ML20215F210

Transcript of 870608 Meeting W/Util in Bethesda,Md Re Idvp Insp for Plant.Pp 1-42.Related Documentation Encl

ML20215F210
Person / Time
Site:	Sequoyah
Issue date:	06/08/1987
From:	NRC COMMISSION (OCM)
To:
Shared Package
ML20215F150	List: ML20215F146 ML20215F210
References
NUDOCS 8706220281
Download: ML20215F210 (53)

Text

o ggGiHAL l

UNITED STATES NUCLEAR REGULATORY COMMISSION IN THE MATTER OF:

DOCKET NO-1 3

MEETING BETWEEN NRC AND TVA l

,J LOCATION:

BETHESDA, MARYLAND PAGES:

1 - 42 l

DATE:

MONDAY, JUNE 8, 1987 k

i O

1 ACE-FEDERhL REPORTERS, INC.

_b OfficialReporters 444 North CapitolStreet i

Washington, D.C. 20001 (202) 347-3700 i

8706220281 870612 i

P R ADOCK 050 7

NATIONWIDE COVERAGE

lti CR}l237.0 i

TAiLOE/sg 1

2 UNITED STATES OF AMERICA i

2 l

NUCLEAR REGULATORY COMMISSION MEETING BETWEEN 3

NRC AND TVA 4

5 Nuclear Regulatory Commission 6

1 4350 East-West Highway Fifth Floor Hearing Room 7

Bethesda, Maryland i

0 Monday, June 8, 1987 l

9 I!

The neeting convened at 1:00 p.m.

l!

10 l!

b l

11 '

12 lU j!

13 14 15 '

16 '

17 i

18 l

i i

l 19 20 i

21 I

l i

22 1

23 24 25 I

~

ACE FEDERAL REPORTERS, }NC.

202 347 3700 Nationwide CoseraFe '

8(6 336-6646 l

)

l i

i

'i 3J237.0

[

2 1

TAY 1

1;

_P R C C E E D I NGS 2[

MR. KEPPLER:

Good afternoon.

The purpose of l

3 today's meeting is to discuss the recent letter which the 4

NRC sent to Admiral White regarding the need to do an t-5f independent design inspection at the Sequoyah plant prior 6

to startup.

7 What I would like to do. Admiral, is to give you p:

s 8 l' some of our thinking as to what went into that letter, and 9

then to -- I think what we need to focus on is whether the 10, NRC does that inspection or whether TVA gets an independent 11 contractor to do the inspection; and lastly, we will be 12 prepared to tell you what systen that we want to look at as 13 part of this effort, and what some of our thoughts are with 14 respect to the independent aspect of it, and how this will 15l all impact on TVA's schedule.

Uc will try to do it in a 16 way that makes the least impact on that schedule.

17 The plant has been shut down now for almost two 18, years, and during this outage a number of problems have o

19 been identified which the Staff has been dealing with with i

20 i

TVA to discuss the resolution of these issues, and one of 21 the problems involves design changes that have occurred at 22 i

the plant since licensing for which a design base line 23 clarification program was put into place to determine the i

24 impact of these design changes.

And there have been, as I I

25 mentioned, numerous other management and technical issues, i

l l

ACE-FEDERAL REPORTERS, INC.

202-347-3700 Nationwide Coserage 8(n336 6646

f 3j237.0 b

3 TAY l

1 j; a.11 of which, when resolved, TVA thought would provide the 2!

assurance that the plant was ready to resume operation.

3 Another background or pertinent consideration in.

4 what has gone on is that Uatts Bar, which the Staff l:

5L believes in many ways is very similar to Sequoyah, has a 6

number of design and construction licensing problems that 7

will have to be dealt with.

h 8"

Additionally, there are still allegations open 9

regarding the Sequoyah plant's compliance with the final 10 safety analysis report, and lastly, Commissioner Asselstine 11 h raised several questions concerning TVA's problems and 12 questioned, among other things, the need for the Staff to 13 [

require an independent design inspection.

The concerns 14 that were raised by Commissioner Asselstine are observed V

i 15; largely by the Staff.

We forwarded these questions to TVA 16*

on 11 arch 31st, and TVA is still yet to respond to these 17 ;

questions.

I'm hoping during this meeting that we will i

18 find out when we will get the response to those questions.

19 During the meeting that we had down at i

Chattanooga on May 21st, when we went through all of the 20 i

21 programs that TVA was conducting, I made the statement that 22 I f elt TVA's pursuit of technical problems has been quite I

23 comprehensive.

However, I mentioned that I viewed the I

24 l

effort as an evolving process and somewhat fragmented, and

~

l 25 that the Staff was concerned that all major issues may not i

l ACE FEDERAL REPORTERS, INC.

202-347 3700 Nationwide Coverage 800 336-6646 I

~

I i

31237.0 l

4 IAY l

1j have been identified by this process, particularly in 2[

interface areas.

F 3

Also, although we recognize there are clearly 4

i differences in the design and construction programs between 5

Sequoyah and Watts Bar, these differences by themselves do i,

6 not provide assurance that similar concerns do not affect 7

Sequoyah.

8 So, with that' background of information, I made t

9 the decision that the Staff would require an independent 10 design and construction verification of at least one 11 safety-related system and provide the additional assurance 12 that all major construction and design problems have been 13 identified and resolved prior to restart.

14 Their position was cleared by the EDD.

He sent 15l the letter to you on June 2 conveying their position, and 16 emphasizing it was not necessary to redo extensively work 17 that TVA has done as part of its verification efforts, but 18 to focus on areas that have been overlooked in the process.

i 19 So, with that, we are meeting today to get your 20 reaction to the letter as to how you see it.

21 I will mention for the record that you and I did 22 have some discussion down at Browns Ferry last week, in 23 l which you expressed some concerns that this type of effort 24 I

that we are looking for might take as long as nine months.

I 25 i

I will tell you that I have had some limited opportunity to i

i i

l l

/\\CE. FEDERAL REPORTERS, INC.

202 347 3700 Natbnwide Coserage 804 336-6646

t 31237.'O 5

TAY 1

look at what Staff has required in the past, and that seems 2

to ce a very pessimistic portrayal of what we think will be 3

required for this effort.

i 4

Before we get into what some of our your 5,

thoughts are, would you like to make some comments?

f 6"

MR. UHITE:

Yes, I would.

I wonder first if we i

7 could find out who is in the room today.

8 (Participants introduced themselves. )

9 MR. 2UOLINSKY:

There is one administrative 10 matter.

Our recorder was unable to get your names.

We do 11 have an attendance sheet going around.

Will you please 12 identify yourself and your affiliation and we will attach i

l 13 that to the meeting minutes.

1 14 [

MR. WHITE:

TVA's recovery program as described 15 h in volumes 1 and 2 of the nuclear performance plan is a i

16 thorough and in-depth program to assure the safety of 17 b Sequoyah.

It is a good program.

As described to you l

[

18 during our 21 May meeting, we are well along in our program 19 leading to the startup of Sequoyah.

He do not believe that 4

20 l any additional assurance is necessary.

If I felt that I 21 would have already included it in the nuclear performance 22 plans.

Nevertheless, you sent us a letter dated 2 June 23 i

asking TVA to add a vertical slice of a system to further 24 verify the design and construction of Sequoyah.

The I

25 l verification of the design and construction of Sequoyah is ACE-FEDERAL REPORTERS, INC, i

202-347-37(0 Nationwide Coserage 800 336-6646

i h

31237.0 i

6 TAY l

f I

1,,

precisely what I set out to do in January of 1986, as 2

detailed in volumes 1 and 2.

This entire effort has been 3

to provide me the assurance that it is safe to start up 4

Sequoyah.

5 Ue recognize that there are no precedents for j

j 6L the vertical slice for which you ask, that is, it has never 7,;

been required before in this fashion of a licensed, 1

8 operating plant.

This effort, then, is unique and brand 1

9 new, but we will comply.

10 Based on your letter, we looked at the various 11 ways to accomplish what you are asking using the guidance 12 of the September 1986 NRC presentation, we believe, to the 13 ACRS.

That presentation gave three methods which may be 14 used on unlicensed plants.

He looked at those three 15l methods in terms of using them on a licensed operating 16 plant, and the method that we selected was engineering 17 assurance.

De are satisfied that it is independent and 1C that the team is independent.

The people that we select 19 for the team had nothing to do with the design, 20 construction or operation of Sequoyah.

The engineering 21 assurance group doing this program has been observed by the t

22 NRC on a number of occasions and the NRC has made positive 23 comments of their performance, and I might add that 24 performance has been in a fishbowl.

He are comfortable

]

25 that you have checked our engineering assurance effort to l

/\\CE-FEDERAL REPORTERS, INC.

202-3.t7 3700

. Nationwide Coverage 80r> 336-6646 1

k r

31237.0

'h 7

-TAY

[

i it I

1 your satisfaction.

h 2

However, as an added assurance of independence, 3

I would recommend that one or more full-time NRC observers j

4 be added to the team.

In addition, I've directed that the 5

. team would report directly to me.

