ML20247M515
| ML20247M515 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 05/11/1989 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20247M511 | List: |
| References | |
| NUDOCS 8906050059 | |
| Download: ML20247M515 (45) | |
Text
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UNITED STATESF c..
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HERITAGE REPORTING CORPORATION
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e906050059 890526 Washington, D.C. 20005 d
ADOCK0500ggO DR 1J
1 UNITED STATES NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR REACTOR REGULATION I
In the Matter of:
)
)
MEETING WITH TVA TO DISCUSS
)
,TVA'S PROPOSED RESOLUTION
)
TO THE ELECTRICAL CABLE SEPARATION
)
ISSUE
)
- Thursday, May 11, 1989 Ono White Flint North 11555 Rockville Pike Room 1.0811 Rockv111e, Maryland The above-entitled matter came on.for hearing, pursuant to notice, at 9 : 0 0 a. r.i.
PARTICIPANTS:
On behalf of the Nuclear Regulatory Commission:
l BOB PIERSON GERRY GEARS SUZANNE BLACK ANGELO MARINOS HUKAM GARG DAN LURIE ED GOODWIN B.
D.
LIAW l
l FRED PAULITZ H.
B.
CLAYTON TOM ROTELLA on behalf of the Tennessee Valley Authority:
JOE BYNUM JIM HUTSON HENRY WEBER ROBERT WILLIAMS TONY MARK DAVE MALONE DAVID SKRIDULIS l
Heritage Reporting Corporation (202) 628-4888 1
_---_- __- _ a
2 1
PROCEEDINGS 2
9:00 a.m.
3 MR. PIERSON:
Good morning.
I'd like to call this 4
meeting to order with TVA to discucs the cable separation 5
issue at the Browns Ferry nuclear plant.
I'd like to take a 6
moment and describe what we of the NRC Staff hope to 7
accomplish in this meeting on the cable separation issue at 8
Browns Ferry.
9 This meeting follows a number of meetings on this 10 issue, and it is our understanding that some of the i
11 previously conveyed information did not accurately portray 12 the cable testing as it was performed at Browns Ferry.
13 Consequently, we would like for TVA to describe to the Staff 14 what previously conveyed information is no longer applicable 15 and to provide the Staff with the correct information with 16 r'espect to the sampling, testing, and confirmation of cable 17 separation which you have done.
18 We would like your presentation to include, if 19 possible, a description of the statistical or other 20 methodology used to determine the scope and magnitude of the 21 separation issue, a description of the acceptance criteria, 22 and a discussion of the scope of the EA and QA oversight, as 23 well as an evaluation of your results, if you're prepared to i
24 do so.
25 MR. BYNUM:
Good.
My name's Joe Bynum, with the j
l l
Heritage Reporting Corporation (202) 620-4000
t i
l 3
1 vice' president for nuclear power production with TVA.
2 The words that you have in my introduction, I 3
think, correspond very well to the things you just 4
. mentioned, Bob.
We are here to formally resolve the data j
i 5-inaccuracies that you have received in submittals and in the 6
two. previous meetings we had on February 16 and March'14.
7 We're also here to present to you and to respond to 8
questions regarding our methodology that we've used to 9
evaluate.the cable separations issue.
That does include the 10 methodology and the criteria'that we have used.
We're also 11 here to discuss, based on that, our conclusions which i
12 provide reasonable assurance that the cable separations at 1
13 Browns Ferry will not adversely impact the operation of 14 Browns Ferry Unit 2.
15 So, with that, I'll turn it over to Jim Hutson.
16 MR. HUTSON:
Thank you.
17 Good morning.
I'm Jim Hutson, chief electrical j
i 18 engineer with TVA.
19 We provided the handout this morning.
If you will 20 turn to the third page in that handout.
It should be 21 entitled " Background."
22 Bob and Joe had both identified, our primary 23 objective today is to resolve any inaccuracies which we 24 provided to the Staff in previous meetings and discussions, l
j 25 as well as to provide results from this reconfirmation which Heritage Reporting Corporation (202) 628-4888 i
L
4=
1 we've performed.
Before we do:that, I'd like to spend just 2
a minute on the background.and reiterate some of the things f
3 that we've discussed.
'4' As you're aware, we provided this submittal on 5
January 6 of this year.
This submittal, basically, that we 6
did have separations problems.
They were identified from 7
the Ampacity walkdowns, which were performed as a part of 8
the Ampacity program for Unit 2 restart'.
There were 9
drawing discrepancies generated from this effort.
- These, 10-basically, identifiedtwoarfasofconcern.
One was 11 divisions cables routed in nondivisional raceways, and
' 1:2 nondivisional cables which were routed in both divisions 13 raceways.
14 As a result of this submittal, we have had 15 meetings.to' discuss this submittal.
These meetings occurred 16 in mid-February and-mid-March of this year We discussed 17 some details of that submittal.
In those discussions, j
18 there were extensive questions regarding the verification l
19 that had been performed to insure that the installed l
l 20 configuration matched the' design configuration.
Based upon j
i 21 that, we provided some discrete numbers with regard to that l
22 effort, and these numbers basically came from the Ampacity 23 walkdowns and from some previous Appendix R verifications l
l.
24 that had been performed in the '85 '86 time frame.
l l
25 As a result of these discussions, and as a results i
Heritage Reporting Corporation (202) 628-4888 1
5 1
of the re-evaluation we were doing of the numbers,_there 2
were some inaccuracies identified.
The data was incorrect 3
in some areas.
This was identified on March 30.
On March 4
31, after reconfirming that the data was inaccurate, we 5
notified Region II,as well as the Staff, of these 6
inaccuracies.
Based upon that, we initiated an effort to 7
resolve these inaccuracies.
The effort was begun on the 8
First of April, and we have completed that review.
That 9
review was completed on May 3.
10 This effort has, as'we've stated earlier, 11 reconfirmed the numbers that are available for use,_and we 12 have evaluated the results and developed the' statistical 13 numbers to support those results.
We have developed what we 14 feel to be positive results from this effort.
15 In addition to this reverification we 16 performed, we had two oversight groups involved with the
-17 effort.
One was our engineering assurance-organization, 18 which provided an oversight review of the quantities 19 involved, with regard to the number accuracles, with regard 20 to what the data said, et cetera.
In addition, we had our 21 quality assurance organization at Browns Ferry site luuk 22 into the data that we were using, to insure that the data 23 was acceptable for use.
Those efforts were completed on May 24 4 and 5, and the results were positive from those reviews.
