ML20235Q731
| ML20235Q731 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 02/17/1989 |
| From: | NRC COMMISSION (OCM) |
| To: | |
| Shared Package | |
| ML20235Q725 | List: |
| References | |
| NUDOCS 8903030012 | |
| Download: ML20235Q731 (149) | |
Text
_
+
1' p
.a,,-
UNITED STATES NUCLIlmt REGULATORY COMMISSION In the Matter of:
)
)
)
PUBLIC MEETING OF THE TENNESSEE
)
VALLEY AUTHORITY ON OPEN SEISMIC
)
CRITERIA ISSUES
)
)
)
)
)
PAGES:
1 through 147 PLACE:
Rockville, Maryland DATE:
February 17, 1989 HERITAGE REPORTING CORPORATION osata orem m
1220 L Street, N.W., Suke 600 Wasinngton, D.C. 20005 soo303001jt (.jyj$$359 (202) 6M POR ADOC PDC T
l 1
j
}
i 1
2 TENNESSEE VALLEY AUTHORITY / NUCLEAR REGULATORY COMMISSION 3
MEETING ON OPEN ISSUES 4
5 6
7 8
9 10 11 12 13 14 15 Nuclear Regulatory Commission 11555 Rockville Pike 16 Rockville, Maryland 17 Friday February 17, 1989 18 19 20 21 22 23 24 25 HERITAGE REPORTING CORPORATION -- (202)628-4888 I
2 4
1 PARTICIPANTS:
2 On Behalf of the Nuclear Reculatory Commission:
3 Bob Pierson B.D.
Liaw 4
Gerry Gears John Fair 5
Tom Cheng Dave Terao k
6 Tom Rotella Ed Goodwin 7
Roger Woodruff 8
On Behalf of the Tannassee Valley Authority:
(
9 Charlie Fox l
John McCall 10 Bill Raughley Alan Chan 11 Wayne Massie Pat Carier 12 F.L.
Moreadith Ron Haupt (Consultant) 13 14 15 16 17 18 1
19 l
l 20 21 22 23 24 25 e
l
()
l HERITAGE REPORTING CORPORATION -- (202)628-4888 l
3 1
1 t3OCEEDING1
)
2 MR. PIERSON:
I would like *o start the meeting.
I 3
have a few opening remarks that I would like to make.
4 This meeting is a continuation of a series of 5
-meetings held over the last months and years to resolve open 6
seismic issues of Browns Ferry.
We hope the outcome of this 7
meeting will be a plan for resolution of open issues such that 8
the seismic validation program for piping and associated 9
supports can be completed on a schedule consistent with TVA's 10 schedule for Browns Ferry's restart.
11 To place this meeting in an historical context, the 12 existence of problems in the seismic area at Browns Ferry was 13 first identified in January 1980 when TVA discovered the 14 seismic loads were not included in the initial design of pipe 15 hangers.
TVA's corrective action for pipe supports was a 16 subject of a January 1985 Notice of Violation when significant 17 deficiencies in the support inspection program were 18 identified.
19 In July 1986, the NRC requested that TVA provide a l
20 program plan to address the Browns Ferry seismic issues.
This 21 plan was provided in April 1987.
j 22 In March 1988, the staff indicated provisional i
23 acceptance of TVA's program for piping, and made some comments 24 on the interim criteria.
We understood these comments to be 25 generally acceptable to TVA, and assumed that the program HERITAGE REPORTING CORPORATION -- (202)628-4888 i
u_______
_ - - -. ~ _
r 4
1 would be implemented on that basis.
2 In June 1988, TVA identified nine issues concerning i
i 3
the detailed criteria which they. wanted to discuss farther.
1 l
4 After a summer of intense negotiation, the staff believed they 5
had reached general agreement with TVA on design criteria and 6
provided its position on resolution in Snptember 1988.
At 7
that time, the staff believed that the program was being 8
implemented in accordance with the resolutions reached.in I
9 September.
10 During a visit at Stone and Webster in November 11 1988, the staff identified an issue with TVA's use of time 12 history analysis for piping which differed from the September 13 1988 agreement.
Subsequently this and several other seismic 14 issues were resolved in the series of meetings between' the 15 staff and TVA.
The staff found these meetings to be 16 beneficial in understanding the technical basis of issues, and 17 developing a mutually agreeable resolution.
18 However, in a recent inspection at. Stone and 19 Webster's Cherry Hill facility, the staff discovered that TVA 20 had recently made additional changes to its piping design i
21 criteria which the staff questioned, some of which are the 22 subject of today's~ meeting.
23 Further, we are concerned that little progress 24 appe.ars to have been made in the actual reanalysis of 25 individual piping runs and piping supports, or in performing s
HERITAGE REPORTING CORPORATION -- (202)628-4888
5 1
necessary modifications to the actual hardware at Browns 2
Ferry.
We hope through this meeting to make substantial 3
progress in reaching our joint goal--resolving the few 4
remaining open issues concerning the detailed design criteria 5
for analysis and modification of piping supports at Browns 6
Ferry.
7 There is one issue on your agenda that we would like
{
8 to discuss early in the meeting.
That is the question of how 9
you resolve, how you plan to resolve the vitreous clay buried 10 ripe in the seismic Category 1 system.
Since Browns Ferry 11 declared a number of systems to be inoperable, and the lack of 12 these systems may impact near-term future operations of the 13 plant, we believe it is appropriate to examine this issue 14 early in our meeting.
15 MR. FOX:
Okay.
16 MR. PIERSON:
That concludes my opening comments, 17 and I wished to provide this for historical perspective and 18 also so that we are all at least understanding what our agenda 19 today is.
Then if you would like to pass out the, your agenda 20 with the modification that we may want to discuss the vitreous 21 clay pipe early, I think we are ready to proceed.
22 MR. FOX:
I would like to cover the clay pipe.
It 23 will be in the third grouping of items on the agenda.
Let's l
24 look at the agenda and discuss them.
If you really want to 25 hit it up front, we can re-order it.
HERITAGE REPORTING CORPORATION -- (202)628-4888
6 1
MR. GEARS:
Could I add one point--that somebody 2
from NRR is following the clay pipe, too, and would like to 3
attend the meeting, so if we could establish when that was, I J
i 4
think we could give him a call.
)
5 MR. PIERSON:
Fine.
6 MR. FOX:
If you look at the agenda today, you will 7
see that what we plan to do after our introduction is to cover 8
the items that we feel like are closed based on the meeting I 9
had last week with B.D.
Liaw and Dave Terao here, and based on 10 mutual understandings I think we have developed on those.
11 Then we would like to go into the open technical 12 issues of which we add clay pipe to that, and today we are 13 prepared to discuss the problem and the range of engineering 14 fixes that we are looking at to solve that problem.
We are 15 not prepared to put one particular item forth.
I 16 MR. PIERSON:
Let's agree to discuss the clay pipe q
j 17 issue say at 10:30 this morning then.
That allows Gary to 18 make the contact with the NRR representative.
19 MR. FOX:
Okay.
20 MR. LIAW:
Before you start, let me just add 21 something to what Bob Pierson said earlier in his opening 22 remarks.
23 The reason I placed some importance to just today's 24 meeting is in order to support a goal of a restart date 25 sometime in September 1989.
We need to bring all, I HERITAGE REPORTING CORPORATION -- (202)628-4888
7 1
underscore all, issues to closure, including several 2
electrical, and obviously today only, on several issues.
3 MR. FOX:
Yes.
4 MR. LIAW:
So that you can proceed with your 4
5 production runs and calculations and also to start' fixing what 6
needs to be fixed in the plant, and what bothers me the most 7
was this evidence of little effort that we saw when we visited 8
Cherry Hill, that there were so few production men.
I may be 9
wrong to come up with that perception, but the important thing 10 is after today, we need to make decision and after today you 11 need to go out there to make things happen.
12 MR. FOX:
Well--
13 MR. LIAW:
Some of the stuff, even though we may not 14 be able to reach the agreement, but we will give you our 15 positions.
I guess, you know, you don't like it, I would 16 suggest maybe, you know, there is a formal process of appeal 17 where necessary you can do, but I certainly hope that is not 18 the case.
Okay?
19 MR. FOX:
Okay.
Six. weeks ago, I got a call from 20 Gerry Gears and I believe Steve Richardson, B.D.,
expressing i
21 your concerns about what you observed at that audit at cherry l
22 Hill and the fact that there was an observation that was made 23 by staff that TVA specifically was using artificial time i
24 history well beyond the intent of what the perceived screement 25 was with the NRC staff.
HERITAGE REPORTING CORPORATION -- (202)628-4888
8 1
You also expressed your concern about the number of 2
open civil' issues, and Jerry, as best I remember, also 3
expressed his concern about diving into the electrical issues 4
as well.
5 I discussed that with Oliver Kingsley.
Oliver 6
Kingsley came back and told me to take charge of the Browns 7
Ferry civil and electrical issues, which I did.
8 At the Cherry Hill audit of two weeks ago, which was i
9 attended by Dave Terao.and Bob Pierson, John Fair among 10 others, John McCall-and I were looking at the issues that were 11 open at that time plus where we had come from.
Six weeks ago 12 we had over a hundred open civil issues.
We didn't even have 3
13 agreement as to how we would seismically analyze the 14 structures and components in the plant.
15 We have now gotten down to what I see as three or 16 four issues, and it's our intent today to present to you our 17 proposed disposition of those issues to summarize the 18 agreenents that I think we have on the other issues, which we 19 have closed or we perceive as closed based on the recommended 20 action that I left up here last week with you and Dave Terao, 21 and it is our intent to be in an implementation mode in civil 22 at Browns Ferry next week.
23 Now with regard to electrical, there is only one 24 issue that's on screen, and there was a meeting here with your 25 staff yesterday on the separation, and it is the statistical HERITAGE REPORTING CORPORATION -- (202)628-4888
9 1
approach.
Bill Raughley and I.were briefed on that last night 2
by Jim Hudson who handled that matter.
There were a range of 3
options that we at TVA have under consideration that deal with 4
whether or not TVA needs signal trays, the B3 trays.
We will 5
look at that very carefully, and we will be back to staff 6
within the next week.
7 MR. PIERSON:
B3, B2 and B1 trays.
8 MR. FOX:
Right, and we will deal with all this.
We I
l 9
feel like we have a good regulatory precedent for how to deal 10 with B1 and-B2, which will be in our argument.
We didn't see i
11 any additional work on that.
12 We did have to think very hard about the B3 and come 13 up with a proposed solution to that, and we are going to try 14 to do that within the next week.
In fact, Bill directed Jim 15 Hudson to bring the Sergeant Lundy back with him last night to l
l 16 Knoxville and to work on that until they can come up with a j
i 17 recommended approach, clear up through their line management, 1
18 both Bill to Fred on up to Oliver Kingsley and myself, so that i
t 19 is the one electrical issue that's on the table at Browns 4
20 Ferry.
I know of no other criteria issues, and your staff 21 yesterday gave us a proposed solution to that which we have to 22 evaluate very carefully before we can solve that, so we have 23 one electrical issue.
By my count, we have four civil 24 criteria issues, and today, we want to get an up or down 25 decision on our recommended approach on these four civil l
l HERITAGE REPORTING CORPORATION -- (202)628-4888
10 1
issues.
So with that--
2 MR. LIAW:
So on that electrical issues, who has the 3
ball on it?
4 MR. FOX:
TVA has the ball.
We have the ball.
As 5
we say, we will be back to you next week.
6 MR. LIAW:
Okay.
Fine.
7 MR. FOX:
Okay.
Let's look at the agenda.
Last 8
- week, B.D.
and I met with you and Dave Terao was involved in a i
.t 9
number of our discussions and Tom Cheng came in and joined us
)
10 a time or two.
We covered these issues under item 2, and onc l
11 of these issues, the SRSS of inertia and SAM loads, is in your 12 shop, and hopefully we will hear today from staff about the 13 recommendation.
t 14 I am going to give you a handout which summarizes I
15 these items.
I am going to have Wayne Massie, who is our 16 licensing engineer at Browns Ferry, run through these issues.
17 John McCall probably should take the first item, which is G9, 18 the impact of the new ARS and structural models.
19 A month ago we met on that up here and discussed it 20 and discussed the approach we would take, and we told you we 21 would go back, evaluate that.
We are now prepared to commit 22 to the approach, and I guess maybe we start off by letting 23 John McCall speak to CSG 9, 24 I am going to let Wayne Massie summarize the other J
25 issues.
When we get to EMG 002, I guess it would be HERITAGE REPORTING CORPORATION -- (202)628-4888
11 1
appropriate for staff to speak to that, NRC staff to speak to 2
that since the ball is in your court on that issue.
3 John?
4 MR. MCCALL:
Okay.
On the item of CSG 9, to help us 5
all recall what that was, is that was the issue of there being 6
two basic ground motion criteria for the plant or basic input 7
criteria, one being the El Centro time history input, and the 8
other being the artificial time history developed to closely 9
envelope the Hausner response spectrum, 10 The issue was or is how would these be used in the 11 analysis and design of the plant, both previous verification, 12 future?
I believe we have resolved all the issues relative to 13 this except the question on, relative to new work, and 14 secondly, the question of how major items of equipment within 15 the plant would be qualified, and so let's take first the 16 second issue I mentioned, which is how to qualify major issues 17 of major equipments of the plant, and the specific item 1
18 discussed was the reactor pressure vessel and internals, and l
l 19 items such as that, and what we had proposed and we have 20 discussed was the use of the El Centro time histories, and 21 taking the model of the building, attaching it to the, to the 1
22 model of these major systems, and then running a time history 23 analysis and directly using the results of t' hat time histories 24 analysis to qualify various parts or components of the major 25 equipment, and we have done enough work at this point that we l
HERITAGE REPORTING CORPORATION -- (202)628-4888
i 12 1
would like, it is app'ropriate that we agree ' At that is the 2
way to do it.
Specifically using the El Centro time history 3
and doing that analysis does continue to show all of the major 4
equipments like the reactor vessel and its internals qualify, 4
5 so we can basically agree to what was proposed as an agreement 6
I believe about six weeks ago in this area, that is, the use
]
7 of the El Centro time history.
That would be the first part 8
of the agreement.
9 So I guess what I am doing is what we said last time 10 we discussed this, was that we are almost sure that that would 11 work out and yes, it does.
12 MR. CHENG:
We understand the time history 13 represented the licensing requirements, and we also agree to 14 use the El Centro time history to generate the load for the 15 major equipment should be the way to handle it, and we agree 16 with that.
17 MR. LIAW:
All say the same thing?
18 MR. CHENG:
- Yes, I
19 MR. LIAW:
CSG 9 is closed.
20 MR. MCCALL:
That's Part A of the issue.
Then there 21 is another part which is what will we do for new work?
That 22 is, if we were to go out and install a new heat exchanger or j
23 we were to run additional--and that was a second part of the 24 question, and we propose for that that the new commodity be 25 identified as either a commodity related to piping or all the HERITAGE REPORTING CORPORATION -- (202)628-4888
4 a
13 1
rest of the items in the plant, and for the piping area, we 2
intend to use,' continue to use the acceleration response 3
spectra associated with the Hausner close fit time histories, 4
and for the other components, we would propose to use the El i
5 Centro time. histories and its results, so that would mean 6
specifically that, that for things related to what is in 7914, 7
small bore, control rod drive, tubing, those things, we would 8
use the acceleration response spectra or results associated 9
with the, with the Hausner close fit time history, and for the 10 civil structures, HVAC items, cable tray conduit, platforms, 1
l 11 things in that group, we would use the El Centro as a basis.
l l
12 MR. TERAO:
You said El Centr.o time history.
I 13 assume you are meaning El Centro time histories and amplified 14 response spectrum?
15 MR. MCCALL:
Yes, I am.
I am trying to 16 differentiate between the two time histories which envelope 17 the basic criteria for the plant, which is the Hausner curve.
1L MR. PIERSON:
We are in agreement with that?
19 MR. FAIR:
Yes.
~
20 MR. FOX:
CSG 9 is c1osed?
21 MR. CHENG:
I think, I think I had a third issue 22 based on our original understanding, their portion of piping
~
23 or some other work being done, based on the original response 24 spectra, our understanding was TVA will use the new ARS to 25 re-evaluate those piping or equipment to see the impact about HERITAGE REPORTING CORPORATION -- (202)628-4888
14 1
a new ARS, and that's not TVA want to redo the whole thing 2
again.
Otherwise, just based on our understanding, you can 3
see the impact of the new ARS.
4 MR. MCCALL:
Okay.
I'm not sure I am understanding 5
what you are saying.
6 MR. CHENG:
Well, let me repeat again.
There were 7
certain percentage of piping and the equipment being evaluated l
8 based on original FSAR, ARS, that were being done already, 9
instead of redo the whole thing, based on the new artificial 1
10 time history areas, so TVA will go back to look at, to compare 11 the two sets of ARS and then to see the impact on the original l
12 completed works.
That's what our understanding.
l 13 MR. FOX:
To see if there would be impact?
14 MR. CHENG:
Yes.
15 MR. MCCALL:
That's part of what we have already 16 done in the past.
17 MR. CHENG:
Yes.
It is not a new issue, but that's 18 part of the CSG 9 concerns.
19 MR. MASSIE:
It was documented in an audit that Tom 20 Cheng had in October to November 10th, as CSG 9--I can read 21 you the issue.
22 It says upon completion of aRS generation, TVA 23 should assess impact of changes on presently completed program 24 evaluations.
This impact assessment should be discussed with 25 NRC.
HERITAGE REPORTING CORPORATION -- (202)628-4888
15 1
MR. MCCALL:
That was part o our agreement last 2
fall, in September I believe.
3 MR. CHENG:
Yes.
4 MR. FOX:
It is still a good question.
5 MR. PIERSON:
GSG 9 is then in fact closed.
l 6
MR. FOX:
Very good; Wayne Massie, did you want to i
7 cover 14?
8 MR. MASSIE:
I will summarize the discussion that 9
Charlie had up here last Friday.
Thermal growth of steel 10 structure as it relates to the general program, not 11 specifically related to drywell platform beams, which a i
12 portion is the general topics--thermal program, platform
)
13 thermal growth is similar to that used at Sequoyah.
A review 14 of this issue will be performed during the NRC audit of 2-20 15 through 2-24, 1989.
J 16 MR. CHENG:
I would like to add something to it.
17 The CSG 14 was identified based on the staff October, November 18 audit.
During that time, the staff was, concentrated on the 19 steel platform instead of the drywell.
That was the concern 20 of the thermal growth issue.
21 Staff closed that item based on the recent audit 22 performed about a month ago, and staff did not have any chance 23 to look at anything outside the drywell, so in other words, 24 the CSG based on the staff understanding is primary for the 25 steam inside the drywell.
HERITAGE REPORTING CORPORATION -- (202)628-4888
1 16 1
As far as the thermal growth on the steel structure 2
outside the drywell, as a part of that performance plan Volume 3
3, the staff understands 80 percent of the work is being 4
completed by TVA, so the staff already arranged the audit.
As 5
one of the audit topics next week, we will take a look at this 6
before we draw any conclusion.
7
-MR.
LIAW:
What you are saying is the statement 8
stated in this piece of paper, in this sheet of paper, f
9 addresses really two issues here--the first, the thermal float 10 is similar to Sequoyah I guess.
When we say closed, close, 11 Wayne, we mean those inside the drywell?
12 MR. MASSIE:
Portion of CSG 14 related to inside 13 drywell is closed.
The portions outside of drywell--
P 14 MR. LIAW:
Your second sentence here, review will be 15 performed during audit of February 20 to February 24,
'89, 16 applies to the outside drywell?
17 MR. MASSIE:
That is correct.
18 MR. CHENG:
As far as the staff concern, CSG is 19 related to steel inside drywell.
The staffing is closed based r
20 on the last audit.
21 Now as I just stated, as far as the steel outside 22 the drywell, we treat as part of a performance plan Volume 3 23 issue.
It is not a CSG 14.
That's, I would like to make it 24 clear.
25 MR. FOX:
So 14 is closed?
HERITAGE REPORTING CORPORATION -- (202)628-4888
17-1 MR. CHENG:
Fourteen is closed.
2 MR. FOX:
Okay.
3 MR. LIAW:
Okay.
4 MR. MASSIE:
GSI 24, the buckling of HVAC ductwork, 5
this similarly was a topic brought up in Tom Cheng's October 6
through November audit.
We agreed at that time on the 7
equations and formulas issued to satisfy, to resolve this 8
concern.
TVA has initiated, had a study required for 9
resolution of this, so I'think we are in agreement as to the 10 approach that nust be taken to bring it to resolution.
Study 11 is in progress, and we will present that to you.
12 MR. LIAW:
So study will be as a' consequence of--
13 MR. MASSIE:
Also the study--
14 MR. LIAW:
Consequence of have excessive span?
15 Either you are going to demonstrate--
16 MR. MASSIE:
Buckling will not occur.
17 MR. LIAW:
Structural integrity or leak?-
18 MR. MASSIE:
The leak will be tolerable.
19 MR. FOX:
No adverse radiation exposure, 20' specifically no impact to control room.
21 MR. MASSIE:
That is the intent of the study, either 22 verify no buckling occurs, or if it does occur, the leakage is
' 23 tolerable.
24 MR. LIAW:
Study complete before we start.
25 MR. FOX:
Make functional criteria of the system.
HERITAGE REPORTING CORPORATION -- (202)628-4888
4 18 1
MR. GOODWIN:
I think it is probably appropriate for 2
our planning purposes to ask when the study would be completed 3
and available for review?
4 MR. LIAW:
Speak up your name.
5 MR. CHAN:
Alan Chan--the study is scheduled to 6
complete in early April.
However, we believe that in the 7
middle of March, we will have sufficient information completed 8
to sit down with Tom in his next audit to go over the results.
9 MR. LIAW:
I guess, Charlie, I am not to do the 10 audit before you complete it.
I think to enforce the process, 11 I would like you to, to look at it, and you come back to show 12 us after you are satisfied that your contractor has done the 13 job for you, and you tell us and we will have new audit.
14 MR. FOX:
Okay, so the action is for us to notify 15 you when we are ready for the audit.
Very good; we will do 16 it.
17 MR. LIAW:
Okay.
Twenty-six?
18 MR. MASSIE:
Interim allowable stress for aluminum 19 conduit--this topic was discu : sed with Tom Cheng during our 20 technical meeting of January 23rd through the 24th.
We 21 reached agreement at the time as to what the allowable stress 22 value should be.
TVA was looking.at worst case, five worst 23 case evaluations to verify that we do satisfy that interim 24 stress allowable for any given meeting.
1 25 MR. LIAW:
That is the 1.16 S sub Y?
j HERITAGE REPORTING CORPORATION -- (202)628-4888
19 1
MR. MASSIE:
Divided by'.75 times 2.3.
2 MR. LIAW:
We understand?
3 MR. CHENG:
Yes.
4 MR. MASSIE:
We have agreement on the formula we 5
must satisfy.
We are doing those studies'and we will discuss 6
those with you next week during your~ audit.
7 MR..CHENG:
Ok?v.
8 MR. MASSIE:
The next item is EMG 001, item i
9 identified during John Fair's 7914. audit two' weeks ago, 1
10 ratings of standard component supports.
