ML20247E760
| ML20247E760 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 03/14/1989 |
| From: | NRC COMMISSION (OCM) |
| To: | |
| Shared Package | |
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| References | |
| NUDOCS 8904030233 | |
| Download: ML20247E760 (60) | |
Text
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UNITED STATES NUCLEAR REGULATORY COMMISSION o
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In the Matter of:
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me d !'S FEPAY NUCLEAR STATION
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(Catie Separation Criteria)
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Fages:
1 through 58 Fla e:
F.ockville, Maryland
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1 Date:
March 14, 1985
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o UNITED STAfES NUCLEAR REGULATORY COMMISSION In the. Matter of:
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TVA BROW' S FERRY NUCLEAR STATION.
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'(Cable Separation Criteria).
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NRC Building Eighth Floor Conference Room.
11555 Rockville Pike Rockville, Maryland Tuesday March 14, 1989 1:10'p.m.
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'P.R'O C E E D I N G S
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(1:10 p.m'.)
MR. MORAN:
Okay, gentlemen, I'm Dave Moran, 4
Pr ject. Manager on Brown's Ferry for Nuclear Regulatory 5
Commission.
E TVA asked for this meeting, and I will, before
. turning it over to TVA, ask B.D.
and Bob Pierson whether E
they have anything they want to say on kick off.
?
MR. PIERSON:
Well,~I'll start.
10 As-I understand it, what we're going to talk about-l' is the statistical sampling and cable separation.
And it's
- 2 aise our understanding that it is your desire to have this-12 mer; ting, and so we're willing te let you come and give your 14 presentation to try to understand what it is you're trying 15 to convey to us.
16 And if we have any questions, as you go along, 17 we'll ask the questions and try to resolve whatever issues 18 we've ge~.
19 B.D.,
do you have any other comments?
I' 20 MR. LIAUJ:
No.
21 MR. PIERSON:
- Okay, B.D.
doesn't have any 22 comments, and I guess we're ready to start.
1 E
23 Do you need a projecter or something?
24 MR. CARIER:
No.
25 One of the things you might want to do is go Heritage Reporting Corporation (202) 628-4888 u-_--_______
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-around'the room and make surefeverybody knows each other..
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'There's some new faces, Art Zeringe, our-Site Director.
.1 Go ahead.
MR. ZERINGE:
Art Zeringe, Site. Director, ' drowns
.I Ferry,- TVA.
E.
' MR. BYNUM:. Joe Bynum, Vice President, Nuclear Power Production.
E MR. HUTSON:
Jim Hutson, Chief Electrical' 9
' Engineer.
10 MR. CARIER:
Pat Carier,, Site Licensing Manager.
11-MR. GARG:
Hukim Garg, NRC.
II MR. MARINOS:
Angelo Marinos, I'm the Chief of the 13 Reactor Operations Branch.
14 MR. PIERSON:
Bob Pierson, Assistant Director, if
. Technical Programs, NRC.
16 MR..PAULUTZ:
Ed Paulutz, electrical engineer.
17 MR. MORAN:
Dave Moran, Project Manager for 18 Browns' Ferry.
19 MR. SCHAFFER:
Al Schaf#er, Sargeant & Lundy.
20 MR. IPPOLITO:
Tom Ippolito, TVA Advisor.
21 MR. LIAUJ: B.D.
Liauj, NRC.
22 MR. GOODWIN:
Jcy Goodwin, NRC.
23 MR. CARIER:
You stated it correctly.
We would 24 like to continue our discussions on the electrical 25 separation issue.
In partir.ular, we have one outstanding Heritage Reporting Corporation (202) 628-4888
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-item'left in that4 issue that.we seelright now-to begin to come to' resolution on and we're ready."to continue that dialogue.
And it'~s.concerning the statistical sampling.
4
< Tha~. # s : exactly what we' re here to talk about, _ and we' d: like.
5 to continue to discussing with the staff, trying to come to E
a resolution.
And with that, I'd like to turn it over to Jim
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9 Hutson, who is going to go through'that remaining issue and 9
hopefully we'll get someplace and come to an agreement-20 today.
11 MR. HUTSON:
Thank : yo'u, Pat.
12-We appreciate the opportunity.to come up and 13 discuss it with you again today.
14 As Bob has indicated and as Pat has indicated, 15 we've had several meetings discussing cable separations.
16-And what we sould like to discuss today is, in our opinion, 17 another additional item that warrants further discussions.
18 And it's basically the acceptance criteria which we've been 19 discussing the past few weeks.
20 The exceptions criteria, as we discussed last 21' week, was regarding literal compliance with the design 22 criteria in the FSAN.
That would be the acceptance criteria 23 that would be used in any type of sampling or statistical 24 evaluation to determine its acceptance, whether it be on a 25 population of 155 or whatever we were looking at.
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And, as-we discussed briefly.last. week;and in the J
meetings'before, it involves literalicompliance of the 1
criteria.versus a design or a safety significance review of 4
the discrepancy.-
Basically, we do have known discrepancies'
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5 with~ regard to the installed configuration.versus the 6
design.
And our objective in' evaluating those
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discrepancies is to determine or develop a confidence icval
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9 in~our design data. base such that we could use it in the 10~
further evaluations which we've already completed.
Those-
'11 evaluations and results, of course, were submitted in early.
12 January of this year.
13 Again, what we're trying to develop is a
.24 confidence level in the' installed configv. ration of the 15 cables.- And our previous discussion have evolved into us 16 looking into the different voltage levels, primarily in the 17 V-4, V-5 arena -which is the power cable.s for the plant.
And 18 in the'v-3 level which is the control power cables, and also
' 19 in the V-1 and V-2 which is the instrument level-type 20 circuits.
I 21 But, again, what we'd like to discuss today is the 22 acceptance' criteria of literal compliance with the criteria.
1 23 What we'd like to propose is a supplement to che FSAR which 24 basically identifies the ability to perform a case by case 25 evaluation of the discrepancies to ensure that there is no
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l design significance or safety significance from the discrepancy.
That type of analysis is basically bounded by j
4 present day regulatory guidance as well as IEEE or industry.
5 standards, Reg. Guide 1.75 and IEEE 384.
And the procedure l
C for dcing it would be in accordance with IEEE 379, which is present day single failure criteria.
E So with regard to the review, we would be I
performing it in accordance with those documents, and those IC
' reviews that we have done to this point are in accordance 11 with those documents.
12 So it would be that type of evaluation that we'd 13 be proposing.
That would be the acceptance criteria to 14 determine whether or not further review was required.
If 15 there is no design significance, then there would be no 16 further review required.
If there was design significance, 17 then we would propose looking at a root cause analysis of 18 that issue, or of hat significant item.
And from that root 19 cause, look further into the evaluation based upon that.
20 But it would take a design significant item before we' d l
I 21 continue the review.
22 And as we've discussed in the past on the V-4, V-23 5,
we've evaluated those and found no design significance in And looking at the statistical approaches, we 24 that area.
25 have been looking at the V-4 V-5 which was basically a l
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statistical evaluation of_those'-discrepancies.- From that,.-
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2 you' draw a: greater thanL95l95 confid'nce level.
e That's.primarily the' item we wanted'to. discuss a
with you.today.
5
, MR.' PIERSON:
Does anybody have:any questions 6~
befcre'they start on their -- ?
~~ '
(No response) 8; MR. PIERSON:
Why don't you go ahead,.then?
9 1G1. HUTSON:
Okay.
If you look at the design
- C significance,
-11 VOICE:
Is this'a handout?
12 MR. HUTSON:
No, I'm just going from thic.- If you 13 look at the past meeting of'the handouts we looked at there,.
14
- 15 MR. PIERSON:
This is a' summary from your handout 1A last time?
17 MR. HUTSON:
Yes.
This is the --
18 VOICE:
Is this is March.7th handout then?.
19-EMR. HUTSON:
Our basic purpose was to get your 20 feedback from what-I just said, though, regarding design 21 significance, whether or not there was -
you know,-the.
22 discussion I have there is the design significance.
Our l
23 definition of it would be, evaluating-the discrepancy to 24' insure that the safety function is not degradable on.an L
25 acceptable level for 3 and 4.
Heritage Reporting Corporation (202) 628-4888
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U-8; MR.1PIERSON: :Let me paraphrase:what I think I i'
heard.you'say.
You're' going to look at what is defined in 3
the FSAR~for.anything which deviates which you have in the-F S A...
.5 MR. HUTSON:
Or the design criteria.
E MR. PIERSON:
Or the design criteria.
And that i
will come to constitute, for lack of a better. term, I'll E
call a hit.
Something, an' anomaly, or something that you'd
'9
.have to somehow resolve.
4 10 Now,-once you define that and for some reason i
11 doest.'t meet the criteria as you specified, then you go back-1' and de an evaluation to determine whether there's anything 13 safety significant or safety related with that particular 14 discrepancy?