25 Based upon that, what I'd like to do now is turn i
l Heritage Iteporting Corporation (202) 628-4888
6 1
.to the next sheet and go.into the methodology, if we could.
2 This is our reconfirmation effort that we've performed.
3 Our first step was to reconfirm the existing 4
installed. cable routing information that we had available 5
for use and to confirm that the information provided to NRC 6
was correct.
There were inaccuracies identified in those 7
numbers.
As I said earlier, this information came from two 8
areas.
One was the Ampacity walkdowns that had been 9
performed, and also from the Appendix R walkdowns which had 10 been performed in the mid '80's.
11 Once we reconfirmed the data and obtained all the 12 data, we undertook an evaluation process.
As we discussed
.13 in previous meetings, this was a proposed option that we.had
-14 discussed, taking the data available and doing the 15 evaluation.
Thia is existing data that was there from those 16 previous evaluations.
We took that option and evaluated it.
17 We looked at all the existing data that we had available.
A 18 very extensive, exhaustive review of that effort was 19 performed.
20 We found additional data available from those 21 walkdowns that was not previously in the effort.
We did 22 find additional data.
23 What we did was we evaluated that data for 24 discrepancies.
A discrepancy is defined as, the cables 25 installed configuration does not agree with the design Heritage Reporting Corporation (202) 628-4888
_________-__-_____________--_A
7 4
.1 configuration; that is, it does not match, the installed 2
versus design.does not match.
3 We then took those discrepancies and we evaluated 4
them for design-significance.
That is the acceptance 5
criteria for this evaluation.
Design significance, 6
basically, is,-the discrepancy is found to be in 7
- nonconformance with the applicable code, standard, or 8
licensing requirements, and in this case that would be the 9.
FSAR, the design criteria.
We have used the term in the pastwithregard'toliteralfompliance.
10 That's what we have 11 applied to this evaluation.
Design significance is the 12 acceptance criteria, and it is literal compliance with the 13 criteria, what we used in this evaluation.
14 From this evaluation, we then took the results, 15 which'we'11 discuss here shortly.
We took the information 16 obtained-for this review and we de
,9d a confidence level 17 and a quality level based upon the design significance 18 acceptance criteria.
The method is analogous to NCIG-02, 19 which is the visual weld acceptance criteria.
20 From that evaluation, however, we did take the 21 design significant discrepancies one step further; that is, j
22 as required by our procedures.
We did perform a safety l
23 significance evaluation, though.
We were required to do 24 that per our procedures, take it one step further and insure
]
i 25 that there was no safety significance from the J
Heritage Reporting Corporation (202) 628-4888
4.
8
'1 discrepancies, the design significant discrepancies 2
identified.
3 Safety significant is basically defined as 4
insuring you did not exceed single-failure criteria.
That's b
the' safety significance that we' applied.
6 That's the methodology.
If you turn to the next 7
sheet, we'll discuss the results from this evaluation.
8 What we have shown on the results page here is, 9
basically, three groups of cables.
We discussed them quite 10 extensively in the past, but'I'll go back through them to 11 refresh our memories.
The VI and V2 cables, that's voltage 12
. level 1 and 2, those are instrumentation cables.
As we 13 discussed in the past, our population of concern there are 14 Appendix R cables.
The V3 cables are control power cables.
15 They are your 250 volt de, 120 volt ac cables, less than 30 16 amps.
V4 and V5 are your power cables.
They're the 17 category of cables of greater than 30 amps and the 480 vult 18 ac and 4160 volt ac cables.
19 What I'd like to do is to go through each of these 20 groups, if we could, starting out with the V1/V2s.
- Again, 21 the cables of concern here are the Appendix R-required 22 cables for shutdown of the unit.
23 We previously identified that there were 64 cables 24 in this population, and we have reconfirmed that there are 25 64 cables.
We have done a review of those 64 cables.
We Heritage Reporting Corporation (202) 628-4888
9 1
-have done a field inspection of those 64 cables and have 2
verified that there are no design significant discrepancies 3
with regard to those cables and that.they do meet the 4
Appendix R requirements.
That effort is complete.
In the 5
previous meeting, we had not performed that effort; we now 6
have performed it; it is complete, with positive results.
7 And there are zero safety significant discrepancies from 8
that effort.
9 In the V3 cables, or the control power cables, we 10 previously identified that trie population of concern is 11 approximately 20,000, and those 20,000 cables are comprised 12 of both safety cables and what is called " associated 13 cables;" that is, a cable which is nondivisional or 14 nonsafety but is routed with a divisional cable.
We 15 previously identified approximately 20,000 in that category, 16 and that number still stands.
17 With regard to eh sample population of cables, we 18 previously identified that there were 155 cables available 19 for evaluation; that is, there had been 155 unique cables 20 which had been field-verified for their installation.
The 21 present number, the actual number, is 266.
When we went 22 back and looked at the available data, there were more 23 cables in both the Ampacity program and the Appendix R 24 program available for evaluation.
We previously identified, 25 from the 155, that there were 80 Ampacity and 75 Appendix R.
Heritage Reporting Corporation (202) 628-4888
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There are,.however, 144 Ampacity and 122 Appendix R cables 2
available for evaluation.
3 In addition, we discussed the results from that 4
155:in the previous meetings.
As you'll recall, at that 5
' time we knew of two design significant discrepancies.
There 6-was a potential for 14 more.
For those 14, we identified 7
that we had not performed a design, significance review.
So, 8
therefore, you see there, there was the potential for 2 to 9
16 of that population.
We have now reviewed those remaining 10 14, as well as the additiona cables picked up from our 11' further review.
We have three design significant 12 discrepancies.
13 I think, if you'll recall, from the previous 14 meeting regarding the 14, we identified that the cables were 15 involved with a particular type of tray.
We went back and' 16 have confirmed one of two things.
One, that particular tray 17 segment did not exist; that is, the nondivisional segment 18 was not there; it was truly a divisional segment or tray.
19 Or the cable did not enter into that.
As we identified 20 earlier, we identified we may go back and reconfirm the 21 data, and we have done that, and that cable did not enter 22 that nondivisional section of tray.
So the results have 23 identified three design significant discrepancies trom that 24 population reviewed.
25 Once again, we took it the step further, and there Heritage Reporting Corporation (202) 628-4888
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11 1
.is zero safety significance from the three design 2
significant discrepancies.
3 With regard to V4 and V5, the power cables, we 4
previously identified that there was a population of concern 5
'of 982.
That was the quantity of cables involved in the 6
Ampacity program; that population is larger than that when 7
you take into consideration the safety and associated cables 8
of concern.
It's approximately.2,000.
