MARTINOVICE:
That's correct, in
~
19 addition to identify insulation systems which are not 20 combustible, in which case the potential for fire 21-propagation does not exist.
Z2 MR. CALVO:
How are.you going to convey
(
23.
that message to the craft personnel or the people who 24 are going to do the next?
j 25 It's okay for the ones that you already 4
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62 1 I have built, but how are you going to convey that
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2 message for future work that you are going to do?
3 In this case you are going to do i t this d
way, and in the other case you are going to do it
(
5 this way?
Do you intend to do it that way?
6 MR. MARTINOVICH:
We intend to incorporate
~
7 I all the details provided in the inspection criteria on 8
, construction drawings. All of the necessary clarifica-f 9
tions which may not have existed prior, okay,-we will 10 now be sure th at the subtleties are on the drawings.
11 MR. MARTINOS:
Well, in order for us to i
12 J ve you constructive comments with regard to your 13 analysis, it will be given us as a plan and we can k
14
.make a comment on the plan.
15 When you talk analysis, if we don't know 16 more specifically what the analysis will include in 17 terms of criteria --
18 MR. CALVO:
We know the analysis will 19 include -- it will be in accordance with IEEE 384, El it will require that testing must be performed.
21 MR. MARTINOS:
Well, that's one-thing he 4
Z2 did not specify.
(
23 MR. MARTINOVICE:
Yeah, I'm coming to that.
24 MR. MARTINOS:
Okay.
C.
25 MR. MARTINOVICH:
Any questions on that?
e m
ny....
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63 1
MR. MARTINOS:
Go ahead.
2
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MR. MARTINOVICH:
Okay.
That brings us to 3
the summary of results.
4 -
1 As I mentioned, the analysis has established
(
5 what separation is required for various types of 6
circuits utilizing flexible conduit, where the flexible 1
~7
.i conduit is a suitable barrier; and it also specifically 8
identifies where it may not be acceptable to use as a 9
barrier.
)
10 l
That criteria has been incorporated in a i
11 ' written inspection criteria from which the reinspection j
12 procedures have been written.
13 The reinspection is currently in progress.
b(
14 Approximately 50 percent of the panels involved have 15 al, ready been inspected.
l 16 Now, in answer to your question, a physical 17 test is in the works, and the objectives of this i
I, 18 test will be to address the heat transit characteristics 19 of the cable and conduit assembly, to address the i
20 integrity of the conduit under short-circuit conditions, 21 which we feel are the major hazards from adjacent D
trains.
I 23 All of these activities currently are, 2d well underway.
The third-party independent review is 25 underway.
The analysis itself.
1 64 l
1 l
As I mentioned, the inspection is 50 percent 2
complete and the test' procedures are being developed,
[
) and we hope to have the whole thing wrapped up in the 3
l next few weeks.
4 I
5 MR. CALVO:
Okay.
What is confusing me is
.6 that you are going to perform this test.
Let's say j
i 7 l that you demonstrate the acceptability of the flexible w
l 8
conduit as a barrier.
9 You still may recommend that in some-10 g cases conduits can touch or conduits cannot touch?
11 MR. MARTINOVICE:
That's absolutely 12 correct.
We have incorporated.in the inspection 13 criteria what I feel is a very -- more stringent 14 criteria than is prob' ably required.
4 15 MR. CALVO:
Also, my impression is that 16 it's going to be a very complex criteria. ~You inform 17 the craft personnel working in this panel here, in 18 this case you can have those conduits touching each 19 other, but in the other panel next to each other, in N
here for whatever other reason we had, now there they i.-
i 21 cannot touch each other.
I 22
. Sc.it looks to me like continuous attention
(
23 will be given when you start these things up for 24 somebody who understands what needs to be done and
?".
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25 what is different.
3
~ -.
l l
65 1'
1 You gave a criteria that was simple and
,r '
2 straightforward, one-inch separation between acceptable 3
1 cables inside conduit.
i l
4 Now you are saying in~this case-it's okay
(
5 and in the-next case it's not okay.
When we talked to 6
some of the craft personnel who were here, they had 1
7 I-trouble trying to understand that one.
Now, on top 8
of that~one, you put in some variations to that one..