11 The NRC and TVA agree on a program for resolution 12 which basically is two-part.
TVA is to confirm the vender and 13 material suppliers of components as they exist, and where 14 unknown commodities are found, TVA is to use conservative 15 assumption for generating capacitors.
16 MR. PIERSON:
We are in agreement with that, John?
17 MR. FAIR:
Yes.
18 MR. FOX:
The next item is EMG 002.
That item was 19 involved, provided to NRC I think a couple of weeks ago, and 20 we would like your feedback on that.
21 MR. PIERSON:
We can provide feedback later.
We 22 will go ahead with your portion of the agenda.
23 MR. FOX:
Then we will come back to this one, okay 24 MR. MASSIE:
EMG 005, which is the MSSP 58 and 25 emergency condition--agreement, as I understand it, TVA is to i
HERITAGE REPORTING CORPORATION -- (202)628-4888
20 1
demonstrate compliance with a
.9 F sub Y limit for both the 2
emergency and faulted conditions, and TVA agrees to do that.
3 MR. FAIR:
The staff agrees with that resolution 4
also.
5 MR. MASSIE:
And the last item I have, EMG 013, 6
which deals with code consistency, we discussed this item at 7
John Fair's 7914 audit relative to the use of ASME equations 8
and the B31 vintage plant.
t 9
We agreed at that time'to perform an NA 1140 study 10 of the two, of the various. codes using a Don Landers as a 11 consultant.
He will be preparing that for us.
We agree with 12 it.
Method of resolution, we will have those study results 13 for you as soon as they are available..
4 14 MR. FAIR:
That is agreeable to the staff also.
15 MR. GOODWIN:
Approximately when?
16 MR. MASSIE:
Can we give--do we know the--my 17 understanding is the end of, end of February, but--
18 MR. MOREADITH:
I am not certain we have the 19 estimate yet from Don Landers.
20 MR. PIERSON:
Maybe we ought to leave that for you 21 to return to us sometime next week and tell us what the date 22 will be.
23 MR. MASSIE:
We don't anticipate a problem with it.
l 24 MR. PIERSON:
Does that conclude the summary of the 25 closed portion of the--
HERITAGE REPORTING CORPORATION -- (202)628-4888
21 1
MR. FOX:
That is correct.
Now are you going to 2
cover EMG 002, which we understand that we are together on 3
that?
l 4
MR. PIERSON:
Let's discuss EMG 002.
What I would 5
like for you to do is go through your portion of the agenda 1
6 and we will come back and discuss that because we may have 7
some other things we want to amplify with respect to your open 8
technical issues, and we can put it all together for you.
9 MR. FOX:
TVA now would like to cover the four open 10 technical issues, and it locks like we may want to delay clay 11 pipe since we have agreed to 10:30 to cover that, so the first 12 issue we will cover is load sharing and spring bottoming, the 13 operability criteria issues, EMG,12.
14 MR. MCCALL:
Discussing first the EMG 12 issue 15 relative to load sharing, make sure that we all understand 16 what load sharing is and the concept is, is that this is a 17 method that we propose to use to determine operability of 18 systems.
19 The method involves doing an analysis of a piping 20 system, and identifying hangers or commodities which would be 21 in a condition of exceeding the allowables that we have agreed 22 upon, and in that case, performing a second analysis of that 23 same system removing the hanger or commodity which exceeded 24 the allowable, and assessing whether the piping in that 25 condition was acceptable or not, specifically the concept HERITAGE REPORTING CORPORATION -- (202)628-4888
22 1
being that if a hanger is not meeting allowables, that the 2
loads that were on the hanger, if they could be resisted by 3
the adjacent hangers, and the piping, that was not 4
overstressed as a result of that redistribution of load, then 5
our belief would be that it is a conservative engineering 6
assessment to say that you indeed do have an operable system.
7 In the event of an earthquake or some other adverse situation.
8 you would not unzip or fail several hangers in this situation, 9
and the system would be safe.
10 MR. PIERSON:
In what context are you trying to 11 define operability?
12 MR. MCCALL:
Okay.
What I am trying to define it as i
13 is for the restart of the Browns Ferry units where this, where 14 we have a single hanger say that's an issue or a problem, then 15 we would use this to delay the modification of that hanger 16 until after restart.
17 It would still have to be modified as part of the 18 long-term program.
19 MR. PIERSON:
We are in basic disagreement with 20 that?
21 MR. FAIR:
That is correct.
I would like to first 22 go back and put this, this--
23 MR. LIAW:
I think we ought to tell them how we 24 disagree with them.
Our disagreement, this is isolated case 25 because of excess problem or whatever.
HERITAGE REPORTING CORPORATION -- (202)628-4888
23 1
MR. PIERSON:
B.D, wait.
Let John discuss what he 2
has got.
I think that it is important that--we have discussed 3
this in detail last week, and I think it is important that 4
John bring out what our position is with respect to this load 5
share.
6 MR. LIAW:
I was going to say that--
)
7 MR. PIERSON:
We understand what you are trying to 8
say.
I think John ought to say what he has got to say.
9 MR. LIAW:
Fine.
10 MR. FAIR:
First, I would like to go back and put 11 this into historical position as far as the interim or restart 12 criteria for Browns Ferry.
13 The first time that the TVA proposed the Browns 14 Ferry interim criteria was at the meeting we had last March 15 when the program plan in which we put out a meeting summary 16 with the conringent approval of the program plan, i
17 After we had the meeting, and gave our contingent 18 approval of the program plan, we sat down with TVA's technical 19 people and their then interim criteria CEBCI 2197, and went 20 through that criteria and stated our positions on the various 21 criteria in that.
22 I believe that the position that we took at the last 23 audit on the load sharing was consistent with.the position 24 that we gave TVA last March on that same criteria.
I would 25 like to see if TVA has the same understanding or different HERITAGE REPORTING CORPORATION -- (202)628-4888 L
24 1
understanding.
2 MR. McCALL:
We have the same understanding of that.
3 MR. MOREADITH:
Could you, John, be referring to the 4
discussion that we had on the telephone before the 5
commissioners meeting where we realized that--
6 MR. FAIR:
No, sir.
This is.specifically Browns 7
Ferry criteria that was proposed.
This was a March meeting on 8
Browns Ferry.
9 MR. MCCALL:
So that everyone is together, let me 1
10 say this is a meeting which was held between ourselves, 11 ourselves being myself and I believe Alan Chan was in the 12 room, and I believe Carl Sidley was there, although I'm not i
13 sure.
I know John Fair was there, and--
i 14 MR. PIERSON:
Was it a working meeting on site, or 15 was this a noticed' meeting?
16
.MR.
MCCALL:
No.
It was a meeting here.
17 MR. FAIR:
Here at the NRC.
18 MR. MCCALL:
Here, and we basically went through the 19 criteria, and I had identified areas which John felt that we, 20 he couldn't accept at the time, and this was brought out as 21 one of the things that John felt that we didn't necessarily 22 want to accept or he didn't want to accept at that time.
23 We were concerned that subsequent to that meeting, 24 there was no SER, and we also embarked on a lot of discussion i
l 25 of what the basic seismic criteria of the plant was, and the HERITAGE REPORTING CORPORATION -- (202)628-4888
1 25 1
basic methodologies for the plant, and so we rather than going 2
back and removing this item, and there was this item and I 3
believe some others that we will be discussing, rather than j
4 removing them from the criteria, we left them there because 5
there was no SER and no clear we accept this and that there 6
was rather a discussion.
l 7
MR. PIERSON:
I am disagreeing with your assessment j
8 at the end about what we agree and disagree with.
I think j
l 9
that John--and if John could amplify--was very explicit in j
10 what we would accept.
The question was whether you were 11 willing to accept what we were willing to accept.
12 MR. MCCALL:
Right.
13 MR. PIERSON:
I don't think it is a case where we 14 had not provided to you the guidance that you needed to 15 understand what our position was.
I think that was very 16 explicitly defined to you at that point.
]
17 The question that remains is whether you yourself 18 were happy with what that position was, and I don't think 19 that's what you said.,
20 What you just said, if I heard it correctly, was 21 that there was a confusion upon your part because there was 22 indecision on our part, and I would like to point out that 23 that wasn't the case.
24 MR. FOX:
John, let's deal with issue on its merits.
25 I'm not sure I understood the same thing, Bob.
HERITAGE REPORTING CORPORATION -- (202)628-4888
26 l
1 MR. MOREADITH:
B.D.,
perhaps we could just stop and 2
forget the past for a moment, and let me state TVA's position 3
on this issue.
4 First of all, it is not a criteria issue.
It is a 5
calculational issue.
We are talking about how to perform an 6
engineering calculation to justify that the plant is safe to 7
operate.
(
8 Now let's for a moment think about a simple example 9
so that I can describe TVA's position.
10 Think about a two-span continuous beam, and we check 11 this beam, which happens to be a pipe in this case, and we 12 check the three supports against a restart criteria which has 13 stress limits, and go through all the numbers, and we find out 14 the middle support is overstressed, but we also find out that 15 i't won't fail.
Then analytically we consider the model with 1
16 the middle support removed analytically, and we check the pipe 17 and we check the two remaining supports and the pipe and the 18 two remaining supports analytically are not overstressed at 19 all.
Conclusion--the condition is safe and it's satisfactory 20 for restart.
21 MR. PIERSON:
And I think our position is that we 22 would not agree with that.
The reason we won't agree with 23 that is because we had, we have in the past accepted that 24 arguement for interim operability for plants that were 25 operating to continue until their next refueling outage.
We-HERITAGE REPORTING CORPORATION -- (202)628-4888
__ ___-----i--_------------------
27 1
have never accepted that to my knowledge for a plant to 2
restart in particular from an outage of the duration of which 3
you have got at Browns Ferry.
4 Now I would like--John, could you amplify on that?
5 MR. TERAO:
I would like to add one more thing.
The 6
staff is not saying that the load sharing concept is not 7
acceptable, the concept itself.
1 8
What we are saying is that we havr. accepted its use 9
for an operating plant that justified when you find a failed 10 support, failed analytically or failed physically.
11 MR. MOREADITH:
Excuse me.
We shouldn't use the 12 word failed here because we imply failure.
We are talking 13 about not meeting acceptance criteria.
14 MR. TERAO:
I am saying either failed in it fails to 15 meet analytical stress allowance, or whether it has physically 16 failed; but we have to keep in perspective what we are doing 17 on TVA that's a little different than other plants, and that 18 is the use of this interim criteria to allow restart.
I 1
q 19 With other plants, it's, the restart is based on 20 meeting the design basis, and the use of the load sharing is 21 used to justify an interim criteria or a safe condition of the 22 plant to allow continuation of the plant until the next outage 23 when they can fix that support to the design basis.
24 Now what you are proposing today, or let's back up a 25 little.
For TVA plants, we have allowed restart of your HERITAGE REPORTING CORPORATION -- (202)628-4888
28 1
plants to an interim criteria, not to a design basis, but to 2
an interim criteria.
That is going a little beyond what the 3
staff normally accepts, but that was agreed upon from the very 4
start of TVA projects.
5 What you are proposing now is to go beyond that 6
interim criteria to allow restart.
You are saying that these 7
supports do not meet the interim criteria from the analytical 8
standpoint, but it doesn't matter because now your analysis l
9 shows that support will not fail.
That's what we are saying 10 is not acceptable.
11 MR. FAIR:
Let me, could I, Fred, try to explain the l
12 bases for the interim criteria?
l 13 MR. MOREADITH:
Go ahead.
14 MR. FAIR:
The bases for interim criteria on piping 15 systems, its origin is based on a supplement to bulletin 7902.
16 The bulletin supplement essentially said for interim criteria, 17 plants will not have to enter tech spec action statements if I
18 they have piping supports with factors of safety of at least 19 2.
This applied to expansion anchored belts,.what it was j
l 20 geared to.
You extrapolated to the rest of the piping 21 supports.
22 The statement at the end of this interim criteria 23 says the above criteria may be applied provided that, that the 24 effective systems are upgraded to the design margins of a 25 factor of safety expediously for normally accessible supports HERITAGE REPORTING CORPORATION -- (202)628-4888
29 c
1 and by the next refueling for non-accessible supports.
2 The intent of this interim criteria was, as 3
explained by Dave, for a plant that was just entering a 4
start-up or was operating at the time to have some 1
5 availability to do an engineering evaluation in order for them 6
to get to the next refueling outage and then do a repair to 7
the design criteria.
8 In order to determine if we are being fair in the i
9 application of this criteria, I went back to agreements that 10 were made between TVA and the NRC staff before the current 11 Office of Special Projects was formed.
There was a staff
~
12 safety evaluation dated December 19th, 1986, on the alternate 13 analysis program.
In that staff safety evaluation report, 14 there was an evaluation of proposed interim criteria by TVA at 15 that timeframe.
16 I won't go through all the details of the criteria 17 which I have here.
We are essentially allowing for Browns 18 Ferry's interim criteria criteria that is somewhat less 19 conservative than this original agreement that was made on 20 Sequoyah's.
21 However, in the Sequoyah agreement, there was no 22 discussion of the load sharing failed support criteria.
That 23 was not proposed nor accepted by the staff.
24 The purpose of the interim criteria in terms of you, j
25 of TVA going to restart is we would like TVA to have all pipe HERITAGE REPORTING CORPORATION -- (202)628-4888
30
)
1 supports to final design criteria prior to restart.
- However, 2
to be reasonable, and to give TVA a chance to, to have a 3
technical basis for restarting their plants without 4
overburdening them with excessive modifications, we have been i
5 willing to allow an interim stress based criteria for TVA.
6 We think we have been more than fair with TVA with 7
what we have been willing to accept for interim criteria, and 8
even more fair than the original staff evaluation of the 9
proposed criteria on the alternate program.
l 10 MR. LIAW:
So Fred'sexample, two span beam, you say 11 middle support did not meet stress criteria, and you take it 12 out analytically and analyze it.
The piping in it, remaining 13 two supports are still able to meet interim criteria.
I guess 14 I am telling you if you can show that the piping and two 15 remaining supports can meet the final criteria, you must take 16 it out and we will not have that problem with you.
Is that 17 correct?
18 MR. MOREADITH:
B.D.,
that's a good description, but 19 our position is it's, there is no need to take the middle 20 support out because it will just run away from the load if we 21 demonstrate that it will not fail and cause any loss of 22 function, so it's not necessary in our engineering opinion to 23 remove that middle support.
24 MR. LIAW:
All right.
25 MR. FAIR:
Fred, I have discussed this.
HERITAGE REPORTING CORPORATION -- (202)628-4888
31 1
MR. MOREADITH:
So I think the, the difference of 2
opinion is clear.
It is a matter of how you interpret whether 3
or not you have met the criteria, the allowable stresses 4
Our position is that the example that I described to 5
you, we have in essence met the criteria.
6 MR. FAIR:
May I, Fred, ask if your technical staff 7
here at the table can tell us unequivocally from that 8
evaluation removing the support is a bounding condition for a 9
case where a support may fail during a seismic event, where 10 you would get dynamic load transfer due to dead weight, a 11 change of the seismic forces over what your analysis is 12 predicting, or is TVA's position that the proposed method of 13 analysis is a bounding condition?
14 MR. MOREADITH:
Your question then is a good one, 15 and I'm not sure that we can give you an absolute yes on that, 16 and we might have to take another look at it, but my, I 17 believe my judgment is that if we analyze, if we take or model 18 and analyze with and without the support, the real condition 19 in place, if the event actually occurred in the process of 20 again the middle support in the example we used, trying to 21 move away from the load, yes, I believe that the two analyses 22 would bound the behavior that would actually occur.
23 MR. FOX:
Let me ask a question.
If TVA can answer 24 that question yes after some further review, would that be 25 acceptable to staff?
HERITAGE REPORTING CORPORATION -- (202)628-4888
3 l
32 1
MR. MOREADITH:
Any judgment is being confirmed by 2
our B 31.1 code consultant, Mr. Ron Haupt.
That's H-A-U-P-T.
1 3
I don't have the evidence obviously.
l 4
MR. FOX:
If TVA could show that, would that be 5
acceptable to staff?
6 MR. PIERSON:
Well, before we make an agreement to 7
that sort of a question, you understand what our position is.
8 If you are willing to come in with something to further 1
9 substantiate your position, then we will look at it and l
l 10 consider it, but I think, I think it would be premature on our
'I 11 part to give you concurrence on an analysis which is described 12 in very outline form without actually looking at the 1
l 13 evaluation and looking at the outline.
14 MR. FOX:
I understand that, but my question is in 15 principle, would the staff, if we can demonstrate that l
't 16 clearly, to your satisfaction?
I i
17 MR. PIERSON:
My feeling is I personally would be 18 opposed to that.
I feel that what you have got in this 19 situation is you are asking us to go beyond what we have ever 20 done for any other plant,- so my inclination is no, I would not 21 accept it.
22 MR. TERAO:
It raises another question about how far 23 out do you carry that, assuming one failed support, you now 24 assume two failed supports on the system, three, all three 1
25 fail systems, on a system?
cHERITAGE REPORTING CORPORATION -- (202)628-4888 m
33 1
MR. MOREADITH:
Again, I am picking at your words, 2
Dave.
I feel the semantics are extremely.,important.
We are 3
not talking about any failed supports.
If there were truly 4
going to be a support failure, we would'not contend that 5
because we wouldn't know what would happen ~to that support.
6 We are talking about a support which has failed to 7
meet a stress limit.
l 8
MR. TERAO:
That's what I am speaking of.
What you 9
say failure, but failure to meet a stress limit is in itself F
10 important.
11 MR. LIAW:
In a regulatory sense, how one defends 12 failure, and I guess the particular one, you go with different 13 level of stress limit.
I don't know other way to define it, 14 and I, you know, I know, I mean we can continue sharpening the 15 pencil.
l
)
16 MR. PIERSON:
Wait a second.
The problem with this 17 is you are presenting this-as if it is one support in your 18 system, but in reality it is not one support in your system.
3 19 It is multiple supports in your system which you are using 20 this evaluation for.
21 Now the second thing is if I understand what you are 22 saying, you are not considering the failure mode.
Now suppose 23 that, as John pointed out, that this end support you are'using tN' justify the operability of the middle support is a support 24 25 that fails?
Now where does that leave us?
That's why our HERITAGE REPORTING CORPORATION ---(202)628-4888
34 1
position is as we have stated.
2 MR. MOREADITH:
Could we step back for a moment?
4 3
MR. FOX:
Before you step back--
4 MR. MOREADITH:
Hold it.
We are, I think we may all i
5 be forgetting that each time we would use this approach, we 6
would present it to you, and you could evaluate it in detail.
7 MR. PIERSON:
For each individual support?
8 MR. FOX:
Absolutely; case-by-case basis.
9 MR. MOREADITH:
Our proposal is each time we need to 10 use this interpretation of the criteria, which we feel is very 11 technically justified, this is a case, we want to do it, here 12
.are the details.
In our professional opinion, these i
13 engineering calculations demonstrate safety of the plant as 14 affected by the behavior of this pipe support.
15 MR. PIERSON:
_In the case if we didn't agree you 16 would?
17 MR. MOREADITH:
We would discuss it.
If you were 18 right, we would agree with you.
If we were right, hopefully 19 you would agree with us.
20 MR. FOX:
Let me clarify, and I guess early on we 21 didn't make this clear.
We are not asking for blanket
)
22 approval.
We are asking--we are not asking for generic 23 approval.
We are saying that we would like to come to you on 24 a case-by-case basis where we feel like we can analytically 25 justify this position.
We ccre to you on-a case-by-case.
We HERITAGE PEPORTING CORPORATION -- (202)628-4888
]
35 1
are not asking for blanket--
2 MR. FAIR:
How many cases do you anticipate?
3 MR. FOX:
There could be as many as 200.
That
)
4 doesn't mean--that's only 6 percent, 7 percent of the
)
1 5
supports, B.D.; that's not a big fraction.
i 6
MR. FAIR:
I think that's quite a bit of relief for 1
7 the NRC staff to anticipate.
8 MR. FOX:
I said up to.
I don't know that we would l
9 necessarily come to you.
It might be half of that, a third of 10 that.
I cannot tell you the number today.
That's a TVA l
l 11 swaying at this point.
That's the best Stone and Webster 1
~
12 could give me.
13 MR. TERAO:
Your proposal is something that we 14 should think about, but what we also would like you to think 15 about is the possibly take out this load sharing from your 16 design criteria.
That's what we are having a problem with, 17 because when you put the load sharing in the design criteria, I
I 18 it establishes to your engineers %ka t that is an acceptable j
J 19 criteria together with the pipe.
i i
20 MR. MOREADITH:
I wouldn't have any problem with l
21 that.
1 22 MR. FOX:
Fair enough.
23 MR. LIAW:
Just to give example for future abuse in 24 the sense that some day two years from now, five years from l
l 25 now when you are gone and people come along and they don't l
l 1
HERITAGE REPORTING CORPORATION -- (202)628-4888 l
l
36 1
understand the basis for agreeing to that and it will continue 2
to use that.
We see, for example, inspections through G-29 3
C--
4 MR. MCCALL:
What we were proposing to do, though, 5
was what we did at Sequoyah. -At Sequoyah it appears in the 6
design criteria.
The way it appears is it says you can use 7
load sharing, but case-by-case we will come back and discuss 8
or advise you of tht situation, and it is covered as a 9
procedure to do.
10 MR. MASSIE:
I would like to clarify that John Fair 11 had referenced a, a TVA-NRC meeting in 9 of 86, September
'86, 12 where we first presented interim operability criteria for use 13 at Sequoyah.
l 14 Load sharing was not part of that interim 15 operability criteria.
However, we met again on September 1st, 16 1987, whereby we presented document CEB-C21.89, interim 17 operability.
I have got the exact title for it--interim 18 operability criteria for prioritizing modifications for 19 restart, and the conclusions of that meeting, load sharing was 20 included as a statement of 21.89.
21 In conclusion, at that meeting, NRC accepted the use 22 of the support modification restart criteria at Sequoyah Unit 23 2 with limitation on two criteria.
2:4 In response to TVA, NRC agrees that the load charing l
l 25 and piping system operability restart criteria will only be
)
HERITAGE REPORTING CORPORATION -- (202)628-4888
i 37 1
used in limited applications and only with NRC approval.
2 MR. FAIR:.And to go back on the, to correct the 4
1 3
record, the intention of quoting the criteria in '86 was to 4
give you a perspective of our implementation of interim 5
criteria versus the way it has been implemented by NRR staff l
6 to try to get you to understand that we are not being more 7
restrictive than the other licensing staff in the application 8
of interim criteria.
In fact, we have been slightly more 9
lenient in the application.
10 To go back to the discussions that I had with the 11 TVA personnel on the use of the interim criteria, I explained 12 at the time the reason that we put the case-by-case prot'isions 13 was, the intent was to have it apply as it normally is with 14 plants.
That is, if they run into a case while they are 15 starting up their facility, or they are in operation at their 16 facility, that they have some alternative method of evaluating 17 it to show that they met some interim criteria and not have to 18 go into tech spec action statements.