Basically, what that 9
means is that there's approximately 500 safety cables and
~
10 1,500 associated, is what we're estimating.
11 With regard to the sample population, we 12 previously identified that there are 443 cables that were 13 field-verified.
Further evaluation has identified that 14 there. are 951 cables field-verified.
What we have 15 identified is that there were several cables or several -- I 16 won't quantify it as hundred, but there were several cables 17 that were field-verified as a part of the Ampacity effort 18 that did not get put into the-Ampacity program because there 19 was no involvement in that.
However, we did find that 20 information, it was acceptable data for use, and we have 21 used that information in this effort.
That 951 breaks down 22 into 936 Ampacity cables and 15 from the Appendix R efforts 23 that were performed.
24 We previously identified, also, with regard to 25 design significance, that there are 11 design significant fleritage lleporting Corporation (202) 628-4888 l
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discrepancies.
That quantity is now 8.
The 11 from 2
previously identified breaks down as, we removed 5 based on 3
further evaluations of those discrepancies, and essentially 4
added 2 more back, so that equates to the 8 that are 5
identified.
6 Once again, we took them to safety significant 7
discrepancies and found zero safety significance from the 8
review.
9 As a result of this effort and the results I've justprovidedtoyou--ifyfu'llturntothenextsheet i
10 11 we have drawn some conclusions from this evaluation.
12 Again, based on design significance as the 13 acceptance criteria, and that is, based upon literal 14 compliance with the criteria, with regard to the V4 and V5 15 cables, the evaluation provides a 95 percent confidence of-a 16 98 percent quality level or greater for the total 17 population.
With regard to V3, design significance provides 18 a 95 percent confidence of a 97 percent quality level or 19 greater for the total population 20 In addition, we have taken the discrepancies one 21 step further, and from that we have zero safety significance 22 for the sample that was reviewed.
23 Based upon this, we draw the conclusion that, with 24 reasonable assurance with regard to cable separations, that 25 Unit 2 is ready for safe operations with regard to health fleritage Reporting Corporation (202) 628-4888
13 1
and safety of the public.
2 That completes my presentation.
I'd like to now 3
open the floor for questions or comments.
4 MR. GARG:
I have a question.
For VI and V2, I 5
think my one concern is about other external events.
I 6
don't know if you have done that yet or not.
7 MR. HUTSON:
Yes.
We have performed that 8
evaluation, and there are no external evente that could j
9 affect the V1 and V2 cables.
i OneitemI'dlikefoidentifyisthatwehave 10 11 prepared a draft submittal to revise the January 6 12 submittal, and we have it in the review cycle.
That does 13 address the issue with regard to jet impingement, pipe whip, 14 et cetera.
15 MR. MARINOS:
How did you limit it only to 16 Appendix R cables?
Other instrumentation cables you've 17 found that is unnecessary?
18 MR. HUTSON:
Well, if you remember our 19 discussions, we basically identified that the VI and V2 20 cables are low-energy circuits.
Because of that, from the 21 routing perspective, we were not concerned with where they 22 were routed.
But there was some questions regarding the 23 assurance that, if the cable was misrouted, could we insure 24 that there was no external events that could affect it.
The 25 issue of most concern was the Appendix R issue.
The Heritage Reporting Corporation (202) 628-4888
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14 l'
Appendix R cables, we have.to maintain the 20-foot 2
separation, so that's why we focused on the Appendix R 3:
cables.
We had to insure the 20-foot separation or whatever 4
was applicable to where the cable was located; we maintained 5
that.
I think Browns Ferry is somewhat focusing on the' fire 6
zone concept.
7 We focused it just on the Appendix R-required 8
cables, and from that we did a field verification that they 9
were routed according to the design and met the Appendix R 10 requirements.
11 MR. PIERSON:
So your sense on VI and V2 is that 12 associated circuits are not a concern because of --
13 MR. HUTSON:
Not a concern because of the low 14 energy.
That's correct.
15
'MR. PIERSON:
And, because you have looked at 16 Appendix R, the 64, and you found zero design discrepancies 17 and zero safety significant discrepancies, you're assured l
18 that you don't have problems in the sense of jet impingement 19 or damage, something like that?
20 MR. HUTSON:
That's correct, yes.
21 MR. GARG:
How did you do the walkdown?
22 MR. HUTSON:
The walkdown on the 64 Appendix Rs 23 was done by a visual inspection.
They were able to -visually 24 verify each of the cables involved.
25 MR. MARINOS:
I have a further question on that.
Heritage Reporting Corporation (202) 628-4888
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l' It's not clear to'me.
You said " low energy;" I understand i
2 that, so we're not going.to attack that one in any way.
But' l
3 the external events for instrument cables that are not l
1 4
associated with, necessarily, the fire protection, but other 5
6 MR. HUTSON:
The external event statement is 7
applicable to all VI and v2 cables.
8 MR. MARINOS:
- Okay, i
9 MR. HUTSON:
It's applicable to the total 10 population, yes.
l
?
t 11 MR. MARINOS:
All right.
That's fine.
l l
12 MR. GOODWIN:
What is'the definition of " external l
l 13 event"?
'14 MR. HUTSON:
External event would be pipe whip, j
15 missile, jet impingement --
l
'l 16 MR. GOODWIN:
17 MR. HUTSON:
Oh, yes.
The earthquake is
)
10 applicable as well, yes.
19 MR. GARG:
Two over one, too?
20 MR. HUTSON:
Yes.
The seismic evaluation has been
.21 performed.
l 22 MR. LURIE:
How were the samples selected?
l 23 MR. HUTSON:
Well, on tnc Appendix R cables, it i
I 24 really wasn't a sample; it was the total population.
It was 25 the 64 required, and we evaluated all 64.
I Heritage Reporting Corporation l
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1 MR. LURIE ' All.right.
And what about.the main, 2
The 951 cables from V4/v57 3
MR. GARG:
No, we are talking right now V1/V2, I 4
.think.
Let's go one:at a time.
5 On visual inspection, you said you verified all of 6
them?
7 MR. HUTSON:
Yes.
All 64 were field verified-by 8
visual inspection, yes.
9 MR. GOODWIN:
And this is-from device to 10 termination.
11 MR. HUTSON:
Yes.
End-to-end verification, yes.
12 MR. CLAYTON:
Can you explain how you went about 13 determining that there was no safety significance in-the 14 sample that you looked at, what that involves?
15 MR. HUTSON:
What the safety significance 16 evaluation involved?
17 MR. CLAYTON:
Right.
18 MR. HUTSON:
Yes.
