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| {{#Wiki_filter:Official Transcript of Proceedings NUCLEAR REGULATORY COMMISSION | | {{#Wiki_filter:}} |
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| ==Title:==
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| NRC HEAF Phase II Information Sharing Workshop Docket Number: N/A Location: North Bethesda, Maryland Date: April 18, 2018 Work Order No.: NRC-3640 Pages 1-301 NEAL R. GROSS AND CO., INC.
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| Court Reporters and Transcribers 1323 Rhode Island Avenue, N.W.
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| Washington, D.C. 20005 (202) 234-4433
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| 1 1 NUCLEAR REGULATORY COMMISSION 2 + + + + +
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| 3 NRC HEAF PHASE II INFORMATION SHARING WORKSHOP 4 + + + + +
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| 5 WEDNESDAY 6 APRIL 18, 2018 7 + + + + +
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| 8 9 The NRC HEAF Phase II Information Sharing 10 Workshop met in the 02A14 Classroom of Three White 11 Flint, 11601 Landsdown Street, North Bethesda, 12 Maryland, at 8:44 a.m., Michael Cheok, Deputy 13 Director, NRR, presiding.
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| 14 15 STAFF PRESENT 16 MICHAEL CHEOK, Director, Division of Risk 17 Analysis, Office of Nuclear Reactor 18 Regulation 19 THOMAS AIRD, General Engineer, Division of Risk 20 Analysis 21 THOMAS BOYCE, Branch Chief, Regulatory Guidance 22 and Generic Issues Branch 23 ROBERT DALEY, Branch Chief, Region III 24 STANLEY GARDOCKI, Program Manager, Regulatory 25 Guidance and Generic Issues Branch NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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| 2 1 NICHOLAS MELLY, Fire Protection Engineer, 2 Office of Nuclear Regulatory Research 3 KENN MILLER, Office of Nuclear Regulatory 4 Research 5 MARK HENRY SALLEY, Branch Chief, Fire and 6 External Hazards Branch 7 DAVID STROUP, Project Manager, Office of 8 Nuclear Regulatory Research 9 GABRIEL TAYLOR, Senior Fire Protection 10 Engineer, Office of Nuclear Regulatory 11 Research 12 MICHAEL WEBER, Director, Office of Nuclear 13 Regulatory Research 14 15 ALSO PRESENT 16 JENS ALKEMPER, FM Global 17 SCOTT BAREHAM, NIST 18 JANA BERGMAN, Curtiss-Wright 19 ROBERT CAVEDO, Exelon 20 FRANK CIELO, KEMA Laboratories 21 MARK EARLEY, NFPA 22 KENNETH FLEISCHER, EPRI 23 DANIEL FUNK, Jenson Hughes 24 FRANCISCO JOGLAR, Jenson Hughes 25 CASEY LEJA, Exelon NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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| 3 1 ASHLEY LINDEMAN, EPRI 2 DAVID LOCHBAUM 3 SHANNON LOVVORN, TVA 4 MATTHEW MERRIMAN, Appendix R Solutions 5 ALICE MUNA 6 FRANCESCO PELLIZZARI, EPM 7 ROD PLETZ, AEP 8 SUJIT PURUSHOTHAMAN, FM Global 9 ANTHONY PUTORTI, NIST 10 ROBERT RHODES, Duke Energy 11 BRENDA SIMRIL, TVA 12 THOMAS SHUDAK, NPPD 13 STEPHEN TURNER, Independent Consultant 14 BAS VERHOEVEN, KEMA Laboratories 15 BETH WETZEL, TVA 16 17 18 19 20 21 22 23 24 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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| 4 1 C-O-N-T-E-N-T-S 2 Opening Remarks . . . . . . . . . . . . . . . . . 5 3 Introduction & Meeting Objectives . . . . . . . . 5 4 Review of Phase I HEAF Research . . . . . . . . 19 5 Generic Issues Process . . . . . . . . . . . . 58 6 Aluminum HEAF PRE-GI-018 . . . . . . . . . . . 60 7 Pilot Plants . . . . . . . . . . . . . . . . . 106 8 Arc Flash/Blast/HEAF Definition & Bin 16 . . . 137 9 Small Scale Testing at SNL . . . . . . . . . . 164 10 PRA Modeling Implications . . . . . . . . . . . 191 11 NFPA Perspective . . . . . . . . . . . . . . . 207 12 EPRI Perspective . . . . . . . . . . . . . . . 226 13 Physical Testing & Failure Rates . . . . . . . 252 14 Public Comment . . . . . . . . . . . . . . . . 299 15 Adjourn . . . . . . . . . . . . . . . . . . . . 301 16 17 18 19 20 21 22 23 24 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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| 5 1 P-R-O-C-E-E-D-I-N-G-S 2 8:44 a.m.