15-MR. HUTSON:
That's correct, yes.
-16 MR. PIERSON:
Now, if there isn't, you drop it at 17 that point?
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18 MR. HUTSON:
That's correct.
19 MR. PIERSON:
If there is, then you go from that l
1 20 point and try to cetermine what the root cause was?
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21 MR. HUTSON:
Yes.
22 MR. PIERSON:
Now, tell me, elaborate from that 23 point from the root cause?
24 MR. HUTSON:
Well, from the root cause, as we've j
25 discussed, there would be a further sample based upon the i
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.roct. cause..
MR. PIERSON:
So you would look'at that point' specifically at whatever the root cause was, for instance, fer lack of a better example, you would. pick a group of4
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5 individuals that. installed cable..
Maybe you decided that f
the' cable was installed improperly. -You'd go back and look at another sample of cables that were installed by that
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crew, by that time frame or whatever it happens to be, and 9
then try to evaluate from that whether that root cause was 10 endemic to mere than just an isolated example or whatever?
1:
MR. HUTSON:
That's c6rrect.
You would do a 12 further sample based upon the root cause, yes.
13 MR. PIERSON:
Now, what would happen then?
14 MR. HUTSON:
Well, prior to entering into the 15 sample, you would determine the population of that root 16 cause area.
And from that population, you would determine l'
your sample population with an appropriate acceptance j
18 criteria.
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19 MR. PIERSON:
Okay, now suppose that you don't 20 meet the acceptance criteria.
What happens then?
21 MR. HUTSON:
Well, without meeting that acceptance 22 criteria, you'd be looking at 100 percent of that particular 23 population.
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24 MR. PIERSON:
Of the particular population as 25 defined by the root cause.
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MR. HUTSgN:
As' defined by.the. root cause,fyes,;
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MR. PIERSON:
Now that's for V-4,-V-5, andEV-3,..
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That would be for V-4, V-5 and V-3, E
yes.
t MR. PIERSON:
Right.
But'it would? exclude V-l'and:
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MR.'HUTSON:
Yes.
On-V-1 and V-2, as we discussed
.10 earlier, with regard to.v-1 and V-2, basically.what we're 11.
pursuing there is.due-to the nature and type of the 12.
circuitry that we're dealing with, it's very_ low energy, so 13 therefore, from a separation standpoint, a pure separation-1
-14 standpoint, we will not pursue any reviews in that area, 15-because of.the low energy.
,16 MR. MARINOS:
What'is'the attribute you're basing 17 this adjustment on?
18 MR. HUTSON:
Okay, the attribute we're basing it 19' on is with regard to the type of-. circuit that it is. ' It's a 20 very low energy cir. cit.
We're dealing with circuitry with 21 regard to amperage which is your primary concern for cable 22 protection.
We're dealing in the milliamp range with-regard 23 to these cables.
'24 MR. MARINOS:
Have you considered external events 25 though as attributes or just the internal?
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Well,-what we would be.considering,'
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'Angelo'twould be'tneLeable itself.
'If the cable itself~
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MR. MARINOS:
I understand.
What.about events,.
external events like fire or?
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6 MR. HUTSON:'
Okay,-from a: fire perspective with 9-regard to Appendix R, those V-1 and V-2 cables that-are
-10 required'for' Appendix R which is as we discussed before ie 11-less than 100. cables, we will' field verify those cables to
.t y 12 ensure that they are properly routed.
But with regard to-13 other types of V-1 and V-2 cables, we're not pursuing.
.14 anything in that area.
15-MR. MARINOS:
Well, what about jet impingement and 16' things like this?
17 MR. HUTSON:
From regard, well, if the V-1 and V-2 16 cable is damaged, should you'have anfault on that cable.
19 MR. MARINOS:
No, I'm not saying a fault, external 20 event,.like a jet impingement.
21 MR. GARG:
Missile arcs, jet impingement.
22 ijR. HUTSON:
Okay, I'm not understanding --
23.
MR GARG:
When you test a cable for redundant 24 instruments you lose volts.
How do y3u assure that --
25 MR. PIERSON:
Do you understand what his question j
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MR. HUTSON:
No, I don't.
I don't think I
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4 MR. PIERSON:
Le'.'s take it as an example.
We 5
have a tray here and a tray over here, and they met the f
separation criteria.
Now, we've got a cable going such that the cable to the both trains or both divisions are both in
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E the same cable where, one cable's here and one cable's over 9
there.
Now, we have an accident, some sort of a jet 1:
impingement, some sort of a faalure, and it takes out this 11 tray, but in this particular case, it took out both the 12 compenenre for that division and train of safety.
13 MR. HUTSON:
Well, if you look at the original 14 separations that was established for Brown's Ferry, it does 15 not allow them to share the same tray tier, but they can be 16 in the same physical proximity with regard to the three-foot 17 and five-foot criteria.
So you would have to have --
18 You're saying that they could be routed in the 19 same tray itself.
20 MR. PIERSON:
Well, I think what he's saying is 21 that they could both be taken out by the same accident.
22-MR. HUTSON:
Well, they would have to be routed in 23 the same tray for that to occur.
24 MR. MARINOS:
Well, your analysis though has only 25 considered the internally generated events like a fault in Beritage Reporting Corporation (202) 628-4888
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MR. HUTSCN:
A propagation path, yes.
MR. MARINCS:
-- so you're not concerned very much 4
because'you're not going to generate enough energy.
So even 5
if you have violation of separation about this, you won't f
worry about it because you're not going to start the tray on fire.
However, an external event can take the tray out.
E And that would take both trains of protection that are mixed 9
in a tray.
10 MR. HUTSON:
I will have to, we'll look into that.
We proposed a submittal with regard to that.
I do not have
- 2 a definite answer on that today, but we will evaluate that.
12 The results will have to be posited from regard to 14 those questions.
15 MR. PAULUTZ:
Well, the extension, 175 is not, at 16 one time when it was first written was inclusive to only be
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an internal problem.
However, after Browns Ferry's fire, it 16 got rewritten and says all external events have to be 19 considered.
The degree of separation is directly 20 proportional to the hazard, whatever it is.
21 MR. HUTSON:
Yes, it is, and that's what we need 22 to confirm is that there are no areas of this nature.
23 MR. MARINOS:
So that has to be either walked down 24 te verify that either V-1 or V-2 are not subjected to 1
25 whatever these events are and systematically addressed.
I Beritage Reporting Corporation (202) 628-4888 l
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14 MR. PIERSON:
Well, I don't know whether they need to walk down.
MR. HUTSCN:
Right. We'd have to look and ensure.
4
- understand what you're saying from the hazardous area 5
standpcint and that will be provided in the submittal to E
you.
i MR. PAULUT2:
Okay, then how about V-37 E
MR. HUTSON:
With regard to V-3, we have a
?
quantity of cables which have been verified by signal 1:
tracing.
And we have pursued partial review of those cables.
There's a quantity of 155 cables that we have 12 signal trace data for, okay.
That data was gathered from 13 other review programs.
14 With regard to that, what we would do is we'd 15 review those items.
There are 94 discrepancies from those 16 154 cables.
17 MR. PAULUTZ:
From the FSAR?
18 MR. HUTSON:
From the FSAR design criteria with 19 regard to --
20 MR GARG:
Separations?
21 MR. HUTSON: With regard to separations, well 22 there are discrepancies.
We are reviewing those with regard 23 to separations.
24 MR. MARINOS:
How does that relate, the previous 25 meeting we had last week you identified to us, there were Heritage Reporting Corporation (202) 628-4888
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twc groups'in the 155 --
MR. HUTSON:
Yes, there were 80 --
MR. MA~.INOS:
-- a group of 80 that was associated with --
5 MR. HUTSON:
From the Ampacity program.
and 75 from the fire protection E
VOICE:
~
program.
E MR. HUTSON:
From the Appendix R effort.
MR. MARINOS:
If I remember correctly, you 10 identified two failures on the group of 8, and 14 which you 11 had not yet identified the nature of in the group of 75.
12.
Hcw did they' rise to 92 now.
'13 MR. HUTSON:
Okay, now, as we said last week, 14 there was a population of 155 cables.
80 of those came from 15 the Ampacity program indirectly from the Ampacity program.
16 75 came from the Appendix R signal tracing effort that was 17 perfermed in the 'B5 '86 time frame.
From those 155, we had 16 94 discrepancies.
All 80 of the cables from the Ampacity 19 program were discrepancies.
From the 75 Appendix R cables, 20 there were 14 discrepancies.
21 MR. GOODWIN:
Excuse me, Jim?
22 MR. HUTSON:
Yes?
23 MR. GOODWIN:
Perhaps everyone else here is aware 24 of what you mean by discrepancies.
This is discrepant 25 relative to what criteria?
I Beritage Reporting Corporation 3
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-MR. HUTSON:
What a discrepancy with regard to1 the discussion at this point is defined as is the installed 2
configuration does not agree with the design configuration..
