ML20199D774
| ML20199D774 | |
| Person / Time | |
|---|---|
| Issue date: | 06/12/1986 |
| From: | Advisory Committee on Reactor Safeguards |
| To: | |
| References | |
| ACRS-T-1521, NUDOCS 8606230061 | |
| Download: ML20199D774 (82) | |
Text
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OR G NAL oU UN11EU STATES NUCLEAR REGULATORY COMMISSION IN THE MATTER OF:
DOCKET NO:
ADVISORY COMMITTEE ON REACTOR SAFEGUARDS
.AD HOQ SUBCOMMITTEE ON TVA PARTIAL TRANSCRIPT O
Q.s LOCATION: CHATTANOOGA, TENNESSEE PAGES:
323-400 DATE:
THURSDAY, JUNE 12, 1986 A038OE80[ObfY
?.o%Jemovejrom ACRS Tice p
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PUBLIC NOTICE BY THE UNITED STATES NUCLEAR REGULATORY COMMISSIONERS' ADVISORY COMMITTEE ON REACTOR SAFEGUARDS THURSDAY, JUNE 12, 1986 The contents of this stenographic transcript of the proceedings of the United States Nuclear Regulatory Commission's Advisory Committee on Reactor Safeguards (ACRS), as reported herein, is an uncorrected record of the discussions recorded at the meeting held on the above date.
No member of the ACRS Staff and no participant at
- ( ),
this meeting accepts any responsibility for errors or inaccuracies of statement or data contained in this transcript.
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u marysimons UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 3
ADVISORY COMMITTEE ON REACTOR SAFEGUARDS AD HOC SUBCOMMITTEE ON TENNESSEE VALLEY AUTHORITY 7
Tennessee Valley Authority Chattanooga Office Complex 10 1101 Market Street Chattanooga, Tennessee 33 Thursday, June 12, 1986 12 The subcommittee convened, pursuant to notice, at 13 8:30 a.m.,
Charles J. Wylie, Chairman of the Subcommittee, 14 Presiding.
15 ACRS MEMBERS PRESENT:
C.
WYLIE, Chairman M. CARBON
~
18 J.
EBERSOLE C. MICHELSON 19 G.
REED D. WARD 20 ACRS CONSULTANTS PRESENT:
P.
BARTON H. HAGEDORN 23 COGNIZANT ACRS STAFF MEMBER PRESENT:
C]
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U marysimons NRC. STAFF AND PRESENTERS PRESENT:
C.
STAHLE J.
OUNGBLOOD 3
L.
CROCKER D.
CLARK 4
R. HERNAN COTTLE 5
R. GRIDLEY DENISE 6
E.
SLIGER W.
DROTLEFF 7
J. HUSTON OTT 8
J.
RAULSTON 9
D.
LAMBERT J.
COAN gg S.
WHITE 11 12 Od 13 14 15 16 17-18 19 20 21 22 23 24 25 ACE-FEDERAL REPORTERS, INC.
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1 EVENING SESSION 2
(6:00 p.m.)
3 (Slide.)
4 MR. DROTLEFF:
The other area I wanted to talk 5
about today was establishing better design control, and this 6
is an explanation of what our program is, and engineering is 7,
taking the lead on this program.
But this design control is 8
not only an Engineering Division responsibility, but design g
control is a function, a team work function between 10 operations and modifications and qualify assurance and 11 engineering.
We are taking the lead on it.
12 Most of these things are underway.
We are not
()
13 talking about what we are doing in the future and we are not 14 talking about what has existed in the past.
This program is 15
- underway, f
16 The key points on this one are that we are 17 establishing the design basis.
18 I think you point it out that somewhere along the 19 way since the plant went into operation the design basis in 20 many cases was lost to engineering.
They didn't have 21 feedback on the drawings.
Operations used their own set of 22 drawings, as-constructed drawings.
Engineering used their 23 own drawings that were as-design drawings.
So we lost 24 somewhere along the way what the design basis was.
25 So we are doing that and we are establishing that.
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We are also establishing a permanent change 2
control process, and I have another slide that covers that, 3
and that change control process will include a specific way 4
of issuing a plant modification package, it will have a way 5
of controlling the drawings in the future and it will close 6
the loop, and I think you were talking about that earlier on 7
the final modification within the documentation to assure 8
that after that modification is installed that there is a 9
appropriate safety determination made on it and that it is 10 reflected back into the design input drawings.
11 MR. EBERSOLE:
I wonder if in the course of 12 evolution or whatever you want to call it some of these n
(
13 early concepts have in fact just disappeared in the mist?
v 14 First it is the old boiler.
It was one of the early 15 doughnut jobs with suction headers at the bottom of the 16 doughnut and they had suction headers to the pumps, and I 17 guess they are still there.
18 Later on they took suction right off the 19 doughnuts, but that had suction headers.
It was required in 20 the licensing phases of that project that one invoked the 21 thesis that in the course of some mechanical upset like a 22 seismic event or whatever you lost the suction headers and 23 you had a pipe break, and that was a containment break 24 because the containment has a pipe in it, namely, the 25 suction header going to the RHR pumps.
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That led to a struggle to invoke a thesis of 2
recovery involving unit cross-ties which had additional 3
requirements set in it that yoa could fill those light bulbs i
4 clear up to the refueling floor with river water and they 5
were to redesign and strengthen so they wouldn't collapse 6
like a wet paper bag to hold the interim hydraulic pressure 7
as it rose.
You know, they tend to swag out at the bottom.
8 That accounts for the presence of a rather unique 9
system down there which so far as I know may have been taken 10 out in the ignorance of the people who ran the plant. I 11 don't know what is left down there beyond the reasonable 12 conceptual requirements.
()
13 But these don't appear very much on paper.
They 14 are just there is physical reality if they built it that 15 way.
Whether the operators ever learn to use those things, 16 I don't know.
17 MR. DROTLEFF:
I am not familiar with that 18 particular one.
19 Jerry?
4 20 MR. CHAPMAN:
Yes, if we lost the suction header, t
21 there is no way that we could fill up to the pool with that 22 cross-tie because we would have to fill the building up.
23 MR. EBERSOLE:
Oh, the building was designed to g4 till it.
25 MR. CHAPMAN:
Yes, but we would cover up our f~
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reactor boards and everything would wash.
What the cross-2 tie takes care of is if we lose the suction header, we can 3
cross tie and cool an adjacent reactor.
4 MR. EBERSOLE:
Yes.
5 MR. CHAPMAN:
But we also have in there what you 6
call a river water fill.
If we don't lose any of the 7
containments, we would be able to fill the thing, but if we 8
ever had a hole in the containment, the river water would 9
fill up the building as well and we would be in trouble 10 because we would drown out our electric.
11 MR. EBERSOLE:
The original stated objective, 12 Jerry, was to design to compartmentalize, and there are
'( )
13 three of them, the compartmentalized civil engineering 14 structure to carry the building with the filled dry well and 15 torus right up to the ---
16 MR. CHAPMAN:
As long as the torus and containment 17 stay together, we could do that.
The building would take 18 it.
But what I am saying is you can't put a hole in the 19 containment and then put the river water in there.
20 MR. EBERSOLE:
Not the secondary containment.
21 MR. REED:
I think we should put you two guys on 22 the second one.
23 (Laughter.)
24 MR. CHAPMAN:
We have not taken it out and I will 25 rely on it in the alternate.
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MR. EBERSOLE:
The visualization of the terminal 2
case was the entire block was full of water.
3 MR. WYLIE:
Let's move along.
4 MR. DROTLEFF:
Part of the design change process 5
though, Jesse, will answer that in that any modification 6
made by operations or modifications to an engineering design 7
has to be approved by engineering, and also when a 8
modification is complete, it has to be factored back into 9
the engineering input documents and an engineering 10 determination has to be made to the final safety.
That is 11 part of the process that is being put into place.
12 That is where we expect to go within the long term
()
13 and we are working that out.
In the meantime we are r
14 instituting a transitional control system that we are 15 putting into place right now which includes a change control 16 board to review each change that is produced to make sure it-17 is necessary, that it has a safety significance and we have 18 to do it.
19 It will take many of the engineering products that 20 at one time were scattered around and issued over a period 21 of time.
The engineering changes
.*.n the past were issued as 22 hundreds of drawings by each discipline over sometimes a 23 period of months.
We are going to issue everything as a 24 package now.
25 Part of the other key points on this is that if ACE. FEDERAL REPORTERS, INC.
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there is a change made by the modifications group to that 2
engineering design while it is being installed there won't 3
be any verbal changes.
It will be documented and approved 4
by engineering if a change is being made.
5 And we are also going to get rid of the two 6
drawing system which was a system where operations had their 7
own set of drawings, engineering had their own set of 8
drawings and there was a third item out there of plant, and 9
they all three were different.
10 So that is part of our transitional system.
11 MR. CLARK:
Bill, by implementing instructions, do 12 you mean what is now the work plans on that slide?
()
13 MR. DROTLEFF:
No, sir.
The modifications group 14 will still do their own work plans.
15 MR. CLARK:
Okay.
That's good enough.
16 (Slid **)
17 MR. DROTLEFF:
Let me put this one up.
This is 18 the plant modification package.
That is what will go into 19 it.
The implementing instructions will be if you have to 20 have this plant in a special condition to make the 21 modification and if the modification has to made in a 22 certain sequence or if there are special testing 23 requirements, QA requirements, that those would be spelled 24 out by the engineers.
25 There are the items that we intend to put in that s-ACE FEDERAL REPORTERS, INC.
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Package.
P
.2 (Slide.)
3 One of the key things out of this whole plant 4
modification package is that the modification will be' issued I
f 5
again not as a series of drawings by electrical and a series 1-6 of drawings by' mechanical over a period a months, but they f
7 will be issued as a single package.
We will-work with a s
8 modifications group as a team to produce this.
We will 9
assign for each package a task engineer responsible for that i
10 modification to follow it from birth to death when it is 11 finally installed and modifications will assign a work plan 12 engineer, and that is the man who takes these and actually
()
13 converts those.into the actual installation procedures.
He L
14 works with the craft people who will actually' install that.
i So this is a way that we hope to tie engineering 15 16 and operations a little bit closer together.
17 These are the requirements that we are imposing on l
18 the permanent design change system.
We are actually issuing
(-
19 this as a program.
That program is in the final stages now.
20 These slides that I am showing you now, this is a 21 process that we have developed.
It is being reviewed in TVA i
22 now and it will be implemented.
Of course, we-have to work 23 with the operations people and the QA people to assure that l
l 24 the whole program as we come out with it ties together.
But l -
25 the whole concept here is that that last item of when we l
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complete a modification that the plant configuration is 2
updated and it is corrected-and everybody works from one set 3
of drawings and we know what is out there.
4 MR. BARTON:
What level of management makes the 5
decision that one is going to be made in the first place?
6 You know,-people can dream up all kinds of things that will 7
improve the plant, and who really decides which ones are 8
going to be passed through and carried out?
9 MR. DROTLEFF:
What we didn't want to do was get 10 into a major modification where there was a lot of f-11 engineering that might be required and have some low-level 12 manager approve it.
So we have instituted a Change Control 13 Board which has been put into place at at least two of the 14 sites now, and I think it is in place at thrrte of the sites, 15 and that includes the Project Engineer level, the Site QA l
16 representative level and the Plant Manager is on that.
So
).
17 it is a fairly senior level at the site.
18 A preliminary modification study is made, and the 19 Change Contro1' Board would review that at the front end to 20 assure that that change is necessary before it goes any i
21 further.
It will be costed and then the work would be~
l 22 done.
This chart is a schematic of how the flow would be, e
23 and actually before there is probably one other place that-24' the Change Control Board will come in here and give that one 25 final review, and I would guess that is after we issue our ACE. FEDERAL REPORTERS, INC.
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.g modification package and before it gets installed that there 2
would be another Change Control Board review of it.
But it 3
will receive a senior management level review at the site 4
before significant work is done.
5 10t. YOUNGBLOOD:
If you make a change with 6
Sequoyah, where is'the determination made of whether that 7
change should or should not be made at Watts Bar with regard 8
to changes and so forth.