19 The intent was not to allow this as a design 20 criteria to push off modifications to the next refueling 21 outage.
22 MR. LIAW:
Let me ask question.
What are we talking 23 about?
What are these.200 modifications or potential 24 modifications you have to do if we don't agree with that 25 criterion?
HERITAGE REPORTING CORPORATION -- (202)628-4888
1 38 l
1 MR. MOREADITH:
May I respond?
i 2
MR. FOX:
Sure.
3 MR. MOREADITH:
Again, I think--
4 MR. LIAW:
Talking pipe hangers?
5 MR. MOREADITH:
We are tending to confuse ourselves 6
with semantics.
Going back to Dave's suggestion, which is an 7
excellent suggestion, we probably started creating the 8
confusion in and amongst ourselves by ever putting that in the 9
criteria because to me it is a calculational method.
i 10 Now let's step back for a moment.
It is really l
l 11 redistribution of internal forces, and we all know at this 12 table that different codes even have code requirements which 1
13 permit redistribution of internal forces.
14 There is a lot of redistribution of internal forces l
15 permitted in piping codes.
16 MR. LIAW:
Fred, I don't have a problem with 17 internal distribution.
We have got to. talk 'about the static 18 condition, and I don't have a problem with that, I mean from 19 technical point of view, but when we have a dynamic situation,
)
20 a bunch of supports there, quote, reach the elastic limit, it 21 is not going to behave elastica 11y, you have different system
'l 22 to deal with, and I just don't want or I just don't have the 1
23 resource to deal with each one of the 200 cases.
I 24 MR. MOREADITH:
Good question.
Let me consult with i
i 25 Mr. Haupt.
HERITAGE REPORTING CORPORATION -- (202)628-4888
39 1
MR. PIERSON:
Would you like to have a quick 2
five-minute break?
3 MR. FOX:
Let's take a break.
4 (A brief recess was taken.)
5 MR. LIAW:
I guess at_this point, we have continued 16 on discussing the technical merits of what you say, Fred.
I i
7 guess I want you to know from regulatory perspective, not 8
purely from technical, in-house expert, Ed Goodwin is my tech i
9 asistant, and I would ask him to make'a statement hopefully to 10 help you understand where we are coming from.
Ed?
11 MR. GOODWIN:
I am not in a position where I can 12 make any sort of a judgment as to the technical validity of 13 your position, but I wanted to just clarify what, if our 14 people did agree that you, your position were technically 15 valid, where I'm left from a regulatory perspective.
16 And as I understand it, this concept of load sharing 17 is contrary to both the design basis standards that you are i
18 applying, that are applied to this plant, and to normal design o
19 engineering practice, that if you were designing a project, 20 you would not be using this method, and because it is not 21 directly a regulation, it does not require directly 22 necessarily an exemption.
23 Now that will require a little research, but the 24 exemption-regulation 5012 applies as far as the general 25 philosophy that this Commission uses in allowing deviation, HERITAGE REPORTING CORPORATION -- (202)628-4888 l
j
40 1
and basically the bottom line I have to reach is that this 2
concept first represents reasonable assurance of no undue risk 3
to the public health and safety, and the term reasonable 4
assurance is usually considered synonomous with conservative 5
in accordance with normally accepted engineering practice.
6 And where perhaps one such application of this 7
deviation doesn't reduce, reduce the margin of safety of the 8
entire plant particularly much, 200 is a lot different to 9
explain, a lot more difficult to explain because there I'm 10 looking at a reduction in reliability.
Clearly margins are 11 being reduced across a broad front, so we are troubled first 12,
about how many.
13 The second is that in order to grant an exemption, I 14 am required to not only make a find of technical adequacy, but j
15 that application of the regulation or in this case the design 16 standard on a consistent basis, and as John says, our basis to 17 this, to this point has been not to allow plants to restart 18 from an outage in this condition, that applying this standard 19 consistently, I have to, I would have to show that doing this 20 would represent an unusual hardship to the utility different 21 from that experienced by other utilities in the same 22 situation, and that's even if you can make a showing of 23 complete technical adequacy, and you know, this showing of 24 hardship can be made several ways 25 Time is one of them.
If a month before restart you l
HERITAGE REPORTING CORPORATION -- (202)628-4888
41 1
came up with one or two hangers that didn't pass, and that 2
would be very difficult to repair in one or two months, and we 3
go through the exercise of this load sharing, and it is 4
technically acceptable, that's a reasonable showing it is an 5
undue hardship, but this plant has been down four odd years, 6
and then to make the showing that it would represent an undue 7
hardship to replace 200 of these would require considerable 8
deafness that I think it would be difficult to write in such a 9
way that it would be easily acceptable, and so that that's my 10 problem.
If these folks tell me it is technically acceptable, 11 I have still got a large regulatory hurdle to go through.
12 MR. LIAW:
So what Ed is saying is,,
Fred, if you 13 don't get it, you get fired,,and that's undue hardship to your 14 family, but definitely to TVA for a plant worth something 4, 5
15 billion dollars, and to repair 200 hangers is not such a big 16 dea).
I am telling you.
17 MR. PIERSON:
Let me bring out something here.
B.D.
18 ma".tioned something there, and I would like to stress that we 19 have had a very good working relationship with you people, and 20 I would like for everyone to understand that, and I would like 21 to point out that I don't consider any of this to be discredit i
1 22 personally to any of you, and I feel like that should be 23 pointed out to your management.
We do feel we have a very 24 good working relationship, and we continue to hope that it 25 will continue to progress.
HERITAGE REPORTING CORPORATION -- (202)628-4888
42 1
MR. MOREADITH: Thank U.
1 l
l 2
MR. FOX:
We take pride in that.
Thank you.
3 MR. TERAO:
I would also like the record to show 4
that what B.D.
said was taken in a slight sense of humor and 5
we were laue;hing about it.
I 6
MR. MOREADITH:
Let's make sure the record is clear, 7
though, that is the most eloquent 1o I have heard in recent 8
times!
9 Now with that thought, if we could leave you with 10 the thought,.all right, or with that answer you have given us, 11 and that's the answer February the 17eh, 1989, it is very 12 clear.
13 Would you be open to, since we are talking in 14 general terms here, and we are not looking at specifics, we 15 are not looking at a specific example, it may not even be 16 clear in everybody's mind the total process that we are l
17 describing, you know, to reach a conclusion that we have an g
18 acceptable safe condition, would you be open, and we don't 19 need an answer today--as we begin implementing, we find a case 20 and we look at it, and if we could agree today to start 21 calling it redistribution of internal forces rather than load 22 sharing, because I think that's more appropriate technical 23 terminology.
We look at it, we perform a calculation, and we 24 feel we have satisfied the criteria, before we do that, we 25 delete this concept from the criteria under the suggestion of HERITAGE REPORTING CORPORATION -- (202)628-4888 w__
l
~
43 1
Dave Terao that it is really a calculational method rather 2
than a criteria item.
We complete our calculation, and we 3
design review it as we should, and then we hand it to an 1
4 independent consultant which we would both agree upon 5
beforehand.
That independent consultant would review that 6
cale and send us both the report as his independent opinion, 7
that calculation, and whether or not it represented a safe 8
condition for the plant to operate?
9 MR. LIAW:
But that addresses only the first part of 10 Ed Goodwin's question.
How about the second part?
11 MR. MOREADITH:
The second part, it may not occur.
12 MR. LIAW:
Second part being to demonstrate the 13 hardship urgency or whether or not I had to--
14 MR. MOREADITH:
You want to put me on hold?
15 MR. FOX:
Okay.
Let me put Fred on pause, not hold, 16 but pause for just a minute.
We always have the option to 17 come to you with the fact this might, there might be l
18 substantial ALARA considerations so that goes out saying we l
19 realize on a case-by-case basis where we can demonstrate a 20 hardship, we have that option, so Fred, now you can talk again 21 so you know what we have clearly agreed to.
22 MR. LIAW:
The understanding is you delete it as a 23 generic criterion.
24 MR. FOX:
Yes.
25 MR. MOREADITH:
We agree.
i HERITAGE REPORTING CORPORATION -- (202)628-4888
44 1
MR. PIERSON:
Do you have any problem with that?
2 MR. GOODWIN:
And that in the specific cases that 3
you are going to send to your consultant, that you not only 4
have to make the argument of technical adequacy, but why the 5
burden of replacing that particular support would be undue, 6
not because we didn't find it until October, but because of 7
some intrinsic characteristic in that particular location.
8 MR. FOX:
If it fits the agreement I feel like I l
9 have with Tom Cheng and John Fair and and Bob Pierson, we 10 don't need to send that to a consultant.
I think we have a i
11 good understanding of what constitutes a hardship.
12 MR. LIAW:
You understand the definition on that?
I 13 MR. FOX:
- Yes, I
14 MR. PIERSON:
Good.
15 MR. FOX:
Okay.
The next item is spring hanger 16 bottoming--
17 MR. LIAW:
Just a minute.
Let me make sure of that.
18 When we go down for the audit, if we see a statement that 19 appears again in your design book--
20 MR. FOX:
Give us a little while to get it out,
~
21 please.
22 MR. LIAW:
I will cite you for that.
23 MR. FOX:
Fred Moreadith has made a commitment 24 today, TVA has made a commitment today to strike that from our 25 criteria.
That's our intent to do that, and we will follow HERITAGE REPORTING CORPORATION -- (202)628-4888
~ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - - _ _ _ _ _ _ _ _ - _ - _
45 1
through.
2 MR. LIAW:
That's fine.
That's'your intent.
I told 3
you my intent is to if we go down there and see it and we will 4
cite you.
5 MR. RAUGHLEY:
As long as you don't come Tuesday.
6 MR. FOX:
In fact, I think we ought to give them a 7
date.
We ought to take that as an action item to tell them 8
when we will have cleared this, not just at Browns Ferry, but 9
at all plants.
Okay.
10 MR. LIAW:
let's move on.
11 MR. FOX:
Spring bottoming.
12 MR. MCCALL:
The spring bottoming. issue as it is 13 called, what that is is that there are spring hangers in the 14 plant, and the concept is that during either operation or 15 during a seisid e event, TVA had proposed in their i
16 methodologies to allow a condition where the spring would 17 travel through its normal travel distance and bottor out or i
18 come against the stops at the end of the can, and if we 19 can--the piece of hardware is a can with a spring in it, and 20 an arrangement moving up and down that reaches the end of the 21 can, and our argument or belief was that if you reach the end 22 of that can, and you could demonstrate based on the loads, be 23 they thermal or seismic, that the can was still' acceptable as 24 a structural commodity, that is, it would not fail, then that, 25 that would be an item that we could delay to post-restart, and HERITAGE REPORTING CORPORATION -- (20.2)628-4888
46 l
1 modify 1,t at some future date.
i 2
We have gone back and looked at this, and what we 3
would like to propose is that we will adjust the bottomed out 4
springs or adjust the springs such that bottoming out does not 5
occur, specifically so that this will-cease-to be an item, and 6
we would do as we had done at Sequoyah, which would be either 7
to sdjust them or modify them.
8 The impact of this is that we believe there is about 9
400 total springs in the plant, and of this, probably about 55 10 will need to be reset, and 21 we expect--and these are numbers 11 based on not doing all the analysis but rather estimates based 12 on a relatively small sample, but in the order of 20 or 21 13 would require modification such as making the spring can or i
14 the stroke longer or some other action to prevent bottoming 15 out as it is called.
16 MR. FOX:
Whatever the actual number is, we will 17 treat it as we have stated here.
We will adjust and modify as 18 necessary.
19 MR. PIERSON:
I think we are in concurrence with 20 that opinion.
~
21 MR. FAIR:
Yes.
We agree with that.
i 22 MR. FOX:
Very good.
23 MR. LIAW:
I hope we don't have to spend engineering 24 money on that.
l 25 MR. FOX:
On adjusting the springs?
HERITAGE REPORTING CORPORATION -- (202)628-4888
47 1
MR. FOX:
No, I don't think we will.
We will have 2
to maybe spend some on some modifications, but the next item 3
is the the CRV piping, and let's look at our time.
I think we 4
can cover this in 20 minutes.
5 MR. MCCALL:
No.
You skipped one--low temperature 6
thermal analysis.
7 MR. FOX:
Okay.
That's a non-issue, but let's cover 8
it anyway.
9 MR. LIAW:
So first I just want to say that what you N
10 perceive based on discussion my staff had with you, with your i
11 staff, was erroneous the best I can tell.
I guess if you like 12 I will ask John Fair to restate what he say to your staff so s
1 13 that everybody is clear in their mind, in his mind, that we 14 were asking you to modify the possibility of each support in 15 the plant and to do a complete analysis of the whole plant.
I 16 don't think that that was the intent of what John Fair stated 17 to your staff.
John?
18 MR. FAIR:
Yes.
First, this issue came up I believe 19 for the first time with the January 20th, 1989 revision of the 20 design criteria.
The exclusion of the low temperature thermal o
21 analysis was put in for the first time.
22 I questioned as to why you were doing a generic 23 exclusion and why not, since you are redoing all the analyses 24 and since you were just beginning to redo all the analyses, 25 that you ju-a don't do the thermal analysis because its HERITAGE REPORTING CORPORATION -- (202)628-4888 l
48 i
1 manpower and' cost is practically negligible in the production 2
line analysis.
3 TVA's concern was that for some of these systems on 4
the low temperature thermal analysis, support loads may come 5
out to be high, and unrealistically high because there is 6
little thermal movement.
7 I told TVA people that a perfectly acceptable option I
8 to the staff if TVA had a case where this unrealistically high 9
load was predicted on the support, it would be acceptable to 10 the staff to model in the support stiffness and thereby reduce 11 the load and not have to make the modification.
That was the 12 only intent of my comments to TVA on that issue.
13 MR. LIAW:
The case--
I 14 MR. FAIR:
That is correct only for the case where 15 it was TVA's benefit where a load, a support came out I
16 overloaded and they wanted to refine the analysis to keep from 17 having to modify the support.
18 What I said along with that statement, that if TVA 19 was going to do that kind of a model refinement, that they 20 should do it consistent 1y'through that analysis problem and 21 through all the load cases for consistent assumption in the 22 analysis.
23 MR. MCCALL:
Okay.
And I guess what the--
24 MR. FOX:
And we clearly understand that now, and 25 there was substantial miscommunication on that issue,'which HERITAGE REPORTING CORPORATION -- (202)628-4888
49 1
B.D.
and Dave Terao very quickly were able to come to that 2
conclusion last week, and we regret that there was that 3
miscommunication in the past.
We do understand the position, 4
and we can demonstrate that in reality, this is not a problem.
5 MR. FAIR:
I would like to add one further thing, as 6
to a question for TVA.
7 In reviewing this, this particular exemption that 8
was added in the fairly recent revision of the design 9
criteria, I came back and reviewed TVA positions on other 10 programs that are ongoing within TVA, and one of the programs 11 ongoing within TVA was the employee concerns program.
\\
12 As part of the employee concerns program, an issue 13 at Watts Bar had been surfaced as to TVA using a blanket 14 exclusion of the low temperature thermal analysis.
As part of 15 that resolution, all plants at TVA were looked at on the 16 employee concerns report.
17 It was my reading of this corrective action from the 18 employee concerns report that TVA was going to revise all 19 their documents to remove blanket exclusions for the thermal l
20 analysis.
l l
21 My question is, is was this modification of the 22 criteria consistent with TVA's committed corrective action on 23 Browns Ferry from the employee concerns program?
And if not, 24 why not?
25 MR. GOODWIN:
Give them the reference, John.
HERITAGE REPORTING CORPORATION -- (202)628-4888
50 i
1 MR. FAIR:
The reference is employee concerns report 2
No. 21800 recently submited as Revision 3 to the NRC staff.
3 MR. LIAW:
So John, I take it that it is merely a 4
question of consistencies on TVA's commitment in resolving the 5
concern and what they are doing now, correct?
6 MR. PIERSON:
We want to ensure that--in the past I 7
guess that the position was that you are moving toward this 8
exclusion of low temperature.
We felt you should have some 9
mechanism so that you will ensure that previous resolution of 10 items such as your employee concerns were captured by that.
11 Now we understand that we didn't have an issue on 12 this now, but we also understand that there could have been a 13 situation whereby had we agreed to the position earlier, that 14 we might have ended up in a position where you would have been I
15 implementing something contrary to the resolution of, in your 16 employee concern.
That's the issue we are trying to address.
17 MR. LIAW:
Which we disapprove.
18 MR. PIERSON:
I think the other thing that is 19 important is the date on that is what?
The Revision 3 date on 20 that is?
21 MR. FOX:
I would like to borrow that just a moment.
22 MR. PIERSON:
I think that came in last month r
l 23 sometime.
l 24 MR. FOX:
That was just recently.
25 MR. GEARS:
February 1989; I don't know the exact HERITAGE REPORTING CORPORATION -- (202)628-4888
i 51 1
date, but they were'just submitted to us February 6 or 2
February 8.
3 MR. FAIR:
This'is the corrective actions.
4 MR. LIAW:
We approved on January 20, 1988.
5 MR. PIERSON:
'89?
6 MR. LIAW:
'88.
7 MR. PIERSON:
'88.
8 MR. LIAW:
Must be '88 t
9 MR. GEARS:
But the point is, Charlie, you have sent 10 us a totally revised set of eniployee concerns, and they have 11 all gone through in the review.
Apparently that was looked I
12 at, even though it was signed off a year ago, it was still 13 looked at and we have received it, and we started looking at 14 it again, and it still has that statement.
15 MR. FOX:
Let me tell you the process that we used.
i 16 Each of these was sent out to the appropriate line manager 17 that was responsible for implementing the corrective action 18 and he was supposed to review and sign off.
19 We have had Nick Bazendous do the review, so this 20 should be picked up to make sure it gets implemented.
I am 21 going to give Fred Moreadith an action item to disposition 22 this, and also to find out if it was dispositioned in a timely 23 manner or not.
24 I don't--these reports were not given to the line 25 organization at the time that was signed.
They were reviewed HERITAGE REPORTING CORPORATION -- (202)628-4888
R 1
52 1
very carefully by Nick Bazendous for consistency across the 2
board.
What I need is follow-up, is when it was, this put out 1
3 for corrective action and what was done specifically, and we 4
need to make sure that there aren't other things where we 5
might not have followed through with the full intent or spirit 6
of the report.
1 7
MR. PIERSON:
That's the thrust of what our concern i
i 8
is.
1 f
9 MR. FOX:
I am going to ask Fred to take this one as 10 an example and to do lessons learned from it, do a critique of 11 it, and to find out specifically what we did on that.
12 MR. LIAW:
Or whoever who is in charge of employee 13 concern program now agrees with what you propose resolution l
l 14 here at Browns Ferry.
15 MR. FOX:
Well, you know the employee concern task 16 group has been folded away.
These employee concern task group q
17 reports have been sent to line organization for I
18 implementation.
There is no ECPG.
19 MR. LIAW:
Fine.
In that case--
20 MR. FOX:
Now what we have to do is follow up and 21 find out what happened and what is the vehicle that was used 22 to implement that, and if it broke down, why.
23 MR. LIAW:
I can tell you what we;need.
24 MR. FOX:
Okay.
25 MR. LIAW:
Now Fred represent your line HERITAGE REPORTING CORPORATION -- (202)628-4888
.____-_-___________--_a
+
1 organization.
He is responsible for that?
2 MR. FOX:
Yes.
3 MR. LIAW:
So I think he needs to ensure that the 4
commitments made-by TVA throughout the program are being met.
5 In this case, if his position now is no, that was wrong, or 6
you ought to modify, I think it is incumbent upon you to come 1
7 back to us and close it out.
8 MR. MCCALL:
Can we stop a second and read what it i
9 says now?
It says a--this is a proposed corrective action i
10 plan.
Criteria will be revised to add the following--a 11 requirement and procedure for evaluation of the maximum stress 12 range resulting from the system operating temperatures, and 13 there is a star note on temperatures, and anchor movements, l
14 and the star note is a temperature evaluation will not be 15 required if all operating temperatures for the piping are 16 within the range of 20 degrees to 120 degrees.
17 MR. MOREADITH:
John, that's Ref 0.
This is Ref 3, I
l 18 and Ref 3 changes the corrective action is the point.
19 MR. FAIR:. Well, I think, John, if you would read l
20 the entire corrective action statement there, that star is on 21 Attachment B to the design criteria which is small bore 22 piping.
The next item is Attachment A, which is large bore 23 piping, which does not have that star for the exclusion.
It I
24 does have a statement that for small bore pipe, you are 25 excluding within that range.
For large bore, larger than 2 HERITAGE REPORTING CORPORATION -- (202)628-4888
L 54 i
1 and a half of diameter, I did not read any exclusion in that 2
statement.
3 MR. PIERSON:
Are we ready to move on then?
4 MR. UOX:
I want to make one more clarification.
5 Willie Brown i leased this report.
This then went to the line 6
organization.
Now these reports were just recently put out.
7 What I still want to follow up on is what action 8
specifically TVA takes to implement Section 5.1 on the 9
corrective action of this report.
10 Just in summary then, TVA and the NRC staff agree to 11 the low temperature distribution.
TVA takes action to follow 12 up on the employee concern corrective action?
The low 13 temperature thermal analysis is resolved.
14 MR. FAIR:
I didn't quite understand what--would you 15 please restate?
16 MR. FOX:
We do not have a disagreement on how TVA 17 handles the low temperature thermal analysis is what I thought
{
18 we just said.
19 However, staff has a concern as to what TVA did to 1
20 implement this employee concern corrective action as it deals l
21 with change in the TVA criteria.
22 MR. PIERSON:
You are in agreement with what John 23 said earlier with respect to--
24 MR. LIAW:
No.
Here he talks about 32 degree to 50 i
25 and some problems at 120.
]
HERITAGE REPdRTING CORPORATION -- (202)628-4888
1 1
55 e
1 MR. FOX:
No.
That was.just for Natts Bar.
2 MR. GEARS:
The main issue is exclusion of the low 3
temperature.
4 Our position, John, what is our position again?
5 MR. FAIR:
Our position simply questioned the 6
ex'clusion of the low temperature.
We did not accept or 7
endorse it.
i I
8 MR. LIAW:
Which was correct.
We basically--
i 9
MR. FOX:
All right.
Forget it.
We are together.
10 This is not an issue.
11 MR. TERAO:
But there is an issue because your 12 proposed resolution says exclusion of low temperature piping 13 thermal analysis is acceptable, and it is consistent with the i
14 industry practice.
15 MR. LIAW:
May not be consistent with your employee j
1 16 concern resolution.
17 MR. PIERSON:
Let's get off the employee concern i
18 resolution.
19 MR. FOX:
The two are mutually--
20 MR. PIERSON:
What we are trying to accomplish here 21 and I think what John is saying is that we are not agreeing 22 per se to exclusion of low temperature piping thermal 23 analysis.
24 What we are agreeing to is the use of an analysis on 25 a case-by-case basis looking at a particular support within i
HERITAGE REPORTING CORPORATION -- (202)628-4888 U
56 1
your analysis if you uncovered that that particular support 2
does not meet your allowable stress.