4
- f yeu look at the. cable pull card and it says to'go'into-5 Tray X, it went into Tray Y in the field, that's a f
discrepancy.
When those two do not match exactly, that's a discrepancy.
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E MR. GOODWIN:
Not pulled as design.
9 ME. HUTSON:
Not pulled as designed, exactly.
1:
MK. GOCDWIN:
-- what a discrepancy is?
1; MR. HUTSON:
That's correct.
Now, what we do then is take the discrepancies and 13 compare them to what they actually are, and that is done in 14 accordance with the design criteria of the FSAR.
35 Now, from that, we have reviewed the 80 from 16 Ampacity, and two of those do not comply with the design 17 criteria of the FSAR.
We have 14 remaining to be reviewed, 18 which we have not done at this time.
19 What we're proposing instead of, in order, before 20 it would be a failure or a hit, okay, I guess not a hit but 21 before it would be considered a true discrepancy or a true 22 difficulty, we would run it through the design or safety 23 significance review, okay.
24 With regard to the two out of 80 that we have 25 reviewed, those are not safety significant.
That review has-j Beritage Reporting Corporation (202) 628-4888
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MR. MARINOS:
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2 or separations, necessarily?
4-MR. HUTSON:
That's correct.
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VOICE:
There had besn some discrepancies within 5
the same division?
Not truly violatzons W
bGl. HUTSON:
Right, that's correct.
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MR. PIERSON:
To make this a little clearer, could 9-we run through, say, several examples, one example, say of 10 the subgroup of 80 that turned out not to be a discrepancy g
'll and then maybe the two that did turn out to be
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. discrepancies, so we can get a sense of what you're talking 13 about.
14 MR. HUTSON:
Okay.
One that does not turn out to 15 be a discrepancy, for example, would be, let's say it,'s a IE Division 1 cable, and instead of going in, and I'll use 17 terminology here, these are not specific' tray' numbers, but 18 say it goes into Tray X-1, which is Tray X, Division 1.
19-Okay, instead of going into X-1, it goes into Y-1, which is
~
.20 appropriate.
There's no difficulty with that.
That means 21 when the guy went to lay it into the tray tier, instead of 22 going into Tray X, he went down below or something and went 23 into Tray Y.
24 MR. PIERSON:
So Y would be --
25 MR. HUTSON:
Yes.
Y would be vertically in the Beritage Reporting Corporation (202) 628-4888
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That would be an example.
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2 Another example would be, let's take a no$.-safety
.4 cable and it would be a non-safety cable instead of going 5
into Tray X it went into Tray Y, okay.
It's a discrepancy.
6 It means that the design-configuration doesinot match up i
with'the installed configuration.
1 8 We take those and we evaluate those as to whether-9
-or not they comply with the criteria.
The criteria 10 basically says.that if, cu have a division cn: a safety 11 ~
cable, it goes into the appropriate division.
If you have a.
12 non-safety cable,-once it becomes associated with a division 13 or a safety cable, then it stays with that throughout.its 14 route.
15 Now, the two that we have identif'ed, one is a i
16 safety cable, and one's a non-safety.
The one safety cable 17 is a divisional cable that gets into a non-divisional tray, 18 okay.
Now, with regard to seismic qualification, we've 19 eva1uated the tray and it is seismically qualified.
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20 And once, if you look at the 384 or Reg.. Guide 21 175, basically what happened when that cable got into that 22 tray, it was no-longer a non-safety tray, it's in a safety 23 tray.
Okay.
So all the cables around it become associated, 24 essentially.
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'which'ioo'ked at all the remaining cables in that tray,;we.
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' evaluated them'to ensure that,theyEwereinot routed with'a 3'
- redundant safety function.
And that's-basica11yJwhat is.
4 perf rmed.
On an item,7when it does notimeet;the' criteria,.
5 you extend the evaluations.
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'MR. GOODWIN: ~ Excuse me, Jim?
7 Okay, now you drop this division 1 cable into a-E non-dirisional tray.,'And.there are perhaps 30.other' cables 9
in'that tray that are non-divisional. 'And these have.all 10 becomeLassociated.
.n 11 MR. HUTSON:
'Yes, thos~e'30 became associated, yes.
11 MR. GOODWIN:
Right now.
-13 MR. HUTSON:
Yes.
14 MR..GOODWIN:
Suppose those 29 others were 15 discrepant.but that they were bouncing in and out of 16 division 2 but they never went to division 1.
- You would 17 have identified them'as discrepant.
But now that they've i
18 become associated with, division 1, is there a process such 19 that could repick that up?
20 MR. HUTSON:
Yes, that's what we did.
We took 21 those associated cables, okay, and we looked at their route 22 to ensure that they did not route'with the other divisions.-
23 If they did route with the other divisions,-we made sure 24 they were not routed with redundant safety function,,that 25 this divisional. cable was performing.
We insured.th9t the Beritage Reporting. Corporation (202) 628-4888 s_
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-is'what we've' ensured.
MR. PIERSON:
Does thatt answer your' question?
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MR. HUTSON:
But that's basically what we are:
.5 proposing ~on V-3, to use.again, though.
We-used the design-6 cr safety significance as the acceptance criteria.- Now, if we have a. design.or safety significant item, then we'would E
again determine'the root cause.
From that. root'cause, we~
9 would perform an additional review.
We determined the 1:
population in that root cause, determine a sample with.a il preset' acceptance criteria based upon the sample. size.
1; MR. PAULUTZ:
How did you determine the root cause 13 population?
I'-
MR. HUTSON:
Well, I can't until I determine what 15 the item is, Fre'.
I'd look at it from physical routing.
d 16 As we~said last week, if you look at'the 14 which we picked 17-up from Appendix R, basically what it is is you have a 18 linear section of tray.
19 It r=y be easier if I could draw a picture on the 20 board for this one.
21 MR. PIERSON:
Go ahead.
22 MR. HUTSON:
I'm not sure how we transcribe that.
23 MR. PIERSON:
Just describe it.
24 MR. HUTSON:
Okay.
What we have is a linear 25 section of tray, and I'll use the same designations as I Heritage Reporting Corporation (202) 628-4888
e 4
21 used last week.
And then you have a condition, this is a linear section of tray, this is designated as NAR-ESI which means that's a division 1 tray section.
You have a barrier 4
in the tray.
Then it becomes a non-divisional tray, NAR, E
it's a non-divisional section of tray.
f We have a cable that we've signal traced.
And this cable is supposed to have gone in like that and did
~
E that.
9 MR. PIERSON:
Describe that so he gets it on the 1:
tape.
MR. HUTSON:
Oh, I'm sorry.
The cable was
- l designed to enter the division 1 tray and exit the division
- 3 1 tray in such a way that it would maintain a division 1 14 route.
15 MR. PIERSON:
Prior to reaching the --
16 MR. HUTSON:
Prior to reaching its end point.
1-What we found from the signal tracing effort, the cables 18 actually entered the division 1 tray and subsequently got 19 into the non-divisional section of tray and exited.
20 MR. GOODWIN:
What type of overlap are you talking 21 about?
22 MR. HUTSON:
Well, we're trying to get the exact 23 footages on that now, Bob.
Basi.cally, what we have, I think 24 it varies anywhere from three feet and above.
I don't know 25 what the limit is exactly on that, but, you know, we were Heritage Reporting Corporation (202) 628-4888 l
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22 1
talking anywhere from three feet up to;several feet.
I.
don't'know what the exact maximum is.
We're trying to chtain that now.
i.
o 4
MR. MARINOS:
Is this one cable?'
5 MR. HUTSON:
That's one of the 14.that we havenft
.E:
dene the further review on yet.
MR. MARINOS:
Is this one cable that fell in that 4
8 category, or?
9 MR. HUTSON:
Well, out of the 75 from Appendix R, 10 I don't want to confuse numbers, but out of the 75 from.
Appendix R, okay, the 14. discrepancies, all 14 of them fall 12-inte this category here.
13 MR GARG:
What kind of a barrier have you got?
f 14 M?.. HUTSON:
I'm not sure, Huk.
I'm not sure what 15 type of barrier it was.
I do know there is a physical 16 barrier place there.
It's hard to determine now with regard 17 to what was there with regard because of the plain mastic, 16 etcetera that's on the tray.
19 MR. MORAN:
Jim, I'd like to pursue what Fred
. :2 0 Paulut started.
21 Once you determine a root cause, your next step in 22 your analysis is to determine the population, and then go 23 into the statistical.
24 MR. HUTSON:
Using this as an example, if this 25 turned out to be the root cause, then we'd find all the-Beritage Reporting Corporation (202) 628-4888
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trays that had this type of possible configuration.
And we' d determine the cables that were designed to be routed, fer example, in a division tray.
And from that population, 4
we would preset, prior to the sample, we' d determine the 5
total population involved, and we'd determine a sample rate 6
based upon that.