- 9. (
I still don't see how can you -- where you 10 determine flexible conduit is acceptable as a barrier, i
11 what prompts you in some cases to have one option and i
12 in other cases to have another option?
1 13 -
MR. MARTINOVICH:
Well, we have tried to 4
14 minimize these options.
The cases in which --
Don't
}
15 misunderstand.
16
'The cases in which we are saying that it 17 may not be acceptable represent a relatively small Is number of cases.
19 MR. MARTINOS:
Are you dealing only with y) already-installed systems, or are you. going to ba -- I 21 guess this is where this confusion is.
22 What criteria are you going to be using I
23 for later, for. future installations?
Are you merely 24 dealing now with what's there to find justification or
.)
25 do whatever modification is required based on some i
l
I 66 l
1 l criteria you have developed?
Is that what it is?
I 2
MR. CALVO:
Well, not only for the present,
['
3 I'n saying maybe also for the future.
l MR. MARTINOS:
Well, that's what I was 4
I
('
5
, But I think he's dealing now with what he's got.
He 6
wants to make an assessment of the adequacy of what 7
you've got now; is that correct?
I 8
1 MR. MARTINOVICH:
Well, that had to be 9
done.
That was the'first issue which had to be I
10 l addressed; and, of course, that has been done.
11 Consideration also has been given to the 12 future in terms of -- again, I go back to the inspectior, I
13 criteria.
A*()
14 This was critically reviewed from that 15 perspective, that it should not be something so 16 complex that it could not be carried out or understood.
17 MR. CALVO:
Why can' t you consider while 18 you are doing this test, doing a test for the worst-19 case condition, worst-case condition where the conduits 20 are touching each other.
21 If you prove the point with that test, you 22 have no options.
Then you say either touch or don't f
23 touch; it doesn't make any difference, because the tests 24 have shown that.
25 Then the question is, if you have not
,7
67
~
1 proved your point, then-it is something that you worry D
2 about.
1 j
3 So I am wondering whether they are touching 4
.or whether they are within ~ene-quarter of an inch or 5
one-eighth of an inch, from the standpoint of independer,t 6
party review whether that is acceptable or not.
~
7 You see what worries-us?
8 MR. MARINOS:
Minimize your options.
Just
}
9 look at the worst-case and if that's acceptable, you 10 can apply this across the board.
11 MR. CALVO:
You are saying to me that you 12 are going to come up with a test and this test may not 13 be exhaustive enough to prove the worst-case condition, O
14 and that's when the conduit is touching each other.
15 I'm looking at it from an independent party 16 looking at that.
Unless you~tell me while you are 17 in there that you are coming up with an option; are 4
18 you coming to that?
19 MR. MARTINOVICH:
Well, that is a M
consideration.
It is something that we would like i
21 the test to also conclude, and.that is certainly 22
-something we will try to establish, is a worst-case I
23 condition.
I 24 All I'was saying is that it was not our t,
(s 25 intent to use this test as a vehicle for requiring l
4
I 68 ilessentiallynoseparationin the control board.
1
(~)N 2
l It is our feeling that separation should 3
always be maximized unless it's absolutely impossible; 4
and in keeping with that philosophy, we do not plan --
fat P
least I don't believe we intend to use the test as 5
6 this type of vehicle, just to change criteria.
7 MR..MARTINOS:
To change criteria.
8 MR. CALVO:-
Buttsgain,'you are going to --
9 MR. MARTINOVICH:
But again, you may well 10 conclude'--
j ustify - those-where ' you are r ot 11 MR. CALVO:
12-meeting the criteria, based on that test.
13 MR. MARTINOVICH:
That may well happen, 14 that those on which we require more separation may turn 15 out that they don't require that separation.
16 I don't know that we will relax that 17 requirement.
That's something that we have to 18 consider.
19 MR. JONES:
We will certainly give it 20 every consideration.
I agree with what you are 21 saying.
22 MR. MARTINOVICH:
It is from a philosophical i
23 point of view, you know, if we can do something, we try 24 to do it.