9 MR. DROTLEFF:
There is an unresolved safety 10 question determination that has to be made, and that safety 11 determination has to determine whether or not there is a 12 generic implication.
()
13 MR. YOUNGBLOOD:
So the generic is wrapped up in 24 there.
15 MR. DROTLEFF:
Yes, sir.
16 MR. MICHELSON:
How does this activity interface 17 with the Safety and Licensing?
18 MR. DROTLEFF:
Dick Gridley's Licensing and 19 Safety?
20 MR. MICHELSON:
Yes.
21 MR. DROTLEFF:
They review where each of these 22 affects our license.
They review the change to the FSAR, 23 the change to licensing commitments to assure that it can 24 meet our commitments.
25 Dick, maybe you can answer this.
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i MR. GRIDLEY:
I have an organization block that 2
provides licensing interface with Mr. Drotleff's 3
organization.
Whenever there is a plant mod and the 4
evaluation is completed, the change to the license, whether 5
it is tech spec, FSAR update or any other commitment that we 6
have made to the NRC, it is my responsibility then to work 7
with the engineering organization, and in particular John 8
Raulston's group, and verify the adequacy of the work done 9
to meet the licensing commitment.
10 So the interface is an organization interface.
I 11 was talking this morning about getting interface procedures 12 prepared so that we know where the lines of responsibility r~s x/
13 are.
But I do have an organization that interfaces with i
14 engineering both at the site and in Knoxville.
15 MR. MICHELSON:
Do you jump through that hoop 16 before installation or after?
17 MR. GRIDLEY:
Let's just take that mod package for la Sequoyah.
My Site Licensing Manager and his regulatory and 19 compliance organization will work with the Project Engineer, 20 with Doug Wilson before it starts.
21 MR. MICHELSON:
Before it starts or before it is 22 installed?
23 MR. GRIDLEY:
While the mod package is being 24 prepared.
25 MR. MICHELSON:
While it is being developed?
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MR. GRIDLEY:
Yes.
Now the thing that I am not 2
committing to you is that we don't have those interface 1
3 procedures all written in.
4 MR. MICHELSON:
Okay, thank you.
5 MR. WYLIE:
Other questions?'
6 (No response.)
7 Thank you for the presentation.
8 Let me ask a question.
We have got several items 9
left.
How long do you think TVA is going to take if the 10 subcommittee constrained themselves?
11 MR. GRIDLEY:
It is not 8 o' clock yet, Charlie.
12 (Laughter.)
13 We are talking 10 or 20 minutes.
We could set a 14 target for before 7 o' clock.
15 MR. WYLIE:
Then we have Sequoyah and Watts Bar 16 and Browns Ferry specific issue.
'17 MR. COTTLE:
I'll give it 15 minutes.
All it 18 really was was a slide with bulletized isoues and we can 19 make that simply part of the handout package and respond to 20 questions on those technical issues tomorrow while we are at 21 Sequoyah.
22 MR. WYLIE:
That would suit me.
23 MR. MICHELSON:
How about for Browns Ferry?
24 MR. COTTLE:
We may not be able to answer your 25 questions while you are at Sequoyah, but if you have ACE FEDERAL REPORTERS, INC.
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1 questions on the Browns Ferry technical issues tomorrow, we 2
can collect those questions and respond to you, Mr.
3 Michelson.
4 MR. WYLIE:
What is your pleasure, Carl?
5 MR. MICHELSON:
I have a strong feeling that it 6
would be preferable to do it today simply because I think 7
delaying until tomorrow isn't the answer because tomorrow 8
will be probably even tighter than today.
9 MR. WYLIE:
Well, why don't we put it up and then 10 take a look at it and see what questions develop.
11 Then the staff has presentations on the total 12 program that they would like to wrap up with.
13 So we are talking about probably another hour.
14 Why don't we take a short break.
15 (Recess taken.)
16 MR. WYLIE:
Why don't we resume.
17 MR. GRIDLEY:
The next speaker is Jim Huston, 18 Deputy Manager of Quality Assurance, Office of Nuclear 19 Power.
20 MR. HUSTON:
Good evening, gentlemen.
I was all 21 prepared to say good afternoon.
22 (Laughter.)
23 MR. WYLIE:
The son is not down yet.
i 24 MR. HUSTON:
My name is Jim Huston.
I am Deputy 25 Director of Nuclear Quality Assurance.
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1 I am Stone and Webster employee on loan to TVA.
2 Mr. Richard Kelly is the Director of Quality Assurance and i
3 he is not here obviously for this meeting, but I will make 4
the presentation.
5 I also have with me.Mr. Ed Law who is the Chief of 6
the Quality Systems Branch.
7 What I want to talk about, and I will try to be as 8
brief as I can, are the efforts that we have undertaken in 9
the last four months with respect to the Quality Assurance 10 Organization of TVA.
11 (Slide.)
12 I will talk about that organization as it existed
()
13 last year as a point of reference and as it exists today.
14 I will talk about the resources which we have 15 currently in place and have planned for quality assurance.
16 I will talk about the accomplishments that I think 17 we have achieved in the last few months with respect to 18 quality assurance.
19 And, finally, there has been a question with 20 regard to some of the issues which QA has been is.volved in 21 the review of in a retrospective manner, and I wanted to 22 address some of those issues.
23 Then I will be prepared to answer any questions.
24 (Slide.)
25 This is the organization of quality assurance, l
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But before, let me just associate myself with Mr. Drotleff's 2
comments about the types of. reviews that we did in order to 3
come to the decisions regarding the restructuring of QA.
We 4
did a very extensive review.
We have interviewed the people 5
in the organization and we have visited the sites and we 6
have sought our own counsel to come to the new organization.
7 This is how the organization was structured about 8
mid-1985, and one of the things we did find was that the QA g
organization in terms of structure was fragmented, and this 10 slide I think demonstrates that.
11 Under the Manager of Power and Engineering there 12 was an Office of Nuclear Power which had a site Director at 13 the various sites, and a Division of Quality Assurance which 14 had a plant QA staff.
This was basically the operations 15 organization.
16 Then under the Office of Construction there was 17 Quality Assurance Branch and a Project Manager.
The 18 Quality Assurance Branch had an onsite QA unit and there gg was a Quality Manager's organization which was responsible 20 to the Project Manger.
21 Then in the Office of Engineering there was a 22 Quality Management staff that Mr. Drotleff had earlier 23 referred to which, in addition to doing audits of the 24 Engineering Organization Programmatic, was also involved in 25 evaluating the suppliers of services and equipment to TVA in ACE FEDERAL REPORTERS, INC.
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a shop inspection mode.
2 (Slide.)
3 This is the new structure of the Quality Assurance 4
Organization.
We have now consolidated all of the functions 5
which were previously spread within construction, operations 6
and engineering into a single organization reporting 7
directly to Mr. White, the Manager of Nuclear Power.
8 That Quality Assurance Organization, which I will 9
show you more detail on in a minute, has a strong dotted 10 line relationship with Engineering Assurance for 11 programmatic aspects of the engineering assurance program 12 and focuses very strongly on the Site Quality Organization, p)
(_
13 (Slide.)
14 Under myself and Mr. Kelly there are basically 15 four headquarters branches reporting to QA.
The branches 16 and the bullets indicate in your notes the major functions 17 being performed by the various branches, by the Audit and 18 Evaluation Branch, which is a consolidation of the previous 19 auditing activities performed in the QMS staff with respect 20 to operations and the auditing evaluation that was done 21 within the Operations QA Organization.
22 Procurement quality assurance, we have taken those 23 elements of vendor inspection and qualification and combined 24 them into a single branch which now has responsibility and
~
25 accountability, not only for the qualifications vendors to v
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supply services of hardware to the TVA, but also for the 2
shop inspection activities.
3 The same Quality Systems Branch which was 4
basically the responsible and accountable activity for 5
procedural systems.
6 And then at each site we have established a site 7
quality assurance organization.
8 (Slide.)
9 The Site Quality Manager's organization has been 10 substantially expanded and enhanced.
One of the major 11 actions we have taken is to bring the inspection activities 12 which previously reported to the Construction Organization n(j 13 and integrate those into the Corporate Quality Assurance 14 Organization.
15 That is the Quality Engineering and Control 16 Organization.
Quality control was basically the field 17 inspection activities and quality engineering has to do is primarily with the tools which are used by the field 19 inspectors to perform their functions.
20 MR. GRIDLEY:
Are you aware, Jim, that you didn't 21 provide this chart.
22 MR. HUSTON:
I'm sorry.
I did not provide this 23 chart and I will provide it to the committee.
24 The Quality Assurance Manager is responsible for 25 surveillance and, in addition, we have added a new function 7-
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.g which is called Quality Improvement, and this is one of the 2
more substantial enhancements in_the program to collect and 3
trend short-tera quality performance data and to use that 4
information interactively with the line organization to 5
identify trends and quality improvement initiatives which 6
will allow the improvement in activities and modification or 7
in construction.
8 For instance, to take data with respect to things 9
like large bore hanger reject rates and to analyze that data 10 on a short-term basis to allow the construction, craft and 11 project management line organizations to deal with that 12 information in a way that allows them to improve their
.()
13 performance.
This is more of a short-term program as 14 opposed to the longer term trending for non-conformance 15 reports and things of that nature.
16 (Slid **)
17 The major effects of the reorganization of Quality t 18 Assurance that we are intending.to achieve, first of all, is 19 to eliminate the fragmentation that existed in the 20 organization.
21 Quality Assurance at TVA has evolved like it has 22 in most of the industry, and in the TVA, as was pointed out 23 earlier, with the fragmented and often changed structure of 24 the organization, QA has gone through that same sort of an 25 evolutionary process.
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So we have the assuring responsibility centralized' 2
within the Division.of Nuclear QA.
QA now reports'to the k
3 highest level nuclear managers.
As was talked in some 4
detail about earlier, _ we now report indirectly to Mr. White
]
5_
who;has the overall responsibility for all nuclear power 6
operations within TVA.
7 The resources available to the QA Organization-have been increased, and'I have some information on that.
!~
8 9
The; pay and organizational status of the QA personnel is 10 consistent with the pay and status of the line personnel 11 over whom they have the responsibility to exercise quality 12 assuring functions.
l
()
13 1Gt. CARBON:
That has not been true in the past?
r 14 MR. HUSTON:
To as certain extent in the past the 15 pay and status of the management and individual contributors 16_
within QA has not been on an equal basis with the line 17 organizations over which they had responsibility for their 18 function.
i.
ig MR. WARD:
I can see how you adjust the pay, but 20 how do you adjust the status?
21 MR. HUSTON:
Well, we adjust the status by i
22 changing the management positions in which those people 23 exercise their responsibilities.
For instance, you may make 4
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and similarly on down through the supervisors.
2 MR. WARD:
Okay.
So when you say pay and status,-
3 it is just sort that you have changed the pay grade.
4 MR. HUSTON:
Well, it is more than that though.
5 It also has to do with the involvement of those managers in 6
the process of work.
I think it is clear to all the people 7
within the organization that Mr. White has put a strong 8
emphasis on quality first.
9 To achieve that, that means that the QA personnel 10 within the organization, be it site or corporate, have to be 11 involved in the decision-making process.
So when I talk 12 about elevating the status, I not only mean giving them more
-(m_)
13 pay or elevating their pay grade, but I also mean involving 14 them more directly in the decision-making process.
15 We have a Site Quality Manager who is now 16 responsible for all assuring functions and has a higher
-17 status in that he is at a higher level within the site i
18 organization where he dotted line reports to the Site 19 Director, and we have integrated the quality control
. 20 inspection function with the QA function at the sites, which is the next bullet, that all inspections are now performed 21 22 by our division personnel and we are independent of the line 23 organization.
~
Within engineering, as Mr. Drotleff indicated, we 2
25-have established an Engineering Assurance Organization, and O-t ACE-FEDERAL REPORTERS, INC.
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that organization has a very strong tie to the Division of 2
Nuclear Quality Assurance.
3 And, again, all vendor audit and surveillance 4
activities have been consolidated and brought into one 5-central organization, not only to quality the vendors and 6
maintain the approved suppliers list, but also within the 7
same organization to perform the shop inspections for goods 8
and services ability.