We would like the 6[

opportunity this afternoon to describe to you the-program I

7 we have come up with, which we believe meets the intent of 8

what you have asked for; and I think it is it;.portant for 9

the startup of Sequoyah that we try to get two decisions 10 from you today.

First is the approval to proceed in 1

11 accordance with the idea of using our engineering assurance 12 program that we are ready to present to you today, and 13 i second is for you to select a system so that we can get 14 [

right to work.

I would hope that you would find it-15j possible to caucus today, to provide that decision to us.

16 I would like to respond to two other things.

In j

17,

your opening comments you mentioned that we have not yet j

i 18 [

responded to the questions that originated from 19 Commissioner Asselstine.

As you know, the public meeting

)

20 l

of the 21st of May, th6t was one of the primary intents of i

21 that meeting, was to answer as best we could those 22 questions.

We then expected.to receive other questions 23 from the NRC, which we would also answer.

By review of

)

i 4

24 l

your June 2nd letter, we felt that we should further delay

{

l 25 the answers to that question.

And the second thing I would i

f

/\\CE. FEDERAL REPORTERS, INC.

202-347-3700 Nationwide Coserage 8(0 336-(M6

f 31237.0 h

C TAY l

r 1 j.

like to comment on --

i.

2L MR. KEPPLER:

I don't understand that at all.

3 Why would you want to delay answering these questions?

I 4

MR. UHITE:

Delay it for this meeting, l

5 Mr. Keppler.

In other words, we did not expect the June H-6 2nd letter.

We had really expected to see if there were 7

other differences, things that you didn't feel were fully 8

explained on the 21st of May, and we were prepared to do 9:

that.

And as you know from our conversations, I was then 10, ready to submit that letter.

I regret that there is 11 misunderstanding.

12 Referring to our conversation at Browns Ferry, 13 the nine to 11 months that I mentioned, I,

too, have done 1

14 some checking since then, and I believe that the nine to 11 15, months is a realistic and not a pessimistic view of the 16 l 1ength of time that it would take to conduct the vertical 17 slice using the other methods.

He are prepared.

I don't 10 j' know which way you prefer to go.

We are prepared to make a 19 presentation on what we think would meet the intent, and I i

20 would recommend that perhaps we start with that, Mr.

i 21 Keppler.

22 MR. KEPPLER:

Before we do -- I guess I'm 23 troubled.

I have been familiar with a number of l'

independent design verification programs that have been j

i 24 ll I

25 carried out at the plant, and while you talk about the fact i

l t

l

/\\CE. FEDERAL REPORTERS, INC.

202 347-3700 Nationwide Coverare '

800-336-6646

l.

34237.0' 9

TAY h

i 1l that there is no precedent for their effort, I would tell-2 you that the majority of the plants that have been licensed I

3 over the last six or seven years, I would wager that 90 i

i 4

percent of them have gone to an IDVP, or an IDI, or an 5

engineering assurance program, and the reason for that is 6

simple:

It is to provide the Staff with added assurance

]

)

7 that no major problems have been overlookea through the 8L processes.

9 These types of efforts, to the best of my 10' knowledge, have required anywhere from three to five months, i

11 depending upon the scope and complications associated with 12 these efforts.

Bechtel did an IDVP for the Byron plant j

i 13 with three systems, 30,000 man-hours, and it took them 14 4-1/2 months.

I would think that doing one system, with 15:

the kind of concessions I gave in my letter to you that we 16 would not redo everything, would be considerably shorter i

than that time frame.

17 b

I 18' Toledyne did an IDVP for LaSalle in 19 approximately 4-1/2 months.

Oak Creek effort, I believe i

20 l

that was done by Setgeant Lundy, which took about 5-1/2 i

21 months, but it was a very complicated protocol and j

i i

22 independence factor that the state of New Jersey required-i I

23 l

for that plante which I would not envision would be a 24 prerequisite to your program.

25 so I guess I really don't understand why you i

l l

l l

l ACE. FEDERAL REPORTERS, INC.

2r 347 3700 Nationwide Coserage 800-336 6646 l

[r h'

J1237.0 10 TAY 1

think an IDVP would take nine to 11 months.

There's been 2

one case that I'm aware of at Clinton that took about nine 3

months, but that was because they found problems, and the,

t 4 [

Staff required that project to do additional work as a 5,

result of the problems found.

Hopefully we would not be 6

talking about that, since we have identified some problems.

I 7

So, I'm a little troubled that we are not b

8f talking from the same base point.

9 MR. UHITE:

I think that is fair enough.

10 L Perhaps that is where we should start.

First of all, I was 11 careful in my choice of words.

Clearly these things are 12 precedented on unlicensed plants, particularly, as you i

13; pointed out, the last few years.

I certainly know of no 14 similar effort on a licensed operating plant that has ever I

15 [

been requested, required or accomplished, and it is 16 considerably different, conducting a vertical slice of a 17' plant that is about to be licensed, a new plant, in 18 accordance with today's standards,.that is quite a bit i

19' different than looking back and trying to reconstruct using 20 today's standards, to reconstruct what happened in the case 21 of Sequoyah seven or eight or more years ago.

So from that 22 prospective, it is clearly in my eyes unprecedented and a 23 l new effort to accomplish that.

i 24 l

We are prepared, clearly, in any of the cases I

I 25 that you suggested, to discuss the' length of time that 1

l l

I l

ACE. FEDERAL REPORTERS, INC.

200 347-37(0 Nationwide Coverage 8(0 336-6646

1 3;1237.0 11 TAY h

1[

tnose IDVPs have taken.

I think we must be cautious of the 2L definition of the start and completion, because, for 3

e x ampl e, the start and completion of Clinton, the 1

4 advertised time, which is perhaps nine months, as you 5;

suggest, when I called the v. ice president in charge of that i

6 9 and discussed it with him, it turned out it was a 7[f considerably longer period.

l i

8h If the start period begins when you start 9

searching for the contractor, getting the contractor in 10 place and up to speed, getting the contractual requirements 11 worked out, getting a plan made by these people who have no 12 L prior experience in that plant, getting those plans made i

13 and submitted to the NRC for their review, and then i-14 commencing the review.

The review itself probably only I

15 [

does take five or six months, and then that is followed by i

i 16 ;

usually, I would say on the average of a two-month report.

i 17 So if you take the five months and you take two 18 or three months at the beginning and a couple of months at g

19 l

the end, you come up with nine months, and we are prepared 20 to discuss the specifics of any of the cases, having I

21 contacted a number of people involved in a number of 22 utilities as to the overall time period, not the specific 23 work time period.

24 MR. KEPPLER:

I was told the overall time period -

l 25 for the Byron plant is 4-1/2 months.

i I

I

(

/\\CE-FEDERAL REPORTERS, INC.

202-387 3700 Nationwide Coserage 8h336-6646

O 11237.0 12 TA Y l<

MR. WHITE:

Perhaps we should answer that first, 2[

if I may.

I' 3(

MR. CA POZ Z I:

Mr. White, I would like to say I

4 something, because it is important for me personally, and I 5[

think it is important for their discussion, and I'm not one 6

to preach schedules.

7 I am concerned about the ability to find 8b problems.

I think we need to look at the history of TVA.

9 There has been a lot of contractors in, and a lot of people, 10[

including the NRC I might add, have not been able to find 11 these major problems.

I've got evidence since I've been 12 here that TVA, through the organization, we have been able 13 to do that.

So I think, as you indicated at the April 20th 14 meeting, I think we need to look at the track record and 15f measure us as a group, to be able to find problems, which 16 other independent groups have not been able to, and I 17 really feel if we all have it in our heart to find major 18 problems, we need to look at that report card, on both 19 sides of the house.

That is just a comment.

20 MR. KEPPLER:

Let me say, I don't -- I have been 21 supportive of the effort that you people have done d;vn 22 there.

I sort of get the feeling because I want additional 23 assurances that I don't appreciate what has been done.

24 !

That is not the case.

But I think when you talk a little i

25 bit about the concept of doing something like this, I have I

/\\CE. FEDERAL REPORTERS, }NC.

202 347-3700 Nationwide Coverage

- 800-336 *i46

F,

.e l

31227.0

'13 TAY I

1, a little bit of a problem in my own mind of coming to a i

2L conclusion that the engineering assurance approach would be 1

I 3

" independent" for this kind of effort, because I think you 1

I l

4 have lived with this project now for several months; you 5[

have gone through and you have explored it as well as you I

61 can, and I think frankly it would be very difficult for you j

7 to provide the prospective of a fresh look at it.

That is b

8" my only problem.

9 MR. UHITE:

Mr. Keppler, perhaps we can save i

10, time if you let us go through this, because certainly one 11,

of the plans would show that what you perhaps have i

12 described may not be the case.

13 So, if you would let us go through and describe o

14 why we think it is independent, and try to convince you 1

15' that it is independent.

i 16 MR. CAPOZZI:

Thank you.

17 Mr. Kepple r, I personally looked at your June t

18 2nd letter and I have listed in the packet _that has been 19 handed out five major points that the letter makes:

That 20 l

both independence; vertical review of at lease one safety I

t 21 i

system; the focus on the interface and interactions, which 22 are very important; to build on the existing programs; and 23 to identify any major problems as they may exist.