What it did.was, it looked at 19 the discrepancy as it existed and insured that the redundant 20 function that was affected by that cable's misroute was not 21 affected.
It's basically insuring the single-failure 22 criteria.
l 23 MR. MARINOS:
Jim, in the design significance that 24 you earlier stated being your criteria for acceptance, was 25 that the pure separation?
Heritage Reporting Corporation (202) 628-4888 l
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MR. HUTSON:
It's the pure separation where a 2
divisional cable is routed in a divisional raceway, in the 3
appropriate divisional raceway.
A nondivisional cable, once 4
associated with a divisional cable, does not become 5
associated with the redundant division.
Or, in the case of 6
nondivisional, has redundant overcurrent protection that we i
7 previously discussed.
8 MR. MARINOS:
Okay.
In the discrepancies in the 9
V3 and V4/5, which we have 3 and 8, those are design 10 significant discrepancies?
l 11 MR. HUTSON:
Yes.
12 MR. MARINOS:
Meaning the separation is violated 13 and that further review of the safety significance --
14 MR. HUTSON:
Insures that the redundant safety 15 function is not affected by that misroute.
l 16 MR. PIERSON:
Could you give us an example of one 17 of those?
18 MR. HUTSON:
Okay.
For example, on the three V.1 19 cables, one of those cables is a safety cable routed in a 20 nondivisional raceway.
The remaining two are nonsafety j
21 cables routed between redundant divisions, or between both 22 divisional raceways.
We took, for the nonsafety cable, for 23 example, we took and evaluated the other cables that were in 1
24 that raceway and looked at their routes to insure that their 25 subsequent routes did not interact with the redundant Heritage Reporting Corporation (202) 628-4888
18 1
function.
2 MR. MARINOS:
Your confidence level is based on 1
3 the design significance, not on the safety significance.
4 MR. HUTSON:
That's correct.
The confidence in 5
quality level is stated as based upon design significance.
6 MR. PIERSON:
So your sense, then, is that you 7
meet the separation criteria, and the safety significance 8
aspect is just an icing on the cake.
9 MR. HUTSON:
Is an icing on the cake, and a 10 requirement per our procedur6s to do that.
11 MR. BYNUM:
That's an evaluation, obviously, that 12 you have to make.
Once you recognize that you didn't meet 13 the design criteria, then obviously you have to do the 14 safety significance.
15 MR. PIERSON:
But your sense is that you've met 16 the design criteria.
17 MR. BYNUM:
That's correct.
18 MR. HUTSON:
That's correct, yes.
19 MR. MARINOS:
And that is true for V4 and V5?
20 MR. HUTSON:
As well, yes, both.
21 MR. MARINOS:
If you put it into the statistical 22 equation, you will come up with the confidence level on 23 design significance.
l 24 MR. HUTSON:
That's correct.
The confidence 25 levels stated were design significance.
i Heritage Reporting Corporation (202) 628-4888 1
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MR. GARG:
On V3, your previous total of the 2
sample was 1557 3
MR. HUTSON:
Yes.
4 MR. GARG:
And the actual is 266.
5 MR. HUTSON:
266.
6 MR. GARG:
Were any of the 155 which you 7
previously-recorded dropped in this 266?
Are all 155 8
included in that?
9 MR. HUTSON:
There were some of them dropped.
Doyoufavethenumber?
10 MR. GARG:
11' MR. WILLIAMS:
It's going'to need a bit of 12 explanation.
13 Bob Williams, TVA.
14 Of the original 982 V4 cables that were reported, 15 there were 73 V3 cables in that population.
They were there 16 simply because they got routed in the four trays somewhere 17 in their route.
So that's part of the difference.
18 If you looked at the 75 Appendix R cables and the 19 80 Ampacity cables, there were 26 duplicates in those two 20 figures.
They were dropped out cf the population.
There 21 were 51 additional Appendix R signal traces that were found 22-that were added to the population, and the rest of the 23 difference is additional Ampacity.
24 That's essentially -- there were 73 --
25 MR. HUTSON:
Cables picked out from the V4/V5 L
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20 t
population.
1 2
'MR. WILLIAMS:
And of that 73, there were 26 3
duplicates between it and the-V3, Appendix R. cables.
4~
MR. PIERSON:
We would be interested in seeing 5
that breakdown when you submit.something in writing.
6 MR. HUTSON:
It's in the submittal.-
It's a-7 breakdown of'where the numbers changed'and why they changed.
1 -
8 That is in the submittal.
9 MR. GARG:
Especially if they're dropped from the' l
10 significance items.
.11 MR. HUTSON:
With regard to the significance, 12-those 14 are still in the program.
Those are still in the 13-quantity.
Those 14 are still there, yes.
14' MR. PIERSON:
Taking the worst case there, the' i
l 15 design significant discrepancies, all 16 of those possible 16 cables were maintained throughout.
17
.MR.
HUTSON:
Oh, yes.
They're still in the 18 program.
Oh, yes.
The only thing that was really dropped 19
. were the duplications.
That was all.
1 20 MR. GARG:
So you found the data on all the 21'
. previous data.
l 22 MR. HUTSON:
Yes.
23 MR. GARG:
It's not that you didn't find that 24 which you did not want down.
25 MR. HUTSON:
Yes.
And, to expand a little bit on Heritage Reporting Corporation (202) 628-4888
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,I 21 1
i
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1 the data that we have, what we have gathered is that we have-1 2'
on individual record for every' cable involved in the j
- 3 program.
With regard to that individual cable, we have all 4
the information supporting that, with regard to the walkdown
]
5 data, the discrepancy evaluation, the design significance' c
6 evaluation, and the safety significance evaluation.
It's' 7
compiled on a per-cable basis.
This document that we're 3
8
- talking about, since we evaluated almost 1,200 cables, this 9
document is almost 13,000 pages, since we have them on each-10 individual record.
But when'you review that document, I l
11 think you will find that there is a record there -.I-know 12 you will find that there is a record there for every cable 13 involved in the program.
i 1
14 MR. PIERSON:
And the V3 were also evaluated in 15 terms of external eve ~nts.
16 MR. HUTSON:
The V3s?
17' MR. PIERSON:
Yes.
18 MR. MARINOS:
V3s and V4s.
19 MR. HUTSON:
Well, the V3 and V4 and V5 cables 20 were looked at purely from a separation standpoint; that is, 21 meaning literal compliance with the criteria as previously 22 established.
That criteria is developed such that you 23 prevent any external events from causing a problem, as part i
24 of the original criteria.