7 MR. MARINOS:
The important qualification here is e
that you will do this root cause only if a cable is safety 9
significant ?
10 MR. HUTSON:
That's correct, yes.
Only if there safety significance or a design or safety significance 11 was a 12 in that area, that's correct.
12 MR. MORAN:
And you would be going to your 14 drawings to determine the number of trays with this barrier 15 or this configuration?
16 MR. HUTSON:
With this particular configuration, 17 yes.
Yes, that's correct.
16 MR. MORAN:
And it seems to me you told us last 19 time we met that your drawings had been brought up to 20 scratch, is that correct?
21 MR. HUTSON:
I'm not following you, Dave.
Brought 22 up to scratch?
23 MR. MORAN:
Brought up to configuration so you now 24 have configuration on all your trays?
25 MR. HUTSON:
Don't remember that being a topic of Heritage Reporting Corporation (202) 628-4888
c, W
~24
.'l discussion but.I'm not sure of the status, if you're speaking from an as constructed, versus as designed, I'm not' 2
'sure.
-4 MR. MARINOS:
They were going to update to get 5
everything in the computer.
f-MR. HUTSON:
That's.what we're considering, yes.
Right now, the unit I and unit'II cables,are on what's known as conduit'andicable schedule drawings.
They're not in a 9
computer database.
.Okay, what it would take would be,. you'd 10 leek at the physical layout of the trays in the plant.
11 There's tray layout drawings th'at shows the physical 12 configuration of the trays in the plant.- Then you'd' 13 determine those trays that fall into this category based on' 14 that review.
15 Then once you determine the trays, it would be a 16 manual search to go through and find the cables that fall 17 into those trays.
That's how you would find them.
16 MR. PAULUTZ:
The cables that may exit a tray and 19 say go into a conduit, your conduits wasn't pre-engineered, l
20 they were field run,,is that correct?
21 MR. HUTSON:
That's correct, yes.
22 MR. PAULUTZ:
You would have problems trying to 23 get from, quote, drawing, per se, to find out what actually 24 occurred out there?
You know approximately where the 25 thing's supposed to be going but you'd have to physically go Heritage Reporting Corporation (202) 628-4888
ic uas E
25 out and look, wouldn't you?
t@,. HUTSON:
Well, with' regard t'o the conduit 2
-routing, of course, we sized the initial conduit, etcetera, 4
.and we gave.a proposed routing.
But the. final physical 5
installation was field routed.
But as far as entry or exit E
points, we would have designated where it should have 7
entered and exited with regard to trays.
6 MR. PAULUTZ:
.You' d 'still have that designated.
9 MR. HUTSON:
That's correct, yes.
Andfwith regard 10 tc the conduit installation, of course, there's installation 11 requirements to maintain separations, etcetera.
12 MR. MORAN:
Jim, I'm still not clear on how you 13 assure that the drawings that you're.looking at to determine 14 this population which fits your root cause or tells you-your 15 root cause population, I'm not sure you're able to lay hands 16.
on drawings that you know reflect what actually is going on 17 out in the, what actually exists in the plant.
And we're 18 talking as designed versus as built.
You said that you 19 would go out and look at the trays and determine that, and I 20 assume that none of these trays have --
21 MR. HUTSON:
If further sampling is required, we 22 will have to field verify where those cables were routed, 23 okay.
But our objective is to ensure --
24 MR. MORAN:
But you don't sample until you've got 25 your population.
And in order to determine your population, t
}
Heritage Reporting Corporation (202) 628-4888 1
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- 26.
you're talk'ingrabout'getting your arms around the:whole-i thiny.
2 MR.'HUTSON:
That population will be established 4
based on reviewing dssign documentation.
That's the only 5
way tofdo that.
E MR' PIERSON:
What would you do?
Lookfforftrays 7
where you had a barrier there?-
8 MR. HUTSON:
Using this;as an example, where 9
.you've got'a divisional, where you've got a. tray that's 1
10 designated with divisional and non-divisional?
11 MR'GARG:
In this case.is simple.
They_can work 12 back. In other cases though they cannot do that --
13 MR. HUTSON:
Well, I think it would be,,we're trying to.
14 theorize what the root cause would be and we really 'on't d
15 know what it is.
You have to look at.the problem is'and 16 from that make a sound engineering decision on what the root 17 cause is 18 MR GARG:
But, let ask you thing.
I mean you are 19 proposing that, you-took a sample of 155, you fout.c 94 20 discrepancies, you are asking us to make a judgement that is i
21 not all the time significant, so its all right forius to go 22 nd trust your design documents.
23 MR. HUTSON:
- Well, I. guess that's'a two part 24 question.
One, we're not dealing with a true sample from o
25 that perspective.
What we're dealing with is an amount of Heritage Reporting Corporation (202) 628-4888
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data-which we have gathered via other programs, and we're 1
requesting the option to at least evaluate that data to -
2 draw, to develop a confidence level.
And that confidence.
4 level would be established based on a statistical evaluation 5
of-the1 data.
We would take the 155 cables that we've f
reviewed or signal traced, and evaluate the impact of any 7
anomalies that came from those results.
E MR. MARINOS:
But as you prefaced' earlier, Jim, we 9
have to agree, at'least agree to disagree or agree on the 10 acceptance-criteria we're going to use.
11 MR. HUTSON:
Yes, I think -
yes.
12 MR. MARINOS:
Because you use present, future and 13 past.
And of course, it's confusing w_ather you ie 14 planning, and I'm waiting to see whether you're going to 15 say, I'm going to do something more or I have done all I'm 16 going to do, and I'm going to stay with what I have and I'll 17 evaluate them on the basis of criteria that we'll mutually 18 agree upon.
So I don't know if you've finished your story.
19 MR. HUTSON:
Maybe if I can just walk back through 20 then the V-3 effort.
I think that hopefully that would 21 clarify it.
22 MR. PIERSON:
That would help.
23 MR. HUTSON:
We would take the population of 155 24 cables and we would review those results, which we have 25 partially done.
We'd review those results and any anomalies Beritage Reporting Corporation (202) 628-4888
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or discrepancies against-the criteria.
Then we.would perform'a further' evaluation to determine the significance 1
ef.the discrepancy.
And that significance would'be based
- 4 upon its design or safety significance with regard to:
' redundant safety function.
.f From that, the acceptance criteria ~would be'zero design significance.
If there is design significance,.then
~
E we would perform a root cause evaluation.
From'that root 9
cause evaluation, we would determine.the total population-10
-invclved with that root cause situation.
11 With regard to the total population, then we would-c 12 perform a further sample of'that.
And in.my opinion, our-13 acceptance criteria again should be on that sample though 14
'should be again zero design significance.
15 MR. PAULUTZ:
Jim, I can't believe that out of the 16 155 that you haven't really analyzed to the nth degree 17 exactly not just the lack of compliance of separation but 18 the safety significance of them.
As you already know, those.
19 answers are ready.
And that you're asking us to plus the 20 plan when you already know that you're going to come out 21 clean.
22 MR. HUTSON:
Well, I think as we discussed last 23 week, we have looked St.those 80.
And as I've stated here 24 today, 60 of those have been looked at.
And there are two 25 that are discrepant with regard to the criteria, but we have Heritage Reporting Corporation (202) 628-4888 i
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4-
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29 performed-a design significance review and there is no 1
design significance in those two..
MR. PAULUTZ:
I can't believe that the other 14 4
haven't been looked at either, yet.
5 MR.-HUTSON:
Well, they'have not been looked at 6
with regard that, okay.
And the reason for that is that that is a time consuming effort.
The design significance E-review is not an easy effort.
That's why you do not want to 9
have that as.your criteria to start with.
You want a much 10 easier tool in order to deal with your cable separations.
11' We have not reviewed the other.14 with regard to 1:
. design significance.
1?
MR. PIERSON:
You've reviewed all 80 for ampacity, 14 but you haven't reviewed the 14 for --
15 MR. HUTSON:
That's correct, yes.
16 MR. MARINOS:
As we indicated to you'in the last 17 meeting, we have, at least I don't have any problem, and our 15 statistician also reiterated that we have no problem with j
19 the root cause analysis that you're proposing to do on thu 20 cables that you find that have violated the separation 21 criteria.
22 The question that we raised to you, and you're 23 here, perhaps, to clarify and further discuss with us is, 24 hew do you establish your sample and what credibility does r
25 one place on your sample when it is discrepant, and how do j
Heritage Reporting Corporation l
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we accept that as - an acceptable sample oJ :the total pcpulation' to make a - judgment ' about the. discrepancies: being F
significant or insignificant for'the whole population with 4
' regard to discrepancies, 5
MR. HUTSON: 'Well, with regard to how.the cable E
information was. gathered,' the intent'was not cable i
separations.
.So'because Of that, 'I would consider the 6
population of.155 to be at random, in my.. opinion,.from 9
gathering that data.