25 MR. CALVO:
But I feel we are..beyond the
_~ _
f 69 l
1 I philosophical point of view at this time.
We are try-
~
2 I ing to come up with a design that is adequate and can j
3 be implemented in a more simple way.
4 The reason you are where you are today is 5
because of the requirement, the people could not 6
l-understand why you could do things this way or the 7
other way.
8 As a result of that, you violated the I, criteria without having an acceptable barrier, 9
just i
10 flexible conduit.
11 It appears to me that without knowing more 12 about your plan, that maybe you are leading to another 13
~
set of criteria on top of the complex one that you fI) s 14 have now that is going to make things difficult to 15 control.
16 That's all my. fear is on.
17 MR. JONES:
Well, we will certainly, in 18 doing these, give that every consideration; and 19 certainly, if there is any way that we feel that based 20 on the test or based on the analysis that we can 21 simplify the separation criteria, the' drawings, M
details, or whatever, of the criteria that there are,
(
23 I thi~nk certainly that will be one of the goals that 24 '
we will be' looking toward doing.
()
25 MR. MARTINOVICH:
One point I haven't I
e
.. ~..
70 1
mentioned is that we have also worked closely with the 2
people who are doing inspection in going over the
^
i 3
procedure with them in short training sessions, to 4
make sure that they are -- question-and-answer type
(
5
- sessions to make sure there is a clear understanding-6 ; and to get this type of feedback from them where they 7
feel something is too cumbersome or complex to l implement.
8 9
This has also been done.
10 MR. CALVO:
Okay.
The other thing, again 11 l like before, we would be very interested to know in 12 those cases where the separation is not being met, 13 we also would like, if you could consider, identify those systems to see which systems they involve, so 14 l
can assess together the importance of that system to 15 l we l
16 l the plant safety.
17 MR. JONES:
You mean as they are going 18 through the inspection?
19 MR. CALVO:
Well, you've got some conduits 20 today that you say if you made the installation that 21 is one inch -- if you prove that the flexible condui t n
is acceptable as a barrier, and then you go back and
(
23 in most all the cases the flexible conduit from 24 redundant trains are separated by one inch, we are not
()
25 going to worry about those.
e c
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71 f
The ones that are touching each other, 1
lundertheseoptions that you have, we'd like to know r%.
2 s-i
[
3 which ones are those so we can assess the importance to f
4 safety of those systems, 5
When we are deviating from established 6
criteria, we like to know, even though you have proved
[
i t
7 l your case, we like to know what~ systems they are.
1 8
Are those cables associated within the
+
9 control, and if control, what system was that?
Was i
10 that a very important system or was it a secondary l
! system.
11 i
l 12 MR. MARTINOVICH:
The analysis actually 13 will document each and every case, specifically each s
14 and every case in which touching of conduits is l
l l permissible.
15 l
16 MR. CALVO:
Okay.
l i
17 MR. MARTINOVICE:
So it will not be --
I 1
18 MR. MARTINOS:
The circuit will be made, 19 also, then?
l
)
20 MR. MARTINOVICH:
That's correct.
That 4
i
~
21 has been done, t
Z2 MR. CALVO So in the identification, l
(
23 maybe you should also consider the assessment, your
[
24 assessment gf the importance of that circuit to the s
25 system and that system to the plant safety.
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MR. JONES:
That has not been done to date.
l 2
MR. MARTINOVICH:
No.
l 3
l MR. MARTINOS:
When you say you are going i! to identify the circuit, you say it's at the decay heat 4
(
5 removal control system?
You will be saying that?
6 MR. MARTINOVICH:
I'm sorry, it's what?
7 MR. MARTINOS:
A decay heat removal, RHR I
8
' system or whatever.
That information 9-MR. MARTINOVICH:
Yes 10 would not readily be available.
11 MR. MARTINOS:
How would you identify it 12 then on the circuitboard? ~
13 MR. MARTINOVICH:
They are identified by 14 the associated channel numbers assigned, which'are 15 traceable to a system.
16 I mean, it could readily be found out.
17 It's just not as presently structured, you wouldn't 18 know unless you --
19 MR. MARTINOS:
When you say " channel,"
20 you mean Train A or Train 3 or --
21 MR. MARTINOVICE:
No, no.