25 MR. MARINOS:
But in the cables that you had, the i
Heritage Reporting Corporation (202) 628-4888
~
22 1
8 and the 3, that you have violated, so to speak, the design 2
criteria, which is the separation, you need a further 3
evaluation of the safety significance.
4 MR. HUTSON:
Right.
And that was with regard to 5
that.
That, again, was looked at to insure that the 6
redundant safety function was not affected by this misroute, 7
from all possible combinations.
8 MR. MARINOS:
But in terms of external events, 9
though, as Bob was asking, did you look at those cables?
10 MR. HUTSON:
Yes.
11 MR. MARINOS:
From that aspect.
12 MR. HUTSON:
Yes.
13 MR. MARINOS:
Okay.
14 MR. GARG:
You did a root cause analysis?
15 MR. HUTSON:
Rogt cause from the perspective of 16 why the cables were misrouted?
17 MR. GARG:
Yes, and whether you could have other l
18 cases like that somewhere else.
1 19 MR. HUTSON:
We looked at the root cause from that 20 perspective and evaluated it.
It was something in addition; 21 it was not part of the -- it was not a requirement of what i
i l
22 we were doing.
But we took it one step further.
j I
23 Basically, we came up with errors with regard to 24 the routing.
It was primarily revolving around the 25 convenience of getting the cable to where it needed to go.
l Heritage Reporting Corporation l
(202) 628-4000 l
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23 1
In some cases, it was a condition where the cable was 2
intended from point X to Y, and there was two trays 3
available, and they ran parallel; they picked one tray 4
instead of the other, and it was a misroute because of that.
5 The tray that they may have picked should have been a 6
divisional tray, and it got into a nondivisional tray that 7
was in parallel with that.
8 MR. PAULITZ:
Jim, on that V4/VS, the eight design 9
significant discrepancies, was any of those cables or 10 multiple cables in the same bray associated with the same I
11 train where, if you had a problem, it could look like a bus l
12 fault rather than individual cable fault, so the 13 coordination would have to be looked to make sure that the l
14 incoming supply breakers didn't open up?
l 15 MR. HUTSON:
No.
They were not in that category.
16 MR. PAULITZ:
You didn't find any in the same 17 tray, or enough of them in the same tray that, if the fault l
l 18 affected more than one, that you could have an effect that 19 looked like a bus fault?
20 MR. PIERSON:
In other words, what he's asking is, 21 of these eight cables, were, say, three of them in the same 22 tray, such that, if you had a failure, you could end up with 23 assuming that there's a bus failure.
24 MR. HUTSON:
There was three faults instead of 25 one?
Heritage Reporting Corporation (202) 628-4888 1
Le; 24 L'
l' MR. PAULITZ:
Yes.
2-MR. HUTSON:
I-guess I'm not sure where you're 3
headed with that.
By the way the slight coordination 4
evaluation is done, it's done with-both syn-bus = faults, and 5
that would --
1 6
MR. PAULITZ:
But slight' coordination.is usually 7
-done'on a single cable, per se.
If you had taken'it up.
8 against'the bus, that's true; it would already be taken care 9
of.
But: if you're. assuming that only one circuit at a time 10
- gets into trouble, generally'what's done, they look at the 11 largest motor it's associated with and coordinate with'it.
12 If you've got enough cables affected by.the same problem, 13 then.the fault current may look more like a bus fault.
14 MR. HUTSON:
That would be there regardless of 15 whether the cable is misrouted or not. That would be there 16 because you're in a situation where you have a tray over a 17 board, for example.
You'll have multiple cables from the 18 same bus going into a common tray.
This exists regardless 19 of whether it was misrouted or not.
20 MR. PAULITZ:
That's true, if you affect one L
21 division alone, but if you have more than one division in 22 there -- if you take the single failure criterion, you're 23 saying that --
24 MR. PIERSON:
But he's saying it mee's the e
25 separation, so that you don't have -- you've met the Heritage Reporting Corporation (202) 628-4888 l
25 l'
separation definition, and you don't have the divisional 2
problems.
3 MR. PAULITZ:
That's true, but the eight here 4
didn't meet the separation.
We don't know whether I
5 they're --
6 MR. HUTSON:
If I could, let me expand on the 7
eight that are in the v4/V5 population.
Those are 8
divisional cables routed in a nondivisional raceway.
9 MR. PAULITZ:
All right.
So they were not 10 division-division.
i 11 MR. HUTSON:
That's correct.
12
.Okay.
We did have -- there were seven cables 13 routed, safety cables in a nondivisional raceway, and we did l
14 have one nondivisional cable routed in both divisions, but l
1 15 there was only one of those.
16 MR. LURIE:
The 266 cables in the V3 you indicated 17 are 144, 122 distribution.
Roughly half and half.
Would i
18 you believe that the population had a similar distribution 19 or any reason to believe that it's distributed differently j
20
.than 50 percent?
21 MR. HUTSON:
I'll let Tony Mark respond to that.
22 He is the statistician which we've ' sed in this effort.
23 MR. MARK:
I don't know the answer to that i
24 question, and I'm not sure that we can determine it from the 25 sampling evidence, given the sample was more or less Heritage Reporting Corporation (202) 628-4888
26 1
opportunistic on both the Ampacity program and the Appendix 2
R program.
Essentially, every single cable which has a 3
traceable QC documentation was included.
So basically what 4
we've got is a collection is everything they could find from 5
either program.
6 MR. LURIE:
All right.
So how were the 266 7
essentially collected?
If they're random, they should 8
reflect the population pretty well.
It's not just that you 9
walk to one corner and decide to take convenient cables.
Tfemethod, in brief, was as 10 MR. MARK:
Yes.
11 follows.
12 First, considering both the Ampacity program and 13 the Appendix R program, every single cable, as I mentioned, 14 which had field walkdown data as well as evidence that the 15 data had been QCed, were included and wrapped into this one 16 sample.
There may have been four, I think, exceptions to l
17 that, in that I believe that they were four groundwater 18 cables which had been signal-traced which are not reflected 19 in these numbers.
There was nothing found wrong with any of 20 those four.
21 Proceeding, since the sample is opportunistic, 22 it's appropriate to ask whether there night have been some 23 intentional or unintentional source of bias which may lead 24 to inferences that are incorrect.
The brief answer is, in 25 the case of population V3, that appears to be the case.
In Heritage Reporting Corporation (202) 628-4888
27 1
other words, the sample appears to be biased, but 2
conservatively so.
The reason I say that is, a lot of the 3
cables that showed up in the V3 sample actually were only 4
identified because they had been routed and were not 5
consistent with the design specification.
They'd been 6
routed in V4/VS cable trays.