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| 3 MR. TAYLOR: Okay, we're going to go 4 ahead and get started. For those in the room, just 5 beware that there's some cords for the transcriptions 6 and please be safe as you move about the room. With 7 that, we already went over the logistics and the 8 administrative stuff, so I will go ahead and turn it 9 over to Mark Salley to open up and introduce him.
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| 10 MR. SALLEY: Opening the meeting up --
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| 11 thank you all for attending. And Mike Cheok, my 12 division director in Research, is going to open up 13 for us. So, Mike?
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| 14 MR. CHEOK: Well, thank you and welcome 15 to the Public Workshop on Phase II Testing of High 16 Energy Arcing Faults, or HEAFs. And first of all, 17 thank you for all your patience as we set up and we 18 have some logistics, too, that came up. And as Mark 19 said, I am Mike Cheok and I am the Division Director 20 for the Division of Risk Analysis in the Office of 21 Nuclear Regulatory Research.
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| 22 So now, HEAFs is an important topic for 23 us. And we would like to better understand the 24 phenomenon and to better characterize the safety 25 significance in nuclear power plants. It is also NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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| 6 1 very important for us to reach out to you all, to all 2 our stakeholders, to get your input as we move 3 forward to the next phase of HEAF testing. So one of 4 the lessons learned here in our first phase of 5 testing was that we need to get stakeholder input 6 earlier in the process to guide future tests. So 7 your experience and expertise are important to us and 8 we value it as we move forward to Phase II of the 9 testing.
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| 10 In addition to all the participants in 11 this room, which there is a lot of, we have also a 12 number of people on the webinar. I would like to 13 point out that this week in France, their OECD 14 nuclear energy agency's fire modeling program led by 15 the French regulator of IRSN, is also meeting to 16 discuss their current activities. So many members of 17 their program are also members of the International 18 OECD HEAF Program and many of them are on this 19 webinar. So I know it makes for a very long day for 20 those participants, and I want to thank them for 21 taking the time to participate in both meetings.
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| 22 As you will see from the agenda, we have 23 more information to cover over the next two days. We 24 encourage your active participation and your input 25 into each one of these sessions. So, starting with NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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| 7 1 it in mind, this slide shows the desired outcomes 2 from the workshop. First, we hope to develop clear 3 and concise definition of the arc flash and the HEAF 4 phenomenon. We will work with you as experts in the 5 nuclear industry and as well as from the National 6 Fire Protection Agency, NFPA -- NFPA Factory Mutual 7 and KEMA Labs to develop definitions that are 8 consistent with the needs of the nuclear community 9 and with the commercial industry as well.
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| 10 Next, as I have mentioned earlier, there 11 was a lot of discussion about the Phase I testing, 12 which said that on testing -- that the test needed to 13 be more realistic and representative of what was 14 found in nuclear power plants. So our second desired 15 outcome as far as to get your input towards Phase II 16 testing. We will discuss the proposed test 17 parameters and methods and we hope to accomplish --
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| 18 and what we hope to accomplish for Phase II testing.
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| 19 Then we will open up the discussion to your opinion, 20 insights and input. We will include the new and 21 relevant information that's made available to us 22 during this workshop.
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| 23 Finally, I would like to mention that 24 Mike Franovich from the Office of Nuclear Reactor 25 Regulation and I are co-chairs on the panel for the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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| 8 1 ongoing pre-Generic Issue on aluminum HEAF. The 2 NRC's generic issue process is a phase process where 3 we evaluate the issue is safety significant enough 4 and if there are generic implications to warrant 5 further study or action. We hope to get additional 6 information from this workshop and from subsequent 7 testing to help us inform the resolution of this 8 issue on aluminum HEAFs.