3 MR. FOX:
If there is a problem, we have agreed as 1
4 to deal with that'on.a case-by-case basis.-
)
5 MR. FAIR:
Okay.
1 i
I 6
MR. FOX:
And you have told us a method that we can l
7 use to do that, so ve,are together, 8
MR. FAIR:
So-let me--does that mean that this was, 9
exclusion was going to be removed from the design criteria?
I i
10 guess the question is, is the design criteria going to remove 11 this exclusion of the low temperature thermal, analysis?
j 12 MR. MCCALL:
Charlie, can you and I and Fred talk 13 about this a moment here?
I think--
14 MR. LIAW:
We will give you five minutes.
15 MR. PIERSON:
We will take--
16 MR. GEARS:
At 10:30 we will talk about pipe, or i
17 just before.
18 (A brief recess was taken.)
i 19 MR. PIERSON:
We are going to make a slight change 20 here and talk about the clay pipe issue.
21 MR. LIAW:
Five minutes to get everything off.
l 22 MR. PIERSON:
Can we close out in five minutes?
23 MR. POX:
Yes.
First of all, we need to evaluate 24 the employee concern corrective action and find out whether it 25 is appropriate.
We have a new Vice President of Engineering,
. HERITAGE REPORTING CORPORATION -- (202)628-4888
57 1
a new chief engineer.
I don't know if we had the wrong 2
corrective action.
I don't know what review it got.
It 3
should have been thorough.
It should have been by our VP and 4
chief, former chief engineer.
I just don't know what review i
5 it got.
We have got to review it as to appropriateness, first 6
of all.
7 Now secondly, with regard to the low temperature 8
thermal expansion, what our proposed solution is, is that we 9
look at, experienced piping engineer look at this.
Where we 10 might have long runs we might expect that there might be a 11 problem and that we analyze those situations where we might 12 perceive that there would be a problem, and that's the 13 position that TVA has.
14 MR. LIAW:
Right.
If you find problem, obviously 15 you have obligation to tell us.
16 MR. FOX:
Absolutely.
17 MR. FAIR:
I think at this point the NRC's position 18 is that we would like to see TVA's resolution of the employee 19 concerns, how it is being handled, the bases of why the 20 employee concerns program felt the corrective action is 21 needed, and TVA's bases if they disagree with the corrective 22 action, why they disagree.
23 MR. FOX:
That's fair enough.
We take that action 24 item.
25 MR. GOODWIN:
There is another point, which is a HERITAGE REPORTING CORPORA? ION -- (202)628-4888
58 1-.
)
1 discussion of your internal OA and quality and coordination 2
process such that two different documents addressing the same 3
issue came up with two different resolutions and what 4
corrective action it will take to assure.that that isn't j
5 happening in other situations.
6 MR. FOX:
Absolutely.
What we have just agreed to I
7 only reinforces the action item that we-have given to Fred l
8 Moreadith to take this as a specific case example and find out
}
9 why there was not proper translation from that document to the 10 design criteria and vice-versa and to find out how we have 11 accepted that, and we also need to look at some other cases as 12 well.
13 MR. FOX:
Based on his review, we will take 14 corrective action as appropriate.
15 MR. PIERSON:
Are we ready to go with clay piping?
16 MR. TERAO:
No, no.
I still am not sure that we are l
17 talking about the same resolution.
18 Maybe--let me just state what I think the staff's 19 understanding of that resolution is.
20 That you will run low temperature thermal analyses 21 for the piping, and where you find on long runs that you have i
22 a problem, you will evaluate those.
23 MR. FOX:
No.
That's not what we said.
24 MR. MOREADITH:
We said, what Charlie was trying to 25 say is in general, we will exclude considerations of the range l
I HERITAGE REPORTING CORPORATION -- (202)628-4888
59 1
stated on the handout.
Where an experienced piping engineer 2
believes that there may be significant contribution by this 3
so-called load temperature to range, it will be considered in 4
those cases.
5 MR. FOX:
We are not proposing a full evaluation.
6 We are proposing to evaluate and disposition those cases where 7
an experienced piping engineer would think we might have a 8
problem.
We are not proposing a blanket thermal analysis, 9
MR. FAIR:
Sum up the staff position is we haven't 10 accepted TVA's proposal because we still have the outstanding 11 question as to why the corrective action was identified as 12 part of the employee concerns, and whether TVA's proposal i s 13 consistent with past recommendation from independent reviews.
14 MR. FOX:
Okay, and I want to reiterate one other 15 thing, too.
That was a Watts Bar employee concern, and the 16 piping systems at Watts Bar are radically different and the 17 codes of record and the vintages of the analyses are radically 18 different.
19 We have the consultant, Ron Haupt, who has informed 20 us that what we have done at Browns Ferry is consistent with i
21 the practice during the day.
We have said that where we go 22 back and find in the long runs or we think this is a problem, 23 we will evaluate that, but what I am telling you is that we 24 are going to review the appropriateness of the corrective 25 action in that report where it specifically flags Watts Bar HERITAGE REPORTING CORPORATION -- (202)628-4888
1 4
60 L
s 1
and then it made reference to all.
We need to review that 2-corrective action for appropriateness, and we will do that.
3 We will come back to staff with our resolution of that, and we 4-will either change the criteria or change the corrective i
5 action accordingly.
We will issue that report.
6 MR. LIAW:
Two things, Charlie--first, if you 7
conclude that you have to change the corrective actions 8
proposed to resolve a concern in the program, you come back to o
9 us.
10 MR. FOX:
Yes.
11 MR. LIAW:
Okay.
On top of that, you are going'to
~
12 do a selective analysis based upon experienced piping 13 engineer's judgment to run some low temperature thermal 14 analysis to show that--
j l
15 MR. FOX:
For specific case where we think we have, j
16 might have a problem.
17 MR. LIAW:
Right, and if you have a problem, you 18 tell utility.
i 19 MR. FOX:
Absolutely.
20 MR. PIERSON:
I think it would be wise on your part 21 to constrain somewhat where you think you may have a problem 22 and at least explicitly define it to us what you did consider.
23 I mean judgment is a very open-ended thing.
If you could say 24 he made the judgment that it was 26 feet or something like 1
25 that, that's different than he judged that it was--
HERITAGE REPORTING CORPORATION -- (202)628-4888
61 1
1 MR. FOX:
We will define the criteria.
2
'MR.
LIAW:
Dave?
Is that okay?
Is that consistent?
I 3
MR. TERAO:
I Just didn't think it was appropriate 4
to consider this issue resolved because I still think there is 5
area for discussion here.
6 MR. PIERSON:
Potentially, that is correct.
7 MR. FOX:
On a case-by-case, what we mean--
8 MR. LIAW:
No, no.
We are not talking about the 9
technical issue.
Talking about the employee concerns l
10 resolution first, so this issue is not fully resolved as of 11 today.
12 MR. FOX:
We understand that.
We understand that, 1
l 13 but we do have no intent to do a detailed thermal analysis.
I 14 want to be very clear about where we are coming from.
We have 15 no intent of doing a low temperature thermal analysis across--
16 MR. LIAW:
The whole plant?
17 MR. FOX:
That is correct.
18 MR. LIAW:
That is correct.
Right.
19 MR. FAIR:
And we have not, the staff at this point 20 has not accepted that because it appears to be in conflict l
21 with what the proposed corrective action from the employee 22 concerns, and we will review this technically when you resolve 23 the conflict between this criteria and the employee's concern 24 resolution.
25 MR. FOX:
Okay.
HERITAGE REPORTING CORPORATION -- (202)628-4888
62 1
MR. LIAW:
Is that clear now?
Dave?
2 MR. TERAO:
Yes.
3 MR. LIAW:
Okay.
4 MR. PIERSON:
Are we ready to go to clay pipe?
- Who, 5
Roger?
Do you want to come up front?
6 MR. PIERSON:
Okay.
Use of the clay pipe material--
Excuse me just a minute, Bob.
9 (There was a brief pause in the proceedings.)
10 MR. FOX:
What we have prepared to do on the clay 11 piping is describe the technical problem, and some of the 12 options that TVA is considering at this point in time, 13 technical fixes to the problem as we understand it.
14 Fred Moreadith is going to--
15 MR. MOREADITH:
I think maybe if that's the way you 16 want to approach it--
17 MR. MCCALL:
I'm sorry.
I was--
18 MR. MOREADITH:
Say it again.
19 MR. FOX:
I said as we are prepared to discuss the 20 technical aspects of the clay pipe problem, on the EECW system 21 and to discuss TVA's fixes that it is currently evaluating.
22 No decision has been made as to the fix for this 1
23 problem, but we have some options that are up on the table.
24 Either Fred Moreadith or John McCall is going to speak to 25 this.
Which one of you fellows?
HERITAGE REPORTING CORPORATION -- (202)628-4888
63 1
What we have done is passed out a handout here that 2
shows you the configuration and gives you a description of the j
I 3
condition and also a discussion of the design basis.
1 4
(A discussion was held.off the record.)
5 MR. MOREADITH:
The two options that I know have 6
been discussed, one is the possibility--
7 MR. FOX:
How about giving them statement of the 8
problem first?
9 MR. MCCALL:
If we back up maybe--
10 MR. MOREADITH:
All right.
Looking at the sketch, 11 look at the sketch, you can see that the EECW discharge exits 12 the building and a portion of the discharge is the steel pipe, 13 and that chances into a vetrified clay pipe.
14 During the DBV--
15 MR. MCCALL:
Okay.
Maybe we can make it a little 16 more clear exactly now this is working, Fred, is there is a 17 raw cooling water system that is exiting and flowing out of 18 the reactor building, and the raw cooling water system is not 19 a safety-related system, and what the situation is, is that 20 the emergency equipment cooling water system, the loads for a 21 few pieces of equipment--I believe it's at the bottom.
There 5
22 is three pieces of equipment.
Those relatively small lines i
23 for discharge were tied into the raw cooling water system.
I 24 mean, yes, the concept being then that the raw cooling water 25 flowed out of the building, and this is in piping with l
HERITAGE REPORTING CORPORATION -- (202)628-4888
64 1
Dressler couplings; goes through a pipe tunnel, and that 2
enters the ground and then travels through a two-foot diameter 3
clay pipe and into the very, the large TCW conduit that goes 4
out to the river.
5 So what we have are three relatively small inflows 6
from these, three safety-related systems into that.
Most of 7
the EECW system goes into other, other places.
It is just 8
these three.
9 MR. PIERSON:
Let me ask you a question here.
i 10 MR. MCCALL:
Okay.
11 MR. PIERSON:
If I may--the sketch here shows the 12 raw cooling water passing through the reactor bui'1 ding, and 13 then entering the pipe tunnel, and then goes around to join 14 the vetrified clay pipe.
15 Is that pipe, that steel pipe, is that seismic Class 16 2 structure as you have here on your drawing?
17 MR. MCCALL:
Yes.
18 MR. PIERSON:
Because looking at it, I'm not sure 19 whether you are talking about the pipe tunnel or whether you 20 are talking about the entire pipe thing.
21 MR. McCALL:
The entire pipe was not seismic Class 22 1.
23 MR. PIERSON:
The next question, one other--the raw 24 cooling water that feeds into the EECW discharge header above 25 the penetration of the reactor building, are we talking about HERITAGE REPORTING CORPORATION -- (202)628-4888
65 1
one pipe there, or are we talking about three pipes there?
2 MR. MCCALL:
No.
The EECW discharge that feeds'in, 3
that's the three little pipes.
The raw cooling water is the 4
real basic system that is flowing out.
5 MR. RAUGHLEY:
We have a schematic.
6 MR. PIERSON:
So this drawing really is, is not 7
quite, it is a simplified drawing and so what we have is we 8
have RCW passing into three pipes, a 3-inch pipe, a 6-inch 9
pipe, and another 6-inch pipe?
)
)
10 MR. MCCALL:
The EECW is a system which pumps l
11' cooling water to many loads in the plant, right, and it works 12 out that for three of those loads, the discharge for that is I
13 into the raw cooling water system which is a non, which is not 14 a seismic Class 1 system.
15 MR. PIERSON:
The pipe on the RCK discharge inside 16 the reactor building, what is the dimension of that?
Four 17 inches?
18 If you look at this drawing where your check valve 19 is located, you have got RCW discharge.
You have got 6 inches i
i 20 marked on, 3 inches and 6 inches, but my question is--
l 21 MR. RAUGHLEY:
Twenty-four inches, it comes out in
}
22 the tunnel where it says RHR tunnel.
23 MR. PIERSON:
The next thing I want to know, you 24 have indicated this isn't a seismic Class 1 structure, and 25 presume.bly that includes all the way up to at least the i
HERITAGE REPORTING CORPORATION -- (202)628-4888
66-1 juncture there of the RCW discharge, and I guess the thing I 2
would like to point out is we are also concerned about this 3
issue with respect to moderate energy line breakage inside 4
your reactor building.
I am not sure that that is a factor,.
5 but I think that we need to at least consider'that as a 6
factor.
7 Are there any questions about that?
8 MR. MCCALL:
Well, I think what you are referring to 9
is there is a 2 over one aspect or a, associated with the, 10 having cooling water inside the reactor building.
11 MR. PIERSON:
That is correct.
That's exactly 12 right.
~
13 MR. MCCALL:
Yes.
14 MR. PIERSON:
Go ahead.
I'm sorry to interject.
15 MR. MCCALL:
So what the system is, is then we have 16 a basic non-seismic system coming out and these relatively 17 three small loads were input into it and then it flows out.
18 Now the way this came up is there is two things 19 happening.
We have a normal process in place reviewing this, 20 and it worked out that at the time that John was in Cherry 21 Hill, at the same time as he was there doing the review, we 22 were also beginning to look at this, nnd he asked for a table 23 of all of the materials that were used in Class 1 systems, and 24 he was given a table.
Actually he was given one without the 25 clay pipe one day and with it the next day because we were in HERITAGE REPORTING CORPORATION -- /,202)628-4888
1 l
67 1
the process of discovering it, and-the reason we modified the 2
table is that we, we wanted, you.know, we wanted everybody to i
I 3
know what we know because that is the basic program here.
4 And so there is two issues., One is,from the terms 5
of that table, and he has an audit finding that he' observed 6
that clay pipe in the table.
7 MR. FAIR:
That is correct.
8 MR. MCCALL:
And from the, from the respect of that 9
table, we are presently still evaluating whether, whether that 10 will still be Category 1 or there will be some other 11 resolution.
12 There are numerous resolutions to this problem.
For 13 instance--
14 MR. MOREADITH:
Go ahead.
15 MR. MCCALL:
For instance, as I say, this is a steel 16 pipe with Dressler couplings, which are compression coupling 17 at joints, and if indeed we can't show that we'could maintain 18 the small flow rates here in case of something bothering this 19
. clay pipe, there are several things that might happen.
20 One is that if the clay pipe did fail, it is about 7 21 feet down and there is not, at this time we don't believe 22 there is anything Category 1 above it so the water would 23 probably just go up to the surface anyway.
24 That would cause some back pressures, and the reason 25 we are not saying that's a resolution is there is some HERITAGE REPORTING CORPORATION -- (202)628-4888'
68 1
homework to be done.
2 MR. PIERSON:
Could ultimately affect performance of 3
the heat exchanger?
4 MR. MCCALL:
That's right, because it could affect 5
the grow back on those, and we have got to review that.
6 There is other ways to do this.
For instance, 7
inside the tunnel, there's access to the pipe, and you could 8
put in a, either a device to accommodate overpressure or you 9
could put in a vent stack or a lot of things.
10 MR. FOX:
Flowout panels, stand pipe.
11 MR. MCCALL:
There is a whole lot of things to do, 12 and the thing is that we are kind of at the spot that we just 13 haven't done enough analysis to say long-term what the best 14 thing to do is to fix it.
We are in the-stage where we have 15 several alternatives.
16 MR. PIERSON:
And I can understand your situation 17 and we have looked at your interim operability, in effect the 18 mode 6 condition that you are in now, and the only thing I l
19 would like to point out, too, is that I question these 24 inch 20 pipes which are in your reactor building on the provision of 21 the moderate energy line break.
I'm not sure we included that 22 in your--I may be wrong about that.
23 MR. MCCALL:
Can I just--that's, that steel pipe is j
24 seismically analyzed.
l 25 MR. PIERSON:
Okay.
RCC 24-inch pipe then is 1
HERITAGE REPORTING CORPORATION -- (202)628-4888
. - = _ _
-_-__---_--___ _ a
69' 1
seismic analyzed.
The portion where it becomes unseismically 2
analyzed is outside the reactor building?
3 MR, MCCALL:
In other words, it is seismically 4
analyzed where its failure wo,uld cause the 2 over 1 associated 5
with the water coming out.
6 MR. PIERSON:
What you are talking about on the, 7
here Class 2 structure, you are talking about what is outside 8
the reactor building?
9 MR. MC. CALL:
Right.
10 MR. PIERSON:
Yes.
1 11 MR. CHAN:
I am not sure whether you get correct-12 impression.
The RCW pipe is seismically analyzed all the way 13 through the point in the ground.
Ground is considered--
14 MR. MOREADITH:
At the end of the tunnel.
15 MR. PIERSON:
No longer seismic Class 1.
Where it 16 begins to be seismic Class 1 is where it enters the buried 17 portion there?
18 MR. MCCALL:
Because you have to have an anchor 19 point in the analysis.
20 MR. TERAO:
I don't know if that's where the seismic 21 class ends.
That's where it is seismically analyzed?
22 MR. MOREADITH:
Right.
23 MR. MCCALL:
To me clearly what we are trying to 24 say, it is not necessarily agreeing with all that, but we do 25 analysis to demonstrate that it is not going to fail and i
HERITAGE REPORTING CORPORATION -- (202)628-4888
70 1
jeopardize other equipment through flooding, and I think 2
that's what your real question is.
Right?
3 MR. PIERSON:
That is correct.
4 MR. MCCALL:
As I say, it is, 7 feet is relatively 5
shallow.
6 MR. PIERSON:
Anything else you want to add to this 7
issue?
8 MR. LIAW:
How long is the pipe?
9 MR. MOREADITH:
I don't know.
Do you?
10 MR. MCCALL:
I do not know right off.
Do you, Alan?
11 MR. CHAN:
It varies through different segments of 12 it.
It varies from maybe 20 to 50 feet.
Through the right 13 portion may be over a hundred feet.
14 MR. LIAW:
Over a hundred feet.
15 MR. GOODWIN:
How about the conduit?
What is its 16 status?
The CCW conduit for the 16?
17 MR. MOREADITH:
It is not seismically qualified at 18 all.
19 MR. GOODWIN:
So both the clay pipe, also the steel 20 pipe after it leaves the tunnel, the clay pipe and the conduit 21 are all non-seismically qualified, are not seismically 22 qualified?
23 MR. MCCALL:
Yes, but the EECW as it says is a 24 16-foot round concrete tunnel carrying the major heat, heat 25 sink for the--
HERITAGE REPORTING CORPORATION -- (202)628-4888 c - ___________
71 1
MR. LIAW:
Charlie, when are you coming back to tell 2
us your final resolution?
3 MR. FOX:
Well, I'm going to have to defer to Dr.
4 Moreadith, and I don't think we are prepared today to give you I
5 a schedule, but I will tell'this.
We will give you a schedule
]
l 6
form, a schedule of resolution next week.
]
7 Can we do that, Gerry?
When we are having the i
8 schedule meeting down at Browns Ferry, we will tell you when 9
we will feel comfortable.
We will also be happy to discuss 10 status with you next week.
11 MR. GOODWIN:
For our own planning purposes, what 12 is--these, you have declared these. systems out of commission 13 at the present time, or inoperable.
You made a'50.75 finding.
14 Reasonable arguments can be made right now that de 15 facto have been made about adequacy for present mode.
16 MR. FOX:
That's what John McCall is referring to, 17 not the dresser couplings, the fountain effect.
18 MR. GOODWIN:
When in terms of your plans for heatup 19 of pressurization of the primary system, when are you--not 20 necessarily a mode change, but when are you planning to next 21 do something that will, that would change the state of the 22 primary system?
l i
23 MR. FOX:
I will say this.
We will be prepared to
}
24 discuss that the 22nd when we go through our schedule with the 25 staff.
We are still in the final review stages.
HERITAGE REPORTING _ CORPORATION -- (202)628-4888
72 1
MR. GOODWIN:
You obviously see our problem, which 2
is we have got to make a finding as far as safety in the 3
short-term for any mode change you make.
4 MR. FOX:
We have to do some hydro or something that 5
might--I cannot answer that question today, but we will be, 6
certainly be able to answer that next Tuesday or Wednesday 7
when the staff is at the site to cover the schedule, whole 8
Browns Ferry Unit 2.
9 MR. LIAW:
You clearly understand that this issue is 10 including possible repair or replacements before restart?
11 MR. FOX:
Yes, absolutely.
That is not a question--
12 MR. MCCALL:
Hold it.
It will be done before 13 restart.
14 MR. FOX:
That's what I said.
15 MR. MCCALL:
He was talking and I was--
16 MR. FOX:
Well, listen.
17 MR. MOREADITH:
Bill Raughley does have some 18 detailed information over here.
19 MR. RAUGHLEY:
What we are doing now are 20 calculations--
21 MR. FOX:
Just a minute.
Can we talk just a second?
22 (There was a brief pause in the proceedings.)
23 MR. FOX:
What Bill Raughley had is a preliminary 24 schedule.
Until our chief engineer reviews it, I review it, 25 and we discuss it with all Oliver Kingsley, I don't want to HERITAGE REPORTING CORPORATION -- (202)628-4888-
(
I l
N 73 1-discuss a preliminary schedule with you for implementing the 2
analysis or doing one of the fixes.
l.
,g 3
MR. LIAW:
That's fine with us.
4 MR. MOREADITH:
What day next week is that?
5 MR. FOX:
Next Wednesday, so next Wednesday, we will 6
provide the answer to your question, Ed, and also give you the 7
date which we would expect to start something other than the i
8 current situation.
9 MR. LIAW:
Okay.
I understand that, but 10 nevertheless, I would like to say a few words.
11 Considering the whole range of possible resolution, 12 you come up with something like a consequence where we very 13 small that you can deal with it for long-term solution, and 14 you will be severely, you know, pressed to do an analysis.
I 15 don't know how much.
It is very, very difficult for us to 16 accept that kind of thing.
i 17 MR. FOX:
We will come back with something that will l
)
i 18 technically be acceptable to both staff and us I'm sure.
We
)
j 19 are not looking for some jerryrig fix to it.
20 MR. LIAW:
I am not talking about fix, Charlie.
I 21 am here to talk about the integrity of the piping rather than 22 talk about consequence to live with the consequence.
You.come 23 up with something that you can live with the consequence, j
24 okay.
The staff will find it very, very difficult to accept.
25 You can take it as a word of warning.
HERITAGE REPORTING CORPORATION -- (202)628-4888
r 74 1
MR. GOODWIN:
You are certainly free to propose 2
anything you wish, but we are just indicating the sensitivity 3
with which we would view this.
4 MR. FOX:
Okay.
Well, we plan to evaluate options 5
based on technical merit and disposition accordingly.
Okay.
6 MR. LIAW:
Okay.