There were 73 of those, to be 7
exact.
Out of that entire sample of 266, 146 of the total 8
represented cables with routing different from the design 9
specification.
That represents about 55 percent of the 10 total sample.
Our estimate is that, if you took a true 11 random sample from population V3, that the proportion of l
12 cables whose routing did not conform with the design 13 specification would be at least a factor of two lower than 14 that.
15 The important point is, the sample, we believe, is 16 probably enriched in situations where, if there would be a 1
17 design significant discrepancy, you would expect to pick 18 them up in cables whose routes just don't go where the
(
l 19 designer intended.
So, on that basis, the sample I would l
20 characterize as biased, but conservatively biased.
21 MR. LURIE:
Fair enough.
What about the 22 population of V4/V57 23 MR. MARK:
The V4/VS sample represents a very 24 large, from a statistical viewpoint --
25 MR. LURIE:
Right.
l Heritage Reporting Corporation f
(202) 628-4888
e.
28 1
MR.-MARK My understanding is that, basically, 2
the cables that showed up on.the sample, again,~were 3-selected from predominantly'the Ampacity program; I believe
'4 there were'15 that also showed up.in the Appendix R program.
5-But, again, no censoring or selecting from the cases; they 6
represented a wide spectrum of'different cable types, 7
locations, and whatever.
We're talking about a sample, 8
here, that represents over 47 1/2 percent of the entire 1
9 population.
Because the sample size-is so large --
10 Furthermore, fromfhefactthattheAmpacity 11-program and the Appendix R program never explicitly 12 considered the types of separation criteria that are at-13 issue:here, there was no way to pre-judge or, more or.less, 14 intentionally bias which ones you picked.
My own feeling is 15 that what you have here is a sample which represents nearly 16 half of the entire. population, that any estimates you make 17 relative to inferred quality of that population is likely to 18 be very close to the true answer.
19 MR. LURIE:
Okay.
One more question here.
In V4 20 and VS, how do you track the discrepancies down?
Can you 21 break down the eight, how many of them are Appendix R?
You L
22 may have given them to us.
23 MR. HUTSON:
We have the breakdown with us.
We 24 can provide that.
L 25-MR. LURIE:
Okay.
I'll tell you what may be a Heritage Reporting Corporation (202) 628-4888
'r
{
29 i'
l 1
problem.
If you have only 15 out of the 951 that' fell into 2
the Appendix R category, if you have a single defect'from 3
the Appendix R, it's going to throw this category off.
4 MR. PIERSON:
I don't necessarily see that, 5
because I don't think that you could say -- unless you could 6
show that Appendix R was routed sufficiently different from 7
the Ampacity.
And they just happen to be cables.
It's just 8
they were picked from different samples.
9 MR. LURIE:
Then you don't have to worry about --
10 MR. GARG:
But, anpway, I think I would like to 11 know that.
12 MR. HUTSON:
Yes.
Let me answer the question.
13 All eight came from the Ampacity population.
14 MR. LURIE:
Fine.
1
'15 MR. GARG:
How about in the V3, those three.
1 16 MR. WILLIAMS:
All those are Ampacity as well.
17 MR. HUTSON:
All those are from the Ampacity 1
18 effort as well.
19 MR. LURIE:
What would have disturbed me, if all 1
20 eight would have come from the Appendix R, there would 21 be --
22 MR. PIERSON:
I understand, but I don't think that
'ould be likely.
There might be one or even two, but not 23 w
24 all eight.
25 MR. LURIE:
All right.
1 Heritage Reporting Corporation l
(202) 628-4888 l
1
-_._--_-___._________._____m___________._____J
30 1
-MR.
HUTSON:
In this case, there was zero.
2-MR. LURIE:
Okay.
Fine.
I have no problem with that.-
4 MR. PIERSON:
Any other questions?
5 MR. GOODWIN:
Yes.
I've got a. couple.
.6 As I understand the thread'of the argument, we've 7
looked at all the Appendix R cables, V1/V2, they're_all 8-acceptable.
We have looked at all safety-related routings 9
for V1/V2, and they are not vulnerable to external events.-
10 Therefore, v1/V2.is acceptab1'e.
I 11 MR. HUTSON:
That's correct.
i 12 MR. GOODWIN:
V4/VS, we have looked at essentially 13 all safety-related power cables.-
14 MR. HUTSON:
Large population, yes, the majority.
15 MR. GOODWIN:
No.
Safety-related.
I thought yce, 16 in your Ampacity program, said you had looked at all safety-17 related.
18 MR. HUTSON:
The Ampacity program has evaluated 19 them, but unless there was a question with regard to their l
20 route there is no field verification done on those.
I 21 MR. GOODWIN:
Okay.
L 22 So we ha.2 looked at a very large sample, and we
~23-have this data.
l-24 MR. HUTSON:
A very large sample, right.
1.
25 MR. GOODWIN:
Then, at V3, we have this data, Heritage Reporting Corporation (202) 628-4888 L.
31 g
F 1
which-three of 266 represents 95, 97.
2 MR. HUTSON:
Correct.
3 MR. GOODWIN:
And, therefore, we don't have a I
4
_ problem worse than 5, 5.
5 Most of the data at V3 is from the Ampacity' 6
program?
7 MR. HUTSON:
It splits up 144 from the Ampacity 8
and 122 from Appendix R.
9 MR. GOODWIN:
Okay.
HowmanyV3traysfrethere, individually 10 11 identifiable V3s, roughly, as a guess?
12 MR. HUTSON:
There's probably several hundred.
13 MR. GOODWIN:
That's what I thought.
14 How many trays does the V3 sample represent?
15 MR. HUTSON:
How many unique trays does it 16 represent?
We have not looked at it from that perspective, 17 Ed.
I can't give you a number.
18 MR. GOODWIN:
Because I would guess that, were I 19 doing an analysis for Ampacity, I would look for the one or 20 two most heavily laden trays, and I would guess that, also, 21 a V3 tray probably has 50 cables in it?
22 MR. HUTSON:
V3 cables?
23 MR. GOODWIN:
Yes.
24-MR. HUTSON:
Probably that.
l 25 MR. GOODWIN:
So what I'm a little uncomfortable l
l Ileritage Reporting Corporation (202) 628-4888 1
s
'32 l'
about is, I suspect this data may'only represent three or 2
four trays in the V3 area..
3-MR. HUTSON:. Oh, no.
I can tell you that'now.
l 4
There's many trays involved in'this program.
I can't give 5-you an exact quantity, but it's not location-specific to 6
that effect, no.
7 MR. PIERSON:
My feeling'is it would be at least 8
20 percent of the tray population.