1-MR. MARINOS:
There's no question in my mind about 11 it beingzrandom, and I'm not addressing that necessarily.
12 You have discrepancies yeu've identified.-
The discrepancies-13 are not.necessarily.significant to safety but they're 14 nevertheless discrepancies in the strict criteria of 15 separation.
16 Now, that represents a percentage or at least an 17 extrapolation of a: large number of discrepancies within a 18 very large number of' cables, something like on'the order as 19 we indicated about 22,000 cables.
There is a possibility 20 perhaps that maybe 2, or 3, or 4,000 cables that are 21' discrepant on the strict application of the separation 22 criteria that are imposed on you by the NRC, and you also 23 have to meat the FSAR.
-24 Now, the question I have is, what confidence do I 25 have and do you have that none of those cables and almost Beritage Reporting Corporation (202) 628-4888
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that. population.
How'do we get a confidence. level that we 3
.all.can go home happy with?-
4 MR. HUTSON: -Okay.
With regard.to the population LS
.that I have to' evaluate,.if I' review those 155 cables'and' l
f find ne de.9ign or safety significance, I would have greater than 95 95 confidence level.
That is,. I would have greater
~
E' than 95 percent confidence with a 95' percent reliability.
9 MR. GARG:
But you have related only 16 10 d screpancies.
11-MR. HUTSON:
I'm sorry?
12 MR. GARG:
You have related only 16 discrepancies.
.13
- Whatever it comes to, I don't know.
14
.bm. HUTSON:
No.
Out of the 155 cables, what that.
15-means is that there were 94 cables that when yea looked at:
16 the design information and compared it to'the installed 17 configuration or installed information, there was something.
18 discrepant between the two.
19 We then took each of those discrepancies and we 20 evaluated them with regard to the FSAR design criteria and l
21 we'd take them one step further to ensure that there was no 22 design or safety significance.
So we have evaluated 155 23 cables with regard to that.
,1 24 MR. MARINOS:
You have presently evaluated safety 25 significance for only two cables that you found discrepant.
Beritage Reporting Corporation (202) 428-4888 u_--__.--__.--_.
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e 32 MR.-HUTSON:
No.
1 MR. MARINOS:
In a separation.
2 MR. HUTSONi No, no.
That's incorrect.
We have 4
evaluated essentially all 155 cables with regard;to design 5
significance, okay.
Because if there'was nothing that did 6
'nct conflict with the criteria, we know it's not design or 7
safety significant, so --
6 MR. MARINOS:
The other cables did not. violate the.
9 separation criteria.
Only two you found that violated it.
1:
MR. HUTSON:
That's correct.
That's the only 11 thing that would push me, that's the only thing that would!
12 direct me to doing a further evaluation, is if'it did not 13 agree with the criteria.
If'it agrees 1with the criteria, 14 then there is no by definition, design or safety 15 significance.
If MR. MARINOS:
Well, that's true.
17 MR. HUTSON:
So I have looked'at 155 cables.
18 MR. MARINOS:
Are you suggesting now that whatever 19 other number of separation violations exist within the 20 population of cables, of the nature of the twc that'you've 21 identified, they're all going to be non-safety significant?
22 MR. HUTSON:
With regard, I would have the 23 confidence level of at least 95 percent confidence with a 95 24 percent reliability.
25 MR. GARG:
What it's showing is that at least 5 Heritage Reporting Corporation (202) 628-4888
..v s..
n 33' percent chance-that 5 percent of the cables are not good.
I 1
mean that could have a design significance.-
2
- 19.. HUTSCN:
No, I wouldn't -- well, no.
That's 4
saying that.the potential exists, yes.
It does not 5
conclude that they.are.now.
6
'MR.
GARG:
Well, I mean that-is a 95% reliability-and I don't.
~
E (Participants speaking in chorus) 9 MR. MORAN:
Wait a minute, wait a minute, we are-1C getting off.the subject.
We need to talk about that.
11 MR. MARINOS:
Well, we need to convey to them how 12 we think about this, 13 MR. MORAN: Do you want to have a short caucus,-
14 here then?
15 (Discussion held off the record.)
16 MR. MORAN:
I guess Mr. Pierson is going.to give 17 us --
18 MR. PIERSON:
We discussed your proposal with 19 using the root cause analysis of a discrepancy to define a 20 larger population.
And it's our position that we can't make 21 a statistically valid argument for that justification.
22 Now, what we feel is something that could allow us 23 to use -- to make a statistically valid population argument 24 would be if you would expand your samp.le to the point where 25 you had a minimum of 59 separation significant discrepancies l
Heritage Reporting Corporation (202) 628 4888 l
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. and' on :the basis of that, then look at that sample of 59 separation significant discrepancies, and validate'that none
?
cf them were safety-related discrepancies or~ safety 4
significant-discrepancies.
5 Now,1there's two things you couldldo'with that.
f Angelo says. there's a number of ten percent of the i
population.
I'm not sure but --
8 MR. MARINOS:
You can, keep drawing _ samples from 9
your large population-until you have a' minimum of 59 10-separation violations.
Safety significance is not.being 11; interjected here, just pure separation violations.
And then 1;
of.the 59,-you evaluate them.for significance.
If there's 13 no safety significance, everything is' fine.
14'
-MR.
PIERSON:
We have a problem. We loak at what 15 you've presented to us and we-have a situation where right if now you have tested 155 cables from C-3.
Now, if I remember 17 correctly, coming down from this you've got a sample set of 18 80 Ampacity and 14 dependents are?
19-MR. MARINOS:
So it's 75.
20 MR. PIERSON:
And this goes into 14 and.this goes 21 into 2.
Thus, you really don't know --
22 MR. HUTSON:
No, no.
That number from the 80 --
23 okay, I see.
24 MR. MARINOS:
Separation violations.
25 MR. PIERSON:
What I'm trying to say is, I'm Beritage Reporting Corporation (202) 628-4888
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]
trying to do the maximum amount of separation violations.
You either.have 2 plus some number between zero and 14, 2
okay?
So you've got 2 to 16 here.
4'
- Now,
%at we're saying here is if you; start with a 5
sample of 155, should this number in fact be zero'and you 6
end up with.two here, you would have a statistically valid 7
argument to say, based on our safety significant separation, E
we look at'this, we can make the argument based on 9
. separation.
In other words, the separation'is such that we-
^
IC can make an argument from this.155 to the entire sample that 11 we had valid separation in the plan, because we were within 12 the 95 95 confidence of only two.
13 MR. HUTSON:
What is the acceptance criteria for 14 the two?
15 MR. PIERSON:
Separation.
16 MR. MARINOS:
Separation.
17 MR. HUTSON:
Literal compliance, still.
18 MR. PIERSON:
Yes.
19 MR. MARINOS:
Literal compliance with separation 20 criteria.
21 MR. PIERSON:
Yes, literal compliance.
That would 22 be the two.
23 Now, suppose you don't get that.
Suppose instead 24 of having zero here, you end up with say, 3.
So three of 25 these, now this number's five.
Heritage F Torting Corporation (is2) 628-4888
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the problem with that is, that puts youeinfa
- Now, position:where you have to test the entire sample because-
?
'you failed.that first confidence level.
You can't sell the 4
merits based on separation criteria.
So that puts you in 5
somewhat of a difficult situation.
6 So what we're proposing is this: if you take your-7 plant as a whole, you've already looked at a certain cross E
section, and you've come up with what we call --
9
.MR.
MARINOS:
The discrepant population.-
1:
MR. PIERSON:
The. discrepant population, that 11 violate the titeral intent of the FSAR requirements.
You've 12 done one sample that looks something like this and you've 13 ended up over here with some number from 2 to 16.
You don't 14 know what it is.
15 If this number of discrepants could be as high to if have a minimum population sample has to be at least 59.
17 Now,.if you do this, do a series of others, come up such 18 that the total here 47uals 59, and then you look at these 59-19 discrepants in terms of safety significance, then you can 20 sell the validity of your statistical basis by assuming that 21 we've locked at a large enough population of discrepants and 22 validated that none of them are safety related or safety
~
23 significance.
Therefore, even if they existed, we' d sti11 24 have a safe plant.
25 Now, the danger with only one of 59 here is that Beritage Reporting Corporation (202) 628-4888
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If you increase the populati'on, of course, you're allowed more.
The problem with'this from
?
ycur perspective is the number o'f' samples you'll have!to
~
4 conduct to get this number of'59.,So what we' re willing to I
say is that if this number 2 is correct, that's about 1.5 6
percent.
One and a half percent of your total population,-
7 you might end up conceivably going through the entire 6
population before you ever get 59.
9 So what we're willing to, and I think we can make 1C a statistically valid argument, is that should you reach ten
.11 percent of this number, or 59, 12 MR. MARINOS:
Whichever comes first.
13 MR. PIERSON:
-- whichever comes first,-should you-14 wish to stay with 59.