7 MR. PIERSON:
Are we ready to proceed to the next 8
issue?
9 MR. GEARS:
Roger, do you have any questions?
10 MR. WOODRUFF:
No.
11 MR. LIAW:
By the way--this is off the record.
12 (A discussion was held off the record.)
13 MR. LIAW:
Back to the meeting,now.
14 MR. PIERSON:
Are we ready to proceed with the 15 anchors?
16 MR. FOX:
This is the CRD piping issue.
17 MR. LIAW:
Just a minute, Charlie.
You have rod 18 hanger.
19 MR. PIERSON:
We skipped CRD hydraulic system.
20 MR. LIAW:
I see.
I'm sorry.
21 MR. FOX:
Hydraulic system, EMG 027; John McCall?
22 MR. MCCALL:
Yes.
The control rod drive system, in 23 just a minute I'll show you some sketches to make sure we all 24 understand what it looks like, but the control rod drive 1!5 hydraulic system is an issue that came up back just after the HERITAGE REPORTING CORPORATION -- (202)628-4888
75 1
unit was shut down, and the way the issue started was that 2
during some walk-downs, cable trays were found attached to 3
some of the control rod drive system supports, and the I
4 discovery of those, that condition, and then the subsequent 5
investigation of the control rod drive unit supports led to a 6
series of evaluations ano studies which end--there is a long 7
history of discussions running from what, I believe 1985 up i
8 until the present on this system.
)
1 9
Where we are right now is that during the recent 10 audit being conducted in Cherry Hill, this was, a criteria to 11 do this was included in our design criteria, and we requested 12 that John put off reviewing that until we have finalized what 13 the criteria was, and indicated at that time that we would 14 come back and discuss it more, so what I would like to do is 15 briefly describe what the system looks like to you all, and 16 then indicate what we are thinking of for the criteria.
i 17 MR. LIAW:
John, before you do that, let me say that 18 the problem due to the use of wrong damping factor, that it 19 was supposed to be analyzed for
.5 percent damping, is that 20 your contractor used 5 percent?
21 MR. MCCALL:
Well, that's not what the problem is 22 due to.
The problem is due to--
23 MR. FOX:
The answer to his question is yes, but 24 that's not what the problem is due to.
Go ahead.
i 25 The answer to your question is yes.
The damping HERITAGE REPORTING CORPORATION -- (202)628-4888
[
l l
76 1
l 1
should have been calculated at half a percent.
It was l
2 calculated at 5 percent.
3 MR. LIAW:
That was error in the design or 4
resolution of problems?
5 MR. FOX:
Answer his question, John.
6 MR. MCCALL:
The original design, I don't, I have 7
not seen the calculations and I can't answer your question.
8 What you are referring to is that after this issue 9
was discovered, then Impell was hired to prepare criteria and 10 resolve the problem, an3'they went out-and-looked ~at~it~,
and~
11 when you look at the system, what they found were a lot of 12 pipes which are three quarter and 1-inc.h pipes.
They are all 13 Schedule 80 pipes.
14 MR. LIAW:
With tubes?
15 MR. MCCALL:
Schedule 80 pipe is almost a tube, but 16 it is a very heavy-duty tube if you will, and they found those 17 running in bundles and the bundles are all different lengths 18 because they start at different places and have bends 19 different places, and they found those running through hangers 20 built out of uni-strut, which this is what a gang hanger looks 21 like, and this is a cross-section through one of these where 22 you--and as you can see, what you have are uni-struts and then 23 cross-straps and then a whole lot of these tubes or small 24 pipes running across it.
25 A decision was made during that analysis, one of the HERITAGE REPORTING CORPORATION -- (202)628-4888
i 77.
1 rules used was to use 5 percent damping, and there were two 2
concepts that that was based on.
3 One was that this really, since it is uni-strut and 4
since it is bolted, looks more like a conduit support than it 5
does a piping support, and secondly, that the N-411 damping 6
and some of the new criteria at that time also seemed to 7
support 5 percent damping, so 5 percent was selected.
8 That's really an old issue.
We have, we came and 9
made a presentation and a submittal to you all, and you all 10 have indicated to us that the 5 percent damping is 11 questionable, and what we are proposing today is to use the 12 same rules to design this sy. stem-as we would use for any other 13 piping, that is, that of course is a large set of rules.
14 That's a half percent damping and that includes all, you know, 15 the nine points, et cetera, so that is behind us, the 5 16 percent damping issue, at this time.
17 MR. LIAW:
Question--when was pipes and damping used 18 and when did TVA talk to staff?
19 MR. MCCALL:
The exact dates, I'm not sure of, but 20 the 5 percent would have been used from the '85 to '87 period, 21 and you have to understand that we went out and replaced all 22 of the U bolts, all the bolts.
There is 3,000 of those, we 23 made 800 lots.
So we used to until
'88--
24 MR. LIAW:
Just answer'my question.
When you tell 25 us?
HERITAGE REPORTING CORPORATION -- (202)628-4888
78 1
MR. MOREADITH:
B.D.,
it is my understanding based 2
on what John said that the interpretation was made, an'd I have 3
not looked at any evidence.
I am trying to understand what 4
John is saying--that this, that this system and these supports 5
were more conduit-like than pipe-like, so--
6 MR. LIAW:
A judgment was made back then.
My
)
7 question is when that was conveyed to NRC staff and what 8
response you get from NRC staff?
9 MR. MOREADITH:
I have no knowledge.
)
10 MR. MCCALL:
I believe that was conveyed in 11 the--well, I am not going to say exactly, don't know exactly 12 when it was conveyed,,but I would say the
'86,
'87 timeframe, 13 and the response we received from the staff was that the 5 14 percent damping--I guess we received that in
'87, mid '87 15 would be what I understand--a response that the 5 percent
)
16 damping was.not the correct number, and it was out of that 17 negotiation actually that the concept of using close fit 18 Hausner time histories was discussed.
19 MR. LIAW:
So basically---
20 MR. MCCALL:
With Bob Hermann, and that.came out of 21 the late
'87, and very early
'88.
It was in the process of
)
22 being finally discussed when I first came.
l 23 MR. MOREADITH:
Would you like'for us to research 24 that, B.D.?
25 MR. LIAW:
No.
I think you sense that, and I just HERITAGE REPORTING CORPORATION -- (202)628-4888
79 e
1 want you to know, Fred, that's another case that TVA grab it, 2
run with it, without NRC's' knowledge, and knowing that-the 3
N-411 damping, use of N-411 damping was subject to certain J
4 constraints the staff put forth, and I mean just tell you as a 5
senior staff at TVA--
6 MR. MOREADITH:
We understand what you are telling 7
me, and I think I clearly understand.
8 MR. LIAW:
That type of thing--
l 9
MR. MOREADITH:
When we make a judgment which may be 10 subject to a great deal of scrutiny--
l 11 MR. LIAW:
Or--
12 MR. MOREADITH:
We should put it right up on the j
i 13 table before we get too far down the road.
14 MR. LIAW:
That's right.
Clearly those were deviate l
l 15 from what had been previously.
16 MR. FOX:
I don't believe any of the people in this 17 room were a part of that.
18 MR. LIAW:
I understand that.
That's the reason I 1
an telling you.
20 MR. FOX:
That is not the new TVA.
We are going to 21 meet our commitments.
22 MR. LIAW:
I am just pointing that out as John 23 McCall, you screwed up, t
24 MR. FOX:
I am going to give John the benefit--John 25 wasn't here.
HERITAGE REPORTING CORPORATION -- (202)628-4888
l 80 I
1 MR. LIAW:
From time to time, we would constantly 2
pick on you on this whole issue to help you to change it, 3
okay, and I think that in the long run it will be beneficial 4
to both you and NRC.
5 MR. FOX:
I am hoping a few years down the road the 6
memory of those past practices will be so foreign to our way 7
of doing business that you won't even remember these examples.
8 We intend to meet our commitments.
9 MR. LIAW:
Continue then.
10 MR. MCCALL:
Okay.
So where we are right now is 11 that we are proposing to finalize this using the criteria 12 which is the same as Class 1 criteria for the rest of the piping systems, and that's these criteria 7103--excuse j
13 l
14 me--BFN-50-C-7103 and 7107, and those criteria will be applied 15 to this system.
16 The only thing that we want to make clear, and as a 1'
subject, is that this is a system with, as I say, a lot or a 18 large number of pipes all vibrating somewhat independently, 19 and the frequencies of those pipes are well distributed, and i
20 so we are proposing to use the square root of the sum of the 1
21 square combination to sum up or to determine the effects of 22 numerous pipes on the gang hangers as a methodology, and we l
23 will be revising our design criteria to include that as a
{
24 special page.
I believe it is Appendix A, and the present 25 criteria will be modified.
I l
HERITAGE REPORTING CORPORATION -- (202)628-4888
81 1
MR. LIAW:
So John, as far as you are concerned, you 2
think TVA has taken corrective actions?
Correctiv-action has 3
been completed?
4 MR. MCCALL:
Now let me answer that, that question.,
l 5
is that when we use this type of criteria, which we believe'is 6
appropriate, it works out that the way that Impell actually 7
implemented their work was there are many pieces to the 8
analysis.
9 For instance, they did use a 3 stick model so they 10 did pick up the response spectra inside the containment on the i
11 reactor pedestal.
Our comparisons right now are indicating 12 that due to their conservatism in their analysis, if you look 13 at our work today and then that, that there will be very few 14 additional mods or things required in additiot, to this 800, i
15 MR. LIAW:
My question to you was you think action 16 has been completed?
17 MR. MCCALL:
The action will be completed when we 18 finish calculations which demonstrate that what is out there f
19 is acceptable.
20 MR. FOX:
These calculations are ongoing.
They are 21 in process.
22 MR. LIAW:
I guess I will ask my staff have we 23 looked at the criteria?
24 MR. FAIR:
Let me start from the beginning as to why 25 this was tagged as an open issue at the audit.
HERITAGE REPORTING CORPORATION -- (202)628-4888
r 82 1
It was simply because TVA told me at the time of the 2
audit that they had'not finalized the criteria, so therefore, 3
the staff really hasn't reviewed any specific criteria 4
relative to the CRD system.
5 TVA is now telling me I guess that they are going to 6
finalize this criteria, and the question would be when are we 7
going to see it in some kind of a written form so we can 8
review it?
9 MR. LIAW:
Charlie?
10 MR. FOX:
I think the crit. aria are basically 11 consistent with the direction that we have been given by staff 12 for doing the rest of our analysis.
13 Is that not correct?
14 MR. MCCALL:
What he has to see is criteria, 15 Appendix A to criteria 7103; has to be revised.
That criteria 16 has to be reissued, and Mr. Fair has to see a copy.
17 MR. MOREADITH:
That is referring to using SRSS for 18 gang hanger loads.
19 MR. MCCALL:
I believe we can do that in 20 approximately two weeks.
21 MR. FOX:
I believe you will do it in approximately 22 one week.
I am telling you I want there to be no open 23 questions on criteria.
I want this resolved by the end of 24 next week.
25 MR. FAIR:
The other question we have, the staff has HERITAGE REPORTING CORPORATION -- (202)628-4888
83 1
not reviewed the specific details of this criteria because, 2
because TVA told us it was on hold, and therefore, didn't see 3
any purpose to going forth with that.
4 Your proposal to qualify individual piping forces by 5
SRSS, there is a published staff position on the use of SRSS.
6 It is NUREG 0484 I believe.
As long as you are in compliance 7
with the published NRC staff position, we have no problem with 8
that.
9 MR. TERAO:
I think that doesn't apply.
That is 10 combining loads all on one piping system, dynamic loads on the 11 piping system to evaluate the piping stress.
12 Now but I do have a question about if this use of 13 SRSS for gang hangers, especially on this system--
14 MR. FOX:
John, listen to the question.
i 15 MR. TERAO:
It is my understanding that piping are 16 all the same size, the same thickness, the'same material, and I
17 these gang hangers are spaced same distance apart, i
so 18 obviously the pipe is going to have the same frequency.
19 MR. McCALL:
What we find is that is not true in 20 that first, they are different.
They are different diameters, 21 three, 3 quarter and 1-inch piping, and secondly, when you go 22 out and analyze it, you get a spread of frequencies.
I think 23 the study that we have right now is showing 214, but I think 24 that if I may, that that's, that's part of what we were doing 25 was to perform--we understand that you and we also are HERITAGE REPORTING CORPORATION -- (202)628-4888
84 1
concerned about are these piping similar enough to justify the 2
use of some square methodology, and the way we are attacking l
3 tht or resolving that ourselves, and we would propose to share 4
among us, to actually take several systems, several piping 5
runs, and run them both individually so that we know they are, 6
their individual principles and characteristics, and then run 7
them as a group and compare the answer, and so the exact way 8
to combine the loads would be consistent with that study.
9 That study is underway and not complete, and that's 10 why, that's why I was thinking a couple weeks, Charlie, 11 because we need to get that study finalized.
12 MR. FOX:
We are not going to negotiate the schedule 13 here.
14 MR. TERAO:
Obviously that's an area that we will 15 have to review further use of the SRS for the gang hangers.
]
16 MR. LIAW:
You see any potential to hang up on this 17 one?
18 MR. FAIR:
Well, I don't think that TVA has 19 finished.
They just told you they haven't finished the 20 justification internally for the SRSS.
What John said is 21 correct.
So there, I guess there is a potential internal to 22 TVA that this proposed criteria may not work.
23 MR. LIAW:
Therefore, I take it that the staff might 24 have problems with the use of SRSS?
25 MR. FAIR:
I believe that we possibly have the same HERITAGE REPORTING CORPORATION -- (202)628-4888
85 i
1 problems that TVA is having right now trying to justify it.
2 MR. GOODWIN:
In other words, they have to prove 3
independence among the pipes before they use SRSS, is that it, 4
what you are saying?
j 5
MR. FAIR:
That's essentially correct.
6 MR. LIAW:
Okay.
Charlie, I'm sorry.
That one 7
remains open, i
8 MR. MOREADITH:
B.D.,
just for the record, notice 9
the last bullet.
We don't always try to say no change.
We do q
10 fix things; 800 mods, plus 3,000 clamps.
11 MR. LIAW:
That was before your time so you cannot 1
12 take credit for that!
{
I 13 MR. MCCALL:
Can we make it clear, though, that what 14 is open, what is open or what I think should be open should be i
15 only the issue of how you combine the forces from all these I
16 pipes, which is almost it seems to me more computational issue 17 than an engineering issue rather than a criteria issue.
18 The criteria issue is that they are being, what 19 seismic models we use and things like that.
20 MR. LIAW:
I don't care about concern.
When my 21 staff cannot tell me the configuration their staff to operate, 22 that to me, that issue remain open.
23 MR. FOX:
Okay.
Until you see the analysis', I 24 understand that, but does staff have any particular hang-up 25 with the approach that TVA is taking?
That's what we need to HERITAGE REPORTING CORPORATION -- (202)628-4888
I t
86 1
know.
That's why, that's what'we hoped to take away from this 2
meeting today is that staff thinks that TVA's approaching the j
3 problem right technically.
4 MR. TERAO:
Well, I would suggest this as--I am not 5
suggesting an approach, but what I am suggesting is that if 6
you had a piping system, a bundle of piping systems all with 7
the same size material, thickness, spans, that the loads from 8
that bundle of piping systems should be added absolute sum 9
rather than SRSS.
10 It is obvious that if you have pipes with what I 11 just described, they are going to have very similar 12 frequencies.
If you have a seismic load, if you have a 13 seismic event, the load resulting from those systems are very 14 likely to act at the same time in the same manner, and I don't 15 understand how SRSS could be justified.
16 Now if you have two bundles, if you had two sets of 17 bundles, one half inch and one three quarters, it is possible 18 that loads from those two bundles once you absolutely sum 19 those loads can then be SRSSed, but I think that's what you 20 are trying to work out, too, if I understand what you are 21 working on.
22 MR. MCCALL:
Okay.
Where we are is we have taken, 23 we have selected ten, ten of these pipes, and looked at their 24 configuration, not tried to skew the sample, but ten typical 25 type of pipes, and run stress analysis or run analysis on HERITAGE REPORTING CORPORATION -
.(202)628-4888
87 1
1 those ten as individuals.
i l
2 Then we have taken those ten and we have run them, 3
all ten, as a one big problem, and get the support reaction 4
from all ten, and then we.are comparing what is the support 1
5 reaction when we run all ten versus what would be each of the l
i G
individual ones?
7 And what we find is that the reason, the reason we 8
don't have an answer is because we have been--before we came 9
down here and said that we wanted to use SRSS, I wanted to be 10 sure that that, the pipes were indeed dissimilar enough that i
11 that would be the outcome.
12 What we find is that for instance, at one gang 13 support I was looking at this morning, that with SRSS, you 14 would estimate maybe 25 pounds or whatever the magnitude is, 15 and with the absolute sum, you would estimate maybe 50 or 60, 16 and when you look at actual results for the ten, it was I 17 think 26.
In other words,'it was within very little of the j
18 25, 19 The reason we are not presenting that study to you 20 is that there were somewhere, it was 25'versus 50 and other 1
21 cases where it was 27 or 28 versus 50, and 50--so it was a 22 little above the SRSS number, and I need to go back and 1
23 understand why that occurred and what, what are the attributes 24 that we need to use to identify those cases, but what I am 25 trying to say to you is that before we came down to propose l
l HERITAGE REPORTINO CORPORATION -- (202)628-4888 I
l
88 1
this, we verified ourselves that the frequencies of the exact 2.
runs when'you look at where the bends are, and remember that 3
when you have a tube, the bends are in different location in 4
length-wise for each one, for example, that when you actually 5
look at configurations, they are of different frequencies, and 6
we get a relatively wide range.
I think 2 to 14 frequencies.
7 MR. TERAO:
'fou can also have straight spans that t
8 don't have different frequencies.
9 MR. MCCALL:
That's right, and so we need, we need 10 to go through the system, but that, that kind of thing is not 4
11 what we are seeing right now.
We are seeing, in other words, 12 a lot of difference.
13 MR. FOX:
Incoherent frequencies.
14 MR. McCALL:
The reason we picked SRSS is because as t
15 we all know, a standard technique to combine incoherent things 16 of different frequencies is a seismic analysis, and that's why 17 we had proposed that.
18 MR. LIAW:
Okay, so we will look at it after you 19 complete it, and I guess you hear what we say I think.
It 20 looks like the potential issue, we are probably going to have 21 to wait and see the way the module responds.
22 MR. FOX:
And whether or not in fact we can 23 demonstrate that the frequencies are in fact incoherent.
That 24 is really the issue.
25 MR. LIAW:
Right.
I HERITAGE REPORTING CORPORATION -- (202)628-4888
89 l
1 MR. MCCALL:
But I think that the main thing we are 2
asking you is that we believe this is a good engineering way 3
to solve the problem..
4 MR. LIAW:
We say--
5 MR. FAIR:
To sum it up, the staff has not, did not f
)
6 take the time to review the criteria that was, that were in 7
the piping and support docttments because we were told it was 8
on hold.
We would like to see the actual criteria in black 9
and white and take the time to review the criteria to make 10 sure it is consistent with commitments and other actions that 11 have been taken on TVA before we give you the, our approval 12 and endorsement.
13 MR. MCCALL:
Okay.
14 MR. LIAW:
So TVA will come back with a schedule as 15 when we allow, are allowed to look at it, right?
16 MR. FOX:
Right.
17 MR. LIAW:
Let me ask you last question on this 18 subject.
19 MR. PIERSON:
I have nothing.
20 MR. LIAW:
Tell me a little bit about the nature of 21 modifications.
Do you have any modifications?
22 MR. PIERSON:
I think that was done as part of the j
23 Impell study.
24 MR. MCCALL:
The details of the modifications, in 25 general, in general, as I say, based on thermal loads and HERITAGE REPORTING CORPORATION -- (202)628-4888
90 1
thermal conditions, the U bolts were basically all replaced.
2 The U volts attaching here, some were removed from the thermal 3
movement.
Various resolutions there, and then the frames 4
themselves were strengthened, and as I understand, the 5
uni-strut is now a cover plated uni-strut, things likes that; 6
in other words, plates for welded to uni-strut to increase its 7
section properties.
8 Now I have not gone through those in detail, though.
9 In other words, it is just the kind of things you do to I
10 strengthen the support.
11 MR. LIAW:
Okay.
John, when are you going down to
'12 audit?
I 13 MR. CHENG:
Next week.
I 14 MR. LIAW:
Go to the field and look at some of the 15 modifications, ask them to point you what is being done.
Get 16 feel whether or not there is a potential problem.
17 MR. CHENG:
Okay.
18 MR. LIAW:
Know what I mean?
Done by quote, old 19 TVA, in the development sense, how to look at this; okay.
20 Thank you.
21 MR. FOX:
The next item is the engineering 22 mechanics, item 6, rod hangers.
23 MR. LIAW:
Whose call is it?
24 MR. MCCALL:
Okay.
The item with'the rod hangers is 25 that this is an item which has been discussed between us all HERITAGE REPORTING CORPORATION -- (202)628-4888
91 9
1 several times now, and it started with us suggesting and 2
proposing a displacement methodology.to make an engineering 3
judgment that the hangers were acceptable in compression, and 4
at this juncture, I believe it has come down to the, about the j
i 1
5 only remaining point is the question of us qualifying the 6
hangers to take compression, and maybe we should back up and 7
make it clear to everybody exactly what we are talking about.
8 Are you, would that--
9 MR. FOX:
I think everybody understands the issue.
10 Go ahead and cover the corrective action.
11 MR. MCCALL:
The corrective action would be that if 12 our analysis shows that there is no uplift, then--due to the 13 loads, then we would not do any modification, or do anything 14 further with the hanger other than to qualify it for the 15 downward load.
16 If the net uplift is determined to be there, then we j
17 would either qualify the existing support configuration, or we 18 would modify it so that it is qualified.
We would qualify it 19 using the pr"cedures that we use, and that's really the bottom 20 line.
21 MR. LIAW:
In terms of qualification, I take it that 22 you mean first develop a stable geometry so that it can take 23 compressive loads, and second, you go to ASV, the ratio, to 24 look at load carrying capability of the rods?
4 25 MR. MCCALL:
If you are going to qualify something HERITAGE REPORTING CORPORATION -- (202)628-4888
92 1
in compression, there is a, I guess three major things you 2
need to do.
3 First off, you need to make sure that you have 4
indeed a load path for it to travel down, and so you need to-5 either have in this case double nuts, or something there that 6
indeed will transmit the load.
7 The second point is one of stability, and there is I
l 8
two kinds of stability involved.
One would be where the piece J
9 itself, in other words, the rod hanger--often these aren't a 10 single rod hanger.
Often they are an assemblage of rod j
11 hangers.
12 Another question is could some element in that 13 buckle, you know, just based on axial load using a theoretical i
14 Euler-type buckling and backing off.
15 The other concern that you need to consider, is 16 there a stability issue relative to the source of the load or 17 some component moving relative to what is held, so in other 18 words, if you had a column being pressed together, if the top 19 and bottom are held stabally from moving to the side, it could 20 also fail.- You also need to do that, and so of course,1so you 21 have to also show that.