A tag number Z2 and the cable number.
I 23 MR. MARTINOS:
That would not mean 24 anything to us.
(*
25 MR. MARTINOVICH:
I know.
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73 l'
MR. MARTINOS:
That would not be useful I
4
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2 for'us to make an evaluation independent from you.
3 l
MR. CALVO:
We are expecting for you to ll censider performing an evaluation and indicate the 4
i-5 importance on that particular case with respect to the 6
sa'fety of the plant.
7 Again, this goe s back again, your general 8
plan.says that you are going to come up with the 9
safety significance of the findings.
We'd like to know 10 either you correct the deficiencies or when you are 11 justifying the deficiencies, you've'got to indicate 12 the impact on the' safety of the plant and, I guess, 13 maybe one way to do it among many ways, associate 14 that particular~ deficiency to the system and then 15 what the role of that system plays on the safety of 16 the plant, and then your assessment of the importance 17 of that.
18 That's something when we are reviewing 19 your plan, that's something we'll be asking fer.
Xf MR. MARTINOS:
If it's a support system 21 circuit, it would have a certain impact.
If it's a 22 direct safety system for an actuation of a protective
(
23 action, then it would have a different impact.
24 That goes for the splices, toor that was C
l 25 pointed out to you earlier.
l
l I
74
\\
i 1
1 MR. JONES:
We to date have not done that, g
2 l nor had we planned to do that from'that standpoint.
t 3
We will consider that and talk with you further on l that subject on both of them.
4
(
5 j
MR. MARTINOS:
It should not be a very 6
great effort to identify from the wiring diagrams, somehow you should be able to tell --
7 8
MR. MARTINOVICH:
No, it's not difficult 9
at all.
10 MR. MARTINOS:
-- what that circuit does, 11 and identify it.
12 MR. JONES:
Like I say, we have not done 13 that yet.
f%
s 14 MR. MARTINOVICH:
We just haven't provided 15 that kind of records.
16 Now, on 1.B.3.,
this issue, " Conduit to 17 Cable Tray Separation," originated as a result of, 18 again, during the TRT NRC review of a Gibbs & Hill 19 drawing that was made to provide separation criteria 20 for plant construction.
21 The drawing --
And the design basis on n
the project is -- the guidelines are IEEE 387*,,1974, anc; I
23 Reg. Guide 1.75, Rev.
1.
24 NRC did note on the drawing, however, that
(
25 it contained details of separation between conduits to
4 75 1
. conduits, conduits to open trays, which-are not ex-(]}.
2 plicitly shown in the IEEE Standard or Reg. Guide.
3 We 3dvised NRC that these were based l
4 somewhat on a visual presentation of the wording of
(
5 the standard as interprete'd by us that an analysis 6
had been made in various instances where a cable tray /
7 I conduit separation was not clear, or'there was a 8
potential for some misreading of the standard.
{
9 NRC's position was that this separation 10 l analysis had not been evaluated by them.
11 The action was to retrieve this analysis, 12 as the slide indicates, update it -- not really update i
l 13 it; it'was modified for. presentation for a third-party f
1
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14 reviewer who is currently reviewing this analysis.
f 15 Once we resolve any -.if there are any i
]
16 l
comments and'necessary design reviews, this will be i.
17 made available to NRC for their formal review.
j
)
18 Some of the examples -- The drawings 19 address items such as non-clasp on the conduit to an 20 adj acent safety-related tray.
21 MR..CALVO If I remember correctly, you D
had conduits over open cable trays, and you indicated
(
23 that there was one inch between them, and you indicated i
24 7l that you had performed an analysis that indicated it p,
]
U 25 was not part of the actual 384.
384 would allow it to l
l l
76 1
do that, you indicated, and it was a difference of e-2 opinion on that.
i 3
i MR. MARTINOVICH:
The wording in the I
t standard identifies " reduced seoaration is permissible 4
i
(
when you have an acceptable barrier," and I think it's 5
6 generally agreed upon that rigid conduit is a suitable
! barrier.