You may want to go -- my advice to 15 you is to go somewhat beyond 59 to you could get more than 16 one discrepancy because if you look at this 59 and end up 17 with a safety-related discrepancy, then you' re going to have 18 to go back to the entire sample.
19 So it's divided into two sections.
One is to sell 20 it based on separation criteria.
And you're very close.
If 21 this 14 that you haven't looked at, if you even got one, you 22 end up going to the entire population.
23 MR. HUTSON:
What is the, okay, based on literal 24 compliance with the criteria, what is-the acceptable 25 quantity out of the 155.
Beritage Reporting Corporation (202) 628-4888
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'MR.
MARINOSi.Three, last time-I --
MR. HUTSON-Okay, we're;still --
?
MR. PIERSON:
All 14.
4 MR. MARINOS:
No, but you can't decide'right now.
5 MR.-PIERSON:
You have to decide, and --
.C MR. HUTSON:
Well, I guess, I'll be honest with I'm confused --
you.
E.
MR. MARINOS:
No, but Jim, the 155 don't mean
?
anything.
We are looking;for a sample from'you'--
1:
Please, let's give some consideration to'the court-.
11 reporter, and one-person. speak at a time.
1:
Well, essentially what Bob was trying to convey to 13 you that by trying to attain 59 separation violations,ois 14 essentially you' re doing a sampiing from your discrepant 15 population.
If you could theoretically identify it and 16 isciate.it as a large number of discrepant population 17 meaning not necessarily separation violations, discrepant-18
-cables.
You have lots of them.
If you could identify the
.19 population as separated, you.can take a sample from that, 20 okay, and see whether you can get 59 that are violations and 21 they have no safety significance.
22 But because you cannot do that,.you have to keep 23 taking from the overall population to arrive at 59 24 separation violations which theoretically corresponds to 25 your infinite population of separation violations.
Heritage Reporting Corporation (202) 628-4888
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1 MR.EHUTSON:
I guess that's why I'm confused; I
about',-is why we have'to have 59. separations violations.
U 2
That's.what ! don't understand.
4 MR. MARINOS:
Because.if you're separation 5-
. violations within the 22,000 cables is let's say, 2,000, f
okay., just for example.
If you have 2,000fseparation
]
violations, okay, we have to have the confidence, and you
~
E have to be able to.make the statement that all the 2,000 L
9 separation violations have no safety significance, okay.
Now, if you --
l 11 MR. HUTSON:
Is that 100 percent certainty or 1:
confidence?
13 MR. MARINOS:
95 95.
14 MR. HUTSON:
Okay.
15 MR. MARINOS:
If you were to identify 2,000 16 separation violations, you have to make a statement that.95 1~
95 confidence level that none of those have. safety 16 significance.
Well, if you could identify the population, 19 you could easily take a sample of 59 from this separation 20 violations, and do an evaluation of safety significance and 21 then go awa" If there is no safety significance, then you 22 can say that population of 2,000 separation violations have 23 no safety significance.
24 MR. PIERSON:
So you see, there's two different 25 aspects to it.
One is separation criteria.
You're very Beritage Reporting Corporation (202) 628-4888 La_____2-___-____
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c1'ese to failing your separation criteria based upon the 1
155.
If you could, if the two that you've_got,'the two' n
2 separatien criteria all that you've got, and this number is 4
zer: for the next 14 you'look at, you meet the separation L
5 acceptance criteria, and you can make a statistically valid E
argument that the separation in the plant is-confident i
enough'that you can satisfy the true separation' criteria, 8
not the discrepancy, but the true separation criteria.
9 Now, if you should choose that and you go'over 10.
three in your 155 sample, then you'd have to do the total 11 population.
12 Now,-the next stage down here is, if you decide-13 that that puts you in too much jeopardy, that you might have 14 two or three out of this 14, and you don't want to risk 15 that, you can keep sampling until you build up a population 16 of discrepancies large enough to make it statistically 1.
valid, when you look at the discrepancies, to define whether 18 they're safety-related or not.
19 And say you go to 59 and 0, then you could make 20 the argument that even though we've had discrepancies, we 21 had a 95 95 confidence level that any discrepancy we incur 22 is not safety-related.
23 And we think we can sell it from that perspective.
24 Would you guys like to caucus a little bit and 25 talk among yourselves and then come back?
Heritage Reporting Corporation (202) 628-4888
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1 MR. ZERINGUE:
Well', I'd like to'ask a question, just from a statistical point of view.
?
101. PIERSON:
Sure.
' MR. ZERINGUE: 'Because I may be misunderstanding.
.I. thought that from a statistical perspective, I C
think I understand the 59.
The 59 is --
7 MR. PIERSON:
It's the smallest popuistion that's E
represented.
?
MR. ZERINGUE:
And that takes care of some 10 infinite sample into a number.
So if I took, I'm trying to 11 understand the statistics here, if I took 59 from whatever 11 the size.cf this population was, infinite population, and I 13 have an acceptance criteria, and then if all 59 of those 14
' things met the acceptance criteria, then I would have a 95 15 95?
16 MR. PIERSON:
Right.
17 MR. MARINOS:
Right.
1B MR. EIERSON:
Take 59 and then describing it in 19 terms of discrepancy or errors, and then ended up with out 20 of that 59 population, none of them were safety significant 21 or had a safety impact, you've got 59 is a large enough 22 sample set that we can say that that's representative of the 23 entire population of V-2 cables in the plant.
24 MR. ZERINGUE:
Yes.
What I was trying to 25 understand, this has got me confused a little bit.
You Heritage Reporting Corporation (202) 628-4888
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know, 'if my acceptance criteria-is no safety sign'ificance, and I guess we were --
~3 1GP,. MARINCO:
There's a'two tier thing.
There are 4
twc criteria.
One you have to establish that you have a 5
populatien of cables that violates separation, okay.
So you E
establish that population.
Let's say 2,000 cables within 7
the plant violate the separation criteaia, purely, okay.
1 E-That becomes in itself a population you have to 9
evaluate safety significance on now.
101 MR. ZERINGUE:
But I guess I don't understand, 11 though, why you can't take the safety significant criteria 12 and find an acceptable --
13 MR. MARINOS:
No.
14 MR. PIERSON:
Because you're confusing apples and 15 oranges.
The first question, here's the questions.
The 16 first question is separation.
We have based on our license 17 reviews that we had certain criteria which we called 18 separation which would take credit for in terms of a license 19 agreement.
That's what you're at right here.
20 Now, if you base it on separation criteria, we 21 already know that if you don't meet the separation criteria, 22 you immediately throw that into question.
Now, the question-23 is, we have to get enough of a population of the ones that 24 di dn ' t satisfy the separation, the discrepancies, to be able 25 to make a statistically valid sample that the ones that are i
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discrepancies are not safety related.
1 Because see, we can't, we understand, we know that
~
O we've got a sample.
I'think what'you're trying to say is 4
why can't we start with this 155 and go straight down to 5
safety significant.
6 MR. ZERINGUE:
Just 59, actually.
MR. PIERSON:
Okay, say from 59 down to say, okay, E
we've got 0 safety related.
Because we're not looking.at 9
the cables for terms.of safety-related.
The question is, 10 are they installed, is the separation met.
Because it's
'11 assumed that if you install your cables, you're going to try.
12 te meet the separation criterie.
13 It's also assumed that in every instance.when you-14 don't meet the separation criteria, it's not necessarily.
15 going to be a safety-related problem.
16 So if you take the argument of say 59, and go down 17 to the safety related, then we've got a situation where we 18 know de facto that you don't meet your separation criteria, 19 or at least we think you don't, because we're not even 20 looking at that.
i 21 But the separation is.what you took credit for in 22 designing a plant and making it responsive to certain 23 accident scenarios.
So it doesn't lend the weight.
It 24 doesn't, we can't prove that.
25 MR. ZERINGUE:
Let me walk through something, Heritage Reporting Corporation (202) 628-4888
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= 44; okay.
And you can tell me where I'm off base.on this.
I We have separation criteria and that's there to onsure that we maintain redundancy.
We agree.
'e
-The evaluation that it.will'be done for, quote, 5
safety significance, is an evaluation to ensure that we f
maintain redundancy.
That-there isn't a failure --
7 So be-it --
l l
E MR. MORAN:
The single failure criteria.
9 MR. ZERINGUE:
That's what we're trying to get'to,.
10 single failure criteria.
So we can do single failure 1 ~.
criteria by'looking at separation.-
1:
MR. PIERSON:
Here's'the problem.
!?
MR. ZERINGUE:
Let me finish, sir.
24 We can look at it from separation, we can look at-If it technically to ensure that everything's okay.
So the 16 bottom line is, we're doing an evaluation here to ensure we 17 meet single failure criteria.
16 MR. MARIN05:. If you can evaluate each cable 10 19 the plant that way, of course, nobody has any problem.
20 MR. ZERINGUE:
I understand.
But I'm saying 21 that's the criteria we're trying to get to ultimately.