4 9
MR. GARG:
No, there would be many trays.
10 MR. HUTSON:
We're' definitely not talking a 1
11 handful of trays.
We can_get you the exact quantity in 12 that, but it's a large quantity of unique trays we 13 encountered.
14 MR. GOODWIN:
Okay.
15 But at the V3 level, that's very much.of a
'l 16 statistical argument, and for the acceptance criteria 1 17.
believe there are two requirements.
One is that the l
18 popula' tion is homogeneous, and, two, that the sampling 19 technique is random.
The major defect that I thought I saw
)
20 in terms of randomness, which was that, could the bias in i
21 the Ampacity program to look for a few heavily loaded trays l
22 have unduly biased it.
Then, in the homogeneity area, the 23 Appendix R sampling would typically be looking in those j
24 rooms where the routing is the smallest.
Does that 25 represent a small number of trays relative to the total Heritage Reporting Corporation (202) 628-4888 i
i
.e 33 1
number?
2 MR. HUTSON:
I don't know.
3 MR. GOODWIN:
Okay.
Those are the two questions I 4
think ought to be addressed in the submittal.
5 MR. HUTSON:
Well,'I think, with regard to one of
-6 your questions, regarding the type of sample that was 7
performed -- that information will be provided in the 8
revised submittal -- but, as Tony basically identified, we 9
do not have a random population, but we have a conservativelybiasedpopulafionthatwewerelookingat 10 11 with regard to cable data.
I think that's the basic
.12 conclusion he's reaching.
13 MR. GOODWIN:
Well, I guess that's an argument 14 that I'd like to see defended with some explicitness.
15 MR. HUTSON:
Yes.
16 MR. PIERSON:
Any other questions?
17
( t'o response. )
18 MR. PIERSON:
Let's1have a quick caucus here to 19 make sure that nobody's got something.
l 20 Let's break for a few minutes.
21 (A short recess was taken.)
22 MR. PIERSON:
We'll reconvene the meeting.
23 The Staff had a discussion.
We have a few 24 questions which we'd like to ask.
25 You had mentioned that you did a visual walkdown, Heritage Reporting Corporation (202) 628-4888 i
34 1
I.think, of V1/V2 instrumentation cables.
We would like to 2
have either a description now of what that visual walkdown 3
is, or, if you prefer, to submit it as part of your package 4
when you write it and send it to us.
.5 We'd also like for you to discuss in the submittal
'6 that you provide discussing this issue a description or an l
1 7
evaluation of'the root cause of some of these design 8
significant discrepancies.
In particular, address whether 9.
there's any indication of a common-mode failure in any of 10 these.
11 We would also to like to have included in your 12 written description,the bias, that you discussed here to 13
'some extent in this meeting, of the samples, and why you 14 feel that it represents adequate randomness or conservatism 15 in terms of the bias of the sample.
l 16 We'd also like to point out that, when we receive h'
your submittal, we'll review your submittal, and then,
)
17 18 probably, in the future, we're going to have an 19 inspection / audit performed dewn at the plant to review the 7
l 20 data that you've provided us with.
21 I think that that concludes our meeting, unless 22 you would like to describe your visual walkdown, if you're 23 prepared to do so.
24 MR. HUTSON:
I can expand on that.
25 On the Vis and V2s, it was a visual type 1
Heritage Reporting Corporation (202) 628-4888
_-~
c.
~
35 1
inspection where you took the cable in question and verified 2
that it entered into a conduit with its exit, or a tray, 3
conduit or tray.
You verify that it entered that, and in 4
addition you went to its exit point and insure that it 5
exited.
If it stayed in the conduit, you follow the 6
conduit, et cetera, did a complete walkdown of that.
And 7
you verified that that was the cable that exited the conduit 8
or tray.
9 MR. PIERSON:
How would you verify that?
Bycaflenumber.
The cable had to be 10 MR. HUTSON:
11 identified, yes.
There's a tag on it.
12 MR. GOODWIN:
Question in that area.
Suppose I ar 13 the guy that's following a cable, and I bring it through a 14 wall penetration into a room, verify that it entered a tray, 15 the tray is covered with flammastic, or the things's central 16 bundled.
Do I then just walk to where the cable schedule 17 says it ought to exit and verify that it did exit, or do I 18 check every exit between where 1 lost it and where I can 19 find it again to make sure that it didn't exit and re-enter?
20 MR. HUTSON:
You check it.
21 MR. GOODWIN:
So I check every exit and re-enter 22 for every cable in that tray.
23 MR. HUTSON:
For these 64, it's a complete field 24 verification of that cable's route.
25 MR. GOODWIN:
Okay.
And how about for the V3s?
Heritage Reporting Corporation (202) 628-4888
~
36
~
1 MR. HUTSON:
Okay.
Now, on the V3 and V4 and V5s, 2
those cables were identified'either by visual inspection or
'3 signal tracing.
There's two methods of gathering that data ~,
4 and we will have it'and do have it in the revised submittal 5
that we're putting together.
6 MR. GOODWIN:
But, if it were visual, it was 7
visual exactly the same way?
8 MR. HUTSON:
Yes.
9 MR. GOODWIN:
And if it was signal traced, all 10 you're doing is --
11 MR. HUTSON:
You applied a signal and walked 12 beside it.
13 MR. GOODWIN:
Walking down the tray and making 14 sure you don't lose the signal.
15 MR. HUTSON:
That's correct.
16 MR. WILLIAMS:
There are some of the cables that 17 were partial routes because of the particular program they 18 were in, for instance Ampacity, where they wanted to insure 19 that it stayed with the particular tray segment or it didn't 20 get into a particular tray.
There are some of those that 21 are partials.
They're not full route.
22 MR. HUTSON:
That's correct.
There are partial 23 and total verifications of the cables, depending upon what 24 tne program is looking at.
25 MR. GOODWIN:
I think that's something that ought Heritage Reporting Corporation (202) 628-4888 j
[g
,4
- a 37 Yo 1
to be addressed,_and the randomness argument, too.
h 2,
EMR. HUTSON:
It's definitely in'the submittal.
p-l 3
MR. PIERSON:
.Okay 4
One other thing
-I'd like to have is, if you could-5 provide your'--
In your-background, you have EA/QA 6
oversight review was completed on May 4 and 5.
7 MR. HUTSON:
Yes.
8 MR. PIERSON:
If you could either send that to us
~ 9 separately or as part of your submittal.
10 MR. HUTSON:
I'd pbefer to make that part of the 11
' submittal, as an attachment.to it,.if we could.