7 l
i 8
But the issue here was an open tray and 7 { the conduit, and the interpretation made was that if i
10 i tha conduit enclosed a non-safety circuit, the intent I
11 I of the standard was not to protect the non-safety 12 circuit.
13 So that conduit acted as a barrier for 14 anything away from it, outside of it, and the detail is itself was not shown in the standard, but we feel 16 that --
17 MR. CALVO:
But the intent was there.
18 MR. MARTINOVICH:
The intent was there.
19 MR. CALVO:
And I guess you, within the 20 context of the standard, you are allowed to do'that 21 unless you can prove by analysis the fact that no 22 single event can result in compromising the safety.
i
(
23 MR. MARTINOVICH:
That's right.
The analysi s 24 really just discusses the event and provides the logic r.
(s 25 used for permitting that type of design.
e
---n
77 1
MR. CALVO:
But as you know, in all the 2 I analysis required to justify the adequacy of installa-3 l tion, testing must'be included.
4 In the analysis you are proposing, some
(
5 testing was dene; do you show that?
6 MR. MARTINOVICH:
The analysis was l
t lsubstantiatedforallthedetailsinwhich.the 7
cable ray and conduit were involved.
8 t
9 The various separation distances were 10 supported by tests conducted by Sandia.
i 11 i
MR. CALVO:
All right.
So your independent i
12 party who is going to look at this is going to 13 correlate with the Sandia test that was done and will C.
14 relate these back to the installation in Comanche Peak '
15 and establish that it's app lic able.
16 MR. MARTINOVICH:
I. hope.
17 MR. CALVO:
What I'm saying, I am hoping 18 tnat that's the responsibility --
19 MR. JONES:
That is the intent, yes.
20 MR..CALVO:
Okay.
21 MR. MARTINOVICH:
That's all I have to say D
on that unless there's any other questions.
I 23 MR. JONES:
Thank you, Sam.
24 The last item is 1.B.4.,
and that was rs (J
25 concerned with --
There were two minor violations e
4
78 i
1 i of the control panel separation criteria that were found, I
s
2 l during the TRT.
These were actual physical. violations e
3 y that were found.
I 4
one of them was a field wire cable, the
(
5 separation between that cable and a switch module, and 6
the fact that a rigid barrier, one of the boards that 7
was bolted into the board had been removed, and I i
8 I believe it was lying at the bottom of the board or i
9 close thereby when you found it.
f 10 The status of this is that the NCR's, 11 nonconformance reports were written and dispositioned 12 to correct that particular problem.
13 In concurrence with this inspection, and I 14 think it was in some of the comments that you gave to 15 us as well, the inspections being done under Sam's 16 1.B.l.
a n d 'l. B. 2~.
for the conduit separations, we are 17 also looking as part of that at whether other barriers 18 have been moved or there are other things of this 19 nature that are found.
20 So this will give us a much -- throughout 21 the boards, 100 percent throughout the boards to find 22 areas where this similar-type thing may have occurred
(
23 as well so we can correct that.
24 In addition to that, and into looking into 25 the circumstances aro:ind that, i t was, at least to me, w
)
79 4
1 f indeterminate as to who had done what.
I mean, the I
['N 2 l barr ier-was removed, but there was no way to tell who us 3
i had done it or for what reasons.
i 4
It could have been any number; construction
(
5 could have done it as part of their installation.
l l
~6 l
It's possible that operations needed to 7
remove it to calibrate an instrument, for example, or 8
for some other reason.
But it's pretty much indeterminate 9
as to who has done what specifically.
10 Sut I don't think that's the important 11 part.
I think the important thing is that what we 12 wanted to do is make sure that that doesn't happen 13 again, either from a construction standpoint, if they 14 have to make a modification, or from the operations 15 standpoint, if they have to for any reason remove a l barrier or violate 16 crite'ia that's set any separation 4
r i
17 forth in the standards, that when - they are through with 4
18 that work, that they have to restore those separations 19 to the criteria that's been established.
20 So in doing that, we've been discussing 21 this with the operations people.
As far as their M
maintenance procedures go, they are going to revise I.