24 l In reviewing those major points, we have laid 25 down a plan that carried that out, and it will include i

l I,

ACE-FEDERAL REPORTERS, lNC.

i 202-347-3700 Nationwide Coserage 800-336 6646

)

p I

31237.0

[

14 TAY h

I L

1l every one of those areas.

That plan is to first of all b

2i have you select a system, and we have selection criteria 3

that we have developed which you will see here as we go i

4 through this material.

What you are looking at on the 5

front sheet is a basic outline of what I would like to talk 4

i 6

about.

7 The second area is how we put together the team 8l and what it would consist of:

the existing programs; the 1

9-focusing on the interf ace; the using of detailed checklists, 10i and not taking anything for granted that something was 11' checked without laying down the question and then see if

~

12I indeed another program does cover it; the identification of L.

13 [

major problems, and we will define what major problems are ;

u 14 '

iand the welcome of the NRC inspections as they have done in I

15j other areas as well.

16 Tne purpose of the review will be four major 17 areas, basically.

One is to insure that FSAR commitments 18, have been complied with; the second area is to insure that 19 the documents are themselves technically accurate; that the 20 design process that took us there in developing those i

21 documents is indeed tight as a drum, and if it isn't, we 22 will change it and insure that if there is problems out i

23 there we are not going to have the same problems.

i 24 I

The selection criteria is listed right here, and 25 this is consistent with the guidelines, but again, if you l

ACE FEDERAL REPORTERS, INC.

202-347-3700 Nadonwide Coverage 800-336-6646

I c

p 15 31237.0 F

TAY

[

1 i

1[

pick it, I don't think that is in controversy.

The key L

2l things that I would be looking for is to draw conclusions 3

from the vertical slice for other systems within the plant, 4

other safety-related systems in the plant.

So we need to i

5[

make sure we pick a system that is interactive, that has l-6" all the disciplines involved, and that we indeed focus on 7

that interface that we are all concerned about.

I 8

The review team will be senior people equal to 9

or greater qualifications than the people doing the work.

10 They will be totally independent.

They will have no 11 involvement whatsoever with the Sequoyah project.

12 I will discuss that a litte more as to who those 13 people will be.

It will be a multidiscipline team, 14 involved in not only the technical branches but all the 15 divisions within TVA.

1 16 I think it is important to discuss briefly, 17 L basically, keying on what you said, tir. Keppler, in regards 18 i to us being clouded a little bit.

I reviewed the vertical 19 slice, and if there is anyone who views it otherwise, a 20 major feature of that is the calculation program.

A very i

21 i

large piece of it is the calculation program, an area that 22 engineering assurance has already had extensive involvement, i

23 j

And I think I know, and again you obviously can l

24 second guess me, but we have focussed on a-lot of the areas.

25 There is an awful lot of programs that we have put in place l

l t

ACE FEDERAL REPORTERS, INC.

202 347-3700 Nationwide Coserage 8(KL3364M6

[

.31237.0 16 TAY

[

i.

n 1j to fix the problems.

Now, it doesn't mean to say that 2h there isn't any more out there.

He will look at that.

l 3,

Again, we are not going to take for granted wha,t 4

we have done.

I personally have taken personal interest 5

since I have come to TVA to see if this indeed was a soft 6

point.

He didn't wait until the NRC told me to do i

7 something about it.

0 So I personally have a vision where I want TVA 9

to go, and I am equally concerned if U.ete.is problems out I

10; there.

But I think it is unfair -- I think an outside 11 group would miss some of this chemistry that has been 12 developed, even the chemistry, I might add, between the NRC 13, and the EA people, the technical reviewers who are involved i

14, in this process, which is over a year I might add at this

[

15{

point.

16 Ue will prepare detailed checklists that can be i

17; scrutinized by the Staff.

Those checklists will leave no

.i 1

la; stones unturned, I assure you, and they will look at all i

19 !

the 11 major areas of what an integrated design inspection 20 l

looks at and what an IDVP normally looks at.

He will 21 identify major problems if there is any out there, and I'm i

22 not going to tell you there isn't.

He will find out.

And 23 we have defined what those are.

There are some major areas l

that we will be focusing on:

program breakdown, system l

24 l

25 l

. operability, tech spec compliance, FSAR noncompliance, i

l l

/\\CE-FEDERAL REPORTERS, INC, 202 347 3700 Nationwide Coverage 800-336-6646

j

?1237.0 17 TAY i

i Il restart items which may have been overlooked, something i

2[

that hasn't been identified as such.

i 3

Again, we welcome NRC oversight of those 4

activities.

5 The independent verification review, as 6,

Mr. White indicated, will be conducted by the engineering 7

assurance group.

It is a group that has the chartered l'

8 f independence.

I report to Nick Kazanas on quality 9

assurance matters, and if you look at the EA oversight j

10; activities that were performed, those were done under Nick 11 Kazanas' auspices.

He had his hands in that.

Nick wasn't 12 [

there for the whole duration, but he's had his hands on it, 13,

and his predecessor had his hands in that before him.

14 [

The credentials of the people that we put in i

15 place to try to find these problems, I can't say enough.

16 '

Your staff has looked at the resumes of these people.

They 17 L have comepared them.

They have challenged them, and in 18 some cases we have added people to the team to strengthen 19 the review process.

I personally have added to the team.

I 20

}

We didn't start out with X number.

That's the way the i

21 l

program has taken place.

22 We have already staffs, between Browns Ferry and i

i l

Sequoyah, of some 34 people that are available.

The Browns l

23 24 Ferry people is a total contract effort right now.

With I

25 l

the exception of one person that I use as contract l

l ACE-FEDERAL REPORTERS, INC.

i 202 347 3700 Nationwide CoseraFe MG336-646

y l

l 31237.0 r

18 TAY

[

tt 1L management, that staff is a total Stone 6 Webster staff 2

that I brought in.

It is headed up by Dave Kehoe, un 3

ex-NRC individual, who some of you may be familiar with.

4 He's very strong.

He worked with me when I was with Stone 5

& Webster.

He 's very knowledgeable ; he knows how I think h

6' and he knows how to find problems if they are there.

That 7

was our job.

8[

Ue have put together some key individuals.

My 9

plan is to take these 34 resourcers and to keep a group of 10l people that are familiar with what we did at Sequoyah.

I 11' don't want to lose that.

I think it is a key to finding-12!

those additional problems, if you would, in my opinion, and 13 bring in a number of these other people.

And I have put 14 together a proposed team here which shows you the breakdown 1

i h

15l of who the people are.

I 16 '

There's 20 people that I'm proposing, and if you 17' look at the right-hand column, you will see the i

18 organization that they represent, and where you see TVA, 19 I'm trying to keep a strong link to the work that we have 20 been doing and not have a totally foreign team come in.

I l

21 think it will give us a much better springboard, and be in 22 compliance with your letter giving us the assurance that i

indeed a lot of work doesn't have to be redone.

I think it I

23 i

24 l

is in that spirit that this was put together.

i 25 If you flip to near the back of the material, I

l l

l

/\\CEJFEDERAL REPORTERS,' INC.

202-347 3700 Nationwide Coverage 800-336-6646

..o p

j 31237.0 t

19 l

TAY L

F j

1 I've put together what I view as the review activities that 2 !!

we will conduct.

We will do planning and preparation, and 3

I have gone through there.

This is nothing knew to me.

I l

i 4

know how to gc about it.

I know what we've got to do for i

5 logistics, the material that we need to review, I know the 61 checklists that have to be prepared.

I've done them many,

)

7 many times over.

There will be a performing period and a 9

1 8'

reporting period, and again, depending on what the NRC 9

wishes, I feel that the NRC is an observer on the team and i

)

10j I think they will see first-hand what we are doing, and

)

11 preferentially I would prefer that, and if there are some 12 concerns that they think we are going the wrong way, we 13 will make adjustments.

f 14 Finally, I would like to add that personally I i

15' have managed a number of these vertical reviews, and not 16 only the ones that the NRC accepted as alternatives to an 17 NDI, but many, many others.

I've done them personally.

I l-18 i know what to look for.

If there are some skeletons, I'll 1

19 find them, believe me, and I really believe I'll have a 20 higher likelihood to find them.

I will be at TVA 21 permanently.

I'm not an outsider anymore.

So I have a 22 vested interest in seeing things are done right.

23 So that's all I have to say.

24 MR. WHITE:

I just hope that.the independence of i

l 25 the team has made an impression on you.

I hope, also, that i

i i

ACE. FEDERAL REPORTERS, INC.

202 3n.3700 Nationwide Coverage 8(0-336 6646 l

~

]

a S1237.0 20 TAY i

'l you as observers will watch what the EA does.

I think the 2[

track record has been good.

You know, this is something 3

new to TVA.

We have just established it.

The track record I

4 has been good.

I think that, coupled with observers from 5

NRC, should give you any assurance you want of the absolute 6 l independence of what we are doing.