22 MR. MARINOS:
Ultimately.
23 MR. ZERINGUE:
Ultimately, that's the criteria.
24 Now, my understanding of statistics, and this 25 could very well be wrong, is that if I select a criteria Beritage Reporting Corporation (202) 628-4888
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single failure, and I go do 59 and I-have no hits on 59, 1.
.then': have a 95 95 for unlimited samples sets, for infinite
-sample sets.
.4 MF.. MARINOS:
But-you'have to get into that poi'+..
I First of all, there are two different criteria.
We f
' established separation so:you can go to your population and 7
de a statistical sample on separation alone.
Okay.
6 And if you don't succeed in your statistics, 9
theoretically you do'100 percent evaluation of all your 1C cables to find out how many of the cables do not meet the l'
separation criteria.
So you establish a population now on 1;
the basis cf statistics.
~13 Now, you go into this population of cables that do 14 not meet the separation criteria, and want to make a 15.
judgment about how many of those cables actually have safety 16-significance.
17 MR.'PIERSON:
Very quickly what the problem is 18 with your argument.
Because you're reducing, essentially 19 you' re reducing your argument down Lo a rRA because 20 essentially you have assigned a fact -- we know from what 21 you've done that it looks like your separations, you've got 22 problems with the cable layout.
So already we know that the 23-cable separation is questionable.
24 So essentially what you've done is you've reduced 25 that down.
We can't accept that simply by itself as an Beritage Reporting Corporation (202) 628-4886
's 46 argument unless'we can look at the population:of what the discrepants'were and say, based on the discrepants that-we knew,- because we already know that you've got discrepancies.
4 MR..ZERINGUE':
Unless_I'm wrong, what I suggested 5
would give us a 95 95 that we don't have single failure E
problems.
MR. PIERSON:
You're probably right.
E MR. ZERINGUE:
That's what it would tell us.
9 MR. FIERSON:
Yes.
1:
MR. LIAUJ:
If I may add something to it.
1; MR. PIERSON:
Yes.
12 MR. LIAUJ:
I think you are right.
I think you 13 are right, but Bob's tried to describe to you that we don't 14 license a plant on a PRA basis.
That's not the licensing 15 basis of your plant.
Just let me finish.
- 6 The licensing basis of the plan, theoretically 17 speaking, is supposed to be 100 percent, okay, meeting the 18 separation criteria.
19 Do you understand what I'm saying?
20-MR. ZERINGUE:
Yes, I understand that.
21 MR. LIAUJ:
So what I'm trying to do is take you 22 back of what Bob Pierson's saying.
He's saying, by your l
l 23 argument, you are asking us to accept something on a PRA 24 basis and I'm explaining to you that that's not the way that 25 your plant is licensed.
Heritage Reporting Corporation (202) 628-4888
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MR.:PIERSON:
It's a matter of confidence because 1
already we know that there are problems with cable 2
separation in the plant.
Now, what you're presenting if you 4
say, take 59 and.come up with 0 safety discrepancy, you 5
could use that in terms of a probabilistic argument.
Maybe.
F perhaps we'd have to do that sometime, but we don't like to do that as a basis-for a plant, because we like an E
assumption at least that the frame, the bulwark of what 9
we're trying to start with, we have a higher degree of 10 confidence in that.
11 And since we already know you've got that problem, 12 it would be difficult for us to make the argument that we 13 could --
14 MR. LIAUJ:
Bob, I think it's not a question of 15' whether we like or don't like, but the question's is whether 16.
or not we are capable or we are --
17 MR. PIERSON:
I don't think we'can do that.
18 MR. HUTSON:
Let us caucus for just a few minutes.
19 MR. LIAUJ:
But just a minute before you go out 20 for caucus, do you understand where we're coming from?
21 MR. HUTSON:
I understand exactly what you're 22 saying.
23 MR. LIAUJ:
I don't dispute what you are saying.
24 MR. PIERSON:
Do you understand this?
And 25 remember, the thing I think is very important is, if this Heritage Reporting Corporation (202) 628-4888 l
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48 discrepant population is as; low as I'think it probably is based on what you've said, this,155;is really representative,'and'that'this thit.g, probably if you choose 4
n o t-te gc with this, this would be-zero.
But if that's the 5-case, you may gela long time before.you reach 59.
But we're 6
willing to let ycu go with ten percent, ten. percent of the total; population.
~
E MR. HUTSON:
Could I.ask a' couple questions.
9-
_One, regarding V-4, V-5, does this approach apply 10 to V-4, V-5, as well?
Do we have to do this on V-4,
-5 as 11 well?~
1:
MR. LIAUJ:
Yes.
I think that's what you will go 13 and create a sample for on-the table you already have, and 14 if you can demonstrate 95 95 on the first one, 15 MF,. PIERSON:
Let us go caucus'and discuss that.-
16 MR. HUTSON:
Yes, if you could'during this 1
1 17 discussion, while we're talking, I need to know what 16 direction we' re headed on V-4, V-5.
19 Also, one other question.
The evaluation that 20 we're doing, though, is no more than doing basically either p
21 a 50-59 evaluation or what would be required by present day 22 requirements of 384 or 175, which would be on associated I;
23 circuit.
You know, one of the options with regard to 24 associated circuits, which is what we're dealing with here, 25 primarily, or it is what we're dealing with, associated Heritage Reporting Corporation
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circuits, allows an analysis to ensure that the safety or
. Class lE function is'not-degradable on an acceptable level.
2 That's the present day approach to'this type of situation.
4 MR. LIAUJ:
But how is.it related to this?
I 5
don't' understand.
f MR. HUTSON:
It's related directly to this.
That's basically what you do in a present' day associated
~
E circuit evaluation is you ensure that that association does 9
net degrade your Class 1E function.
That's_all that we're 10 asking to do is to do a present day type of determination.
11 MR. PIERSON:
That's in terms of 59 discrepancies?
12 MR. HUTSON:
That's with regard to the safety 13 significance.
14 MR. PIERSON:
Safety significance.
15 MR. HUTSON:
That's what you would do present day.
if MR. PIERSON:
I think that will be acceptable.
L.
17 MR. LIAUJ:
Yes, as long as you can demonstrate.
18 MR. HUTSON:
That -- okay.
I guess that's what, 19 that's where I have the, I won't call it a misunderstanding.
20 I'm not sure how to categorize it, but that's where I do not 21 understand why --
22 MR. MARINOS:
You said assuming you are --
23 MR. HUTSON:
-- why we don't link it to 155 and 24 then 94 discrepancies from that point with the acceptance 25 criteria being degradation of the safety function, whether Beritage Reporting Corporation (202) 628-4888
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n.
1 MR. PIERSON:
Because the design issue here is do 2
you. meet cable separation.
And you don't meet cable 4'
separation.
So, we, at least it looks like it.
5 MR. HUTSON:
As it's literally presently stated, 6
that's correct.
{
MR. PIERSON:
So it looks like, and so, once we
~
E know'that that design flaw possibly exists,'we have to have
'9 something to validate when we come to those discrepancies 10 that those discrepancies do not necessarily impact safety-11 related aspects.
MR. HUTSON:
Jmd what I'm telling you, Bob, is 13 present day, what that would do present day is to take that i
l' discrepancy and perform an evaluation of it to determine 15 safety significance.
j 16 MR. PIERSON:
That's fine.
17 MR. GARG:
But we don't go by. sample in present j
)
16 day.
f 19 MR. HUTSON:
It would be a case by, case l
20 evaluation, case by case evaluation.
21 MR. PIERSON:
What I'm saying is, from a 22 discrepant point of view, your population isn't.155, it's 2 23 to 16.
I 24 MR. HUTSON:
Well, the cables evaluated, though, 25 fall in a population of 155, and that would be the same l
1 l
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51 category as looking at V-4, V-5s.
MR. PIERSON:
But separation, separation -- I der.'t have my notes here, of 155, you have significantly 4
mere than that.
Something like 80 plus 14 to a total of 94 5
out of 155 didn't meet the separation.
E MR. HUTSON:
No, 94 of them when you compared the design documentation versus the physical installation, there
~
was a discrepancy between the two.
That did not mean that 9
there was a separation item against.
1C MR. BOUNDS:
That it didn't meet the FSAR 11 criter:.a.
1 MR. HUTSON:
That's right.
It did not mean that.
13 A further review is done based upon the --
14 MR. PIERSON:
So how many of those 155 haven't met 25 separation criteria?
16 MR. HUTSON:
From the 80, two of them.
From the 1~
other 14, we have not done reviews on those.
18 MR. PIERSON:
So it could be two to 16 out of the 19 155?
20 MR. HUTSON:
That's correct, yes.
21 MR. LIAUJ:
Okay, let's go off the record.
22 (Discussion held off the record.)
23 MR. HUTSON:
Just prior to going into the break 24 there, there was a statement made regarding a disease of 25 cable separations.