9 The question of human resources, before we 10 reorganized the organization in total, including all 11 elements which budgeted for about 612 people, the actual 12 staff aboard was somewhat less than the budgeted amount.
}
()
13 For fiscal 1987 we are budgeted for 866, which 14 indicates a projected increase of about 42 percent.
15 (Slide.)
16 Those personnel break down as follows.
You can 17 see that the vast majority are in the Site Quality 18 Organization with the rest spread fairly evenly among the i
19 other branches.
20 (Slide.)
l Now let me just summarize the major program 21 22 enhancements which we currently have underway or have 23 achieved.
l 24 As you all know, we have a topical report, and i
25 that topical report was most recently reviewed and approved, l
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and Revision 8 we have now submitted on the 1st of May, an 2
update of that topical report which reflects the 3
organizational changes that have been described in 4
engineering and construction and modifications, and that 5
submission was made on the let of May and is currently under 6
review by the Nuclear Regulatory Commission.
7 We have adopted a two-stage approach for upgrading 8
the Nuclear Quality Assurance Manual, and the first stage is 9
essentially complete.
That is an issuance of an interim 10 NQAM which incorporates all the various manuals which 11 existed within TVA into a single Nuclear Quality Assurance 12 Manual.
)
13 It was a fact that there was a Nuclear Quality 14 Assurance Manual or a QA Manual in Construction and a QA 15 Manual in QA, there was QA Manual, or section of it in 16 engineering, and some various other manuals that had 17 affected the overall quality operation, and those are now 18 consolidated into a single manual.
The second stage will be 19 result in a standardized program applicable for all offices 20 of the Nuclear Power Organization.
21 We have consolidated the construction and i
22 operations audit program and realigned that along a 23 disciplinary line.
We have enhanced the audit reporting 24 system and we are going to incorporate good practices and 25 add an assessment of the data, and we are shifting the ACE-FEDERAL REPORTERS, INC.
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emphasis in audit back towards the hardware.
2 We found that the audit process at TVA primarily 3
concentrated on the programmatics and you need to get a 4
reflection of the hardware into the audit process in order 5
to make it more effective in assessing the problems that may 6
exist.
7 We are involved in an extensive upgrade of our 8
inspection program which includes the development and 9
issuance of standardized certification and training for 10 inspectors, operations and construction.
11 We are going to implement or are in the process of 12 implementing formalized inspection planning which will
()
13 include detailed attributes assigned and directed by 14 engineering into the process to clarify the inspector's 15 responsibilities with respect to evaluating the work 16 performed in the field.
17 And we are working with construction and 18 modifications on the development of new procedures which 19 incorporate and recognize those detailed inspection 20 requirements.
So we are really with construction on the 21 interface between them and the inspectors and also we are 22 working on our own inspection procedures to improve the 23' clarity of the instructions given to the inspectors in the 24 field.
25 We have implemented a corporate level centralized
(~'>
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marysimons V
1 tracking program for conditions adverse to-quality, and that 2
Will Provide for an Office of Nuclear Power-wide system for 3
tracking the CAQ's.
4 We are in the process right now of developing and 5
implementing a program for handling conditions adverse to 6
quality.
7 One of the criticisms that has been leveled at the
?
8 Program is the timeliness of the response, and that includes 9
the escalation of unresolved issues from the line to senior 10 management if they are not adequately addressed.
11 So we are in the process of looking at an enhanced 12 Program for handling those conditions adverse to quality.
J) 13 Tha new quality assessment and quality improvement 14 functions will provide for ongoing monitoring of quality i
15 Performance to support the efforts to improve the quality 16 consciousness of the organization.
17 (Slide.)
18 Now the question been asked have steps been taken 19 to identify the impact of past QA/QC deficiencies on the f
20 hardware to provide corrective actions needed.
The answer l
21 is yes, and these are some examples.
i l
22 The question has been asked regarding Volume 1 of 23
+he Corporate Performance Plan and also the QA topical 24 report, are both forward looking documents.
25 And tnese are some examples of where we have l
l l
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marysimons already taken a'look retrospectively.
i-1 2
The employee concern program, the-ones that are 3
validated and are in fact safety related are being tracked 4
as conditions adverse to quality.
In the Sequoyah welding project, Phase -II, we had 5
6 performed 1,742 reinspections.
With respect to that, 97.4 7
percent of the nondestructive examinations were acceptable i-and 86 percent of the visuals were acceptable.
The.
8 9
unacceptable inspections were subjected to enginee>ing f.
10 evaluation and as a result of that no rework was required.-
a
~
That has already been reported'to the NRC in the final 11 i
12 report with respect to the PhasezII program..
h( )
13 The environmental qualification program, which you 14 will hear a few words about in a moment, we have done 15 extensive ~ reviews and there are approximately 60 significant 16 additional reports for the Sequoyah nuclear project as.a 4
i 17 result of that review.
18 At' Browns Ferry.there have been walkdowns 19 conducted for 79-14 and. configuration control, and the
[
20 problems have been reported to the. Division of Nuclear 21 Engineering.
Usually a drawing is changed and few 1
22 significant condition reports have resulted.
1 23 On the Watts Bar concrete problems which have been I
24 wide reported, in fact three nonconformance reports have 25 been issues or were issued as a result of those
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investigations, and the old work which was performed is 2
being re-reviewed.
3 At the Sequoyah Nuclear Project there is, as you 4
know, a review of all of engineering change notices issued 5
since the operating license phase ongoing.
We are about six 6
weeks into that program and just completing an audit, and we 7
have only found minor problems.
.8 The main problem we found is in the documentation
-9 of engineering judgment in that process, that is the process 10 of the old engineering change notices.
11 With respect.to Watts Bar operational readiness 12 for licensing, design and construction, that program is just
()
13 getting underway.
14 That completes my prepared' slides.
Are there any 15 questions that I might answer?
16 MR. WYLIE:
If I could go back to the original 17 slide of your organization.
4 i.
18 (Slide.)
19 You show a dotted line between Quality Assurance l
[.
20 and Nuclear Assurance.
What is that?
l MR. HUSTON:
This dotted line right here?
This is i
21 22 June 1986.
23 MR. WYLIE:
Yes, I guess that is what I am looking i
24 at.
i 25 MR. HUSTON:
This dotted line right nere?
EO ACE-FEDERAL REPORTERS, INC.
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/~T marysimons L) 1 MR. WYLIE:
Yes.
What is that?
2 MR. HUSTON:
That dotted line indicates that Mr.
3 Weinhold, who is the Chief of the Engineering Assurance 4
Branch reports to Mr. Kelly for quality programmatic issues, 5
and he reports to Mr. Drotleff for administrative purposes.
6 MR. BARTON:
Why should he report over here to the t-7 Quality Assurance Manager?
Why have they put him under 8
Drotleff at all?
9 MR. WYLIE:
I think he has got a dual 10 responsibility.
That is the reason.
11 MR. HUSTON:
Part of the answer is he has a dual 12 responsibility.
()
13 MR. WYLIE:
Well, if I would look at his 14 responsibilities, he-has got actual technical responsibility 15 to review engineering work and checking it.
16 MR. HUSTON:
Yes, sir.
His technical auditing
' 17 responsibilities go to looking in great detail at the i
l l
18 engineering process.
19 MR. WYLIE:
And he also has quality assurance 20 audit responsibility to see that work is properly checked 21 according to procedures, independently checked.
l l
22 MR. HUSTON:
That's correct.
A more fundamental 23 answer to that though ---
24 MR. WYLIE:
You really don't have independence i
25 there.
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1 MR. HUSTON:
Let me give you,1f I might, the more 2
fundamental answer to the question.
3 The more fundamental answer to_the question is in 4
attempting to provide the TVA with the maximum transfer of 5
technology we have modeled some of this after systems which 6
have been successful, particularly at Stone and Webster.
7 With respect to Stone end Webster, that is the way our 8
Engineering Assurance Organization is structured.
9 So we are doing it the way we know it will work 10 and there is a long track record not only with successful 11 projects but of reviews by the Nuclear Regulatory Commission 12 with respect to that relationship, and it has been proven
()
13 and. tested to work.
14 So that is one of the fundamental reasons that the 15 relationship was established that way.
16 And, by the way, if it is unsuccessful in working 17 that way, then we will change it.
If in fact the 18 Engineering Assurance function reporting on the. solid line 19 to the Director of Nuclear Engineering in regard to QA.
20
.doesn't work and doesn't perform its intended function, then 21 we will change the reporting relationship.
22 MR. REED:
No long speech, but just answer what is j
23 bothering me.
QC, and we know what QC is versus QA, is QC 24 say in an operating scene such as in the maintenance group, 25 is the QC performed by line people who are qualified to do N.)
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.the work, or is it performed by your QA umbrella people?
2 MR. HUSTON:
The required inspections, which are 3
stipulated, are done by our quality contro1~ inspectors.
4 MR. REED:
So QC is not in the line organization?
5 MR. HUSTON:
No, sir.
Now there are peer 6
inspections which are performed within operations.on certain-7 evolutions and that is an acceptable practice, but the 8
inspection of say.a hanger is modified or of a major 9
electrical change, those inspections are performed by my in quality control inspectors, the Site Quality Manager's 11 Organization..
J j
12 MR. REED:
I thought for a minute you were going
..( ),
13 to say that was required, but I don't think that would be a 14 proper interpretation.
~
15
'MR. HUSTON:
I did not say it was required.
We i
16 have chosen to perform the function in that manner.
17 Are there any other questions, gentlemen?
l 18 (No response.)
19 Thank.you very much, i
I 20 MR. ELLIOTT:
I am Walt Elliott from the Division L
21 of Nuclear Engineering.
l 22 Today I will be talking about the equipment 23 qualification, the environmental qualification issue and 24 address briefly a little bit of the background, a bit of the 25 cause, the corrective actions and the present status, p
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{marysimons 1-(Slide.)
2 In the way of background, TVA conducted a 3
management review of-the environmental qualification program 4
for 10 CFR 50.49 in July and August of 1985 for all three 5'
plants, Sequoyah, Watts Bar and Browns Ferry.
6 This review indicated that much of the 7
qualification documentation as not readily available and 8
that in some cases there was insufficient documentation to 9
establish environmental qualification.
10 Examples of the sorts of problems that were found 11 included failure to adequately address the similarity 12 between the tested device and the device that was installed
()
13 in the plant.
14 The failure to adequately address the functional 15 ~
Performance characteristics of the equipment and the lack of 16 an available link to establish the link between the 17 Purchased equipment and the equipment covered by the test 18 report.
19 In the case of cause, the cause for the failure to 20 comply with 10 CFR 50.49 in a. timely fashion was attributed 21 to the lack of management attention to environmental 22 qualification.
As a result, responsibility and authority 23 was not clearly defined, and the tool to do the job weren't 24 Properly allocated.
25 The effort prior to the establishment of our ACE FEDERAL REPORTERS, INC.
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corrective action was done in multiple organizations with a 2
fragmented and somewhat inconsistent approach.
The level.of 3
documentation required and the attention to detail that is 4
required for a environmental qualification wasn't recognized 5
and wasn't implemented.
6 Consequently EQ was treated more as an exercise in 7
assembling licensing submittals than the execution of a 8
detailed engineering program.
9 MR. MICHELSON:
Could you explain just a little 10 bit what is mean by documentation not fully auditable?
11 MR. ELLIOTT:
" Fully auditable of course is 4
12 somewhat of a subjective term, but what was found in the l
13 management review was there were cases were the l'4 documentation was not easily pulled together, documentation 15 that was available in files but not readily retrievable and 16 in some cases documentation that was not formally recorded.
4 4
17 MR. MICHELSON:
So some form of the documentation 18 existed, but you just couldn't find it?
l l
19 MR. ELLIOTT:
There was a mixture.
In some cases 20 documentation existed but it wasn't in a form that was 21 easily produced for an auditor, and in some cases there was 22 documentation that was missing from the files.
23 MR. MICHELSON:
Thank you.
l MR. WARD:
When you say it was missing, it was 24 i
25 misfiled or it had never been generated?