\\

7 i

MR. KEPPLER:

The fact is, though, that TVA 8

would be undertaking a program this way that they did not 9"

feel that was necessary to begin with in the first place, i

10 [

and I think that that doesn't give me a very warm f eeling i

11 [

then, saying that I'm getting the kind of effort -- my j

L 12 comment is not intended to individuals.

I have a high 13 regard for Mr. Capozzi.

I think he's done a very strong 14}

job for TVA.

But in effect, I'm asking you to do something 15 [

you don't totally agree with, and by them taking that job t

16' on internally as something, "well, he requires it, I'll get 17 it done," I don' t think.is going to provide us with the 18 i sense of comfort that I believe I'm looking for.

P 19 I I told you, Admiral, when I asked you to do this i

20 program, that I really, genuinely believe that this is the 21 i

quickest way to get this plant back on the line.

I believe 22 it today, that we will have the necessary assurances to go 23 i

before the Commission and presumably before our oversight 24 committees and say, hey, we didn't leave any stone unturned.

l i

25 Right now I feel, despite the overwhelming i

1 l

l 1

i

' /\\CE. FEDERAL REPORTERS, INC.

20>3G3700 Nationwide CoseraFe 804 334 6646

l i

1 J1237.0-h 21 TAY r

1I effort that has been done down there, there is

)

I 2

i opportunities for missed things that I think would show up 3

with a vertical slice, no matter who does it, and I guess 1

1 4

I'm trying to put some sense of strong feeling that i

S !:

everybody will understand that, hey, this was looked at F

I 6

with a genuine attempt to dig in and make sure we haven't 7

left any stone unturned, and, you know, I would not attempt 8f to disagree with the program, but I say to myself, gee, is I

9 their heart really in it to go in and do this thing the way 1

10 I want it done.

11 MR. WHITE:

May I respond to that.

l 12 L First, with reference to undertaking a program 1

13 that you didn't feel was necessary, I would guess that most 14 I of the utilities who have done the engineering assurance F

15 vertical slice have probably not looked at it with L

16, enthusiasm, and yet the NRC has allowed engineering

{

l 17,

assurance as one of the three authorized methods of i

18' assuring independence.

19 MR. KEPPLER:

They have and they haven't.

The 20 i

NRC historically required either an IDI, or an IDVP, and 21 the engineering assurance review came out of -- because the 22 Staff ran into a confrontation over doing one of these IDVPs, 23 and the Staff was also being beat around the head about l

i 24 that, and so they sort of condescended to agree to the EA 25 approach, which is not the total. preference of the way the I

i j

/\\CE. FEDERAL REPORTERS, INC.

i 202 347 3700 Nationwide Coverage 8(Kb336-6646

22 3i237.0 TAY l

i 1b Staff would have gone at it.

You are right in saying that 2

we have allowed them, but I think that we do not as an l-3, agency look upon the EA approach with the same degree of I

4 comfort that we do with an IDVP or an IDI.

1 5

MR. WHITE:

Yes, sir.

I would say that you not l

6 only have allowed them in the past, you are allowing them j

r 7

right now.

I believe right now, isn't there one going on 8'

at Commanche?

c 9

MR. KEPPLER:

I haven't got my car in yet.

J 6

10 MR. UHITE:

Hell, maybe so, but I guess the NRC 11 is allowing it.

The second part to your question is -- I 12 take it, frankly, on a very personal basis, that'if this is i

13 '

decided to be done, that I would take the attitude that, i

14 l well, I would kind of get it done.

That is not my approach.

i h

15 That has not been my approach since the first day at TVA.

16!

I'm not a TVA employee.

I'm not a TVA employee, and I have 17 L the public health and safety in mind at every step of the 18 I way I've gone, and I haven't stopped, and it will be done 19 like everything else since I've been there, and that is 100 20 percent.

It will get my 100 percent backing.

I 21 So I try not to take it personally, but that, in 22 effect, is what it is, because this group would be 23 i

reporting directly to me.

Lord knows, if I can't assure j

24 that they do a complete and thorough job with Capozzi in 25 charge, reporting directly to me, and with the NRC as part l

l l

ACEJFEDERAL REPORTERS, lNC.

202 347-37(X)

Nationwide Coverage 80(L336W46

_J

p 31237.0 23 TA Y -

i 1

of the team observing it, I simply don't know where we can p

2 get any further assurance at independence, and although we 3

may have a disagreement on what it takes to do the other i

4 types of vertical slices, there isn't any question in ny i

5' mind that we have very profound impact on the startup of h

6li Sequoyah unless we are allowed to use -- in your words, to 7

look at the things we have done and to be able to use those 8

things and to allow the people who are up to speed on the 9

system and the program we are using.

If we can't do that, 10 I think it will have a terrible impact.

I have to call it 11 the way I see it.

12 MR. KEPPLER:

Have you gotten any estimates from 13 contractors as to what it would take to do the effort at 14 "

TVA that I asked for?

15 I MR. WHITE:

I have not done that, for the simple 16 reason I'm afraid to go to a contractor and ask him, 17 h because then if that contractor were to be selected.it i.

18 would be questionable whether it was an above board 19 decision.

So, no, I have not gone to specific contractors 20 to ask how long it would take.

I have gone to contractors i

21 l

and utilities to find out how long it has taken in the past, 22 recognizing, again, there is unique, that no one has done 23 this before.

Frankly, I look at even the time periods that 24 has been done at other utilities as being, very frankly, 25 very optimistic.

What troubles me in this is we will be i

I ACE-FEDERAL REPORTERS, INC.

i

. 202 347-3700 Nationwide Coserage 800-33MM6

3i237.0 f

24 TAY

[

1-1l looking at people who will be using today's standard that 2l wasn't licensed last month, but one that is licensed years 3

ago.

I I

4 i

MR. EBNETER:

The attempt is to compare it with 5'

original design basis.

You will not be using today's l

standards.

6 7

MR. WHITE:

No, sir.

I understand that will be 8

the intent.

I kind of question whether it would really j

r 9'

work out that way.

Nevertheless, I'm not trying to look at L

100 the contractor thing as other than, there is a method that 11 ;

is equally independent, that will work as well, 12[

particularly with your NRC oversight.

I have no question v

13l that with the hard-nosed attitude that your team have had 1

1 14 with us -- and I welcome that, that doesn't trouble me --

L 3

i 15l out with the hard-nosed attitude they have had with members I

16' of this group, there isn't any question they would blow the 17 i whistle immediately if they felt something was off track.

18 j.

There isn't any question.

But I don't intend to let 1

19' anything get off track.

So I look at it more as an 20 independent effort, with a minimal impact on the startup of 21 Sequoyah.

Wr. think we can satisfy what you want in your 22 letter.

Just let us get on with it.

i.

MR. KEPPLER:

What is your estimate of the time 23 24 that it would take?

25 MR. WHITE:

If you will pick a system today, I i

ACE. FEDERAL REPORTERS, INC.

202-347-3700 Nationwide Coserage 800 336-6M6 1

ll J1237.0 25 TAY l

l 1[

can come back to you with an estimate.

I can't until you 2

pick a system.

3 i

MR. KEPPLER:

Give me a ballpark.

I 4

MR. WHITE:

My guess is it will not impact --

5 perhaps it will impact it one month.

l h

1 6f MR. KEPPLER:

My guess is if you went out and j

i 7

got an outside contractor, it wouldn't impact any worse j

F 8h than that.

I.would like to know what is your measure of 9

time.

.1 10 '

MR. WHITE:

My measure of time for the outside J

11 contractor is April of next year.

So me, if I've got to --

12,

you've got to balance both'of my estimates.

J 13 I MR. KEPPLER:

Yeah, but I guess -- let me try ll 14 L again.

What is the duration of time that you expect this L

15 to take, forgetting what your schedule is?

16 MR. UHITE:

I can give you parts of it.

i 17 l Capozzi, correct me if I'm wrong.

It will take 1

i 18 '

two weeks to get all the papers, everything in order, and 19 then there is a period of time, depending on the system i

20 l

they pick, that would range from, what, two, four, five 21 months, what, depending on the system?

22 MR. CAPOZ Z I :

Right.- To go down the elements of i

t 23 doing it, the big savings up front, big, big savings, l

24 because they are knowledge based.

25 MR. WHITE:

You mean the two weeks versus two i

i i

l 14CE. FEDERAL REPORTERS, INC.

' 202-347 3700 Nationwide Coserage 800-336-6646

.~

y 23237.0 2C TAY

^

1; months?

2 j' MR. CAPOZ Z I :

Two weeks versus two months.

[

3 There is no question in my mind.

That is subjective.

I I

I 4

know what it would mean to me if you threw me out of the 5

plant on the west coast, for me to come up on a knowledge i

6 base and then find problems if they are there.

If anybody i

7 says otherwise, they are dreaming.

8 MR. KAZANAS:

For it to take advantage of the 9i plans that have been put in place.

10 [

MR. WHITE:

How much did you allow for the 11 report?

i 12; MR. CAPOZ 21 :

The report at the end is going to L

i 13 L take about four weeks.