I was wanting some clarification on 1
Heritage Reporting Corporation
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Do,you feel that we do have a rampant problem.with 2.
' regard to cable separations or?
l 4
MR. MARINOS:
We don't know.
5 MR. PIERSON:
Based on what you've told us, we i
can't make the. argument that there is cable separation i
according to the design basis of your plant...That's 8
essentially the crux of the argument, I think.
9 MR. HUTSON:
Okay.
1 MR. MORAN:
Did.we use the term, disease?
j I
11 MR. GARG:
No, 95 95 percent you cannot say.
12 That's what they don't meet.
13 MR. HUTSON:
I thought that term was used.
14-MR. MORAN:
I didn't hear that.
15 MR. HUTSON:
I apologize for that.
We were 16 concerned.
We wanted to make certain that we were on the i
17 same wavelength with regard to the discrepancies that we'd 18 found.
19 MR. GARG:
Well, if it was'said, it is on the 20 record, I guess.
l 21 MR. HUTSON:
Okay.
That's all we have for 22 discussion.
23 Mr. Bynum has something.
24 MR. BYNUM:
Yes.
I think, you know, we certainly 25 understand the approach that you're taking and the reasons j
i j
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.1 for
.'t.
I guess for us, though,' based on the potential-impact.that we would have because we're talking, you know, 4
potentially about having to signal' trace 22000-cables-and 5
looking at the time, the effort and the man rem,.you know, 6
that that would require, you know, we're really not in a 7
position, I think, to commit to that.
E MR. PIERSON:
To agree to that at this point?
9 MR. BYNUM:
Well, to agree with it, particularly 10 because, you know, our approach, you know, we really feel is 11 consistent with what, you know, other reinspection plans 12 have been.
And, you know,.this, although I understand the 13 logic behind it, doesn't really appear to be consistent 14 with, you know, reinspection plans that I'm familiar with.
15 Eecause for one thing, w<s would have to be looking for not a 16 random sample but a sample that gives us 59 discrepancies, 17 and then doing a statistical evaluation.
18 MR. PIERSON:
You look at a series of random 19 samples until you get 59 discrepancies.
20 MR, BYNUM:
Yes, but you're making my sample 21 population 59 that's based on a non-random.
In fact, it's 22 based on a found sample.
I just don't think that's 23 consistent with the statistical approach that I'm familiar 24 with on reinspection.
Again, I think the point is, you 25 know, we don't agree technically, you know, with the Beritage Reporting Corporation (202) 628-4888
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approach.
And:we've got to go'look at, you know,.at-our I'
situation and our position, and then, and we're' going to-1 have to get back to you.
Because, you know, we do feel?like 4
what we've proposed is consistent with what other.
5
. reinspection programs, other. statistical sample reinspection 6
programs have been.
MR. PIERSON:
We have a couple of other things E
that we'd like to highlight, too, before we adjourn this 9
meeting.
10 And ene isLI think'we can expect something back 11 frem you en V-1 and V-2 in terd.s of impingement.
1 MR. HUTS 0ti:
Yes, we understand the question.
We 13 understand.
~
14 MR. CARIER:
One of the things that we wanted to 15 point out in here is that IEEE 384 and Reg. Guide 175.is in 16 these particular~ areas wasn't back fitted to any of the 17 plants, and it's not part of the Brown's Ferry licensing.
18 b a s i s '.
19 MR. MARINOS:
Well, that's not the issue here.
20 MR. PIERSON:
I think the issue here is does your 21 plant, as built, meet basic separation criteria.
I hope 22 that's what the issue is.
23 The other thing that I wanted to remind you of 24 too, a little seoarate, but when you're working on V-3, we 25 need to understand how this impacts on your Appandix R Beritage Reportin's Corporation (202) 628-4888
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evaluations.
You may have told us in the past how manyL
~
Appendix R cables.there were, but whatever mechanism you use to validate your sample and to validate your separation, 4
make.sure that the same arguments can be used for your 5
Appendix R inspection so you don't have a duplication of E
effort.
Hopefully, it's been our opinion that if we can
~
E resolve this issue, Appendix R will drop out of it.
9 MR. HUTSON:
We're in agreement with that, yes.
1:
We understand the problem, yes.
11 MR. MARINOS:
But the acceptance significance 12 argument should be based on Appendix R, and externally.
13 MR. HUTSON:
Well, one of the attributes that's-14 looked at with regard to the discrepancy is to ensure that 15 the Appendix R perspective of cable separations is met.
16 That'.s not been an item that we foun't to be a discrepancy.
l' We've met Append &x R requirements for the discrepancies that 16 have been evaluated.
19 It's been the literal compliance with the 20 separations criteria, of 1E being with 1AR, and non IE being 21 with only one division.
22 MR. PIERSON:
And so what you propose to do then.
23 is, I presume, to go back and talk to the rest of your 24 management and come up with an op 31on.
d 25 And I guess I understand from what you're saying Heritage Reporting Corporation (202) 628-4888
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So I presume that E
whathyou'11 do is present your arguments, maybe'to have a e'
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4 Lwe'reigoing to do-and<how'we're going to. resolve'it.
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.MR.
CARIER:
We'll :just have:.to look at, you know, f:
what, cur strategy will be i'
MR. MARINOS:
dell, Jim, an additional point on E
the.v-1s, V-2, of course we identified two attributes like:
9 the jet. impingement and to missiles.
Now, there may be
~
10 other you need to evaluate.all other external whatever may-be in the plant events that.can affect:the --
12 MR. HUTSON:
We'll evaluate them against the 13
' design basis that they were implemented under.
We 14' understand.
15 MR. PIERSON:
And then hopefully.we can come and
. 16 resolve this. thing..
17 MR. BYNUM:
Again, you know, our intent is to
'1B resolve this as quick as'we can.
-19 MR. MARINOS:
With regard to V-4, V-5s, you know, 20 you asked a questi.on?
21 MR. BYNUM:
Yes.
22 MR. MARINOS:
I guess we expect the same if you're 23 going to maintain 95 95, establish that confidence. level.
24 Of course, now you have to evaluate these. violations as pure 25 separation violations and not safety significant, and from Heritage Reporting Corporation (202) 628-4888
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1 Lwhat weiknow so far, you.have 13 already, separation
.vic'lations in-the V-4, V-5. -.
3' bm. HUTSON:
Keep in mind, thereLwas 13 total 4
discrepancies.
Eleven of those are true V-4,LV-5.-
.That was i,g.
LE
. the question that we had at theflast meeting.
6 MR. MARINOS:
Okay, that's right.. So if those 11 7
.get you out of the 95 95, you need to establish-a 95 95, E.
however, you.can do that.
9 MR. HUTSON:
Yes, well, yes.
I understand.from IC the last meeting of " t we were discussing there on V-4, V-
.11 5,
basically was to for the evaluations that we have done, 12 if the acceptance criteria is literal compliance, then you 13
. ensure.that for the number of discrepancies you had versus 14
.the total reviewed that you met 95-95.
If not, expand it-15
.and the population of concern there is the.443 which we 16 signal trace Remember, we had a total of 982 which is the 17 total population, 4'43 that we signal traced.
Okay.
.From 18 those 443 that we signal traced, that would be the 19 population reviewed.
20 MR. MARINOS:
A..d if you don't make it then, then 21 you have to go to 95 95.
22 MR. HUTSON:
Yes, we have to go to.the whole 23 population.
24 MR. PIERSON:
Anything else we need to discuss?
25 b2. HUTSON:
That's all.
Beritage Reporting Corporation (202) 628-4888
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. !!lJ' MR. PIERSON:. Well, you can get back with Dave.and.
v' set up a meeting-some time in the future.
! T<.
MR. HUTSON:
Thank.you for youritime.
Appreciate-I.- i
- 4 10.
Thank you.
ti; E
(Whereupon, at 3:20.p.m., the ineeting.was.
.6:
concluded.)
i i=
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t 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Heritage -Reporting Corporation (202) 628-4888
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-o CERTIFICATE 1
.; s :s :: certify that the attached proceedings before the 4
J.,:: e t States Nuclear Regulatory. Commission in the matter 5
cf:
TVA'S BROWN'S FERRY NUCLEAR STATION (Cable Separation Criteria) i Name:
E Occket Nurter:
1 9
Place:
Rockville, Maryland Cate:
March 14, 1989 1 ".
were held as herein appears, 'and that this is the original 1;
transcript thereof for the file of the United States Nuclear 13 Regulatory Commission taken stenographically by me and,
- 4 thereafter reduced to typewriting by me or under the 15 direction of the court reporting company, and that the 16 transcript is a true and accurate record of the foregoing 17 proceedings.
19
/s/
N D^ lab 0
Kon PETER M. DIXON 19 (Signatu.:s typed) :
20 Official Reporter 21 Heritage Reporting Corporation 22 23
(
24 l
25 i
Heritage Reporting Corporation (202) 628-4883