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MR. ELLIOTT:
Both cases.
We has some evaluations
- 2 that were incomplete.
So it had never been generated in 3
that. case.
4 (Slide.)>
5 Subsequent to the shutdown of Sequoyah in August 6
of
'85, TVA formed the Environmental Qualification Project 7
under a Project Manage reporting to the Sequoyah Site 8
Director.
He was charged with the responsibility for 9
development and implementation of a program to meet the r
[
10 requirements of 10'CFR 50.49.
i 11
. Initially it was planned that this organization.
12 would-perform the evaluations necessary for Sequoyah, Watts
()
13 Bar and Browns Ferry sequentially.
However, as the 1
14 magnitude of.the effor't and the schedule durations were 15 recognized, TVA elected to initiate. concurrent efforts for 16 the three plants.
l 17 At the present time there are environmental-l 18 qualification projects or teams now for all three plants
(
19 report to the Project Engineer.
20 At Sequoyah at this-time the effort is aimed-at 21 closing out items involving technical issues or outstanding 22 field work, and this is being accomplished by a transition t
23 team that has been temporarily located on the Sequoyah I
24 site.
This is team is about one-fourth of the size of the
- 25 original environmental qualification project for Sequoyah.
l i
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~ 00000101 354 Hmarysimons 1-As-this effort nears completion, the staffing of a j' 2-permanent onsite section-for EQ is beginning and the f 3. responsibilities that are. handled by that transition team 4 will be then handed over to the permanent organization. 5 (Slide.) 6 The box on the flow' diagram that you see there is i-7 the methodology that is used and what I will be describing-i 8 as what we used on Sequoyah.- J 9 'IS11d**) i 10 In order to convey the environmental data to.the i f 11 qualifiers and the other parties in engineering, TVA. l: -12 initiated a drawing series which identifies all plant zones l -( ) 13 and gives the environmental parameters for the applicable' i-l 14 zones. 15 Using those zones then as input, all 1-E equipment 16 that is~1ocated in those zones is tabulate'd on the Sequoyah t l 17 equipment list. That information is developed from cable 18 schedules and. instrument tabs and equipment tabs, conduit gg and grounding drawings,. et cetera. 20 MR. REED: May I ask you a question. One of the 21 critical residual problems after you do.all this, and I 12 2 tried to cope with it years ago by a drastic method and I 23 got: thrown out for it, is the fact.that you all this work, 24 you put~1n the gaskets and you pump up the cases and you do 25 all this great stuff on a type tested basis. You know, you ACE-FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-336-6646
.. ~ 00000101 355 (}marysimons 1 ~ are reproducing a type from something that was produced in a 2 . factor and tested. There are a whole host of administrative 3 procedures that you have to do'to realize the exact type t. 4 that was tested. If you don't tighten the screws up too 5 tight, it will leak. -If you use the wrong putty or the 6 plastic or gasket or whatever or you have a wrinkle in it, 7 it will leak. 8 So in the list of things that cause reactors to be: 9 probably be suspicious to the public at large and everybody 10 is the fact that you don't really know after you get down 11 with this whether you have finished because you don't ever 12 test'it. And so you don't know when you have an accident f () = 13 whether all of this will work'or whether a part of.it will 14 or whatever, and you are left hanging. ~ 15 I merely want to get your own opinion from another 16 organization as to the illogical or logical aspect of that-i 17 sort of a test? 18 MR. ELLIOTT: I am not sure such a test is 19 necessary. What we have done in the process that we 20 utilized in comparing the tested product to;the product that 21 we have got installed, we addressed all the differences in [ 22 degradable materials. I 23 MR. EBERSOLE: You will put in a thousand items-24 though from one item tested in a factor somewhere, and the lO 25 expansion of potential for error is very large. I think it i-i ACE-FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-336-6646 _. ~,_. - _.. - - _ _ _. _ - -. _ -,,, _.. _ _ _ _ _ ~.. -, _ _ _ _ _ _ _ _ _. _ _ _ _... _. _ _ _ _ _ _.
00000101 356 i marysimons .J 1 is a root problem. + 2 MR. ELLIOTT: Another thing I would like to add is 3 we took a lot of attention in developing what we call QMDS, 4 and it is qualification maintenance data sheets that conveys 5 all the ongoing maintenance requirements. 6 MR. EBERSOLE: I hear you, but I am left with a 7 void of confidence, and I guess I always will be. 8 MR. MICHELSON: Occasionally you wet down 9 equipment for some other reason and you find that it really 10 does leak and so forth. So you have really done the test in 11 simple in situ cases whether you wanted to do the test or 12 not and you found indeed that the environmental () 13 qualification may not be as good as you might have thought 14 or least it certainly needs some sharpening up in places. 15 MR. EBERSOLE: Apart from the drastic method that 16 I Proposed, I would entertain an offer of something as good. 17 MR. MICHELSON: Turn on the water protection 18 system. 19 (Laughter.) 20 MR. WARD: Are you suggesting here instead of 21 trying to patch up all the paperwork that they just ought to 22 go in and test it? l 23 MR. EBERSOLE: Oh, no. Have the paperwork done, 24 but then when you get done let's see what the meaning of the 25 Paperwork was and did it in fact mean anything. l l l ACE FEDERAL REPORTERS, INC. l 202-347-3700 Nationwide Coverage 800-336-6646
00000101 357 { ~marysimons 1 MR. CARBON: Why don't we move on. 2 (Slide.) 3 MR. ELLIOTT: Included on the Sequoyah equipment i 4 list is the equipment necessary to meet the requirements of i~ 5 Reg. Guide 197, post-accident' monitoring. 6 What we have included on that list is that f 7 equipment that is presently installed and operational at the 8 Plant. i 9 In addition to that, we have done process. i 10 interaction studies and associates circuit analysis to i ~ identjfy any ncn-safety equipment that-should be included on 11 12 the list. ] () 13 And for Sequoyah there was no equipment ~ dentified, but there were a small number of cables-that i 14 1 15 were identified and included on the list. 16 MR. EBERSOLE: Did they rid of those junction 17 boxes that they cut in that were put below the expensive 18 water type control devices that were there? 19 MR. ELLIOTT: I am not sure. 20 MR. EBERSOLE: What they did there was they put in 21 junction points below the hermetically sealed control 22 devices like PP cells and what-not and put a tin box below 23 the devices with ill-designed seals and covers which 24 invalidated the whole thesis of procurement of the quality 25 material. I presume that has been fixed. l ACE-FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 80 4 336-6646
4 I' f. 100000101 358-marysimons 7 1 MR. ELLIOTT: I am not sure. I am not aware'of i .We did address' junction boxes as a.part of 2 that problem. 3 the program specifically. 4 MR. EBERSOLE: Pull boxes? 5 MR. ELLIOTT: Yes. } 6 MR. MICHELSON: My question was I think-you 7 inferred that you did a systems interaction study for ) 8 possible relationship to the failure of non-qualified ~ 9 systems and how they might interact on safety functions. Who did that work on TVA? 10 l. 11 MR. ELLIOTT: The Nuclear Engineering Branch did 12 the. process interaction. j :( ) 13 MR.-MICHELSON: -And they feed that back to you-14 relative to what they found? 15 MR. ELLIOTT: Yes. P l 16 MR. MICHELSON: Was that documented as a. topical i l-17 report or something of that sort? 18 MR. ELLIOTT: It is documented as a calculation.- 19 MR. MICHELSON: That's interesting. I just would I. I 20-like to see a little of the details of the criteria you used - 21 in-making these system interaction determinations for non-22 qualified equipment. Is there some document I can read that 23 is your guiding criteria or something of that sort that is l ?- L 24 used.or do you do-this on an ad hoc basis? 25 MR. RAULSTON: The whole process is documented in ,() L i ACE-FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-336-6646 l-._
~ 00000101 359 ( ^; marysimons %j i 1 the calculations which of course if you wish can be made 2 available to you. 3 MR. MICHELSON: I am a little surprised at the 4 calculation because in many cases it doesn't involve 5 calculations. It involves identifying the environment. And 6 once having identified it and trying to follow through 7 systems interactions, it is kind of rare that you calculate 8 that unless you have got some interesting scheme. 9 MR. RAULSTON: Saying it is a calculation is just 10 a convenient way to keep it as a control design input 11 document. There is some calculation in it, but most of it 12 is just --- () 13 MR. MICHELSON: It is possible for the committee 14 to receive a few typical examples of your looking at non-15 qualified equipment from the systems interaction viewpoint 16 and its effects on safety related equipment? 17 MR. GRIDLEY: yes. 18 MR. MICHELSON: Thank you. h. 19 This is not because we are picking on TVA, but'it 20 is becoming a generic issue for entirely different reasons 21 and we would like the input. 22 (Slide.) 23 MR. ELLIOTT: The next step in the process then is 24 that all the devices that are listed on that Sequoyah 25 equipment list are evaluated for category and operating ACE-FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-336-6M6
00000101 360 t'l marysimons (j. I times requirements to identify the accidents for which those 2 devices must function and their operating time requirements. 3 Then using the Sequoyah equipment list and the 4 category and operating times document and the environmental 5 data drawings as inputs, the environmental qualification 6 Project then took into the scope of 10 CFR 50.49 all devices that must function or not fail for the accident that 7 8 Produces a harsh environment at the device location. 9 That set of equipment is identified in the 10 CFR 10 50.49 list or what most utilities refer to as their master -11 list, and the qualification is document then in binders. 12 MR. MICHELSON: How do you handle your non-harsh () 13 environment cases? 14 MR. ELLIOTT: The mild anvironment is handled in 15 the normal design process. 16 MR. MICHELSON: Let me ask you relative.to mild i 17 environments there is a question that comes up periodically l 18 of the so-called external events which unfortunately l 19 includes a pipe break outside of containment but inside of 20 your secondary containment. These escape the PRA process 21 generally because PRA for one reason or another doesn't l 22 consider these to be internal events. These are external. l 23 So in evaluating your equipment qualification l against low energy how do you do this? These are not high 24 25 energy line breaks. So they generally don't result in what .D v i ACE. FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-336-6646
r 00000101 361 {? [-marysimons^ ) 1 you define as harsh environments. -How do you handle the low { 2 energy line breaks? '3 bht. RAULSTON: Typically what we have'found,. Carl, -4 when we look at mild energy line breaks because of the large f 5 area and the low energy the environment is enveloped by the-6 normal transient operating condition environment. In other 7 words, like you may use 115 degrees for a normal temperature 8 in an area, and when you have a low energy line break, that 9 envelopes the condition. 10 MR. MICHELSON: It might possible. envelope 11 temperature, but it certainly doesn't envelope, for i 12 instance, water on the floor and flooding and spraying, et 13 cetera. 1 I 14 MR. RAULSTON: We have done spray and jet s 15 impingement studies. f l 16 MR. MICHELSON: In doing your mild environment-37 qualifications you do,have cases then wherein the equipment i 18 is qualified for water spray in a mild environment? l 19 MR. RAULSTON: yes, sir. 1 20 MR. MICHELSON: Okay. So if I look at your f 21 equipment qualification documentation I would see some cases 1 4 22 for that. t. 23 MR. RAULSTON: That was not done as part of.the ^i 24 equipment qualification. 25 MR. MICHELSON: Well,-how was it done then? eO. i t i ) a ACE-FEDERAL REPORTERS, INC. ~ 202-347-3700 Nationwide Coverage 800 33MM6 -.,, ~. -. - -. -, -.. - -.....