14 MR. WHITE:

So there were six weeks for these.

p 15lj I've tried to grill him on this, and I just r

16 I tried again publicly, and he won't give me a commitment, 17 h nor should he.

He's the engineering assurance guy.

He a

L 18 shouldn't give me a commitment.

is!

MR. KEPPLER:

I know your people were on the i

f 20 phone with Commonwealth Edison, because I was, too.

21 MR. UHITE:

And a lot of others, too.

22 MR. KEPPLER:

What Cordell Reid told me is that c

23 ji Bechtel came in to Byron and did three systems.

They did

[

l 0

i R

24 I

the diesel generators, they did the RHR system, and the aux 25 i

feed system in 4-1/2 months from walk on the site to I

4 I

l

/\\CE. FEDERAL REPORTERS, INC.

202-347 3700 Nationwide Coverage 800 336W46

v.,

l.

i 4 V12 3 7. 0 27 I'

TA Y 1

receipt of the system.

2 That doesn't sound inconsistent 3

MR. WHITE:

Let me just address Byron.

It is a I

I 4

little different.

I'll let all the other peop2 e speak to I

5

,the details.

6(

There was a large effort that took about a year h

7 4 e nc: a half, or maybe longer, at Byron.

They have done a 8

considerable amount of work and then labeled part of this --

9 as I understand, went in and said we will call this part 10 (

the vertical slice, and this part may have' been 4-1/2, 11 6-1/2, seven months.

The actual work was 4-1/2, but the 12.

1 cad up to -- in all these estimates -- Mr. Keppler, unless 13!

the question is asked, is that the all-inclusive time, what I

i 14 '

you get is an estimate from the time the guy starts working 15 until he finishes.

But again, I suggest we get a little i

16 i cit off the subject.

I think what we are suggesting is 17 independent.

18 MR. KEPPLER:

I think it is important., though, l.

19 that we understand what we are dealing with, because to me, 20 well, you can use the words independent for different 21 things.

I would feel not a greater degree of independence 22 of what I'm talking about than what you are talking about.

i l

23 I have to balance that against the impact from the schedule.

l 24 Obviously, if I'm going to impact several months on your 25 schedule, then I will weigh the varying degrees'of I

i i

I ACE-FEDERAL REPORTERS, INC.

200 347-3W C Nationwide Coserare 8(6 334 6646

y b

l:3*1237.0 l'

28 lTAY

.1 independence.

But'what.I'specifica11y' asked -- and I see a 2

l.

gentleman sitting right behind you who I'think could shed

~ 3 some light on the subject,'ifLhe's willing to talk up'up 4

here.

Do you remember the-IDVP at Byron?

i

-MR.'EISCNHUT:

The question.that is a little

.5 6.

. foggy is that - Lyou; remember,a. couple of^ things.. There

)

. as a program under,way.

The. program.was:under way for 7

i w

8 )

some period of.timeE-- th'ere was a program under way j

9[

actually prior to the board's' decision, andfit is not clear r

10p to me to the extent-that program was built on, that. led to 11 [

a supplemental program aftorwards, p

12 [r The actual program, if'I look at' dates, the 13 f start of the.IDVP was April of.'84 on. Byron.

The' final 14 sign-of f approval was like December of ' 8 4. -

l 15 We' haven't gone back and looked at-the fine 16, structure of it as to.what'was done, how1far along itLwas

'i 3

n 1

done, and so1forth.

So, Jim,.I'm certainly' familiar with l

17(l L

18 it.

-I don't know the details'of the specific schedule.

1

.19.

Byron, as you remember,'was.a: pretty contortedLease, also, l

i; 1

20 because there was an ASLB finvolvement somewhere down the j-j 21 l-line.

I don'tithink'we' issued ancactualLletter,to Byron 22 l

. telling them to.:do it.

I don't - know what the date cf; that

.i 23 i

was.

q 24 MR. WHITE:

Mr.'Keppler', even though'there may;

]

25 be aidifference as to when.these' things' start and stop, it 1

L

-l i

I

)\\CE FEDER'AL REPORTERS, INC.

202-347 3700 Nationwide CoveraFe.

800 336-6646 l

I l

ll.

I t

1

,31237o0 29 TAY

[

{

I i

z 1[

is clear in my mind, and I hope there is no question in i

2i your mind, that the preferable method is to try to select

{

s 3 l' one that gives you everything you want with a minimal l

i 4

~

impact on the schedule, and I honestly and truly believe i

~

5 this:

Your people are hard-nosed enough, that they are g

f 6 !!

observina what is going on, and I just can't contemplate h

j 4

c 7[

the whistle not being blown immediately if there is a 8

problem.

9 Now, you know, I would hope that it isn't,

(

10 because I can hold Capozzi's feet to the fire to be sure it i

11 is independent.

12 MR. CA PO2 21:

If I look at what we are doing, wo 13 have gone much beyond really the state of the art of what i

14 is being done.

Cost reference systems are second to none, 15 [

which is really going to give us the quality that one would 16 really ever want.

We are doing a lot of things, and they 17 i should be done.

Don't get me wrong.

They should be done.

18 MR. EISENHUT:

Let me make another comment.

I i

19 haven't gone back and looked at any schedules, because I i

20 j

can count the number of hours that I have actually looked I

21 l

at this thing.

I think the concern, and Steve can 22 interrupt me --

23.'

MR. WHITE:

I will, don't worry.

l 24 l

MR. EISENHUT:

We haven't had a chance to

[

l 25 f

discuss this.

If you look at the IDVPs that have been done, i

ACE-FEDERAL REPORTERS, INC.

202 347-3700 Nationwide Coserage 800-336-6646

31237.0 30 TAY 1

the one that was done on Diablo Canyon, as I remember, it I

2 was initiated in November of 1981, and the final signoff, 3

or the final piece was in late 1984.

That clearly is the 1

4 biggest classic case I can think of, and I would argue that 1

I 5

is extremely unique.

6j On the other hand, it has varied, anything from

)

7 that duration down to the shortest I can remember is 8

probably in the order of six months.

I don't know that 9

that goes from initiation to bringing someone up to speed, 10 h doing the job, and a sign-off report.

I also think it 11 probably would vary tremendously upon a number of the 12i assumptions that goes into it, on how it is conducted, the 131 6epth it is conducted.

You know probably better than I do, 14 [

the other classic case was Commanche Peak, which was 15 initiated in 1984.

I c1carly failed and couldn't pump it 16 l off, but the program is still going on.

17!

Whether there is some form of an IDVP I don't l

I 18 know.

I think the question really is, what is it that 19 $

needs to be done to provide additional assurance?

What is I

20 the bounds of that program so that it can be defir.ed?

I l

21 think that is what you should be hearing.

Not a message of i

22 a lot of other things.

Trying to bound what the program l

1 23 really is and how long it might take.

That.is based on a.

24 total of-about four hours of study.

l 25 1

MR. KEPPLER:

But clearly, Darrell, just to i

l ACE-FEDERAL REPORTERS, INC.

' 202-347 3700 Nationwide Coserage 800-336-6646

i p.

t d1237.0 31 TAY i

1 respond to you, clearly I think you would agree that if an IDVP by a contractor that has been been a part of what is 2

3 going on there right now, could do the job in the same time 4

frame as this engineering assurance approach that has been 5

involved, and -- let me exaggerate for effect -- really 6

doesn't believe that any more is needed right now, I would i

7 buy a greater degree of confidence for the other group.

8j MR. EISENHUT:

Certainly from your prospective --

9 this is a hypothetical situation.

10 MR. WHITE:

I don't agree that that is necessarily so, for the reason that Mr. Capozzi stated i

11 12 earlier.

13 Go ahead.

14,

f1R. KEPPLER:

One of these days I'll teach you i

15 how to think like a regulator.

16 MR. EISENHUT:

From a regulator's standpoint you 17 can probably say it is certainly cleaner.

By " cleaner" it i

18 would mean you can sit back and say, look, there is no

)

19 question about it, postulating, if you have someone come in i

20 l

at the same time, it would be cleaner in one sense, and it 21 l

may be less capable in another sense.

You may have someone

)

22 coming in, coming up to speed, who certainly doesn't know 23 as much about the idiosyncracles and details of the EDPA i

i l

specific situation, that you may have a more superficial 24 I

25 l

program.

.So there are two things you have to weigh on that.

l l

l ACEJFEDERAL REPORTERS, lNC.

l 202 347-3700 Nationwide CoveraFe 800-336-(M6 j

1

p i

31237.0 32 TAY

[

i 1

.You actually might have a better program if you have 2h someone that you have confidence in from an independent I

3 standpoint, " independent," that you had confidence in and 4

could do a good technical job, that person might be able to 5

l come in and do a more meaningful job in better depth and i

6 l might be able to find the problems more quickly and zero in l

7 on a lot of the problems, as opposed to bringing in an 8

organization that has not been involved in TVA whatsoever, F

9p you know, for the last several years, to walk in today and U

10h

say, I'll do an IDVP, et cetera.

You might actually get i

11 [

1ess out of that.

Those are the things you have to weigh.