23 those procedures so that they recognize the separation 2d criteria just in the same manner that construction i
25 people have to recognize the separation criteria.
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They are in the process of doing that now.
.A 2 i We will be reviewing that.
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3 In going toward this, we are beginning to l write up a final report on this and we hope it will be 4
5 out of the way f airly soon on that particular item.
4 6
(Whereupon, the written 7
handouts-relating to the slides shown 8
follow.)
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81 f
MR. JONES:
That was the last of the items 1
I
/'N 2 l we had, and I would like to take just a minute, if I
(-
i 3 !"could, and summarize what we have done today.
I 4
I think this is a fairly good review of k
l what we've done today, and particularly, I hope you 5
6 have gotten from us what I've tried to get across to 7
you, the approach we're taking to all these things.
3 It's not just fix that particular item 9
that is of concern, but we are looking at it from a 10 l broader standpoint.
We are not only interested in 11 that item, but we are interested in what was the root 12 cause of the problem and we are interested in 13 implications in other areas, generic implications.
(
'14 We are interested in seeing that what we
~
15 have learned from here -applies to future work that 16 we are doing in Unit 2 or other work in Unit 1; and 17 that we are willing to go to whatever lengths are 18 needed to make sure-that all these obj ectives are I
19 accomplished, so that not only you are satisfied when 20 we are finished, but that we_are satisfied when we 21 are finished with it, too, and that is important to us.
Z2 We are making really, I think, good
[
23 progress on this.
We have problems with the butt 24 splices.
1 I
25 I think I would say to'you today that from
82 i
1 what we've seen of that problem that we've got now,
'5 2
we have fairly well circumscribed that problem.
(
3h But in the other areas we are making good 4
progress.
We expect that it's ~ not going to be very b
5 much longer before we can put to rest all of them, jandthat in the end you will be satisfied as well as 6
) we will be satisfied.
7 8
Are there any other questions?
9 MR. CALVO:
I guess it goes back to what i
10
! I've been saying.
It appears that the plan that you l
11 l have, the presentation, that you are going in the l
12 right direction; but I still am looking at it from the 13 standpoint of the significance of~the findings with (b
14 respect to the safety of the plant.
15 It looks like you are leaving those to 16 the end and I sure would like fto know what they are 17
.first and know the significance.
Then knowing that 18 and the risk to the plant, we can assess'whether the 19 plan that you are proposing is adequate.
20 I mean for those cases where we are 21 justifying exceptions of a system practice, of a system 22 regulations.
You say, "Well, we didn't do it this way, f
23 but now we have something here that is as good as."
2t I would like to know, to determine whether 1
25 the substitutions are adequate, I would like to know r
I
j 83 1
the significance of the_ findings as they relate to r '-
2 I the systems and the importance of the systems to the 3
l plant safety.
I 4
Depending on the importance, I can assess I
5
.whether the plan is going in the right direction to l take care of these things for these systems and these 6
t 7
l things for the other systems.
8 So I think you should consider that as 9
maybe guiding what your plans should be, so it is 10 something that it is your plan that you are preparing, 11 I trying to find out -- if it sounds okay, if it's 12 consistent with what we have found out.
13 This is the only thing that I have found.
i 14 You end up doing it, but I am just wondering if it I
15 should not be at the bottom, but maybe you should 16 consider to put it more at the top, because I think 17 you can put it in proper perspective, and it has not 18 been put in proper perspective yet.
19 This is the only comment that I have.
3 MR. MARTINOS:
I have no more comments.
21 MR. CALVO:
Does anyone else?
Zt MR. JONES:
That-concludes our presenta-(
23 tion.
24 MR. CALVO:
Before I close, I forgot about f%
\\-)
25 a couple of things.
L
\\
84 l
1 l
Another electrical issue brought up by the Il electrical and instrumentation group was the one with
/'-
2 3
the QC inspectors.
I MR. JONES:
Yes.
There are other issues, 4
t 5
too, that were brought up unde r the ele ctrical.
The 6
cable tray supports or conduit supports, those are 7
l covered by other group leaders.
8 The QA/QC is another, training --
9 MR. CALVO:
Yes.