.f ' 00000101 362 '(}marysimons 1 MR. RAULSTON: It was done as a separate effort 2 when we looked at' low energy line breaks. T 3 MR. MICHELSON: I am familiar with that effort, 4 but I am wondering did that result in qualification of 5 equipment for those conditions. 6 MR. RAULSTON: It resulted in protection of some 7 equipment from jet impingements and sprays. We are now 8 looking at the flooding part of that. So when we have 9 completed that we will have looked at jet impingement, 10 sprays and flooding, and what we have seen is that for the 11 other, the temperature, pressure and humidity that the 12 normal and operating transients are generally enveloped. _() 13 MR. MICHELSON: So you haven't included that as a 14 part of your environmental qualification program, but rather 15 as part of the pipe break outside of containment evaluation? IS MR. RAULSTON: That is correct. 17 MR. MICHELSON: Okay. That is interesting and 18 that is a perfectly acceptable way to do it. I looked in 19 the wrong place to get my information. 20 (Slide.) 23 MR. ELLIOTT: Since the main objective of the 22 equipment qualification project was to assemble the 23 documentation into auditable files, we evaluated several 24 methods to consolidate those files and upgrade the files, 25 and we electod to use a binder concept. That concept -G V ACE-FEDERAL REPORTERS, INC. 202 347-3700 Nationwide Coverage 800 336-6646 n
4 '00000101' 363' (}1marysimons I basically has all the document that is necessary to 2 establish the qualification either in the binder or t-3 . referenced within the binder. 4 The equipment in the scope of 50.49 is grouped by 5 manufacturer and model number and by common environmental l 6 zones. The. intent of grouping equipment into binders is to. 1 l 7 minimize the number of binders for upkeep that will have to t 8 be maintained for the life of the plant, and for Sequoyah we 9 now have 95 equipment binders that have been identified. 10 MR. MICHELSON: Let me ask, as a follow-up to our 4 i. .11 previous discussion, if you had to make modifications to 12 . equipment to' accommodate flooding or et cetera, is it-in the ( 13 equipment qualification binder, those kind of requirements 14 now? If an engineer wants to-change a piece of equipment 15 and buy a new one to put in there, how is he aware of the i 16 requirements that might have been set by your pipe break i l' 17 study, for instance, and does it get into the binders? i i 18 MR. RAULSTON: We have environmental data drawings l 19 that will envelope the environmental requirements for all i i '20 : areas of the plant whether mild or harsh. I ~- l 21 MR. MICHELSON: Was that also including the pipe 22 break flooding and water spray, et cetera? I 23 MR. RAULSTON: I can't give you a firm answer.on L L 24 that, Carl, but I believe that we will probably update those l l 25 and --- C:) i i ACE-FEDERAL REPORTERS, INC. 202 347 3700 Nationwide Coverase 800 336 6646
. - -. ~. .00000101 364 ~ marysimons 1 MR. MICHELSON: I mean I consider those 2 environmental requirements really and that is why I wanted 3 to make sure that all environmental requirements will some 4 day be in one place where it isn't. missed when'somebody 5 wants to buy a new piece of equipment to replace an old 6 piece of equipment. 7 MR. RAULSTON: I understand, and that is our goal f 8 with environmental data drawings. -9 MR. MICHELSON: Thank you, i 10 (Slide.) I 11 MR. ELLIOTT: The binder consists of the elements 12 that are shown on the overhead there, and again I would like 13 to call your attention to the Tab G where we specify the 14 maintenance requirements and we do specify the exact 15 materials for replacement. Piece parts, we specify torquing 16 requirements if there are any associated with the 17 qualification effort. We have done I think a very thorough 18 job in making those requirements plain. Those are conveyed 4 19 to the operator and he incorporates those in his maintenance 20 program. 21 Also included in the QMDS is the replacement 22 intervals for equipment that has shorter than a 40-year 23 lifetime. 24 MR. MICHELSON: If there is a requirement to do 25 things like seal up conduits where they drop off of cable ACE-FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 804336 6646
00000101 365 (J marysimons i x 1 trays, is that considered as a piece of equipment now and in 2 this binder under conduits or something? 3 MR. ELLIOTT: The conduits are not included in the 4 binders and those requirements are conveyed on the conduit 5 and grounding drawings. 6 MR. MICHELSON: So that kind of environmental 7 qualification isn't in this binder. But if he has to do 8 special sealing at the junction box, that would be in the 9 binder; is that right? 10 MR. ELLIOTT: That is right. 11_ MR. RAULSTON: And I believe, Walt, if I am right 12 we verified that those kinds of things were sealed in that () 13 Part of our verification. 14 MR. ELLIOTT: That's right. 15 So we believe the binder is an organized method to 16 demonstrate and document the environmental qualification of 17 the devices in the scope of 50.49. 18 (Slide.) f 19 At the heart of the binder is the check list that 20 is in Tab B of the binder along with the supporting test 21 reports and analysis that we have performed to evaluate the 22 equipment. 23 Again, we paid a lot of attention in development 24 this check list. We used examples from other sources and 25 from our consultant Westek and we developed a check list for ACE-FEDERAL REPORTERS, INC. 202 347 3700 Nationwide Coverage 80 4 336-6646 L
00000101 366 j ) marysimons 1 documenting the evaluation of the equipment in 50.49. We j 2 compared the check list to the requirements of 10 CFR'50.49 3 and to IEEE 323-74 and to other standards to make sure that 4 we covered all pertinent aspects of the environmental 5 qualification. 6 The contents there are are shown, and I won't 7 review those with you. The check list is a comprehensive 8 check, list, and it is over 20 pages in length itself. And 9 because of the comprehensive nature of the check list, we 10 believe that drives us to a uniform product since everyone 11 is using a common check list. 12 MR. MICHELSON: What does aging mean in this () 13 case?- If I go to Section 8 what do I_ expect to find? 14 MR. ELLIOTT: You will find an evaluation of the l i 15 aging analysis on any age degradable material whether it is 16 from thermal or radiation aging. 17 MR. MICHELSON: But as a maintenance man, for 18 instance, what would I do with it, and as a replacer of 1 19 equipment what would I do with it? l 20 MR. ELLIOTT: With that section in particular you l 21 won't do anything because we translate those requirements to 22 the QMDS. So if we have age degradable material that l 23 requires replacement on some definite interval, we translate 24 those requirements to the QMDS and that then is input to the 25 Maintenance Department. l () l ACE-FEDERAL REPORTERS, INC. 202-347 3700 Nationwide Coverage 80 4 336-6646 I
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.00000101: 367 (}/marysimons L MR. MICHELSON: So this is just documentation. 1-2- MR. ELLIOTT: That.is the. analysis, yes. 3 (Slide.) l. 4 The binders,' including the check list, were 1 5 prepared in accordance with-detailed engineering procedures 6 and we included in those procedures a set of guidance for' f the evaluators to guide them through the important aspects of the equipment qualificat. ion. 8 i 9 In order to ensure that the binders reflect the t i 10 equipment that was installed in the plant, equipment, with 11 the exception of cables has been. subject.to a visual field 12 verification and documentation of that field verification is -() 13 included in the binder. i 14 For cable the site pull cards and other records [ 15 were used as a determination of cable type and routing. 16 MR. MICHELSON: How do you make a visual 17 determination that this is qualified equipment? l 18_ MR. ELLIOTT: That visual determination basically 19 is a match-up of manufacturer's serial number, if that is 20 important, and recording that on data sheets. l 21 MR. MICHELSON: The assumption is that the model e i 22 number reflects -- if the vendor had required certain
- 23 modifications in order to qualify that particular model,-it
'24 is now incorporated into the model number as well somehow? 25 MR. ELLIOTT: In some cases. For example, there ACE-FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-336-6646
-00000101 368 {]p-marysimons 1 are date codes on limit switches that they have to fall 2 within certain date codes in order to be qualified. 3 MR. EBERSOLE: In a QA context have you examined 4 the basis of claims for environmental adequacy as it is 5 Produced in the testing laboratories,-because if you 6 haven't, you should be. The Sandia Labs, and I think it-is 7 important that you read their findings of last year 8 sometime, discovered that in the modeling of performance 9 they invoked similarity, and similarity in fact didn't exist 10 in the performance context. There were all sorts of 11 subterfuges and ill-found methods to prove invulnerability 12 to the influence of environment inferred rather than proven. -( 13 I recall where they deliberately preheated the 14' item to be tested to achieve an over-temperature so they 15 wouldn't get internal condensation on the contacts and then i 16 they ventilated the enclosure which was type four which [ 17 usually introduced moisture, but since they had preheated 18 it, it never showed up the problem. 19 So I wonder if you in fact are adequately 20 suspicious of the validation papers you get with this. stuff?_ i 21 MR. ELLIOTT: We are taking a close look at the 22 test reports and the QA programs. 23 MR. EBERSOLE: Do you have type four enclosures 24 where you bore holes in them? 25 MR. ELLIOTT: I am not aware of any. .v ACE-FEDERAL REPORTERS, INC. 202-347-3700 - Nationwide Coverage 800-336-6 9 6
I ~ +% 00000101 369 {}marysimons ~ i 1 MR. EBERSOLE: Well, even the staff was attempting 2 to let industry pass through that crack by invoking a 3 certain amount of leakage using the residual for partial 4 functioning of the control process. I don't know where that 5 stands now, but it was a suspicious process at its best, and 6 I would have hoped that since you are going to be a 7 superlative outfit that you wouldn't permit it. 8 Are you with me? 9 MR. ELLIOTT: Yes. 10 MR. EBERSOLE: In short, they would take 25 ) 11' percent of the leakage current and say well there is enough 12 left to make the job go. () 13 Are you aware of that little excursion in the i 14 business a 15 MR. ELLIOTT: No, not that one in particular. 16 MR. EBERSOLE: I would suggest you look that up. 17 MR. GRIDLEY: Jesse, is that a Sandia report that 18 is available? 19 MR. EBERSOLE: Right. And the staff was bending 20 over backwards to let industry get through the hook with .ji their leakage currents. I don't know at present where that g effort stands. Maybe the staff representatives could tell 23 me. Where does it stand? Do we have anybody that can 24 respond to that? 25 (No response.) n v ACE-FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-336-6646
00000101 370 /~ V} marysimons 1 Well, the fact that you have never heard of it is 2 one reason I am mentioning it to you, and now you have heard 3 of it. There are tricks in this trade all over the place. 4 MR. ELLIOTT: We have gone to great lengths to 5 measure leakage currents in certain devices like terminal 6 blocks and cables, et cetera. 7 MR. ELLIOTT: As part of the binder process, we 8 had several controls in place to ensure the adequacy of the 9 process. 10 In addition to the normal checker function or 11 independent review function, we had a management review on 12 the initial issue issue of the binders, and that review was . [') in place to verify the adequacy and the technical 13 v 14 completeness of the binder along with some measure of the 15 standardization of the product. 16 In addition, we had reviews that were performed by 17 the Sequoyah (N4 site representatives on binders in various 18 states of process. We had quality assurance and engineering 19 assurance audits that were performed along with the NRC 20 staff's inspection of EQ that continues. 21 (Slide.) 22 As a result of the problem that we have executed 23 to date, we have written approximately 60 SCR's, or 24 significant condition reports. Most of these involve field 25 work. The overhead shows some of the most significant items v ACE-FEDERAL REPORTERS, INC. 202-347-3700 Nationside Coverage 800-336-6646 ~ _ _