22 Now how do you show that?
There is, there is many 23 ways.
One way would be to show that the piping was rigid 24 enough or there was a horizontal hanger close enough that it 25 wouldn't permit it to move.
HERITAGE REPORTING CORPORATION -- (202)628-4888
93 1
Another way'might be there would be something else 2
in hardware, but our intent is that you need to address both 3
issues.
4 MR. LIAW:
So when you say one, some rod hangers j
5 will be modified, what kind of modification are you talking I
6 about here, nature of modification?
7 MR. MCCALL:
Oh, what kind of modification?
8 MR. LIAW:
Yes.
4 9
MR. MCCALL:
One thing is to replace the rod with a i
10 strut.
~
11 Another would be to, if it is missing the bolts or 12 shims, to make it able to take the load, and that would be to 13 repair that.
14 Another one, if the only issue would be side 15 swaying, the easiest fix would be to put in something to -
16 prevent the side sway.
17 The reason it gets to the one point, there is some 18 rod hangers you might fix, if there was a rod hanger and it 19 was a compression point, you might just add a little block or 20 something if it was close to the ceiling, a block to prevent 21 it from going up so that the hanger would take the load 22 downward and the block going up.
I mean--so there is a lot of 23 ways to fix it.
24 MR. LIAW:
You don't have linkage, the pin 25 connection, at both ends together?
HERITAGE REPORTING CORPORATION -- (202)628-4888
94 1
MR. MCCALL:
Right.
2 MR. FOX:
Stable geometry loads we discussed last 3
- week, 4
MR. LIAW:
Any question on that?
l l
5 MR. FAIR:
Just to put it, I guess the issue in 6
perspective again, this, the issue came up because the design 7
criteria had a care-by-case use of rod hangers as compression 8
members in there, which was a, a change to the design criteria 9
that have been employed by Sequoyah, and is, is not a 10 condition recommended by pipe hanger manufacturers.
That is, l
11 to use rod hangers as compression members.
12 At the exit, the position that the staff stated was 13 that within the bounds of doing typical analysis, that if you 14 were to make the rod hanger function as a strut, then that 15 would be acceptable solution to the problem.
16 So based on what John stated, I'm not quite sure how 17 that is going to be accomplished with the rod hangers, but I I 18 think our position is still the same as at the exit.
That is, 19 if you want to use it as a compression member, you have to 20 make some modifications so that it functions as a typical 21 compression member would function on a pipe support.
22 MR. LIAW:
Qualify--
23 MR. FOX:
If we plan to use it in that manner.
24 MR. LIAW:
Right.
25 MR. MCCALL:
Just a second.
Just a second, okay?
HERITAGE REPORTING CORPORATION -- (202)628-4888
- _ _ = _ _ _ _ - _ - _
J t
95 V
l 1
(There was a brief. pause in the proceedings.)
2 MR. LIAW:
Five-minute break.
3 (A brief recess was taken.)
4 MR. LIAW:
Back in session now.
)
5 MR. MOREADITH:
As a matter of technical interest, 6
we would like to ask one more question.
7 MR. LIAW:
Yes.
8 MR. MOREADITH:
Which would be a phenomenon related 9
to the analytical consideration of rod hangers; and maybe 10 it's, maybe after the question is asked, and Dave and/or John 11 or all of you say no, or you say yes, then perhaps we should 12 leave it at that, because I don't think.we want to get into an 13 extended somewhat esoteric technical discussion on the issue.
14 In analyzing a system, a sub-system, with rod 15 hangers, and of coursemodeling it for a' linear elastic 16 analysis, and assuming for the initial analytical pass with 17 the basic loads that the rod hangers will stay in tension, all 18 right, and if you analyze it and they do, then you have gotten 19 a good result.
20 If you analyze it and say one of them does not, 21 let's say it's a sub-system with three or four rod hangers and 22 one of them does not, all right, then you know that your 23 linear elastic analysis is invalid because--and let's assume 24 for the moment that the rod hanger has no upward, no downward 25 resistance, in other words, no capability to resist the upward HERITAGE REPORTING CORPORATION -- (202)628-4888
96 1
movement, in other words, it will not behave as a co.mpression 2
effort, so your analysis is invalid because when it is moving 3
up, it is moving with the different dynamic characteristics.
4 And you might agree it is moot saying you have to, 5
that what you have there is a non-linear geometry behavior 6
during the dynamic event.
You don't necessarily have a 7
non-linear material condition.
All right.
8 If one could properly justify through some 9
engineering calculations, and I'm not even going to try to say 10 what they are, that the non-linear geometry behavior during 11 the analytical event, including the seismic, that the, that 12 the system and the supports were within the acceptance limits, 13 and in spite of the non-linear geometry--
14 MR. PIERSON:
Based on your non-linear--
15 MR. MOREADITH:
Non-linear consideration, in other 16 words, take into consideration somehow through valid 17 engineering calculations the non-linear geometric behavicr, 18 would the staff find such a calculation acceptable, 19 automatically unacceptable, or don't know?
20 MR. FAIR:
I can answer that question.
We discussed 21 that particular issue a couple of meetings back, and the 22 staff's position on that particular issue, that when you got 23 to that level of complexity, to try to do a non-linear 24 analysis with two different bounding conditions, one you can 25 uplift and one you can come back down and input, that level of HERITAGE REPORTING CORPORATION -- (202)628-4888
97 1
sophistication of an analysis also requires a level of 2
sophistication of knowledge.of the bounding conditions and the 3
input conditions such as whatever pre-stresses existing on the 4
pipe or whatever uncertainties were existing in the known 5
download on the pipe, and by the time you tried to, to 6
quantify those considerations, we considered that as almost an 7
impossible type of analysis to come to technical agreement on.
8 We didn't say that such an analysis is not 9
acceptable, but we think that.by the time we get done arguing 10 about how do you do the bounding analysis for that case, it 11 will take quite a bit of time to resolve.
l 12 MR. TERAO:
That's a no.
13 MR. FOX:
Thank you, Dave.
14 MR. MOREADITH:
That was almost as eloquent as--
15 MR. LIAW:
Basically I agree with what John is 16 saying.
I think you can agree, too.
I mean here we are 17 talking about little bit hangers, and I don't think it take 18 too much time, too much to modify, 19 MR. MOREADITH:
We do not disagree.
20 MR. LIAW:
Theoretically speaking, I don't disagree 21 with you, but we talk about maybe relatively simple stuff.
22 MR. MOREADITH:
The time and energy and money spent 23 to resolve would greatly exceed the time to modify a hanger.
24 MR. LIAW:
We got a message from Cruthfield 25 yesterday.
It is difficult for me to explain to the HERITAGE REPORTING CORPORATION -- (202)628-4888
98 1
Commission what non-linear analysis consists.of.
2 MR. FOX:
May have been, we have too many Ph.D.s in 3
the room.
We need more blacksmiths.
l 4
MR. LIAW:
I don't have a problem--you send some i
]
5 problem to North Carolina State for Ph.D. dissertation, I l
6 don't have a problem with that.
7 MR. FOX:
Okay.
8 MR. LIAW:
I guess the only question, well, you 9
understand my position, our position, right?
10 MR. MOREADITH:
Yes.
1 11 MR. FOX:
Why don't you summarize it, your position, i
1 12 in the non-linear analysis or the non-l'inear considerations?
13 MR. MOREADITH:
Why don't we summarize it and see if 14 they think we understand what they are talking about?
15 MR. LIAW:
We will summarize to you.
You tell me if 16 you disagree.
Principally just two things--one, stable 17 geometry that is able to compress flow.
18 Once past that, next thing you need to check is 19 ratio, after AISC column equations based on whatever, you 20 know, you have, and I think there are explicit criteria there.
21 And in fact some of you are aware of, I have seen some--the 22 one you had before?
23 MR. FAIR:
I think we restate the position that L
24 normal structural evaluation compression members is acceptable i
25 to us provided that they are modified to function as l
HERITAGE REPORTING CORPORATION -- (202)628-4888
99 1
compressive members.
2 MR. MOREADITH:
Or inherently capable function.
3 MR. LIAW:
Inherently capable.
4 MR. PIERSON:
I have one I would like'to bring up 5
before we close this issue.
l 6
I have one question.
The last bullet here, that out 7
of the 300,000 rod hangers, you will perform modification on a 8
hundred pre-restart and 200 post-restart.
9 Could you amplify on that some more?
10 MR. FOX:
The program is ongoing.
11 MR. MOREADITH:
It is a complete estimate.
1 12 MR. GOODWIN:
What is the criteria by which you l
1 l
13 divide into two, into two bins pre-and post-restart?
14 MR. MOREADITH:
I could only give you an example, 15 one example that I have looked at at this point.
I looked at l
16 one sketch yesterday at the site.
Was it yesterday?
17 MR. FOX:
Day before yesterday; it was Tuesday.
18 MR. MOREADITH:
Tuesday or Wednesday.
19 MR. FOX:
The days are all running together here.
20 MR. MOREADITH:
And it was a hanger, but it w&? an 21 angle bolted top and bottom clamps.
Now it is conceivable 22 that that hanger could exceed the restart criteria, but 1
23 not--am I clear?
i 24 I mean it would satisfy the restart criteria, but 25 not the final criteria.
HERITAGE REPORTING CORPORATION -- (202)628-4888
100 I
1 MR. GOODWIN:
So what you are saying is we are right 2
now predicting that we will have 100 to replace because they 3
don't meet the restart criteria that we have agreed to, and we 4
have 200 more that will moet the restart criteria but not the 5
final design criteria?
Is that what the--
6 MR. MOREADITH:
May turn out to be the other way 7
around.
May turn out to be a hundred mods--
8 MR. FOX:
The key is whatever we have done we will 9
subject to the restart criteria.
10 MR. PIERSON:
I understand.
11 MR. FOX:
Wherever we are.
12 MR. FAIR:
M'aybe it would help to clarify that the 1
13 question on the table that we are trying to resolve is whether 14 rod hangers can be used to take compressive predicted uplift.
15 I think the basis for the question is are we talking about I
16 mods for this particular instance of uplift load, and if we 17 are, how will we make a differentiation between pre and post 18 because they both are buckling considerations.
19 MR. MCCALL:
I think maybe to go back, and we need 20 to recall there is some, there is really two kinds of problems 21 out there that we have agreed, or two ways to do it that we 22 have agreed to already.
23 One set is we have a 35 percent sample, and for the 24 35 percent sample, we take--and for the 35 percent to 25 acceleration response spectra, analysis for those 35 percent, HERITAGE REPORTING CORPORATION -- (202)628-4888
101 1
and then we find some modifications or find some issues and 2
then we design, we either, if it has to be modified, then we 3
design a modification at the final criteria, and if.it needs 4
operability criteria based on'the acceleration response 5
spectra analysis, then we modify it post-restart.
6 Then within the 35 percent, 20 percent of those we 7
are also analyzing by time history analysis, and those time 8
history analyses then are also going back and looking at those i
l 9
20 percent of the problems and identifying attributes, so we j
l 10 would look at whether hangers are failing or succeeding within
~
11 that 20 percent, so then we take those attributes and look at 12 the other 65 percent of the plants.
13 Now so there is two groups out there, and what we 14 are anticipating here is that the second 65 percent of the 15 group, the hangers, the rod hangers that were out there, 16 fixing that would be based on this horizontal attributes from 17 the time history analysis, and secondly, they would have to be 18 based on some other estimate or evaluation on the upper load 19 because you will recall we don't have direct stress analysis 20 on those.
So there is, there is really the two, the two 21 groups out there that we are working on.
22 MR. MOREADITH:
Can we go back to his original 23 question?
24 MR. MCCALL:
That's I think your question.
25 MR. MOREADITH:
His original question.is because I HERITAGE REPORTING CORPORATION -- (202)628-4888
4 102 4
1 just made a misstatement earlier.
Not being that familiar 2
with the details of the criteria, I was assuming that for 3
compression loads, that there was a restart level of 4
acceptance, and a post-restart level of acceptance.
I have 5
just checked with Alan Chan, and that is not the case, so my 6
. earlier statement was incorrect.
Okay, and what John just 7
described is why some may be deferred.
8 MR. GOODWIN:
So the 200 are, if I find a hundred 9
that are buckling in 35 percent, I expect to find 200 more in 10 the other 65 percent that I won't catch until after restart?
i 11 MR. FOX:
No.
~
12 MR. MCCALL:
I am going to find some number in the 13 35 percent.
I don't know it.
See, you have to remember that 14 as John observed, we have taken the methodologies that we had 15 proposed the middle of last year and we have done analysis on 16 the 35 percent, and we know the effect of that.
17 One of the key things in that analysis is either 18 using--and we did some of them.
One, we did them on all one 19 of two ways.
Either we just used the ZPA ground motion, or we 20 used the ground motion without amplification in the building, 21 and since that analysis was done, then in Tom's discussions 22 with us, we have basically added a vertical model to the 23 analysis which is there is a frequency of 12 or 14 Hertz, 24 Now we have, while we have redone much of the 35 25 percent analysis, we haven't gone back and looked at the HERITAGE REPORTING CORPORATION -- (202)628-4888
103 1
effect of all that.
Based on what we did before, and where we 2
are, our guess was that out of all of them, the hundred 3
percent, you would see a hundred or so mods, but we wanted to 4
be clear that there,will be post-restart due to both causes, 5
both issues, one being, one being the fact of well, T guess 6
the primary difference being issue on the time history, and 7
the horizontal sample versus the detail stresses.
8 MR. LIAW:
I don't know.
9 MR. GOODWIN:
Does anybody else understand that?
10 MR. PIERSON:
I don't understand it.
11 MR. MOREADITH:
Let me try.
12 MR. LIAW:
Time out--why are we making this so 13 complicated?
Principally a hanger is just a hanger, and I 14 think 35 percent, you know approximately what size and how 15 long a hanger, do not have any compressive capability at all.
16 Why couldn't you just go out and look at 65 percent and those 17 hangers just either modify or get rid of it?
18 MR. MOREADITH:
Could we go off the record a minute 19 and let me try to tell you what I think we said, then come 20 back on the record?
21 MR. LIAW:
We are in public.
22 MR. PIERSON:
We can break for a conference, but I 23 think if we need to describe it, you need to put it on the 24 record.
I 25 MR. MOREADITH:
I am not sure I can describe it HERITAGE REPORTING CORPORATION -- (202)628-4888
\\
104 1
properly and I didn't want to try three times before I have 2
got it right.
3 MR. PIERSON:
Five-minute break.
4 MR. GEARS:
Let's break for lunch and then meet back i
5 at one.
6 MR. MOREADITH:
I have got to head for the Metro at 7
one o' clock or I'm going to miss a plane, and we are almost I
8 through I think.
I 9
MR. FOX:
Let's take a five-minute break.
10 (A brief recess was taken.)
11 MR. LIAW:
Back in session.
~
12 MR. FOX:
Okay.
Very quickly, we wan't to take the 13 numbers off.
The numbers are confusing you.
They are 14 confusing us.
We don't understand the 100, 200 either.
Now 15 what we would like to do is explain specifically what we are 16 doing.
John?
The numbers will come out whatever they are.
17 MR. CHENG:
Can we wait for John to come back?
18 MR. FOX:
Sure.
John, what I just said is 'that the i
19 numbers 100, 200, 300, have no meaning.
We are going to 20 explain to you what we are doing, and the numbers are going to 21 come out whatever they are, so we would like you to mark the 22 numbers on your slot, Just delete the bullet.
Let us tell 23 you what we are doing and let's see if you agree in principle 24 with what we are doing.
25 MR. MCCALL:
If I can, I would like to use the HERITAGE REPORTING CORPORATION -- (202)628-4888
105 1
blackboard, but I will express what is on the blackboard in 2
words if we can, and as I go, if there is any questions, maybe 3
we can discuss them.
4~
The problems in the program that we are discussing, I
5 the vigorous analysis program, are broken really into three 6
separate groups.
The first group is a 20 percent group of 7
problems.
The second group is 15 percent, and the third group 8
is 65 percent.
9 Now the first group, the 20 plus 15, constitute the 10 35 percent that we have advised you that we would complete 11 prior to restart, so for that 35 percent, both for the 20 and 12 15 percent, we will do acceleration response spectra analysis, 13 and we will make modifications to those systems based on the 14 results of that analysis.
15 In other words, we will find mods, including rod 16 hangers, things that need to be modified, and where they need 17 to be modified, we will modify them to long-term criteria.
We j
18 will decide whether that modification is pre or post-restart, 19 based on the operability criteria as it is called, or the 20 restart criteria.
21 Now then, in addition to that, since we are only 22 analyzing 35 percent of the problems, we have reached an 23 agreement on what we do with the other 65 percent, and for 24 that 65 percent, we are doing the following.
25 First, we are performing time history analysis on i
HERITAGE REPORTING CORPORATION -- (202)628-4888
106 1
the group of 20 percent,. and we are taking that time history 2
analysis and we:are looking at what hangers or what things do 3
not meet operability criteria.
Those things that do not meet 4
operability criteria based on the time history analysis we are 5
evaluating to determine what generic attributes or what things 6
about that hanger or item resulted in it not meeting the 7
criteria for the time history analysis.
8 Taking that things or attributes, we.are then 9
creating a punch list and going through the other 65 percent 10 of the plant using that punch list, and that's what we have 11 heretofore called the horizontal attributes evaluation, the 12 horizontal walk-down for the whole plant.
13 Then after, after restart, we will the,n be 14 continuing, and we would be doing acceleration response 15 spectra analysis for that group of 65 percent which would be a l
16 continuing process, and out of that will also come i
17 modifications.
18 What we are saying here is that we have not yet 19 developed these attributes because as I explained earlier, we 20 have not yet evaluated all the supports associated with this 21 first 20 percent using the time history analysis.
Thus we 22 don't know the attributes at this time.
From the work we have 23 previously done, we see very few attributes applied to this 24 rod hanger issue.
25 Now there is a couple reasons that could be, one of HERITAGE REPORTING CORPORATION -- (202)628-4888 l
107 1
them being that we use lower vertical input motion than we are 2
using today in the new analysis, so we'are in a situation not 3
knowing exactly what the modifications are or what this will 4
result in, but it was, what we are doing is that we will have 5
horizontal attributes from the time history.
6 MR. LIAW:
I understand it and I think it is okay 7
except one thing--you say that additional ARS review of the 8
remaining 65 percent will be done after restart.
That is 9
generally correct except I want you to know that we are not 10 saying you are to stop for restart.
We-are saying that you 11 are to continue with good faith effort, you know.
12 MR. PIERSON:
Let me ask you a question.
13 MR. LIAW:
Irregardless when you start your point.
14 MR. FOX:
That is estimate based on perceived 15 schedule and a rate that we are undergoing.
I 16 MR. LIAW:
I basically agree with what John was 17 saying.
18 MR. GOODWIN:
It also represents a commitment.
19 MR. FOX:
No, it does not.
20 MR. GOODWIN:
Then you have not committed to doing 21 35 percent?
22 MR. FOX:
He haven't made a commitment.
23 MR. LIAW:
Originally it was what, 50 percent?
24 MR. FOX:
I don't remember a commitment.
I remember 25.
that we said we would, that the rate based on the schedule HERITAGE REPORTING CORPORATION -- (202)628-4888
108 1
would be about thus and so.
I did not make a commitment.
I'm 2
not aware.
3 MR. LIAW:
There was a commitment.
4 MR. PIERSON:
B.D.,
if he doesn't understand there 1
5 is a commitment, we don't have it written down, we don't have 6
a licensed documentation to say that, then let's not quibble j
i 7
about whether 35 percent or 30, 40, now.
8 MR. FAIR:
Could I stop you?
Regardless of TVA's 9
commitment, the NRC staff had put down in the meeting summary 10 of last March what it accepted.
l 11 The staff's acceptance of TVA's program as stated in 12 that meeting' summary was contingent on approximately 50 13 percent of the work being done.
This 35 percent completion 14 was a recent modification that TVA'put in on their schedule, I
15 and the staff has neither accepted it nor rejected it at this 16 time.
17 MR. PIERSON:
Let me ask--
18 MR. FOX:
So you are saying that you made it a 19 requirement.
I am telling you that we never made a 20 commitment, but if you made a requirement--
21 MR. LIAW:
No.
The requirement is too strong a 22 word.
We have a general understanding about 35 percent.
23 Originally the understanding was about 50 percent.
l l
24 MR. FOX:
That I have no problem with.
\\
25 MR. LIAW:
Right.
I feel comfortable with that.
HERITAGE REPORTING CORPORATION -- (202)628-4888
109 1
Continue with that.
2 MR. PIERSON:
Let me ask one thing that I think I 3
see missing here.
We are all sitting here talking about 4
operability of pipe supports.
Presumably the plant will be 5
operating within that G5 percent.
6 If you find a pipe support that is quote, not 7
operable, what are you going to do?
Enter tbre action 8
statement of your LCO?
9 MR. LIAW:
Yes.
10 MR. FOX:
No doubt about it.
11 MR. PIERSON:
Then it seems to me that if we could 12 talk about some numbers that we don.' t know what :it could be 13 but it could be a couple hundred maybe, it could be ten, it 14 could be 50.
We don't know.
15 MR. FOX:
That's the point.
16 MR. PIERSON:
You're likely to get yourself into a 17 position by going to restart where you are effectively 18 inoperable.
You can't operate.
Every few days you are 19 finding one of these problems.
20 Have you considered that factor?
I 21 MR. FAIR:
Let me add to this.
We had a--
22 MR. LIAW:
Just answer his question.
Yes, TVA is 23 taking a calculated risk that they might get themselves into 24 this situation, and that was understood.
25 MR. PIERSON:
And we are under the understanding HERITAGE REPORTING CORPORATION -- (202)628-4888
i 110 l
1 that we will accept or reject these things based on the LCO 2
and no last-minute crunching out of a justification for 3
continued operation and that sort of thing?
)
1 4
MR. LIAW:
I don't understand your question.
5 MR. PIERSON:
What I am saying, the plant is 6
operating at a hundred percent.
One of the supports becomes 7
They are entered their LCO condition.
They don't 8
come to us and ask for a JCO to continue operating.
9 MR. CARIER:
As part of the tech'opecs, you have to 10 do that engineering valuation, i
11 MR. GEARS:
It was an issue that David and I and Pat 12 worked on a tech spec change where they originally had some 4
1 13 strict requirements on restraints and supports which said they l
14 had to go into a pretty quick LCO.
l 15 Right now, it gives them a latitude, Dave, to do it l
16 within seven days.
I don't recall the negotiated settlement, 17 within seven days do an engineering analysis to determine the 18 operability?
19 MR. TERAO:
No.
It basically said I think it was 20 three days to make a judgment call on the operability of the 21 support system, and per IE Bulletin 7914, they are allowed 30
'22 days to do a detailed analysis to support that judgment.
23 MR. GEARS:
We realized this was a potential 24 problem.
We have in writing what we find is an acceptable i
25 position for making, for them to make their operability en11s.
HERITAGE REPORTING CORPORATION -- (202)628-4888
W 111 a
1 Agreed?
i 2
MR. LIAW:
Yes.
f 3
MR. TERAO:
Yes, but I would also like to add that k
4 their engineering evaluation, their walk-down of all these l
5 piping systems, including the 65 percent, is intended to-flag 6
any major problems up front so that the impact of any 7
modifications later on should be much less.