The QC inspector training 10 and requalification.
You said those are covered under 11 the QA/QC --
12 MR. JONES:
Under the QA/QC team leader, 13 which is excluded from our particular part of this 14 program.
15 MR. CALVO:
There is also another item, 16 that is in the SER and maybe you can tell me how you 17 are going to cover this one.-
18 It was not in the September 18 letter.
It 19 has to do with the conduit supports and it was the l
N use of the procedures by the craf t personnel, where they 21 were not using these procedures.
l 22 MR. JONES:
Installation procedures?
l
[
23 MR. CALVO:
That is right.
24 MR. JONES:
Right.
I noticed that when the rs
(/
25 SER came out as well, and we brought it up.with some e..
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85 1
of the support people in our group; but to the best of i
2 my knowledge, that's not been assigned to anyone
(.
3 specifically yet.
4 But we are aware that that's in there, that i
5 it is not in the original letter.
6 MR. CALVO:
I can't think of any others.
7 l That was the only one, plus the-QC electrical training.
8 MR. JONES: ' That's covered by John Hansell.
9 MR. CALVO: W'e will most probably have to that time.
~I guess it's going to be a l come back at 10 11 ! joint effort, maybe,.between QA/QC and the electrical l
12 instrumentation group, be'cause there was an SER.
13 That's all I have.
We wanted to bring that
. rf,+
L_
14 to your attention.
15 Thank you very much for your presentation.
16 MR. JONES:
Thank you.
17 MR. CALVO:
Excuse me.
I guess maybe the 18 question should be directed to the audience, if they 19 have anything to say, anything to add, any comments?
M (No res'ponse.)
21 MR. CALVO:
The record indicates there fare Z2 no comments, so we'll close.
(
23 (Whereupon, at 10:45 a.m.,
the 24 meeting was conclude d. )
-x.
V 25
///
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CERTIFICATE OF OFFICIAL REPORTER This is to certify that the attached proceedings before the UNITED STATES NUCLEAR REGULATORY COMMISSION in the g
matter of:
NAME OF PROCEEDING: MEETING BETWEEN TEXAS UTILITIES AND THE NUCLEAR REGULATORY COMMISSION REGARDING COMANCHE PEAR STEAM ELECTRIC STATION -
PIPING AND SUPPORT DESIGN DOCKET NO.:
PLACE:
GELN ROSE, TEXAS
(*
DATE:
THURSDAY, FEBRUARY 28, 198 were held as herein appears, and that this is the original transcript thereof for the file of the United States Nuclear Regulatory Commission.
(sigt)
(TYPED)
MARY BAGBY/RJM Official Reporter ACE-FEDERAL REPORTERS, INC.
Reporter's Affiliation i
e e
4
_ w eewe e,
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o, UNITED STATES
[ '$, s- ( Y },
NUCLEAR REGULATORY COMMISSION
- .g
., j WASHINGTON. D. C. 20555
%, %'
- e MAR 0g g Docket Nos.: 50-445 and 50 446 APPLICANT:
Texas Utilities Generating Company (TUGCO)
FACILITY:
Comanche Peak Steam Electric Station, Units 1 and 2
SUBJECT:
SUMMARY
OF MEETING BETWEEN NRC STAFF AND TEXAS UTILITIES GENERATING COMPANY TO DISCUSS THE STATUS OF THE COMANCHE PEAK RESPONSE TEAM EFFORTS IN RESPONDING TO THE TECHNICAL REVIEW TEAM FINDINGS IN THE ELECTRICAL / INSTRUMENTATION AREA AT COMANCFE PEAK STEAM ELECTRIC STATION, UNITS 1 AND 2 A meeting between the NRC staff and Texas Utilities Generating Company (TUGCO) was held on Thursday, February 28, 1985. The meeting was held at the Comanche Peak Nuclear Operations Support Facility near Glen Rose, Texas. The purpose of the meeting was to discuss the status of TUGCO's Comanche Peak Response Team efforts in resconding to the NRC Technical Review Team findings in the electrical / instrumentation area. The meeting was transcribed and a transcript is enclosed. Attendance at the meeting is included in the transcript.