I 12 g It is all predicated on the hypothetical they are both in l'

13 the same time frame, the same resources.

I don't know 14 whether that helps.

Those are the kinds of things we have 15 to weigh.

16 MR. KEPPLER:

What kind of systems do they 17 [

provide in dealing with the outside contractors when an j

i 18 outside contractor is brought in?

19 MR. WHITE:

Well, in~ essence, in terms of what j

20 l Mr. Capozzi just said, this is one of those.

So I guess I 21 would say that's what it is in that case.

Bringing in one i

22 of the others, you know, I would really have to go look at i

23 it to see if they have any knowledge.

In fact, they are 24 just arriving now.

Aren't they.just arriving now?

So 25 other than the one which happens to be the Browns Ferry one, l

i l

ACE. FEDERAL REPORTERS, INC.

02 347-3700 Nationwide Coverag 8(G336-6M6 l

1 31237.01 i

33 TA Y '

l 1

where they are. familiar with it, but the others are not, 2

they are just starting to build up.

So again, they are i

3.

i strangers coming into it.

4-MR. KEPPLER:

Okay.

I would like to take a 5

brake and meet with my' Staff.

1 6 l Before I do that, though, I would like to hear i

l'

.i 7

where you stand on the' issue of calculations, the civil

'8 counts, Land what.is your attempt to deal lwith that.

9 MR. FOX:

As'you are. aware, and we_ identified 10 p previously,-there are approximately-5000 civil:. calculations 11 associated with Sequoyah.

Those calculations were done by 12 L two contractors, primarily-by EDS. Nuclear and Basic b

d 13 F Enginoering.

Those calculations were done-under~a bona' j

14 fide OA program.

He have gone through'and. identified a i

1 15' thousand of those calculations which meet the. definition'of h

1 16

" essential."

By " essential" that means.that there could'be i

17 L some sacrifice of the system integrity, there-could.be a

l 18 [

compromise in the shutdown-of.the plant, or the radioactive 19 releases as a result of those would, in fact,~ exceed'-10 CFR 20 l 100.

Anything that fits that definition'we'have committed --

t 21

. as early as. December 15th of this cpast year, -I' made. a L q

22 l

personal commitment-before:the NRC when-:-I brought our.

1 23 calculational program first, if~it met the'definitionLof' 24 essential, we would regenerate that.. Admiral White has -

25 reiterated that on numerous' occasions.-

1 3'

ACE-FEDERAL REPORTERS, INC.

I 202 347 3700

- Nationwide Coverage 800 336 6646 :

U

,31237.0 34 TAY h

L L

1[

So we will be doing approximately 1000 of those 2

5000 that fit that category of essential prior to restart.

3 That is our commitment.

Anything that is an essential 4

calculation will be done prerestart.

He will regenerate 5

all of the calculations, every one of them.

6 MR. KEPPLER:

Why shouldn't I expect them all 7

before startup?

8 MR. FOX:

We f'el like the ones that should be e

r 9[

done prior to restart are the ones that would be associated 10 with safe shutdown or accident mitigation of the plant.

c 11i; Those that we determine as being essential we feel like we L

12' should do prerestart.

We feel like we should do all of l

13 them eventually, and we will give you a schedule as to all 14 of them just as soon as we can get them.

15 i

MR. KIRKEBO:

In addition to generating the t

16 thousand, if we find any root causes or generic problems or i

17 programmatic issues within the process, we will run that 18,i totally horizontally into the ground, so we are doing 1000 l

19 of the 5000, we are writing CAQs where CAQs need to be l

l 1

20 written, and we are running those root causes for technical I

i l

21 adequacy across the board to the entire scope of-the 5000, i

22 in fact, to the entire scope of all calculations.

e 23 MR. KEPPLER:

Aren't these. piping and pipe 24 supports?

25 MR. KIRKCBO:

These calculations that we are I

ACE-FEDERAL REPORTERS, INC, 202-347-3700 Nationwide Coverage 800 336-6M6

1 j

l'

'i

~*

6

.31237.0 35

,TA Y -

1 referring to are large bore pipe supports.

l 2l MR. KEPPLER:

The 50007 i

'3 MR. KIRKEBO:

Yes, sir.

In other words, we l

24 l

receive from'the contractor the_ drawings for the pipe i

4 j

5 l

supports.

He kept-in his files calculations,. or he had i-r 1

6 i

calculations internal.

Those calculations were never li - transf erred to the; TVA of ficial quality assurance records j

7 l

8 l

and maintained. :So we did receive from the supplier the E

1 9

drawings.' So.he gave us the drawings.

He'was also j

~!

10 responsible for that scope of-supply.-

But the calculations, 11 jl-due to OA records' breakdown - -

8 i.

12 h MR. WHITE:.

Let's. face it, they screwed up.

I i

13,

believe they told the company to destroy;them.. They didn't i

h 14 L need them.

E I

15 g MR. KEPPLER:

I don't have any appreciationlof.

j i-4 16 [

why I wouldn't want them all before restart'.

I l

17 Piping and pipe support' systems, large-bore pipe.

l 18 MR. KIRKEBO:

Sir, there is no question about 1

19 the piping systems and.the pipe stress analysis that l

1 l-20

~

determine compliance with our FSAR. commitments, we have:the i

21 pipe stress analysis.

We can demonstrate the adequacy of-l 22 the piping systems to withstand ~ seismic' events or other-23 j

design basis' events.

So what we are referringL to here is 1

24 the calculations for stresses and strains inlindividual 25 pipe supports, the members of the pipe supports'for large ACE-FEDERAL REPORTERS,' INC.

t 202 347 3700 Nationwide Coserage

' 800-336-6646

p i-

,31237.0 l-36 TAY i.

i l-1l bore piping.

So we have the stress analysis.

2 MR. KEPPLER:

Would you let a flue plant start 3

up with that kind of missing calculations?

\\

t 4

MR. KIRKEBO:

Only after I reviewed and could i

5y convince myself or be convinced that there was no question

)

6 as to the technical adequacy of those pipe supports.

In i

7-other words, the onus is on us.

He feel the obligation to I

i 8"

be able to demonstrate technical adequacy for all the pipe 9'

supports.

There are a number of ways that we believe it is l

10 h possible to do, and what Charlie Fox just outlined we k

i 11:

believe will demonstrate technical adequacy for the pipe i

i l

12 supports without adding 100 percent of those qualifications.

13 MR. KEPPLER:

What will it take to get all 5000 14.

of those?

15 MR. WHITE:

Mr. Keppler, I think we can go 16 I through today the general program, but I really think it 17 needs to be gotten into much more technical detail than 18 frankly we were prepared to do today.

j i

19 You know, we can walk through the --

)

1 i

20 MR. KEPPLER:

I would suggest we do that, then.

I

)

i 21 MR. WHITE:

Okay.

We will do that.

{

I 22 MR. KEPPLER:

I get accused of holding the plant i

23 up all the time, and it wears a little thin.

i 1

24 l MR. WHITE:

I hope you don't feel I've accused i

25 you of that to date.

i l

/\\CE. FEDERAL REPORTERS, lNC.

202 347-3700 Nationwide Coserage 800-336W46

31237.0 37 TAY i

1 MR. KEPPLER:

I think that 5000 missing 2

calculations not done, I think is an issue that needs to be 3

l dealt with promptly.

I' 4

MR. CA POZ Z I:

Mr. Keppler, one other thought.

I 5

was concerned about those missing calculations when I first 6

i came.

The point was they did exist.

I want to point that 7-out.

That doesn't mean that we don't need them.

We do ll 8h need to get them.

That is a point often missed by people.

9 They did exist.

10 l MR. WHITE:

We will certainly be prepared in 11 less than a week to meet with you on a technical basis to 12!

go through the program to your satisfaction.

l 13 '

MR. KEPPLER:

How would you react, before I go 14 to caucus with my staff, but what would be your reaction if 15 I said that, if you didn't bring in an independent 16 organization, that I might choose to have the Staff do the 17, IDI instead of having your EDA organization do it?

18..

What would be your reaction to that?

1 19 MR. WHITE:

Well, I would assume by the Staff, l

20 you mean the Staff or contractor?

21 l

MR. KEPPLER:

We would have to bring in a 22 contractor.

23 l

MR. WHITE:

If you have to bring in a contractor -,

1 24 perhaps it would be the same as if we got a contractor.

In fact, it might take you longer.

I really think what we 25 i

l i

l l

l I

l

/LCE. FEDERAL REPORTERS, INC.

I 202-347 3700 Nationwide Coverage MKL 336-6M6.

F 34237.0 30 TAY

-1 have presented is independent.

2 MR. KEPPLER:

Ue are of the view that to do such 3'

an effort, it would probably take 3-1/2 months.

4 Okay.

5 MR. UHITE:

Let me reemphasize one final time:

j 6h We not only desire, we welcome the NRC to become part of f

7[

this thing in terms of monitoring what we are doing and j

8 watch us every step of the way.

9 MR. KEPPLER:

Let me suggest:

It is quarter 10i; af ter 2: 00, or almost quarter after 2:00.