8 MR. CARIER: 'That is correct.
9 MR. LIAW:
In a sense we all understand what it is 10 and we are taking a calculated risk.
11 MR. CARIER:
That is correct.
3 12 MR. LIAW:
And that includes the hundred percent 13 walk-down before restart.
That's your commitment.
14 MR. FOX:
What now?
15 MR. LIAW:
Mundred percent walk-down before restart, j
16 MR. PIERSON:
Are we'taking a calculated risk on the 17 safety of the plant, or calculated risk in the operability of 18 the plant?
19 MR. LIAW:
Safety of the plant--I'm sorry.
Time 20 out.
Time out.
I'm sorry.
21 MR. GOODWIN:
Please correct the record on that.
22 MR. LIAW:
We are calculating risk on the 23 operability, not the safety of the plant.
24 MR. GOODWIN:
I have attempted to refresh my memory 25 on what I thought I remembered from the discussions about a HERITAGE REPORTING CORPORATION -- (202)628-4888
112 1
year ago, and what I read from our minute notes and what was 2
consistent with my memory was that the purpose ~of establishing 3
percentages was such that the staff had what they considered f
4 an adequate sampling-of the, of all configurations and j
5 components in that project.
6 And the number, the number that was thrown around at j
7 that time was approximately 40 or 50 percent, and that was not j
8 a warranty that if you completed 40 or 50 percent, we would 9
find the plant acceptable for restart.
I 10 What it really was, was if you have done 40 or 50 11 percent, and we find that the rejection rate is acceptably 12 low, that we would assume that the 40 or 50 percent sample is I
13, representative of a plant where the number of problems is not 14 unduly large.
15 Also we said that you will complete 20 percent.
We 16 will do an initial audit, and at that point, if we find the 17 rejection rate unacceptably high, we may say that the program 18 per se is unacceptable and we are back to ground zero, so 19 there were the two criteria.
Now that, we were dealing with 20 40 or 50 percent based on your schedule then.
21 Your schedule of doing analysis and doing 22 modifications has' slipped, and I believe there have been oral 23 discussions, and your projection was well, perhaps we will 24 have 35 percent done by restart, and though we have not in 25 writing said that is acceptable, i t was, I believe that HERITAGE REPORTING CORPORATION -- (202)628-4888
113 1
probably it was fair to categorize our informa) responses 1
2 that's close to 40 or 50, but you start moving back toward 3
that 20, and suddenly we are in the. position where we have got 4
to justify the safety of the entire plant on a quite small f
5 sample, which makes you uncomfortable.
6 MR. FOX:
I think I can straighten this out.
First 7
or all, you used the word minimum of 35 percent.
We have i
8 written direction from you saying approximately.
I said 9
about.
The issue I took was with the specific minimum of 35, j
10 which we were saying was approximately 35, and in a letter of f
11 December 22nd, 1988.
12 MR. LIAW:
Okay.
13 MR. FOX:
What we are saying is that based on the 14 proceeding schedule and based on the rate, we thought it would 15 be about 35.
You made a very explicit statement, a minimum of l
16 35.
1 i
\\
17 MR. MOREADITH:
I would like to pick up on what Ed 18 said and just change a few words to change the tone a little 19 bit.
20 I think what we are both agreeing is we have a 21 provisional agreement pending us doing certain percentages of f
22 work, identifying certain modifications in another certain i
23 percentage of work, and then defining for the balance of the i
24 work those type of supports which have proven to be typically
)
i 25 needing modification because of something and going out and
[
HERITAGE REPORTING CORPORATION -- (202)628-4888
)
J 114 1
finding all of those supports and modifying them, j
2 MR. FOX:
Specifically the guidance that you gave j
'3 me, B.D.,
is when you do this and the report card you are 1
4 going to get based on this first audit of the approximately 20 5
percent, we are going to look at you as to how well you have d
6 done what you have done, how well you have developed those 7
horizontal attributes and then pushed them through the j
8 analysis.
9 MR. LIAW:
So endorsement we give you was the 10 methodology for doing it appeared reasonable to us.
I think 11 that was stated in the report which we sent you.
And back to 1
12 Bob Pierson's question' earlier, I just want to get it 13 perfectly clear, yes, we are taking a calculated risk on the I
14 operability.'
They understand they might run into situation i
15 when they have interaction statement except the action
.)
16 statement will be somewhat modified as described by Jerry 17 Gears, what, three days underlying problem?
18 MR. GEARS:
I can't remember.
It is on the record.
19 It is a formal transmittal to you.. Dave may remember.
20 MR. LIAW:
We have that, 21 MR. GEARS:
We made sure that it was explicitly 22 stated when you got into that situation you know what we 23 wanted.
24 MR. FOX:
Yes.
I think we have a good, clear 25 understanding of it.
a HERITAGE REPORTING CORPORATION -- (202)628-4888
115 1
MR. LIAW:
So in that case, why don't,we go back l
2 there to audit?
We find that you do such a lousy job in 3
extrapolating to the remaining 65 percent in identifying the 4
mod, that required to be mod and you miss it, then we will 5
call time out and regroup again.
6 MR. FOX:
One of the reasons--I want to address a 7
comment you made very early in the meeting, B.D..
One of the l
8 reasons why I choose the word approximately rather than 9
minimum of 35 percent, TVA, if I am misunderstanding or 10 whatever else, did a lot of ATH work, time history analysis, 11 which has no benefit to TVA.
It was contrary to what the 12 staff perceived as their part of the agreement, so we had some 13 wasted motion there.
l 14 MR. MCCALL:
This is the 20 percent on the board.
15 MR. FOX:
I know.
I am telling you--do we not have 16 some wasted motion, Alan?
17 MR. CHAN:
In terms of the production, l
18 MR. FOX:
That is exactly what I am talking about.
19 I will talk about it in terms.of production.
20 MR. MCCALL:
But for the horizontal sample, we had 21 to do--
22 MR. FOX:
I am talking about the cale of record.
23 MR. PIERSON:
Well, I would like to add one thing.
24 You are saying approximate and so forth, but reading this, 25 this letter here, which was an internal memorandum from B.D.
HERITAGE REPORTING CORPORATION -- (202)628-4888
-~
116
~
1 Liaw to Susie Black, which I presume was transmitted to you as 2
part of the meeting, agenda for a meeting on the 17th of 3
November, 1988, it says TVA's completion analysis of 35 4
percent of pipe is the originally proposed methodology.
TVA's 5
current schedule projects that reanalysis of this 35 percent 6
to the criteria agreed to at September 9,.1988 meeting, and 7
will be complete in March 1989.
8 And there is nothing there that says approximate.
9 It is very clear it means 35 percent.
10 MR. GOODWIN:
You stated approximately in your 11 letter.
12 MR. FOX:
No.
Your letter to us dated December 13 22nd, 1988, says approximately.
14 MR. MASSIE:
It is dated December 14th, 15 MR. FOX:
It is stamped received December 22nd, i
16 excuse me; December 14, 1988, Docket No. 5260, Susie Black, to i
17 Oliver Kingsley.
I see it--to reanalyze approximately 35 18 percent of the 200 and do stress problems using rigorous 19 piping stress analysis before Unit 2 restart, the remaining 65 l
20 percent, and it goes on.
21 MR. PIERSON:
Well, do we have any questions or 22 comments about that?
23 MR. FAIR:
Yes.
I would like to clear up and stop, 24 stop the haggling over the approximately or the exact 35 25 percent.
HERITAGE REPORTING CORPORATION -- (202)628-4888
117 1
If I go, if we go-ba.ck to the original agreement 2
that the NRC has not endorsed the program by the March meeting-q 3
summary until we do a final pre-restart audit on how well this 4
program is functioning, the part of this program that hasn't 1
5 been explained is No.
1, we haven't accepted any specific
.6 figure as the number that's acceptable prior to restart.
7 What the NRC wants is that TVA do as much of the 8
rigorous analysis prior to restart as possible And not have to 9
rely on this generic extrapolation.
10 What we have stated in a couple of meeting summaries i
11 is that, is that we wanted TVA to proceed with this-work in an l
l i
12 expeditious fashion, and not to halt it at any given figure of 13 completion.
14 The other thing is what TVA is intending to do at 15 least what they have stated to us in the emergency meeting, 16 was to do a check of this generic extrapolation by taking some 17 sample problems and doing the rigorous analysis to make sure 18 that they are not missing anything, so that this whole 19 acceptance of these generic attributes won't be finalized 20 until you are about ready to go to restart.
~
21 The other issue is that if it were to come out 22 during restart, after restart that 200 out of 300 operability 23 modifications were missed, then that would say that the 24 program was not very well implemented.
25 I think in our November discussion on the HERITAGE REPORTING CORPORATION -- (202)628-4888
118
\\
1 presentation of this generic extrapolation, it was the intent 2
to do this in a conservative fashion so that very little or 3
few modifications to operability would be identified.during 4
operation, and that I think was the intent of TVA and that is 5
the intent of the staff in this program.
6 MR. LIAW:
I just want one more thing here.
I 7
really don't want to argue over exactly 35 percent or 50 8
percent or approximately, you know.
It doesn't matter.
9 The important thing is we, we have a general
)
10 understanding that utility proceed in good faith with your i
11 effort of rigorous analysis, okay, and at some point in time, 12 before restart, the staff through audits will make a judgment j
i s
13 whether or not you are doing a good job in identifying those 14 mods in the remaining 65 percent.
I can tell you example.
If 15 we started look and find out, you know, population of like ten
..{
16 supports, for example, and we start to find'something like two 17 or three out of them should have been modified, you miss it, j
18 and we will probably come to you very quickly, call time out.
19 MR. FOX:
The whole intent of my remark was that 20 what we do we want to do very high quality.
Our commitment, 21 the requirement that you mentioned in the letter that Ed 22 Goodwin has a copy of there, was approximately 35 percent.
23 Al1 I wanted to say about mentioning that is that I 24 am putting the emphasis on quality, not on quantity.
We have j
25 said we will take a target of approximately 35 percent, not a HERITAGE REPORTING CORPORATION -- (202)628-4888
a 119 I
1 minimum or--
1 2
MR. LIAW:
Charlie, I understand what you are f
3 saying.
]
1 4
MR. FOX:
Quality is what is so important, doing it 1
5
- right, j
i 6
MR. LIAW:
You will demonstrate your quality when we 7
go back to look at it.
If you will star' see a lot of, you 8
know, mods that need to be marked, you miss it, then your i
9 quality argument will be down the drain.
10 MR. FOX:
Absolutely.
11 MR. LIAW:
Let's leave it at that.
Any problem--
12 MR. PIERSON:
Are we ready to proceed then to.the 13 next issue, CSG 19?
1 14 MR. FOX:
I think the next issue just walked out the 15 door.
16 MR. FOX:
Try well clip anchor.
17 MR. MOREADITH:
I think maybe on this we have a 18 non-issue at this point.
19 MR. LIAW:
I'm glad to hear that.
20 MR. MOREADITH:
Let's see if it works'out that way.
21 I will be cautiously optimistic.
22 As Charlie indicated to you on Friday, in relation 23 to our use of test results, and interpretations to eliminate 24 some modifications, Charlie indicated to you that we would fix 25 what needed to be fixed and we are committed to that.
HERITAGE REPORTING CORPORATION -- (202)628-4888
120 1
We are revisiting the test results, re-interpreting, j
l 2
and we have not completed that, but we will, what we will come 3
up with is a much sounder technical interpretation and use of i
i 4
the test results.
l l
5 That is estimated to have some impact on reducing l
I 6
the modifications, but it will not eliminate all i
l i
7 modifications.
I 8
We are currently estimating in the neighborhood of 9
30 additional modifications.
l I
10 We have previously made over 80 modifications l
11 already to date, so this is another case of where we are not i
12 trying to avoid, in other words, we are not trying to engineer 13 away everything.
We are only trying to accept what should be k
I 14 accepted and we are modifying what should be modified, i
15 Now that's a summary of the platform clip angle 16 question.
1 17 MR. LIAW:
That's fine, Fred, except now by not l
l l
18 defining the criteria, then we have the issue still open l
19 there.
20 MR. MOREADITH:
Well, it is my understanding Tom 21 will be at the site next week, and if our interpretation is l
l 22 satisfactory to Tom, would that not completely clear it up?
23 MR. LIAW:
Because the conversation I had with j
24 Charlie was you would not use any test results to develop l
25 criteria.
Is that not the case any ore?
Is that the message HERITAGE REPORTING CORPORATION -- (202)628-4888
l 121 a
1 you are giving me?
2 MR. MOREADITH:
I don't know.
3 MR. FOX:
Well, look, we met before I came up here 4
last week and the decision paper and the discussion was that 5
we would not use test data.
At that time, I thought that the 6
staff was objecting to the fact that TVA was attempting.to use l
7 data from uncontrolled non-OA tests.
8 The reason that we brought this thing back up was we 1
9 felt like if we could.do controlled tests that that data of OA 10 program pre-determined criteria--
11 MR. LIAW:
Charlie, you are saying the tests have 12 not been done yet?
13 MR. FOX:
What I am saying--
14 MR. MOREADITH:
That was a misunderstanding last 15 night.
Let us tell you what we think your concern.was, and we 16 think your concern was that we had misapplied test data.
17 MR. CHENG:
No.
Let me clarify that.
18 MR. MOREADITH:
Okay.
19 MR. CHANG:
Before I do that, I would like to give a 20 little background or history.'
i 21 In March and April last year, TVA proposed what it l
L 22 called interim criteria fore platform steel structures.
At 23 that time, the purpose of the proposing this criteria is 24 because TVA cannot meet FSAR criteria stating it's Table 25 12.2.16.
In that criteria, the stress was limited to.9 F sub HERITAGE REPORTING CORPORATION -- (202)628-4888
122 Q
1 Y,'so that's why TVA proposed using 1.6 times S.
'The S is the 2
allowable defined in the AISC specification, and based on AISC 3
requirement, the F sub Y, of course, and then the S defined 4
equal to.75 F sub.Y; in other words, for the plate bending in 5
the weak axis is allowed.75 F sub Y.
6 If you multiply 1.6 times
.75, it is equal to 1.2 F 7
sub Y.
In other words, you go beyond yield for 20 percent 8
about, so the staff issued SER for interim purpose.
The staff 9
accepted that, and in your calculation done in early
'87--
10 MR. LIAW:
Just a minute..You say something, the 1
11 staff accepted that 1.6 interim criteria?
h 12 MR. CHENG:
Times S.
13 MR. LIAW:
I know what S is.
You say staff accepted 14 that as interim base when was it?
j l
15 MR. CHENG:
July 26 staff isued SER, 26th
'88.
J i
16 MR. MASSIE:
TVA submitted interoperability criteria 17 3 of '88 which did not include the test results, and Tom Cheng 18 reviewed that interim criteria and wrote an SER dated July of 19
'88 which accepted that as submitted criteria.
That's my 20 recollection.
And he came down for April audit, and noticed 21 that the criteria had been revised to incorporate test 22 results, and was questioning why.
23 MR. LIAW:
I guess what you are saying is the 24 original approval of 1.6 times S in which S is based upon 25 whatever, minimum value normally is understood to be something HERITAGE REPORTING CORPORATION -- (202)628-4888
123 l
s 1
like.75 S sub Y, but in view of taking,the value from AIC you 2
are going to get that from test, testing.
Is that correct?
3 MR. CHENG:
No.
The test is something else, because 4
they cannot meet this 1.6 S.
They, they conducted testing 5
program, the test program.
For each case, they only tested 6'"
two samples, okay, and then define it instead of defining the 7
allowable stress, and define the allowable loads, okay.
8 During the last October and November audit, we look at that 9
test result roughly.
We find out as much, it is much less 10 conservative compared with 1.6 times S.
11 MR. LIAW:
What do you mean by that?
Less 12 conservative in what. sense?
13 MR. CHANG:
The stress level allowables.
14 MR. LIAW:
When you do the test you get load.
15 MR. PIERSON:
Wait a second.
16 MR. MCCALL:
There is a misunderstanding.
You need 1
17 to go through the bullet of the presentation to help everybody 18 understand.
19 MR. CHENG:
John, before you do that, because I 20 wrote the hi~ story here, I want to go through everything and 21 let everybody understand how the review was processed.
22 MR. TERAO:
I don't think that is necessary, Tom.
23 If you re'ad the bullet, it says they are using the operability 24 criteria.
25 MR. CHENG:
They still want to use the test results.
HERITAGE REPORTING CORPORATION -- (202)628-4888
i 124 o
1 MR. TERAO:
Let's get through the bullet.
1 1
2 MR. MCCALL:
Let me explain the bullet-here.
- Okay, j
3 What we are on this side of the table trying to explain is l
4 that there were some tests performed, and the tests duplicated 5
some of the conditions in the plant.
In other words, some of 6
the shapes and sizes of angles and some some other things.
7 As we understand, Tom came down and was reviewing 8
those, and I think that there is agreement that you cannot 9
just take the load directly from that test and say that's the i
10 allowable load.
11 What we are saying is okay, how do you solve this 12 problem?
Well, there is two ways to solve it.
One way would 13 be to do a very large complex analysis or--which has a lot of 14 assumptions associated with it, or alternatively, we could 15 take the test and say that the test, if we observe how the 16 thing fails and how it behaves, we could identify what the 1
17 critical attributes are in the connection in. terms of its 4
18 behavior, and using those critical attributes, we could define 19 its strength, so what we are talking about is looking at the 20 test results, and say that those test results define 21 structural behavior.
They define what things fail, and then 22 we are going to use our normal operability criteria that we 23 have all agreed upon as a stress allowable against that 24 mechanism of failure that we observed in the test.
25 MR. LIAW:
I think you are comparing apples and HERITAGE REPORTING CORPORATION -- (202)628-4888 q
125 1
oranges and here criteria was specified on the stress level, 2
and you are testing the gross behavior of the joint.
3 MR. MOREADITH:
Let me try a different way of 4
explaining it.
We have the operability criteria from a stress 5
point of view.
We understand that.
6 MR. LIAW:
Right.
7 MR. MOREADITH:
In some cases, in performing 8
calculations using the operability stress limits, we find that 9
a connection detail is not acceptable.
All right.
Then we 10 have another, we have test results, and these types of 11 connections, like all steel connections, test considerably 12 higher than any calculated values.
13 In other words, the allowable stress, the allowable, 14 allowable load or reaction capability for the angle using the 15 9 tenths Fy or even the 1.6 S would be a low percentage of the 16 ultimate test value for the connection, maybe 20 percent, 17 maybe one fifth, maybe one 10th, because connections have so 18 much more capacity than the calculations tell you, so instead 19 of using the 1.6 S as an acceptance limit, what we were trying 20~
to do was use a percentage of the test capacity as a basis of 21 establishing an acceptable limit.
El MR. LIAW:
Sc; you are trying to define your 23 acceptance criteria ba' sed-upon the load capability rather than 24 s ' re s s 'r 25 MR. MOREADITH:
Correct.
HERITAGE REPORTING CORPORATION -- (202)628-4888 j
126 1
MR. LIAW:
Is that--
2 MR. MOREADITH:
That is correct.
Did I say that 3
right?
4 MR. MCCALL:
I think we ought to go and talk a 5
little bit.
6 MR. PIERSON:
Let's have a five-minute break.
7 MR. LIAW:
Just a minute.
I want to say something 8
that might work.
9 Let me first say something about 1.6 S sub Y, and 10 Tom state it was.75 of the yield, right?
Therefore, 1.6 11 times.75 1.2 yield Fy, the reason we say it is okay, interim 12 criteria was based upon our. general understanding of the 13 behavior like I mean, you know that, I mean the riveted bridge 14 connection, there are all number of rivets in there. -You know 15 a joint can take some more carrier capability, but we back to 16 school teach seismic, that is, the connections do not have any 17 moment carrying capability, so you take that joint, the stress 18 joint to test it, sure, you could have higher stresses than 19 what we permit it.
20 I guess that type argument you are making, q
21 presented, is and analogy to what I just, analogy to what I 22 just, you know, instructed, so when we understand and give you 23 something and then you charge ahead, try to further quantify 24 something else, I think that's a problem fundamentally we are 25 having with it.
HERITAGE REPORTING CORPORATION -- (202)628-4888
e 127 O
1 I recognize, yes, you take a joint, tested gross 2
behavior, you have higher load.
I guess my only solution to 3
that will be, you know, if that's the case, fine.
We can work 4
out criteria and we can accept based on joint behavior, gross 5
behavior, and let's argue whether the factor of safety should 6
be two or three or four or you know, you are going to the 7
stress criteria, then I will say you either, you might have to 8
do something else.
I don't know what it is.
9 MR. MOREADITH:
Well, what we are suggesting, first 10 '
of all, what we are saying is we are modifying platform 11 connections.
12 MR. LIAW:
Fine.
13 MR. MOREADITH:
To meet acceptance criteria.
14 MR. LIAW:
Fine.
15 MR. MOREADITH:
One small piece of that, and we 16 don't want to make a big issue out of it, all right, is some, 17 and it is not many, connections we are proposing, and what I 18 am saying is we can discuss it in detail with Tom next week.
19 We can look at calculations.
We can look at test results, l
20 Anyway, to continue the thought, we are proposing 21 that the acceptance of some connections be based on test 22 results rather than calculations entirely.
23
-MR.
LIAW:
Based on test results compared to what 24 criteria?
Compared to 1.6 criterion?
25 MR. FOX:
The key words here are with prior NRC HERITAGE REPORTING CORPORATION -- (202)628-4888
128 4
1 approval.
Those are the operative words.
In other sords, we' 2
are not going--that means that these criteria have to be 3
discussed and mutually agreed to.
4 MR. LIAW:
Your your goal and my goal before this l
5 meeting was to close up issues, and here I keep running into 6
this case-by-case.
I just don't know how many cases we have 7
to go through then.
I guess I am not trying to reject what 8
Fred proposed offhand, but I guess I am stopping for a minute 9
to stress the concern to you.
I think we cannot continue with 10 that.
11 MR. FOX:
What I am saying is that TVA in a small I
12 number of cases might want to use control test data.
l 13 MR. LIAW:
How many cases?
14 MR. FOX:
I can't tell you that today.
15 MR. LIAW:
Five?
Ten?
16 MR. MOREADITH:
Let me see if I can understand the 17 information I have got here.
It looks like 13.
18 MR. CHENG:
May I throw some numbers-here?
19 MR. MOREADITH:
It looks like 27, but don't held me 20 to that exact number.
21 MR. LIAW:
When I say few cases case-by-case,-I am 22 talking about, you know, I can count it with number of 23
- fingers, 24 MR. PIERSON:
I am getting confused.
I would like 25 to caucus and sit down and talk to B.D.,
and I think you need 1
9 129 1
to, too, Let's go.
2 MR. MOREADITH:
Five minutes? -
3 MR. PIERSON:
Yes, five' minutes.
4 (A brief recess was taken.)
5 MR. PIERSON:
Let's go ahead then, and do you want 6
to aamplify on your position or convey something?
l t
7 MR. MOREADITH:
No.