00000101 371 . O marysimons Q. 1 that were.found. 2 One thing lto note is that some-of these items 3 represent. multiple SCR's. For examplei the first bullet 4 there represents about four SCR's and'the:second bullet 5 again represents again four to six SCR's. 6 (Slide.) 7 Additionally, in execution of.the program we did 8 identify some additional requirements that we needed to beef-9 up documentation in' areas like flooding levels and radiation 10 levels, and those calculations have essentially been 11 completed with a-couple of outstanding issues like the-12 superheat issue: in the main steam valve vaults which is
- 13 '
still underway. 14 (Slide.)- 15 As far'as present status of Sequoyah --- 16 MR. EBERSOLE: Pardon me, just a minute. Where 17 you have a junction boy and you drill weep holes you must- -18 have been trying to keep it from unplugging. t. i 19 MR. ELLIOTT: To allow moisture to drain ~out in i 20 the case of condensation. l l 21 MR. EBERSOLE: What does moisture do before it l 22 drains out to the functionality of the contained apparatus l 23 in the box? lf 24, EMR. ELLIOTT: The. contained apparatus has been l 25 tested in a moisture environment so it should be sufficient. ($I 1 l l l ACE-FEDERAL REPORTERS, INC. !~ 202-347-3700 Nationwide Coverage 800-336-6646 L^ '
-'00000101 372 _f'I marysimons ,-s/ m 1 MR. EBERSOLE: So it is moisture proof? 2 MR. MICHELSON: No. 3 MR. ELLIOTT: It sees moisture and it should 4 function --- 5 MR. EBERSOLE: I mean it can withstand moisture 6 whether it is in a box or not in a box.. 7 MR. ELLIOTT: That is right. 8 MR. EBERSOLE: So it is a junction protected 9 internally to the 'aox by whatever method. 10 MR. E'uLIOTT: That's right. 11 IS13de.) 12 For Sequoyah all the equipment binders have now ,. () 13 been initially issued and we are in the process again of 14 closing out the remaining technical items and field work 15 items. 16 The efforts to baseline the maintenance program to 17 incorporate the QMDS requirements for Unit 2 is about 92 1 18 percent complete and for Unit 1 is about 87 percent 19 complete. 20 MR. EBERSOLE: Where you have terminal blocks up ( 21-there, is that where you got rid of those boxes that 22 contained the terminal blocks and then put in splices and 23 then put on heat shrink seals or something? 24 MR. ELLIOTT: That is where we eliminated the 25 terminal blocks.from the circuits --- ACE-FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800 336-66 4
.00000101 373 /~h T V. aarysimons ? 1 MR. EBERSOLE: That is the one'you talked about .2 earlier.. 3 MR. ELLIOTT: Yes, and that is because of a -4 leakage current problem, yes. 5 On Unit 2 about 69 percent of the field work has 6 been completed and the document has'been submitted to the 7 transition team and approved. -8 The actually completion of the field work is 9 somewhat higher, probably in the 80 or 85 percent range. 1 10 The NRC identified items from previous-inspection 11 trips. The path the resolution has been identified ~cn1 all. 12 of.those and most of the-binders have been updated to 4 f) 13 -resolve those with about three or four remaining to be I-14 closed out by the 23rd, j 15 MR. EBERSOLE: We are talking strictly about i 16 Sequoyah, aren't we? 17 MR. ELLIOTT: Yes, this is Sequoyah. 18 We presently anticipate completion of the field I 19 work and.the remaining technical-issues to be wrapped 20 finally about the end of July. i 21 MR. EBERSOLE: I have to mention something that is f .22 not Sequoyah because it has such terrible importance. The L 23 SRV's on the boilers, of which you have three, have a i 24 supremely critical set of solenoid operated valves, the 25 safety relief valves -- and what are they called -- SAR's, i L ACE-FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage ~ 800-336-6646
2 00000101 374 V(~T marysimons 1 semiautomatic reliefs. Those things have to be energized 2 hot to be held open. They have to therefore survive the 3 environment, whatever it is, which is likely to be critical, 4 when they are needed. 5 If you can't open them, then you can't exercise 6 the privilege of low-pressure cooling. So I think it might 7 be worth a point of making special attention to the 8 environmental capability of those. They had a lot of 9 trouble with them in the research labs when they built them, 10 and there was a lot of doubt as to whether the actual 11 product that was supposed to duplicate those things were 12 ever in fact produced. That is the SRV solenoids. (() 13 MR. ELLIOTT: I am not sure what the status of 14 that is on Browns Ferry. 15 MR. CHAPMAN: Those are the Asco valves on the 16 target rock. They are in the qualification and we are in 17 the process of replacing a lot of them. There are some 18 qualified solenoids that we are going after. 19 MR. EBERSOLE: Did they prove to be bad when you 20 tested them? 21 MR. RAULSTON: There are certain models that have 22 been. The ones on the target rocks, I don't know whether 23 they are the ones that are good or bad. But I know we are 24 going after a bunch of Asco replacements, and I had not 25 heard where they go. ACE-FEDERAL REPORTERS, INC. 202 347-3700 Nationwide Coverage 800 336-6646
~. ~ _. -00000101 375 /}marysimons. 1-1 01. ELLIOTT: I do know that the process will 2 force them to look at the environment in the cold rise due t-3 to the energized state. 4 This basically concludes my presentation. 5 MR. WARD:. Walt, which part of the organization 6 are you with? 7 MR. ELLIOTT: I am with the Division of Nuclear 8 Engineering, the Nuclear Engineering Branch. 9 MR. WARD: Okay, the Nuclear Engineering Branch. 10 MR. ELLIOTT: I report to Doug Wilson, the lead 11 engineer at Sequoyah. 12 'MR. WARD: You are at the site organization but in () 13 the Nuclear Engineering Branch. 14 MR. ELLIOTT: Temporarily, right. 15 MR. WARD: Are you a two-year man? 16 MR. ELLIOTT: No. I am a TVA man. 4 17 MR. WYLIE: Any other questions? i. 18' MR. CROCKER: I heard him give an approximate date 19 of when he might finish on Sequoyah. I did hear on on 20 Browns Ferry. 21 MR. ELLIOTT: I don't have one on Browns Ferry and 22 I don't know if there is a schedule set. 23 MR. WYLIE: Thank you very much. 24 Let's move on, and I believe Mr. Cottle wants to 25 briefly put a slide on and ask whether we have got any 4 ACE-FEDERAL REPORTERS, INC. 202 347 3700 Nationwide Coverage 800-336-6646
.00000101 376 marysimons g. questions. 2; MR. COTTLE: ' Dave,-would you put the restart-3 . issues slide:on for Browns Ferry first. 4 (Slide.) 5 These'are by no means all of the technical or ^ 6- - otherwise identified issues to restart the Browns Ferry 7 unit. We asked the task forces at'each of the plants in the 8 preparation of these three slides to. select about the top 10 h-9 to 12 or more' restart issues that they consider to be real io problem spots with them and real critical to the restart 11 effort. i 12 MR. EBERSOLE: What is the problem with' Appendix .( ) 13 R?' 14 MR. COTTLE: We have not-completed the Appendix R 15 modifications on Unit 2 at Browns-Perry. There is 16 discussion still going on with the staff and we still have I !~ believe an exemption request in for some selected part of 17 l 18 those modifications. 19 .I don't not think at this point in time, Mr. l [ 20 Ebersole, that Mr. White has made a decision whether he is 21. willing to bring the unit back with exemptions or whether.he i' 22 wants to pursue the completion of all modifications. 23 MR. MICHELSON: What is the story cn the torus l l 24 attached piping and the CRD tubing? 1 25-MR. CHAPMAN: The torus attached piping, when we ACE-FEDERAL REPORTERS, INC. 202 347-3700 Natloneide Coverage 800-336-6646 '~
~ ~ I 00000101 377 l(}'marysimons 1 did ourstorus modification we did inspections and NRC came 2 in and in one of their inspections started asking questions 3 .and it opened up the specter that we did not do an adequate 4 QC inspection. j-5 MR. MICHELSON: But this is on the attached piping. 6 to the torus? 7 MR. CHAPMAN: Well, that is all the piping inside 8 and outside to make the torus slow down working. So the new. 9-quenchers.we put in there, all that piping came under 10 scrutiny and we are going back and'relooking.at it. It is-a 11 reverification program. 12 Now the CRD, we looked at that and we found out in s. i f' ( ) 13 one of the inspections, we found a QC problem with not 1 14 having adequate supports on the CRD draw line. So we 1-15 started an analysis of that. i MR. WARD: I see one on the list here, Bill, 16 17 ensure technical adequacy of plant procedures. What is at i 18 issue there, and does that include the emergency operating i 19 procedures? 20 MR. COTTLE: Yes, sir, it does. We are looking at 21 operating procedures, both system operating instructions and. 22 emergency operating instructions and the surveillance 23 instructions which which implement the technical 24 specification surveillance requirements as well as selected 4 i 25 maintenance procedures. < (1 ACE-FEDERAL REPORTERS, INC. 202-347 3700 Nationwide Coverage 800-336-M46
00000101-378 I~T marysimons %J 1 MR. WARD: And what led to this as an issue? 2 MR. CCTTLE: Partially an issue on the operating f 3 engineering instructions of some of the outdatedness of the 4 Plant drawings, including check lists that were in fact in 5 the procedures. 6 On the surveillance instructions, the NRC did a 7 very thorough audit on the technical content of surveillance 8 instructions on our Watts Bar plant and it had to go through 9 several iterations to ensure that those Watts Bar procedures 10 met the intention and the technical requirements of the 11 specifications, and we are translating that over to both 12 Sequoyah and Browns Ferry as part of that review. ) 13 MR. WYLIE: Any other questions? 14 MR. MICHELSON: I have one question on the reactor 15 water cleanup system for Browns Ferry. Outside of 16 containment, is it seismically qualified? Beyond the 17 isolation valves is it seismically qualified? 18 MR. CHAPMAN: I do not think so. 19 MR. MICHELSON: In many plants of that vintage it 20 was not. 21 MR. CHAPMAN: Through the isolation valve it is, 22 but outside of that it is not. We have just written an SER 23 that we did not have break detection in one location, and we 24 are adding break detection to fix that up. 25 MR. MICHELSON: The next question is the break O V ACE-FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-336-6646
00000101 379 [~} marysimons M 1 detection and its qualification and the final questions is 2 do you think the valves will close under break conditions in 3 case of an earthquake, for instance, and keeping in mind the 4 blowdown rates, the two-phase flow flashing occurring and the water slugging and whatever since the reactor is trying 6 to blow down through I think a six inch line in the case of 7 Browns Ferry. 8 It is quite a violent blowdown and it is very 9 exciting and it is outside of containment and you must close 10 the isolation valves. 11 MR. CHAFMAN: As far as I am concerned, I am 12 confident that the isolation valve will close. () 13 MR. MICHELSON: What is the basis for the 14 confidence is what I am asking. 15 MR. CHAPMAN: The basis for the confidence is that 16 we have tested it against full pressure and we think that is 17 a more severe friction load on the motor. Those motors are 18 under our Movex program so that we check degradation on a 19 periodic basis. So we know we have got the torque when we 20 need it. We have done the tests and we have done the 21 calculations. The only forces we see with a two-phase flow 22 is we see the drag forces or momentum forces flashing in 23 there. So we think it has to be between the momentum forces 24 or a combination of that and drag forces. We have looked at I drag forces from steam by itself and we looked at momentum 25 ACE-FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 80433MM6
- 00000101' E380 Emarysimons 1
forces of water by itself. We think.it is in between and we 2 have got enough force in our operator, as long as we check f 3-our operator that we think we can close the valve. 4 MR. MICHELSON: So you are saying that you don't 5 think that.there is any possibility of developing slug flow 6 conditions when you blow down through the line, intermittent -7 singJe phase,-two phase water slug. 8-MR. CHAPMAN: We think if you had a slug of water 9 hitting it, it would be no more than intermittent and it 10 .would not create any more drag forces. 11 MR. MICHELSON: Oh, I think you had.better rethink i I-12 that answer if you hit it with a water slug.. 13 What you have to do is show that you always have 14 either a single phase liquid or;two phase wall mixed or gas j ' 15 ' . phased,-but don't hit it with water slug because I_think 16 that.is where you get into difficulty. 17 So you had better be sure your analysis shows that i i 18 that is an incredible event. l f 19 MR. WYLIE: I would suggest that maybe we write i 20_ some of these things down. f 21 MR. MICHELSON: Well, these have been talked 22 about. 23-MR. WYLIE: I am having a hard time relating that 24 to our mission here. j 25 MR. REED: What is our mission?