We meet back o

11 !

here at quarter after 3:00.

l' 12; (Recess.)

)

t 1

{

13 MR. ZUCLINSKY:

Before we get started for the q

14 remainder of the meeting, I need people to identify 15 themselves on the attendance list.

If you haven't, I'll 16 pass it back.

17 '

Thank you.

N 18 [

MR. KEPPLER:

Admiral, I talked to my staff j

19 during the last hour, and we decided that we either want an 20 independent design inspection by the Staff, or an i

21 j

independent design verification inspection conducted under 22 the sponsorship of the utility.

23 If you prefer not to go that way, we will get i

24 started with the IDI, get my staff and the contractor to do 25 it right away.

i ACE FEDERAL REPORTERS, INC.

202-347 3700 Nationwide Coserap 800-33(rfM6

h 31237.0 i

39

'TAY l

i 1[

The system that we choose is the emergency raw l

2 cooling system.

It is our view that this program can be 3

carried out independent of nonnuclear heatup, so that TVA

.l 4

would be allowed to do nonnuclear heatup with the plant in j

l 5

parallel with this effort.

6 If TVA brings in a contractor to do this, then 7

l we would want a -- well, we would want to agree to the 8

contractor.

We would want a protocol that basically 9'

consists of the following:

NRC would want receipt of all j

10 communications between the IDI project and TVA concurrent 3

11 with transmittal to TVA.

All major findings would be i

12l reported to NRC upon discovery.

These would t>e significant 13 design deficiencies, reportable items, Part 21 issues, LERs,

\\

14 "

et cetera; and we would want to be allowed to participate i

15, in briefings that you have with the IDI project.

That l

16 would be the extent of the type of protocol we are talking 17 {

about.

18 Uhen we talk about, if you bring in an outside 1

19 contractor for this, we would be talking about independence 20 i

in the vein of'somebody who was not involved in the reviews 21 i

that have been under way during the past many months, and i

22 certainly somebody who was not involved in the original

)

23 i

design and installation effort.

[

24 I also think that, to the extent practical, all l

25 of the civil calculations should be done prior to restart.

i ACE-FEDERAL REPORTERS, INC.

i 202-347-3700 Nationwide CoveraFe 800-336-6646

i n

I 71237.0 L

40 j

TAY i

1 I I don't expect you to answer me at this meeting.

2h I've laid everything out to you the best I can.

If you L

3' want to meet with your people and tell us how you wish to -

l 4

proceed, whether you bring in the contractor or whether we I

5[

proceed with the work, I'll wait to. hear from you on that.

6I MR. WHITE:

Well, I understand, of course, what 7

you have said.

We continue to believe that bringing in a 8L contractor very, very probably will' impact on the schedule 9

of Sequoyah.

And certainly you are correct, I'm not in a 10,.

position to agree with either of the alternatives, frankly, 11 because of the impact not only on Sequoyah, but TVA's 12 nuclear program and TVA itself.

Obviously this has budget 13i implications, and therefore rate implications, and I will r

14' have to take it before the board of directors to have a h

15 [

decision.

L It is not a decision I can make.

16 [

17' MR. KEPPLER:

As you know, I chose to bring this 18 [

issue up at this time because I saw it heading in the L

19 direction of having an impact on the schedule.

I want to q

i 20 l

minimize that impact on the schedule.

And quite frankly we 21 i

believe we can do the job within the schedule constraints i

22 i

ourselves.

But the most important thing, though, is not l

-i 23 l

the schedule to me.

The important thing is that I be-able 24 l

to stand up in front of our commissioners and convince them I

I 25 that I think this plant is ready for restart, and in my l

/\\CE. FEDERAL REPORTERS, lNC.

202-347 3700 Nationwide Coverage.

800-336-6M6

[

+

31237.0 41 TAY i

1l View I need this program to complete that effort.

1 2 ii So, I'll wait and hear from you, then, on this.

3 MR. WHITE:

I certainly will go back to the I'

4 board with the information, but I have to say that we do 5

not believe that bringing in a contractor will result in h

6[

anything but significant delay at Sequoyah.

From that I;

7[

point of view, if'you you desire an IDI, you think you can h

8 do it and not impact on the schedule, then that is your 9

decision.

10 MR. KEPPLER:

That comment assumes the ability 11 to do this thing in parallel with heatup?

12 MR. UHITE:

Well, we had from prior discussions 13 already assumed that that would be true, that that 14 /

encompasses a one-month period, and frankly I had already i

15' assumed that would be true.

16 MR. KEPPLER:

Can I just assume that we are 17 going to do this inspection?

i.

18 MR. WHITE:

Yes.

19 MR. KEPPLER:

Okay.

20 l

One other thing I would like to reiterate, and j

21 if there is some confusion, I share in that confusion.

I 22 would like to reiterate the desire to get an answer for 1

23 Commissioner Asselstine's question.

24 I

MR. WHITE:

We will have it to you tomorrow.

25 Let me add, if you decide to do the IDI, I still l

/\\CE-FEDERAL REPORTERS, INC.

202 347 3700 Nationwide Coverage 800-336-6M6

r 7

1 l

,}1237.0 42 i

TAY i

1 am not in agreement that one is required.

I 1,

2l t1R. KEPPLER:

I understand that.

Okay.

Thank i

3 ',

you.

4l MR. ZUOLINSKY:

Mr. White offered to correct the i

5 ll record on the response to Commissioner Asselstine's i

p 6

questions, in that he will supply a letter to the NRC by L

'l l.

Uednesday.

I.

8' (Whereupon, at 3: 25 p.m., the hearing was 9

concluded.)

10 11 12 13

[

14 15 f 16 l

17 18 19 20 l

21 22 i

23 l

I 24 25 I

I l

ACE-FEDERAL. REPORTERS, INC.

202-347-37(V)

Nationwide Coverage 800 336-6646

m

.j.-

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:

MEETING BETWEEN NRC AND TVA' DOCKET NO.:

PLACE:

BETHESDA, MARYLAND DATE:

MONDAY, JUNE 8,-

1987 were held as herein appears, and that this is the original transcript thereof for the. file of the United States Nuclear Regulatory Commission.

(sigt) 8

[

//L (TYPED)

FRANK-,TAYLOE

~ '

'Offici'1. Reporter a

ACE-FEDERAL REPORTERS,,INC.-

Reporter's Affiliation-

i I

1

(

DISCUSSION OUTLINE l

JUNE 8,

1987 DISCUSSION WITH THE NRC i

1.

NRC REQUEST FOR INDEPENDENT VERIFICATION REVIEW (J.

G.

KEPPLER LETTER DATED June 2, 1987).

j i

INDEPENDENCE VERTICAL REVIEW OF AT LEAST ONE SAFETY SYSTEM FOCUS ON INTERFACES AND INTERACTIONS BUILD ON EXISTING PROGRAMS IDENTIFY ANY MAJOR PROBLEMS 2.

PLAN FOR CONDUCTING INDEPENDENT VERIFICATION REVIEW (IVR)

- SYSTEM SELECTION I

- REVIEW TEAM COMPOSITION o SENIOR ENGINEERS I

o MULTIDISCIPLINE AND DIVISION COVERAGE i

o INDEPENDENT OF PERSONNEL PERFORMING WORK (OFF-PROJECT PERSONNEL)

- BUILDING ON EXISTING PROGRAMS I

- FOCUSING ON INTERFACES AND INTERACTIONS i

- THE USE OF DETAILED ATTRIBUTE CHECKLISTS

- IDENTIFY ANY MAJOR PROBLEMS

- NRC INSPECTIONS DURING REVIEW l

t

PLAN FOR CONDUCTING INDEPENDENT VERIFICATION REVIEW o

PURPOSE - PROVIDES ADDITIONAL ASSURANCE TO NRC THAT:

1.

FSAR COMMITMENTS ARE CORRECTLY INCORPORATED IN THE DESIGN DOCUMENTS:

2.

THE DESIGN DOCUMENTS ARE TECHNICALLY ACCURATE:

3.

DESIGN AND CONSTRUCTION PROCESS ARE WELL INTEGRATED AND COMPREHENSIVE.

4 NO MAJOR PROBLEMS EXISTS SYSTEM SELECTION o

SELECTION CRITERIA 1.

ESSENTIAL-TO PLANT SAFETY 2.

DESIGNED BY TVA 3.

GENERALLY REPRESENTATIVE OF SAFETY-RELATED FEATURES IN OTHER SYSTEMS 4.

DESIGN INVOLVING INTERNAL INTERFACES BETWEEN FUNCTIONAL AREAS AND EXTERNAL INTERFACES WITH THE NSSS VENDOR, COMPONENT VENDORS, AND ENGINEERING SERVICE ORGANIZATIONS i

REVIEW TEAM COMPOSITION j

o SENIOR ENGINEERS EQUAL TO OR GREATER EXPERIENCE THAN PERSONNEL PERFORMING WORK l

o REVIEW TEAM INDEPENDENT OF PERSONNEL PERFORMING WORK (OFF-PROJECT PERSONNEL) o MULTIDISCIPLINE TEAM MECHANICAL ELECTRICAL I&C CIVIL / STRUCTURAL NUCLEAR OA CONSTRUCTION / MODIFICATIONS OPERATIONS PAGE 1 OF 2 1

.s_,

BUILDING ON EXISTING PROGRAMS - FOCUS ON INTERACTIONS AND INTERFACES o.