We do have i
- 12 those reports.
13 MR. PIERSON:
That's fine.
p 14 Any other' questions from any of the Staff?
15 (No response.)
16 All right.
We'll adjourn the meeting, then.
17 Thank you very much.
-18 (Whereupon, at 10:10 a.m.,
the meeting was 19 concluded.)
20 21 22.
23 24 25 Heritage Reporting Corporation (202) 628-4888 1
+-
AGENDA
'IVVNRC ME2 TING BROWNS FERIE NUCMAR PIANT ELETRICAL CABLE SEPARAi" IONS MAY 11, 1989 NOCKVIIIE, MARYIAND I.
PURPOSE II.
ISSIE BACKGROUND e Meetings / Submittal e Problem Identification III.
DATA REVERIFICATION e EA and QA Oversight Review 1
IV.
DM:A EVAITATIW e Statistical Methodology e Acceptance Criteria V.
EVAWATION RESULTS l
VI. CONCWSION i
]
I l
I i
l l
l l
l l
l I
l
4 s
PURPOSE OF MEETItG o
m h v RESOLVE PKiVIOUS DATA N IES.
o INNBM '1HE S'IAFF AND RESPOND 'IO QUESTICNS RB:iARDI!G M MEIBODOIiXE TVA HAS USED TO EVALUA'IE 'IHE CABLE SEPARATIONS ISSIE.
o DISCUSS TVA'S CONCLUSIONS WHICH PROVIDE REASONABLE ASSURANCE 'IHAT CABLE SEPARATICN AT BRCWNS FERRY NUCLEAR PLANT WIIL NOT ADVERSELY IMPACT M HEALTH AND SAFEIY CF M PUBLIC.
1..
BACKGBDUND e NRC SUBMITTAL - JANCARY 6,1989
- INNTIFIII) Pf0BLEMS:
AMPACITY hALKDOIrM DRAWING DISCREPANCIES o
DIVISICNAL CABIES BOUIED IN NONDIVISICEAL RACDRYS e
1 NONDIVISIONAL CABLES RDUIED IN BOni DIVISICN RAC3%YS e
NBC/TVA MEETItGS - FEBRUARY 16/ MARCH 14,1989 e
- DISCUSSED DETAILS OF SUBMITIAL
- PROVIDED DISCREE AMPACITY WALKDOWN/ APPENDIX R LOSERS e IDENTIFIED DATA INACCURACIES - MABCH 30, 1989 i
e INK)RMED NBC - MAIG 31, 1989 INITIATED EFFORP 70 RESOLVE - APRIL 1,1989 e
INACCURACIES RESOLVED / POSITIVE RESULTS - MAY 3,1989 e
i EA/QA OVERSIGHT REVIEW CCMPIEEE - MAY 4/5, 1989 e
1 CERTIFICATE 2
4 3
This is to certify that the attached proceedings before the 4
United States Nuclear Regulatory Commission in the matter 5
of:
6 Name:
Meeting with WA to Discuss WA's Proposed Resolution to the Electrical Cable Separation Issue 7
8 Docket Number:
9 Place:
Rockville, Maryland 10 Date:
May 11, 1989 11 were held as herein appears, and that this is the original 12 transcript thereof for the file of the United States Nuclear 13 Regulatory Commission taken stenographically by me and, 14 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.
18
/s/
4 U
J 19 (Signature typed) :
Mark Handy i
20 Official Reporter 21 Heritage Reporting Corporatio:
22 23 24 I
25 l
i i
Heritage Reporting Corporation (202) 628-4888
.. h l
4 MErff0DOIOGY e
RDCONFIR4 EKISTItG INSTALLED CAB 2 IOUTI!G INFOR% TION PROVIDED TO NBC.
- AMPACITY WMEDOWS
- APPENDIX R WMEDOWNS e
EVALGLTE DMA FOR DISCREPANCIES.
DISCREPANCY:
- ACTUAL CAB 2 INSTAILED CCNFIGURATICN DOES NOT AGREE WIM ESIGN CONFIGURATION.
e EVALUME DISCREPANCIES FOR DESIGN SIGNIFICANCE (AOCEPTAtCE CRITERIA).
E SIGN SIGNIFICANT:
- A DISCREPANCY WIG IS FOut0 TO BE IN NCNCCNFOENMCE WITH THE APPLICABLE 002, SDNDARD, OR LICENSIIG REQUIREMENTS (FSAR/TSIGN CRI1ERIA).
e DETERMINE CONFIDEtCEVQUALITY LEVEL BASED CN IESIGN SIGNIFICANCE (MEIHCD ANATIYYTTS TO NCIG-02).
IEIERMINE SAFETY SIGNIFICANCE (AS REQUIRED PER NEPs 6.6 AND 9.1).
e SAFETY SIGNIFICANT:
- A DESIGN SIGNIFICANT DISCREPANCY WICH, IF REMAINED UNDETECED, COUID RESULT IN THE IDSS OF CAPABILITY OF THE AFECTED SYS1EM OR STRUCTURE TO FEREDEN ITS I
INTENDED SAFETY FUtCTICN.
,. +
RESULTS Vl/V2 V3 V4/V5 (INSIRNENIATION)
(COtCROL POWER)
(POWER)
(APPENDIX R REQUIRED)
POPULATICN OF CONCERN PREVIOUS 64
~ 20,000 982 ACIUAL 64
~ 20,000
~2,000 SAMPLE POPUIATION PREVIOUS 64 155 443-ACIUAL 64 266 951 IESIGN SIGNIFICANT DISCREPANCIES l
l (ACCEPIANCE CR.Lu.nIA)
PREVIOUS 0
2-16 11 ACIUAL 0
3 8
i SAFEIY SIGNIFICANT DISCREPANCIES PREVIOUS 0
0 0
ACIUAL 0
0 0
l l
-___r____
l'.l'.
-2....
L CONCLUSION e BASED ON IESIN SIGNIFICANT ACCEPTAICE CRIERIA.
- V4/V5 IESIGN SIGNIFICANCE EVALIRTION PROVIIES 95% CONFIIENCE OF A 98% QUALITY IZvEL Or. GREAER FOR ME 'IDIAL PCPUIATICN.
- V3 DESIGN SIGNIFICANCE EVALIRTION PROVIIES 95% CONFIDENCE OF A 97% QUALITY IZVEL OR GREAER FOR 'IHE TCTfAL POEUATIM.
e ZERD SAFETY SIGNIFICA!CE FOR SAMPLE REVIEWED.
e REASOt&BLE ASSURA!CE FOR UNIT 2 SAFE OPERATIW.
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