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00000101 381 Le marysimons 1 ~MR. MICHELSON: Restart issues on Browns Ferry is 2 the mission at this point. 3 MR. COTTLE: Can I have Watts Bar, Dave. 4 (Slide.) 5 (No response.) 6 MR. WYLIE: Hearing no questions, let's move on. 7 MR. COTTLE: Sequoyah. 8 (Slide.) 9 (No' response.) 10 MR. WYLIE: Okay. Hearing no questions, let's 11 move.on to the next item. 12 We will the the staff then and their comments () 13 regarding the program. 14 MR. YOUNGBLOOD: With regard to the corporate -15 requirements that we had in our 50.54(f) letter that we sent 16 on September 17th, these were the major issues with regard 17 to the corporate. 18 (Slide.) 19 Specify the actions by the TVA Board to remain 20 informed and involved in the nuclear plant performance 21 described in management changes to strengthen regulatory 22 regulatory performance, establish corporate controls to 23 assure the integrated commitment tracking system and improve 24 the program for escalating QA audit findings. 25 Those were the specific issues in our 50.54(f) O(_/ ACE. FEDERAL REPORTERS, INC. 202 347-3700 Nationside Coverage 800 336-6646
00000101 382 marysimons letter. 1 2 MR. EBERSOLE: I think we ought to have "to get 3 and remain." Our_ language slight of hand is too common in 4' NRC. 5 MR..YOUNGBLOOD: Yes, sir.. 6 (Slide.) 7 The TVA Board of Directors has indicated that they 8 plan to be kept informed by three principal mechanisms, 9 reports from the Manage of Nuclear Power, reports from the 10 newly established TVA Inspector General and they had 11 originally indicated advice from the group of special 12 nuclear industry experts. 13 I believe that Mr. Gridley went over the portion 14 on that, that they plan to use INPO and receive reports from-15 several different sources.from within the organization on a 16 routine basis. 17 That will be discussed further I guess within 18 their revision to the corporate plan that they are working 19 on now. 20 The improved corporate oversight is planned by 21 major efforts to improve the management systems and controls 22 through improvements in the programs and procedures, 23 improvements in planning and interaction of the nuclear 24 activities and improvements and commitment tracking. 25 These things have all been discussed today by ACE FEDERAL REPORTERS, INC. 202 347-3700 ' Nationwide Coverage 80 4 336-6646
00000101 383 (}marysimons L 1 other people. 2 (Slide.) 3 Management changes to strengthen the regulatory 4 performance. 5 The establishment of the Office of Nuclear Power 6 that provides for strong central authority unencumbered by 7 non-nuclear activities. 8 The establishment --- 9 MR. WARD: Joe, could I interrupt. I guess what 10 we would like to hear is what you think about each of these 11 things. What is the staff's position? Are you going-to l 12. tell us that? () 13 MR. YOUNGBLOOD: Yes. 14 (Slide.) 15 MR. WARD: Because I think we can stipulate what 16 is here. What we really need to hear is what you think 17 about it. 4 18 MR. YOUNGBLOOD: All right. The TVA submittal 19 provides a conceptual description of the changes in the TVA l 20 intent, but lacks implementation in details. 21 The plan's concept is acceptable to the staff, but 22 we could not make a final finding without the details of the 23 implementation. I 24 MR. WARD: Could I ask you, Joe, what is the basis 25 for your judging that it is acceptable? I mean they have ACE FEDERAL REPORTERS, INC. 202 347 3700 Nationwide Coverage 804336-66M
00000101 384 marysimons 1 made a change.back toward a more centralized management 2 ' organization. 3 MR. YOUNGBLOOD: We believe this is an improvement with this centralized organizat' ion? 4 5 MR. WARD: Why? What is your basis for making 6 that judgment? 7 MR. YOUNGBLOOD: Well, because of the different. 8 organizations not being pulled together into a single 9 overall coordinated group. 10 MR. WARD: But I can read management analyses in a 11 - one situation where the recommendation or the best approach 12 might be to decentralize things. Under another set of () '13 conditions someone might recommend that things ought to be 14 centralized. I mean how do you know they are moving in the 15 right direction here? What is the basis for you making a 16 judgment? 17 MR..YOUNGBLOOD: Our belief is that it be more 18 coordinated. 19 Larry, do you want to speak any further on that? 20 MR. CROCKER: I think the feeling, Mr. Ward, is 21 that under the circumstances they have had down here and 22 where we are trying to go that a central direction now, a 23 strong central direction probably stands the best chance of 24 Pulling things out in any reasonable period of time as 25 Opposed to trying to do it on a bootstrap sort of thing for ACE FEDERAL REPORTERS, INC. 202 347-3700 Nationside Coverage 800 336-6646
[ 00000101 385 (~J\\ marysimons 1 four different sites. 2 MR. WARD: Well, a lot of_ enterprises have been 3 highly successful when they decentralized. MR. CROCKER: Absolutely. This one was not. 4 5 MR. WARD: Well, I don't know if it ever got 6 decentralized. Have you consulted with anyone? Has the 7 staff used any available management expertise? 8 MR. YOUNGBLOOD: We haven't had any management 9 consultants involved with us, not up to this point in time. 10 MR. WARD: Do you think that this is just an 11 unanalyzable situation and it is imponderable and all you 12 can do is go with gut feelings? () 13 It is a fundamental central issue here. 14 MR. YOUNGBLOOD: They were decentralized before, 15 and that was not working. 16 MR. MICHELSON: How long were they decentralized? 17 MR. WARD: Well, something wasn't working, but how 18 do you know that their operation wasn't working because it 19 was_ decentralized? 20 MR. CROCKER: I am not sure, Mr. Ward. Had they 21 come in with a proposal that said, hey, we are going to 22 completely decentralize now and each one of the sites is 23 going to be a complete authority on its own doing its own 24 thing, as far as the NRC is concerned, we would treat them 25 as four separate utilities basically, and we probably would ACE-FEDERAL REPORTERS, INC. 202-347 3700 Nationwide Coverage 800-336-6646
O 00000101 386 (~ ) marysimons x_/ 1 have said fine. 2 I have no reason to say that it won't work. If 3 they want to do it with a central organization under the 4 scheme that they have got, I think they stand a pretty good 5 chance of success, and they may have worked the other way 6 and also stood one. 7 But I don't think we can secondguess them at this 8 Point in time and say yes, this will work and that one won't g work. 10 MR. WARD: As long as they are positive and 11 enthusiastic, is that the --- 12 (Laughter.) f) 13 MR. REED: Well, for what it is worth, Dave, let %/ 14 me just point out that I think, and you can argue this, I 15 think that the successful nuclear activities, and I will 16 name one, Yankee, and I will name another, Wisconsin, and I 17 will name another Kewani, and I will name another Northeast 18 Utilities, those that I am familiar with, I think you will 19 find that those successful operations have all been close 20 coupled, centralized, project team basis activities. 21 MR. WARD: Kewani has got one unit. I mean I am 22 not sure that it is --- 23 MR. REED: Well, take Millstone. I was trying to 24 give you a number because I know you are not impressed by 25 anything but numbers. ('\\ )) ACE-FEDERAL REPORTERS, INC. 202 347 3700 Nationwide Coverage 80lb336-6646
\\ 00000101 387 (^T marysimons s / 1 (Laughter.) 2 MR. REED: Now I don't know what Duke Power, 3 whether they consider theirs a centralized activity or 4 project team --- 5 MR. WYLIE: Duke is very similar to this with 6 maybe minor exceptions. That is the way Duke works. It is 7 very similar to this with minor exceptions. 8 MR. EBERSOLE: you mean it is a split system. 9 MR. WYLIE: Well, sure. I mean it has basically 10 gone to a matrix type organination with project teams 11 assigned to every site, and they are using the same 12 techniques such as packaging modifications and all these () 13 things. It is a matter of control. 14 What I see is that under the arrangement where 15 they went through this transition period of dumping 16 everything but the plants, and I will just use that term, 17 and moving away from centralized organization, I will just 18 say you weren't prepared for it, you didn't make the 19 necessary preparations and you didn't have control. 20 Now you have control, it is a different 21 organization, but you have the control again. The other one 22 would have probably worked if you had had the control. 23 MR. MICHELSON: WeII, how does Southern Services 24 do it with Georgia and Alabama and Mississippi and so forth? 25 MR. WYLIE: It is matrix system. ACE. FEDERAL REPORTERS, INC. 202 347 3700 Nationwide Coverage 80 4 33 & 6646
00000101 388 ~N marysimons (U 1 MR. MICHELSON: Does Southern Service have 2 engineering teams at each site? 3 MR. WYLIE: Yes. They set up projects. 4 MR. MICHELSON: No. I mean after they were built 5 and operating. 6 MR. WYLIE: It is a matrix organization. 7 MR. MICHELSON: I didn't realize that Southern 8 Services had teams at these sites. 9 MR. WYLIE: You can take either approach, but just 10 like Glenn is saying, you can take companies that have one 11 or two units and they have close coupled engineering 12 organizations. Like he said, you could have divided it up () 13 into three utilities, but that of course is not efficient. 14 So, I don't know. It is a matter of a control as I see it. 15 MR. YOUNGBLOOD: I don't believe there is any way 16 at this point in time that we have positive assurance that I any organization is going to work until we see some of the 17 18 implementation and follow up on it. 19 It appears to be a plan that in concept appears to a 20 be workable for resolving many of the problems that they 21 have had in the past. 22 MR. EBERSOLE: It is sort of middle of the road 23 anyway, the matrix. 24 MR. YOUNGBLOOD: It encompasses both of them. 25 MR. WARD: It is not a particularly satisfying ACE FEDERAL REPORTERS, INC. 202 347-3700 Nationwide Coverage 80 4 336-6646
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389 .marysimons i answer. I mean I. guess one answer I' heard is you like it f because it is like Duke's and their's.seems to work. You 2 3 didn't say that.~ 4 MR. YOUNGBLOOD: I didn't say that. 5 MR. WARD: Somebody else said that. It was like 6 'Kewani, and that works. That is what Mr. Reed said, but you 7 say anything. 4 i 8 (Laughter.) [- g MR. YOUNGBLOOD: It is an overall centralized plan 10 that gets at many of the shortcomings with regard to the 11 communications and so forth that have been lacking in the 12 other programs. They are working up procedures and 13 Programs, as'you have heard then explaining throughout the j 14 day. We believe that this concept certainly should improve 15 the corporate management at TVA. 16 MR. MICHELSON: In the other cases where this 17 concept works, I am not aware that any of those cases were j 18 cases wherein the temporaries are being brought in to make ? 19 it work for a couple of years and then phase out of it. ? 20 MR. YOUNGBLOOD: These are the things that we have i 21 to continue to look at and these are the questions that we I 22 have asked them with regard to. 1 23 MR. MICHELSON: I think the structure looks fine 24 as far as a structure. I 25 MR. YOUNGBLOOD: To how they are going to train
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l 00000101 390 l >(~} marysimons ~ U. 1 people, what kind of programs they have set up to accomplish -2 these things and assure that --- 3 MR. MICHELSON: Are we going to be back here in 4 two years, in other words? I hope _not. 5 MR. YOUNGBLOOD: I would hope not, too. 6 MR. HAGEDORN: May I say just a word about the 7 structure? I think it is very dubious to talk about this 8 structure and many other structures.of large organizations 9 in terms of contralization and decentralization because 10 every big organization has lots of things that are highly 11 centralized and lots of other things that are highly 12 decentralized, and it just depends on what you pick in order () 13 to talk about that kind of aspect. 14 Well, you don't have very many basic choices that 15 you can use. In this case what they have really tried to 1 l pull together at the corporate level or nearly the corporate 16 17 level at least is a highly functional organization, and when i 18 you try to organize things that way, then the next order of 19 analytic question that you have to ask is how are you going i I 20 to integrate that strong functional organization, because a i 21 functional organization inherently sets up a lot of f tensions. 22 23 You know, everybody has got an empire, and the 24 question is how do you make those empires work together. 25 And I think that that question has not been completely ACE-FEDERAL REPORTERS, INC. 202 347 3700 Nationmide Coverage 800-336-6646