USE KNOWLEDGE OF EXISTING FROGRAMS AND OTHER INTERFACES o

USE EA AUDITS OF CALCULATIONS AND OTHER AREAS 4

o USE EA OVERSIGHT REVIEW OF DESIGN BASELINE AND VERIFICATION PROGRAM (DB&VP)

USE DETAILED ATTRIBUTE CHECKLISTS TO REVIEW ORIGINAL DESIGN o

REVIEW ATTRIBUTES TO INCLUDE A CHECK OF THE FOLLOWING TOPICS:

)

1.

DESIGN INPUTS AND ASSUMPTIONS l

2.

VALIDITY OF DESIGN SPECIFICATIONS 1

3.

CONFORMANCE TO DESIGN SPECIFICATIONS j

4.

VALIDITY OF ANALYSES 5.

SYSTEM INTERFACE REQUIREMENTS 6.

INADVERTENT SYNERGISTIC EFFECTS OF CHANGE 7.

PROPER COMPONENT CLASSIFICATION 8.

REVISION CONTROL 9.

DOCUMENTATION CONTROL 10.

DESIGN VERIFICATION 11.

AS-BUILT FUNCTIONAL VERIFICATION IDENTIFY ANY MAJOR PROBLEMS

• 1.

PROGRAM BREAKDOWN 2.

SYSTEM OPERABILITY 3.

TECHNICAL SPECIFICATION VIOLATIONS 4.

FSAR NONCOMPLIANCES 5.

RESTART ITEMS NOT IDENTIFIED AND SHOULD HAVE BEEN-NRC INSPECTIONS DURING REVIEW

• MAJOR PROBLEM IS DEFINED AS ANY ITEM WHICH COULD COMPROMISE THE SAFE SHUTDOWN OR ACCIDENT MITIGATION CAPABILITY.

PAGE 2 OF 2

l APPROACH o

SELECT ONE SAFETY SYSTEM IN ACCORDANCE WITH SELECTION CRITERIA

/

UTILIZE DB&VP EA INDEPENDENT OVERSIGHT REVIEW TEAM RESOURCES o

AVAILABLE FROM SQN AND BFN-

]

o REVIEW METHOD TO BE UTILIZED DEVELOP COMPLETE CHECKLISTS EVALUATE ALL ATTRIBUTES USE EXISTING PROGRAMS WHEN COVERED PERFORM FIELD OBSERVATIONS'IF REQUIRED IN OTHER' AREAS FOCUS ON-INTERFACES SCHEDULE INDEPENDENT VERIFICATION REVIEW' ACTIVITIES'AS FOLLOWS:

o PLANNING AND PREPARATION -

2 WEEKS REVIEW

-EXIT MEETING i

REPORT FOLLOW-UP o

NRC SURVEILLANCE

• DURATION WILL'BE HIGHLY DEPENDENT ON PROBLEMS'FOUND AND ACTUAL SCOPE COVERAGE REQUIRED FOR THE SELECTED SYSTEM.

i 1

.l 1

I a

i

j a

1 4

AVAILABLE EA OVERSIGHT RESOURCES f

)

i Seouoyah Organization Name 1.

D. R. Barnaby American Tech 2.

M. P. Berardi SWEC 3.

D. S. Vassalo G/C 4.

P. R. Bevil TVA TVA 5.

D. W. Bogaty T7A 6.

C. Carey 7.

R. J. Floyd TVA 8.

C. H. Gabbard TVA TVA 9.

F. E. Gilbert 10.

J. A. Graziano TVA 11.

J. R. Holloway TVA 12.

X. F. Liao TVA 13.

E. E. McBee TVA 14.

J. W. Semore TVA 15.

R. Tucker TVA 16.

J. W. von Weisenstein TVA Browns Ferry Organization Name 1.

W. E. Bezanson SWEC 2.

A. T. Biviji SWEC 3.

A. W. Budde SWEC 4.

R. Chevel SWEC 5.

E. Hor 1 beck SWEC 6.

R. E. Howley SWEC 7.

V. K. Jain SWEC 8.

D. V. Kehoe SWEC 9.

T. Leba SWEC 10.

K. J. Majmudar SWEC 11.

C. J. Merlo SWEC 12.

C. Mitchell SWEC 13.

G. J. Modi SWEC 14 G. R. Murphy SWEC 15.

A. Y. Ng SWEC 16.

W. E. Stecker SWEC 17.

E. J. Zigmond SWEC 18.

D. P. Burrell TVA Total resources - 34

r a

l Proposed EA Independent Verification Review Team Discipline Organization Name TVA 1.

A. P. Capozzi EA Corporate Sponsor

)

2.

D. V. Kehoe EA Team Leader SWCC SWEC 3.

M. P. Berardi EA f

4.

R. Tucker Mechanical TVA SWEC 5.

A. W. Budde Mechanical SWEC 6.

C. Mitchell Mechanical 7.

J. W. Semore Electrical TVA SWEC 8.

T. Leba Electrical 9.

X. J. Majmudar Electrical SWEC l

l SWEC l

10.

R. Cnevel I&C d

TVA 11.

E. E. McBee I&C 12.

A. T. Biviji Civil / Structural SWEC j

13.

V. K. Jain Civil / Structural SWEC l

14.

G. J. Modi Civil / Structural SWEC SWEC 15.

A. Y. Ng Nuclear 16.

E. J. Zigmond Nuclear SWEC 17.

R. E. Howley Nuclear SWEC O

TVA i

18.

P. R. Bevil Quality Assurance 19.

F. E. Gilbert Construction / Modifications TVA I

a 20.

W.

E. Stecker Operations SWEC 1

I I

l

~

r-.

1 j

h4.'

EA INDEPENDENT VERIFICATION REVIEW ACTIVITIES l

DURATION

-2 WEEKS PLANNING'AND' PREPARATION 1

o ESTABLISH REVIEW TEAM ESTABLISH LOGISTICS FOR PERFORMING-REVIEW (E.G.,

j o

WORK AREAS, PROJECT CONTACTS.. SUPPORT = FACILITIES)

OBTAIN SCOPING DOCUMENTS FROM PROJECT (E.G.,

INPUT FROM OTHER PROGRAM MANAGERS,-DESIGN DOCUMENTS) o

' PREPARE INDEPENDENT VERIFICAT?'M REVIEW PLAN o

-DESCRIBING THE OVERALL PURPOSE,-OBJECTIVES, AND SCOPE OF THE REVIEW o

ISSUE REVIEW SCHEDULE 1

o

. INDOCTRINATE REVIEWERS o

PREPARE DETAILED CHECKLISTS OBTAIN SAMPLES OF DOCUMENTS FOR REVIEW o

PERFORM REVIEW o

ENTRANCE MEETING EVALUATE DOCUMENTS / INTERVIEW PERSONNEL / PERFORM FIELD o

OBSERVATION--REQUIRED WHEN NOT COVERED BY EXISTING i

PROGRAMS f

WHEN COVERED BY EXISTING PROGRAMS, DOCUMENT SPECIFICS l

o AND COMPLETE DETAILED CHECKLIST ATTRIBUTE-IDENTIFY ANY DEFICIENCIES AND CONCERNS AND ISSUE-o ACTION ITEMS t

COMPLETE ALL DOCUMENTATION IN CHECKLISTS; o

o COMPILE RESULTS 1

EXIT MEETING s

HOLD EXIT MEETING'TO DISCUSS.RESULTS WITH-PROJECT 4

o REPORTING ISSUE INDEPENDENT VERIFICATION REVIEW REPORT-o PAGE 1.0F 2 I

j

~

l l

.i l

i FOLLOW-UP ACTION

' RESPONSES TO IDENTIFIED DEFICIENCIES ARE EVALUATED FOR IDENTIFICATION OF CAUSE, EXTENT OF CONDITIONS, AND CORRECTIVE AND PREVENTIVE ACTIONS.

THESE ACTIONS ARE VERIFIED IN SUBSEQUENT FOLLOW-UPS.

i

• DURATION WILL BE HIGHLY DEPENDENT ON PROBLEMS FOUND AND ACTUAL I

SCOPE COVERAGE REQUIRED FOR THE SELECTED SYSTEM.

1 1

1

~

l e

l 1

i l

1 PAGE 2 OF 2

]

~

.c i

i PLANTS WITH INDEPENDENT EA VERIFICATION MANAGED BY PRESENT TVA EA MANAGER

)

MILLSTONE 3 BEAVER VALLEY 2 NINE MILE POINT 2 RIVERBEND 1 (FOLLOW-UP TO NRC IDI) i EA OVERSIGHT ADVISOR WAS ALSO INVOLVED WITH ALL THE NOTE:

ABOVE-LISTED EA VERIFICATION REVIEWS.

)

'