The TUGC0 Comanche Peak Response Team presented the results of additional inspections they had conducted in response to each of the Technical Review Team findings. The evaluation of the hardware situation appeared to be nearing completion. The staff requested additional information concerning the safety significance of the hardware deficiencies identified.
6 S. B. Burwell, Project Manager Licensing Branch No. 1 Division of Licensina
Enclosure:
As stated cc: See next page LP P
{
1
COMANCHE PEAK-MAR 0g 73g5 Mr. M. D. Spence President Texas Utilities Generating Company 400 N. Olive St., L.B. 81 Dallas, Texas 75201 cc:
Nicholas S. Reynolds, Esq.
Mr. James E. Cummins Bishop, Liberman, Cook, Resident Inspector /Conanche Peak Purcell & Reynolds Nuclear Power Station 1200 Seventeenth Street, N. W.
c/o U. S. Nuclear Regulatory Washington, D. C. 20036 Commission P. O. Box 38 Robert A. Wooldridge, Esq.
Glen Rose, Texas 76043
'Worsham, Forsythe, Sampels &
Wooldridge Regional Administrator 2001 Bryan Tower, Suite 2500 U. S. NRC, Pegion IV Dallas, Texas 75201 611 Ryan Plaza Drive Suite 1000 Mr. Homer C. Schmidt Arlington, Texas 76011 Panager - Nuclear Services Texas Utilities. Generating Company Lanny A. Sinkin, Executive Director Skyway Tower Nuclear Information and 400 North Olive Street Resource Service L. B. 81 1346 Connecticut Ave., N.W. 4th Floor Dallas, Texas 75201 Washington, D. C.
20036 Mr. Robert E. Ballard, Jr.
B. R. Clements Director of Projects Vice President Nuclear Gibbs and Hill, Inc.
Texas Utilities Generating Company 11 Penn Plaza Skyway Tower New York, New York 10001 400 North Olive Street, LB#81 Dallas, Texas 75201 Mr. A. T. Parker Westinghouse Electric Corporation P. O. Box 355 William A. Burchette, Esq.
Pittsburgh, Pennsylvania 15230 1200 New Hampshire Avenue, N. W.
Suite 420 Renea Hicks, Esq.
Washington, D. C.
20036 Assistant Attorney General Environmental Protection Division Ms. Billie Pirner Garde P. O. Box 12548. Capitol Station Citizens Clinic Director Austin, Texas 78711 Government Accountability Project 1901 Oue Street, N. W.
Mrs. Juanita Ellis, President Washington, D. C.
20009 Citizens Associatinn for Sound Encrpy David R. Pigott, Esc.
14?6 South Polk Orrick, Ferrington & Sutcliffe Callas, Texas 75224 600 Montgomery Street San Frr.n~cisco, California 94111 Ms. Nancy.H. Williams CYGNA 101 California Street San Francisco, California 94111 6
MAR 06-505 COMANCHE PEAK -
cc:
Anthony Z. Roisman, Esq.
Trial Lawyers for Public Justice 2000 P. Street, N. W.
Suite 611 Washington, D. C.
20036 Mr. Dennis Kelley Resident Inspector - Comanche Peak c/o U. S. NRC P. O. Box 1029 Granbury, Texas 76048 Mr. John W. Beck Manager - Licensing Texas Utilities Electric Company Skyway Tower 400 N. Olive Street L. B. 81 Dallas, Texas 75201 Mr. Jack Redding Licensing Texas Utilities Generating Company 4901 Fairmont Avenue Bethesda, Maryland 20814 1
- e e
4
MAR 0 0 1985 MEETING
SUMMARY
DISTRIBUTION Docket File NRC Participants NRC PDP L PDR V. Noonan NSIC A. Marinos PP.C System M
LESI Reading File S. Burwell Project Manager S. Burwell C. Hale M. Rushbrook D. R. Hunter Attorney, OELD W. F. Smith R. Hartfield*
H. S. Phillips OPA*
4 OTHERS i
bec: Applicant & Service List
- Caseload Forecast Panel Visits i
b ; 162-i t
m
.. ~.
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