We are not trying to make a 8
major issue out of this.
All we are trying to say is that we 9
have some test results, and in some cases, we believe the test 10 results are applicable to the platform connections, and I
11 instead of using the 1.2 Fy as a basis for establishing the 12 allowable for the connection, we are proposing that in some 13 cases, we use the test results to establish the quote, 14 allowables, in lieu of a code type value shall we say, and we 15 will, we are further suggesting that we look at some of the 16 details with Tom when he comes to the site.
I mean the issue 17 is settled.
You know, we are going to modify platforms 18 connections.
We are not trying to a avoid modifications that 19 are required.
We intend to meet our licensing requirements.
20 There is only this one little thing--use of test 21 results in lieu of specified allowable values.
]
22 MR. PIERSON:
Do we have comments on that, Dave?
I 23 MR. TERAO:
- Yes, I'm afraid you said you wanted to 24 use test results in lieu of code values, and I would agree to 25 that, but I thought what we were arguing is using test results i
HERITAGE REPORTING CORPORATION -- (202)628-4888
)
s 130 o
1 in lieu of operability criteria.
3 MR. MOREADITH:
No.
No.
.\\
3 MR. TERAO:
You plan to meet operability criteria?
4 MR. MOREADITH:
We--obviously that one factor of 1.2
{
t 5
Fy, we won't meet that, see, because if we took, if we take i
6 the test configuration and use 1.2 Fy, we will get a certain 7
connection capacity value.
When we test that connection 8
configuration, all right, we get an ultimate value which may 9
be five, six, eight times the calculated allowable.
Then you 1
i 10 discuss well, how much margin on that connection configuration 11 is acceptable?
Factor of safety of three, four?
And then you 12 come up with a new, quote, allowable value established by 13 test.
14 MR. TERAO:
You haven't established that yet.
15 MR. MOREADITH:
You didn't meet--I mean I don't want 16 to confuse you.
You literally are going above the value.
Yoc 17 are establishing allowable value that is above the value you 18 would establish by calculations using the 1.2 Fy.
19 MR. TERAO:
But you haven't told us, my 20 understanding is that you haven't told us what that value is 21 yet.
22 MR. MOREADITH:
No, we haven't.
We wanted to show f
23 the results to Tom next week and show him how we are using 24 them, and see what, what his reaction is from his perspective.
25 MR. TERAO:
Our reaction is you should meet the i
HERITAGE REPORTING CORPORATION -- (202)628-4888
131 4
1 operability criteria that we set.
That's above code already.
2 Are you now saying you want to change your 3
operability criteria?
I 4
MR. LIAW:
Define it in terms of load capability, i
5 load carrying capability or joint?
Is that what you are 6
saying?
7 MR. MOREADITH:
I'm not sure what you just said, 8
B.D..
9 MR. LIAW:
Okay.
Take a joint, four rivets there.
10 Okay.
And you pull and those bend.
Based on operability l
11 criteria in terms of stress, if one spot there reached 1.2 SOC 12 01.6 S sub Y, that's it.
Okay.
One spot, not joined, you 13 know that that's it.
You have to modify the joint.
That's 14 operability criteria in terms of stress.
15 On load carrying capability, first you have to 16 define it such that those loads in terms of tension or 17 compression or come out with bending or shear, had to be, i
18 realistic.
I don't think anyone can tell you or can define 19 load that well.
20 MR. PIERSON:
Let's--
21 MR. LIAW:
Let me finish, okay?
So even that, even 22 the one rivet starts to tear, the remaining three will 23 continue to resist load until it completely fail, so I think 24 we are talking about two entirely different approaches to the l
25 design, and I guess that's where I find myself.
HERITAGE REPORTING CORPORATION -- (202)628-4888
i 132 i
1 MR. MOREADITH:
We are definitely proposing an 2
alternative to the stress limit part of the operability 3
criteria.
4 MR. PIERSON:
And we do not agree with that.
5 MR. MOREADITH:
That's an answer, Charlie.
6 MR. FOX:
The issue is resolved.
We don't need to 7
say anything more.
8 MR. MCCALL:
Summarize, but is that acceptable or 9
not?
Can tests be used not to--
10 MR. MOREADITH:
I think he said no.
11 MR. MCCALL:
There is two questions here.
One is 12 can a test be used alone to define capacity?
I think we-just 13 heard no.
Right?
14 MR. LIAW:
Yes.
15 MR. MCCALL:
Then there is another question, and i
16 let's pick a different example.
17 MR. LIAW:
I take it back.
18 MR. PIERSON:
B.D.,
let's leave it.
Leave it.
l9 MR. FOX:
.This subject involves 13 clip hangers.
20 Let's forget it.
We have already probably wasted more time 1
21 talking about it than it is worth, so John, unless there is 1
22 something really big that you see that we need to get out on 23 the table on that--
24 MR. PIERSON:
I think we are done.
25 MR. FOX:
Very good.
You have got one to cover.
HERITAGE REPORTING CORPORATION -- (202)628-4888
II
~
1
)
s 133 4
1 MR. PIERSON:
We have one we need to cover'for you.
2 Jorn, are you ready to dothat?
3 MR. FAIR:
Yes.
4 MR. CHENG:
Before you do, I have one more question 5
about this issue.
So you say now some clip hangers have been 6
modified based on what criteria?
That's what my question is.
{
7 MR. PIERSON:
I don't think--that's an inspection 8
sort of thing.
Let's take that up next week.
We have already 9
. closed the issue on this meeting.
10 MR. LIAW:
You can assume modified to the stress 11 criteria.
12 MR. CHENG:
I just would like to hear whether they 13 meet the commitment or not.
They committed to go back to the 14 long-term criteria.
15 MR. LIAW:
You look.
If they don't meet commitment, 16 you cite them for it.
17 MR. CHENG:
Okay.
18 MR. PIERSON:
John?
i l
19 MR. FAIR:
Yes.
The last issue was EMG-2.
This 20 issue involved a change in the criteria that was previously, i
21 that TVA had previously prepared for the combination of loads j
I 22 due to inertia and seismic anchor movement load.
I 23 First, I just would like to verify that that is a 24 true statement, that previously that TVA had proposed an 25 absolute sum, and this was a change in the January 20th,'1989 HERITAGE REPORTING CORPORATION -- (202)628-4888
134 l
1 criteria.
2 MR. MCCALL:
We confirm that's true.
3 MR. FAIR:
Okay.
At the, at the audit, the 4
statement, I requested the justification for using this SRSS.
~
5 The justification provided me was, was a position in NRC NUREG 6
1061.
This NRC NUREG 1061 position involved an independent 7
support motion evaluation.
8 Are we in agreement that we are talking about 9
independent support motion evaluation.
10 MR. LIAW:
Yes.
11 MR. PIERSON:
The answer is yes?
12 MR. MCCALL:
Yes.
13 MR. FAIR:
The staff has completed its review and 14 has checked with the NRR people on how this has been 15 implemented.
We are in agreement that the SRSS of inertia and 16 seismic anchor motions are acceptable with the independent 17 support motion position stated in NUREG 1061.
18 However, there is one area of your design criteria 19 which I do not believe is in compliance with that position, 20 and that is in 66-3, B-2,. items.
21 MR. PIERSON:
John, what document are you referring 22 to?
23 MR. FAIR:
This is Browns Ferry criteria 7103.
24 MR. GOODWIN:
And the item number again?
i 25 MR. FAIR:
The item number again is 6.3, B-2, and HERITAGE REPORTING CORPORATION -- (202)628-4888
l 135 G
1 that's the spatial combination for piping, saismic anchor 2
motion, for decoupled branch line analyses.
3 I think that we did discuss that at the audit.
4 There is a position.in here that allows an SRSS of the three 5
direction independent analyses of the branch line connection.
6 After further thought on this particular position, I 7
don't believe that meets the criterion for SRSS because the 8
branch line motion are not statistically independent values 9
from the piping analysis, so I believe with a modification of 10 that section of the criteria, the position would be 11 acceptable.
12 MR. LIAW:
How do you want him to modify it?
13 MR. FAIR:
The easiest and most straightforward way 14 to modify it would be to do that particular combination by 15 absolute sum, although because of the complexity of this 16 procedure, that may be a conservative method of doing it.
TVA 17 may want to re-think that position, but certainly an absolute 18 sum for those independent motions would be acceptable to the 19 staff.
20 MR. PIERSON:
Any questions?
21 MR. FOX:
John, do you or Alan and Chan want to 22 comment at this point in time?
23 MR. CHAN:
I have a question.
The inertia percent 24 combination, you are saying it would be only applicable for 25 independent support motion.
That means it would not be 9
HERITAGE REPORTING CORPORATION -- (202)628-4888
136
=
1 acceptable to do full spectrum analysis?
2 MR. FAIR:
That was the justification'that you 3
provided to me during the audit was, your base was the staff 4
position independent support motion, so that's the base with 5
which I am accepting it.
6 MR. CHAN:
Only for independent support motion?
7 MR. PIERSON:
That is correct, right.
8 MR. FOX:
Are you proposing to use it beyond the 1
9 staff position?
10 MR. CHAN:
We were thinking of using it for both 11 independent support motion and envelope situation.
12 MR. TERAO:
I don't know if we have discussed the 13 envelope situation in-house.
Was that something.that you 14 considered?
15 MR. FAIR:
I assumed that because the justification 16 provided me with the NUREG 1061 which discussed it, discussed 17 only the independent support motion, that that was what the 18 proposal was.
19 The bases for accepting the SRSS of the anchor 20 motion with the inertia was in the conservatism of the entire 1
21 position with respect to independent support motion, and 22 therefore, those same conservatism may not be generally 23 applicable to other circumstances.
24 MR. TERAO:
I still don't understand.
I thought I 25 heard, what I heard you say, John, is thataos, the staff had HERITAGE REPORTING CORPORATION -- -(202) 628-4888
137 1
been reviewing this, the SRSS or absolute sum of inertia and 2
SAM loads for independent support motion enalyses.
3 Now Alan, you just raised the question about its 4
applicability to envelope response spectra, and I'm not sure l
5 if I understood what John's response was to that.
l l
6 MR. FAIR:
My response is I hope we--at the audit, l
7 the proposed method was justified based on the staff position 8
on independent support motion.
I have checked the 9
implementation of the staff position, and with the 10 modifications I have put forth at this meeting, that would be 11 acceptable as the staff has implemented it.
l l
12 I have not discussed any further implementation of
~
13 the SRSS because that was not tabled.
14 MR. LIAW:
Do you understand?
15 MR. CHAN:
I understand.
In other words, he is 16 saying that we have not submitted a justification of using 17 SRSS in the envelope spectrum situation.
18 MR. LIAW:
I guess the justification you cited was 19 not applicable.
20 MR. CHAN:
That's what Chuck is saying.
21 MR. LIAW:
He is not taking a position at all.
He 22 is saying you did not provide it at all.
l 23 MR. FOX:
He is providing a clarification of what we l
24 did provide a justification for.
25 MR. LIAW:
Back to you, Charlie or Fred, do you HERITAGE REPORTING CORPORATION -- (202)628-4888
138 1
intend to propose additional justification to justify the use 2
of it, or you just, you will just quit?
3 MR. MOREADITH:
We heard John's answer to the 4
question which had been put on the table.
At this time, we t
5 don't plan to put additional questions on the table.
6 MR. PIERSON:
So we are not going to be talking 7
about envelopes then?
8 MR. MOREADITH:
I am not trying to be sneaky, You 9
know, I don't know.
This issue, it is the first time I have 10 heard it, so I don't know how to sit here and say you will 11 never hear from me again on this issue.
12 MR. LIAW:
I understand that.
John, what you are 13 saying is we are not reiterating the position, the use of SRSS
)
14 on the end spectrum method, but rather the justification cited 15 by them then was not appropriate?
Is what you are saying?
16 MR. FAIR:
I am saying we have accepted the use of 17 the SRSS with the modifications as stated here for the 18 independent--
19 MR. FOX:
As requested.
20 MR. FAIR:
As requested for the independent support 21 motion; what the staff has accepted for other methods of 22 analyses are absolute sum, and TVA has provided no 23 justification for anything but the independent support motion.
24 MR. MOREADITH:
Agreed.
25 MR. PIERSON:
Let me ask one question.
We are HERITAGE REPORTING CORPORATION -- (202)628-4888
1 trying to close out as many of these items as possible.
Is it 2
your intention to come back on this issue?
3 MR. MOREADITH:
It's our intention--I think we have 4
pretty well got everything closed, but life being what it is, 5
you know, two months from now we may have an issue we would 6
like to discuss with you.
7 MR. FOX:
It will be on a case-by-case on its 8
merits.
Okay?
9 MR. PIERSON:
Do we have any further comment, John?
10 MR. FAIR:
No.
11 MR. PIERSON:
Does anyone else have any further 12 comment?
13 MR. MOREADITH:
Just to say that we thank you for 14 your time and the--
15 MR. FOX:
Just hang on a minute now.
We are goinc j
I 16 to summarize here and have clear expectations of what we owe 17 them and where we are, that we have agreed to that as a part 18 of these very intense weekly communication meetings that we 19 are having.
20 MR. PIERSON:
Are you ready to summarize, Charlie?
21 MR. FOX:
I think we are.
22 MR. GEARS:
Can we go back to GO?
The one thing 23 that maybe is off that John simply said that on Section 63 B2, 24 this was estimates made that were a discrepancy, right?
And 25 therefore, criteria 7103 would be an action item for these HERITAGE REPORTING CORPORATION -- (202)628-4888
140 1
guys to amend or change.
After talking about that, I just l
2 want to make sure that needs to be--
3 MR. LIAW:
Amend that or propose additional 4
justification.
5 MR. MASSIE:
We have no problem with withdrawing the I
6 paragrcph.
7 MR. PIERSON:
We would have a problem with I
8 additional justification.
9 MR. FOX:
He also said there is one easy way to do l
l 10 it, but we need to look at what is the best way and it may or 1
11 may not be absolute sums.
We may be into much more
)
12 conservatism than either NRC or TVA, either one would want, so 13 we are going to look at criteria very carefully, and we owe t
14 them an answer on it.
15 Now it is not a metter of if.
It is a matter of l
16 how, is that not correct?
It is a matter of how they will be 17 changed?
18 MR. GEARS:
Right.
That's the way I heard it.
19 MR. FOX:
That's the closing on it.
20 MR. MCCALL:
We also need to emphasize here that 21 7103, based on previous conversations, not only--this issue is 22 going to need to be revised anyway as part of the 23 implementation, so there is no issue here as to whether that 24 would occur or not.
25 MR. FOX:
We are to use SRSS inertia and seismic HERITAGE REPORTING CORPORATION -- (202)628-4888
141 1
anchor loads.
We can do that for independent suppert motion 2
if we change the criteria, so we have said we want to do this, 3
right?
We would have made a submission to the staff and l
4 discussed it up at Cherry Hill a couple of wooks ago provided 5
them a submittal if we had wanted to do it, so we, by 6
definition, if.we had want to do it, a condition of that is to 7
change the criteria.
8 MR. PIERSON:
Are we ready to summarize?
4
{
9 MR. FOX:
I think so.
10 MR. PIERSON:
Why don't you summarize?
j 11 MR. FOX:
I am, I am going to ask Pat Carier, anyone 12 else on this side o'f the table to assist.
I am going to start 13 with the open technical issues.
14 On load sharing and spring bottoming, that issue is 15 resolved.
You rejected our proposal on load sharing.
You 16 accepted our approach on spring bottoming.
17 MR. LIAW:
That is correct.
18 MR. FOX:
Okay.
On low temperature thermal 19 analysis, there is a question of the employee concern 20 corrective action report and its statement vis-a-vis what we 21 are proposing and using at Browns Ferry, and that I made it 22 clear that TVA will do a limited thermal analysis based on an 23 engineering review of the piping layout to look for things 24 such as the long run where you might have a thermal expansion 25 problem.
HERITAGE REPORTING CORPORATION -- (202)628-4888
142 1
We have to clear up the employee concern.
We will 2
do that.
3 MR. LIAW:
Right.
You have to reconcile--
4 MR. MOREADITH:
We have to resolve the conflict.
5 MR. GOODWIN:
Provide technical justification for 6
the less conservative issue you are now proposing.
7 MR. FOX:
What we are doing is standard industry 8
practice, Ed, so that is going to be part of our justification 9
for the plants of this vintage.
10 The question is why did we overcommit in the 11 employee concern corrective action, and that's the way we are 12 looking at that right now, to be very up-front about it.
13 Okay.
14 MR. GOODWIN:
That is a technical justification.
15 MR. FOX:
I want to find out why, you know, we have 16 got that written down there, and it has not been plowed back 17 into our way of doing business since it is stated.
We may 18 have a process problem there we need to look at.
19 MR. LIAW:
I would recommend that you need to 20 understand the basis why the employee concern was resolved 21 that way.
22 MR. FOX:
Absolutely, and as I mentioned earlier in 23 the meeting, I have assigned Fred an action item to pull the 24 string on that.
25 On the CRDH, you want our criteria in writing.
HERITAGE REPORTING CORPORATION -- (202)628-4888
143 1
MR. FAIR:
That is correct.
2 MR. CARIER:
For review.
3 MR. FOX:
For review; on clay pipe, you want our 4
recommended technical fix and the justification for that.
We 5
will provide that to you, and next week we are going to give 6
you a schedule of when we can face, you know, or when we can 7
plan and expect to have that.
8 MR. LIAW:
On that issue, obviously you have a 9
separate issue with my site people in terms of the 10 deportability and when, how, that kind of stuff, so that was 11 separate from today's discussion.
Today is only on a 12 tdchnical resolution of--
13 MR. FOX:
Technical resolution of the issue; now I 14 am going to jump down to rod hangers.
That's resolved.
15 MR. LIAW:
Compression.
16 MR. FOX:
You gave us your position, and we agreed 17 to that.
18 MR. MOREADITH:
And we understand it.
19 MR. FOX:
We not only understand it, we have 20 accepted it.
21 MR. MOREADITH:
Correct.
Right.
22 MR. GEARS:
We will delete the references to 100 and 23 200.
24 MR. FOX:
Yes.
The 100 and 200 have no meaning.
We 25 got hung up on numbers there unfortunately.
HERITAGE REPORTING CORPORATION -- (202)628-4888
144 1
Now drywell clip angle, that is resolved.
1 2
MR. PIERSON:
Are we in agreement on that?
{
3 MR. CHENG:
Yes.
You should go back to use the 1
4 interim criteria.
5 MR. FOX:
On the other issues that are closed, on 1
6 EMG 02, you had the ball.
Now we have the ball.
The ball 7
that we have is to develop a change to the criteria at Browns 8
Ferry 7103 DC 6.3 B2.
Okay.
9 MR. LIAW:
Is 7103 criteria applicable only to 10 Browns Ferry, or is it generic?
11 MR. MCCALL:
I think it is just applicable to Browns 12 Ferry.
13 MR. CHENG:
Based on my understanding, it was just 14 to the Browns Ferry.
15 MR. FOX:
It is--Browns Ferry 7103 is the title.
16 MR. CHENG:
From the title, Browns Ferry.
17 MR. MCCALL:
There is a different one for each.
18 MR. FOX:
Okay.
Now let me just very quickly look 19 down the list of--
20 MR. RAUGHLEY:
We owe them dates on EMG 013 21 likewise.
22 MR. PIERSON:
Wait.
We are losing track.
You need 23 one voice to speak.
24 MR. RAUGHLEY:
We owe them a completion date on EMG 25 013 as to when the study will be completed and we owe them a l
1 HERITAGE REPORTING CORPORATION -- (202)628-4888
)
i i
i 145 i
i date on CSG 24 as to when that study will be completed and 2
available.
3 MR. FOX:
Right, so with the exceptions of the one 4
we mentioned, I think that's all the action items.
Does 5
anyone--
6 MR. PIERSON:
I agree.
We agree?
7 MR. CHENG:
I think the CSG 26, you still have not 8
complete your calculation ye* for the critical cases.
9 MR, CARIER:
Come in and audit.
10 MR. FOX:
That will be an audit verification.
11 MR. CHENG:
Yes.
~
12 MR. FOX:
We know exactly what we have to do.
There 13 is, you know, it is subject to your review and approval of the 14 results, but okay, so we are now down to--we know what we have 15 to do.
There really is no big question on criteria.
16 MR. LIAW:
I don't recall--
17 MR. PIERSON:
We do not owe you anything.
18 MR. FOX:
Not to my knowledge.
19 MR. LIAW:
Obviously--
20 MR. FOX:
We owe you something.
21 MR. LIAW:
I don't take notes.
Only my staff took 22 notes, so what you get there I think is very complete, but 23 nevertheless--
24 MR. FOX:
It is subject to--we have covered a lot of l
25 material.
t l
HERITAGE REFORTING CORPORATION -- (202)628-4888 lu_-.___________
146 1
MR. PIERSON:
It is our intention to send the 2
transcripts down to you, and we expect something lake a 3
seven-day turnaround, in which case you could tell us where 4
the transcription may disagree and we can do the same with you 5
at that point, and resolve whatever differences we have.
6 MR. FOX:
You send those to Gridley, please, and we 7
will see that they get distributed.
l 8
MR. LIAW:
Transcript is--I don't think this is 9
appropriate.
10 MR. PIERSON:
If it is a situation where something 11 was misunderstood is what I was--
12 MR. FOX:
Clarification.
13 MP.. MOREADITH:
We think we got all the 14 misstatements corrected as we went along.
15 MR. FOX:
I want to. hank you gentlemen for a very 16 professional meeting.
17 MR. CHENG:
I would like to go through a few 18 additional items for next week's audit.
19 MR. PIERSON:
Why don't we talk about that after we 20 close?
21 MR. CHENG:
Off the record.
22 MR. FOX:
Wayne, will you and John hopefully close?
23 Thank you.
24 MR. PIERSON:
Thank very much for your time and l
25 attention, and it looks like we are making progress.
HERITAGE REPORTING CORPORATION -- (202)628-4888
147 1
MR. FOX:
I think we are pretty much in an I
2 implementation mode now.
3 (Whereupon, at 1:15 p.m.,
the meeting was 4
adjourned.)
5 6
7 8
9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 HERITAGE REPORTING CORPORATION -- (202)628-4888
1 CERTIFICATE 2
1 3
This is to certify that the attached proceedings before the 4
United States Nuclear Regulatory Commission in the matter of:
I 5
Name:
TVA/NRC Meeting on Open Issues 6
I t
7 Docket Number:
8 Places Rockville, Maryland i
9 Date:
February 17, 1989 10 were held as herein appears, and that this is the original 11 transcript thereof for the file of the United States Nuclear 12 Regulatory Commission taken stenographically by me and, 13 thereafter reduced to typewriting by me or under the direction l
14 of the court reporting company, and that the transcript is a l
15 true and accurate record of the foregoing proce,edings.
16
/S/ ( eLWh2u,A cz,
s' i
17 (Signature typed):
Catherine S.
Boyd 18 Official Reporter 19 Heritage Reporting Corporation l
20 l
21 i
22 23 24 25 I
Heritage Reporting Corporation (202) 628-4888
(