~ 00000101 391 ( } marysimons Q/ 1 addressed. t 2 Structurally it has been very incompletely 3 addressed so far in the sense that we have 26 people 4 reporting to Mr. White, and you know that that is not a 5. complete or final or ultimate answer. 6 If you go to an extreme version of what somebody a 7 moment ago called three utilities, then you have a set of 8 questions, some of which have just been asked, like can you 9 really justify the maintenance and the paying for all those 10 specialists, and if you don't have that many specialists, 11 then your question obviously is how in the world are you 12 going to arrange for technical competence and how are you ['/) 13 going to share the technical competence that you have well u 14 enough that you can get any kind of effect. 15 So the only point I am trying to make is that if 16 you go to one kind of organization, you have got one set of 17 questions and that you then have to ask in order to be 18 assured that that organization will work, and if you go to 19 the other kind of organization, you have got another set of 20 questions that you have to ask about whether it is going to 21 work, or how you are going to make it work. 22 And I am sorry to have interrupted you. 23 MR. MICHELSON: I think that helps the 24 clarification. The next question of course is what set of 25 questions do we need to ask of the arrangement that they are ACE FEDERAL REPORTERS, INC. 202 347-3700 Nationwide Coverage 800 336-6646
00000101 392 {}marysimons i proposing. I think we have asked some of the questions and 2 I think there are a number of others that perhaps have been 3 asked but not answered. 4 MR. HAGEDORN: Well, there are a whole range of 5 questions about integration of the top levels. You started 6 to ask some questions this morning that are very 7 incompletely raised as yet about how priorities are going to 8 be dealt with then the projects and the plants begin levying 9 requirements on the central support services, especially as 10 we have begun to discover that the central support services 11 are not necessarily huge organizations and that if anything 12 is wanted of some of them, simultaneously from two or more () 13 sources they are going to be hard pressed. And the question 14 of how in the world you resolve that is a very important 15 one. 16 Then there are probably some questions about how 17 you get operating integrity of when you start talking about 18 operations and get beyond the question of design and 19 construction. 20 It is very difficult to -- well, the analogy I 21 like because I once had something to do with the Navy, too, 22 for a while is the captain of the ship. You know, there is 23 no question about what the captain of the ship is in 24 charge. We haven't begun really to ask questions about 25 whether these so-called Site Directors are in charge or what ACE. FEDERAL REPORTERS, INC. 2024 47 3700 Natloneide Coverage 8004 36 4646 - i
00000101 393 'N (b marysimons 1 they are really in charge of. 2 We got some responses a while ago from the Project 3 Engineer that made it pretty clear to me and I am alldly 4 reassured that he really has got a wrenching gutload of 5 responsibility to deal with there, and it may be-that if we 6 ask enough questions about the Site Directors and that 7 central sort of line organization for operations that we 8 would find to be the case, too. 9 But in order for that kind of thing to work in a 10 strongly functional organization, then we have a whole range 11 of qucations that we need to ask about the comparative 12 ranking of this national football league of people that () 13 reports directly to Mr. White, because unless those line 14 operating people at least the equals of some of the strong 15 functional heads, they are going to be swamped by two 16 facts. One, these other guys have the self-confidence that 17 comes without ranking them to begin with and, two, they are 18 going to have a lot more proximity because they are going to 19 be where the man is a lot more of the time. So there is 20 another range of questions that I think needs to be 21 addressed there also before we ever get away from the 22 structure. 23 MR. MICHELSON: But this structure can be made to 24 work or not work as the case may be by the people that are l 25 going to operate that structure and how they finally i I I ACE FEDERAL REPORTERS, INC. l 202 347 3700 Nationwide Coverage 1100 334 6646 L t
00000101 394 (}marysimons 1 function. 2 MR. HAGEDORN: So there is no point in stopping 3 with the structure and there is no point in spending 4 . infinite time on the structure. 'I 5 MR. MICHELSON: My main interest was the 6 continuity of the structure beyond this short infant period 7 and whether or not we have built a foundation upon which it 8 can go and prosper in five to ten years. 9 MR. HAGEDORN: Well, sure, and that gets into a 10 whole series of additional kinds of issues that have to do e 11 partly with internal leadership and politics. 12 One of the obvious things that I mentioned to you ) 13 on the break is who gets promoted in the next two years. If. 14 the White administration and the network of people that he 15 has introduced already are able to identify enough like 16 minded people and promote them swiftly enough and to get t 17 them to cohere enough, then something can be expected to 18 last longer than two years that these people may be here. 19 MR. MICHELSON: And can it be done in two years 20 is one of the questions. 21 MR. HAGEDORN: It is a very short time. 22 MR. MICHELSON: But if it isn't, the organization 23 is going to pull itself apart again if there isn't a strong 24 cadre of directed leadership by the time the contract people 25 leave. 4 () ACE-FEDERAL REPORTERS, INC. 202 347-3700 Nationwide Coverage Mn336-6646
00000101 395 (~ -(-} marysimons 1 MR. HAGEDORN: Now of course you have got the 2 structural fact going for you that for the first time every 3 maybe or at least for many years at least all of the nuclear 4 considerations do come together at a point in the 5 organization, and any successor to Mr. White is going to 6 inherit whatever benefits there are that accrue to that, but 7 a lot of those benefits are again going to depend to an 8 extent on how the 26 people sort out over the next two years 9 and what kind of substructures and who survives and which 10 ones really get his ear. 11 MR. MICHELSON: Then the composition of the Board 12 itself can affect this. () 13 MR. HAGEDORN: It can. So I guess we can go on 14 from that to a whole lot of questions about. team building on 15 the various levels and how you do address the very large 16 number of people who are involved here. 17 I was impressed that in the few minutes he was 18 here that he saw fit to mention that he has initiated the 19 training for 2,200 middle managers. Well, I would have said 20 if he didn't so something like that he was sure going to 21 fair. It doesn't mean you are going to succeed if you do 22 it, but if you don't do it you know you are going to fail 23 because these people have got to begin to recognize the 24 consistency and the persistence with which leadership is 25 going to behave. ACE FEDERAL REPORTERS, INC. 202 347 3700 Nationwide Coverage 800 336-6M6
00000101 396 (J"N marysimons 1 MR. WARD: But you see that as a central important 2 corrective action. 3 MR. HAGEDORN: The training? 4 MR. WARD: Yes, the training. 5 MR. HAGEDORN: No, just an indication of the kind 6 of diagnosis he is making. A brief sort of training episode 7 isn't going to in itself do that much. 8 MR. WARD: But some sort of comprehensive training 9 in management. 10 MR. HAGEDORN: I would be willing to give him the 11 benefit of the assumption that if he is willing to invest a 12 resource in something like this, training 2,500 people for () 13 three days or three weeks or whatever it is, when you stop 14~ to think of it, it costs a lot of money that a lot of e 15 managers are not wiling to spend. And if he willing to do 16 that, then I am willing to make the assumption that that is 17 only the first gun in a big campaign of communication of-18 trying to show the direction that he wants people to go and 19 trying to lead them into acting in ways that -- what was 20 Jesse's word for it -- they are different from your army of 21 self-initiating people doing whatever they please. 22 MR. EBERSOLE: The principle of individual 23 initiative. 24 MR. HAGEDORN: Yes, the principle of individual 25 initiative. I think individual initiative is important. G L/ ACE-FEDERAL REPORTERS, INC. 202 347-3700 Nationwide Coverage 800-336-6646
l 00000101 397 }marysimons 1 MR. WARD: It sounds good to me. He says it like 2 it is a dirty word. 3 MR. HAGEDORN: Well, evidently in his day here it 4 had more harm than good associated with it. You get the 5 accountabilities first and then you get --- 6 MR. WARD: But, see, a training program in 7 manageraent or something hasn't even been mentioned by TVA 8 except for Mr. White. He happened to breeze in and say 9 'something about it. 10 MR. EBERSOLE: It is not in the plan. 11 MR. WARD: Right it is not in'the plan. 12 MR. WYLIE: And I am not sure whether the NRC has () 13 heard that until today. 14 MR. YOUNGBLOOD: We have not heard that until 15 today. You know, our evaluatio5 we say is a preliminary 16 evaluation. We stated that because of a lack of details for 17 implementing most of the critical areas of the 18 organizational structure does not permit the staff at this 19 time to express its views on the adequacy of the corporate P an to eliminate the root causes of the TVA problems and to l 20 21 assure safe operation. We don't have enough information 22 yet. 23 MR. WARD: Can I say something? I have still got 24 a problem here. I mean-I think we were told that TVA has a 25 Problem. The official' root cause of the problem seemingly ACE-FEDERAL REPORTERS, INC. 'i-202 347-3700 Nationwide Coverage 804336-646
. ~. =_ - -. ~.......- r w 00000101 398 (}marysimons .1 agreed to by both TVA and the NRC'is the lack'of commitment 2 in nanagement to achieving excellence. 3 They seem to be doing two things to fix that. One 4 is to, if not centralize, sort of rationalize management, 5 and the other is to put in a sprinkling of new managers who 6 Mr. White says are going to lead by example for two years. 7 Now those are the two cures for the root cause that have 8 been made explicit,-and it is.just clear to me. i-i 9 I thought the talks were good and the people to seemed to know what they were talking about and I was i 11 favorably impressed by most of them, but I am not sure what ~ that means. 12 ] ) '13. I am not sure that'the staff has: prepared itself 14 to evaluate'the licensee in this important situation. Has i' the staffLgone to any trouble to hire consultants and has - 15 i 16 the staff gone to any trouble to educate itself-in the areas i 17 'that are critical? 18 MR. CROCKER: No, we have not, Mr. Ward. i f 19 MR. YOUNGBLOOD: I assume then we are down to a l i 20 statement about the other items that have been given. So l 21 that would finish my slide presentation-. b The other things that were mentioned during the 22 23 day-with regard to the-TVA actions on engineering, the 24 design configuration and engineering control issues, those l -25 were the first time we had heard that, and we haven't heard .() ACE-FEDERAL REPORTERS, INC. _ 202-347-3700 Nationwide Coverage 800-336-6646
00000101 399 { 'marysimons i that yet either. We are waiting for that to be submitted to 2 us and the staff will review those things. That is part of 3 the questions that we have asked them in our May 1 letter. 4 The employee concern program, we were doing a lot 5 of work on that. We have had three or four inspections 6 already with the way the program is set up and the 7 methodology that their using and the criteria that they are 8 using and working closely with TVA on those things. 9 We are assigning program managers to review the 10 various categories that are being reviewed by TVA. So those 11 things we are following. It appears to us that the one 12 thJng that we had not had, and we do have the QA topical () 13 now. There is to be a meeting on that. It was scheduled 14 for the 19th and 20th I believe. I am not for sure. That 15 may have to slip. 16 The preliminary information that I have back on 17 that is that the QA topical more nearly meets _the NUREG 0800 18 criteria now than the topicals did in the past. They are 19 Providing revisions to those things even prior to the 20 completion of our review on it, but we are working with them 21 at this time on those things. 22 Everything is at a very premature stage right now 23 with regard to our review. 24 Any further questions? The impossible ones I 25 can't answer. ACE-FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-336-6646
00000101 400 ] ) marysimons 1 MR. GRIDLEY:. Joe, you didn't mention that you 2 have worked with each of the site task forces, which I think 3 has been helpful in un6erstanding the activities. 4 MR. YOUNGBLOOD: Yes. 5 MR. GRIDLEY: The staff has been closely involved 6 with us in the activities of the task force and have spent a 7 lot of time by traveling down here and going through this. 8 MR. WYLIE: Any further questions of the staff? 9 (No response.) 10 MR. WYLIE: Thank you. 11 (Whereupon, at 8:15 p.m., the subcommittee 12 recessed, to reconvene at 8:30 a.m. In the Managers /g'(,j 13 Conference Room at the Sequoyah Nuclear Power Plant in 14 Daisy, Tennessee.) 13 16 17 18 19 20 21 22 23 24 25 i. ,-_s \\~-) l ACE-FEDERAL REPORTERS, INC. l 202-347-3700 Nationwide Coverage 800-336-6646 _ _~
v-CERTIFICATE OF OFFICIAL REPORTER .\\ This is to certify that the attached proceedings before the UNITED STATES NUCLEAR REGULATORY COMMISSION in the matter of: NAME OF PROCEEDING: ADVISORY COMMITTEE ON REACTOR SAFEGUARDS AD HOC SUBCOMMITTEE ON TVA PARTIAL TRANSCRIPT DOCKET NO.: PLACE: CHATTANOOGA, TENNESSEE DATE: THURSDAY, JUNE 12, 1986 were held as herein appears, and that this is the original ~~ transcript thereof for the file of the United States Nuclear Regulatory Commission. O-(sigt) M (TYPED) h [ MARY SIMONS Official Reporter ACE-FEDERAL REPORTERS INC. Reporter's Affiliation, i l.
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