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| 9 So, again, I thank you all for taking the 10 time to support this workshop. I know your schedules 11 are very busy and demanding. So I appreciate the 12 interest and you attendance today. Your insights 13 will help us perform the necessary research needed to 14 better understand and resolve the issue in more than 15 high energy arcing faults. I am confident that the 16 results from this project will be useful for guiding 17 the safety decisions for both the nuclear and 18 commercial industries. Thank you, and I will hand 19 the proceedings over to Mr. Mark Henry Salley who 20 will lead us through the rest of the workshop. Mark?
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| 21 MR. SALLEY: Can Nick and I go back and 22 forth?
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| 23 PARTICIPANT: Let me turn this off so we 24 don't get too much feedback.
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| 25 (Pause.)
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| 9 1 MR. SALLEY: All right, thank you very 2 much for coming in today. We've got some special 3 guests, Mark Earley from the NFPA is going to be with 4 us at a presentation. We got Bas from Netherlands 5 all the way from -- what? Netherlands? Going to 6 give us a presentation. He runs the KEMA lab over 7 there, which I guess is the mother ship of the one 8 that we work with in Pennsylvania. And also, Ashley 9 -- I see Ashley got a presentation for what EPRI is 10 going to be showing. In addition to that, we've got 11 a lot of NRC folks to talk -- N.J. Taylor, Nick 12 Melly, Stan Gardocki is here, he can talk about our 13 Generic Issue Process. And we've got Kenn Miller 14 back there. He is going to talk about some of the 15 work we're doing with the definitions. So I'd just 16 like to introduce -- if everybody just go around and 17 introduce themself here to get started. If we could, 18 Gabe?
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| 19 MR. TAYLOR: Gabe Taylor, Officer of 20 Research, NRC.
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| 21 MR. MERRIMAN: Matt Merriman, Appendix R 22 Solutions.
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| 23 MS. BERGMAN: Jana Bergman, Curtiss-24 Wright.
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| 25 MR. TURNER: Steve Turner, Consultant.
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| 10 1 MR. BAREHAM: Scott Bareham, from NIST.
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| 2 MR. PUTORTI: Tony Putorti, Fire Research 3 at NIST.
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| 4 MS. WETZEL: Beth Wetzel, TVA.
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| 5 MR. CAVEDO: Rob Cavedo, Exelon.
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| 6 MR. LEJA: Casey Leja, Exelon.
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| 7 MR. RHODES: Bob Rhodes, Duke Energy.
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| 8 MR. JOGLAR: Francisco Joglar, Jenson 9 Hughes.
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| 10 MR. FUNK: Daniel Funk, Jenson Hughes.
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| 11 MR. ALKEMPER: Jens Alkemper, Research, 12 FM Global.
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| 13 MR. PELLIZZARI: Francesco Pellizzari, 14 EPM.
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| 15 MR. PURUSHOTHAMAN: Sujit Purushothaman, 16 Research, FM Global.
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| 17 MR. GONZARIO: Tony Gonzario, NRC Office 18 of the Chairman.
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| 19 MR. DALEY: Bob Daley, NRC, Region III.
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| 20 MR. MILLER: Kenn Miller, Office of 21 Research, Division of Engineering.
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| 22 MS. SIMRIL: Brenda Simril, TVA.
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| 23 MR. LOVVORN: Shannon Lovvorn, TVA.
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| 24 MR. STROUP: David Stroup, NRC Office of 25 Research.
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| 11 1 MR. GARDOCKI: Stanley Gardocki, Office 2 of Research, Generic Issues Program.
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| 3 MR. MELLY: Nick Melly, Office of 4 Research.
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| 5 MR. SALLEY: Okay, thank you. Oh -- yes.
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| 6 MR. EARLEY: Mark Earley, NFPA.
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| 7 MR. CIELO: Frank Cielo, KEMA 8 Laboratories.
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| 9 MR. VERHOEVEN: Bas Verhoeven, also KEMA 10 Laboratories.
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| 11 MS. LINDEMAN: Ashley Lindeman, EPRI.
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| 12 MR. FLEISCHER: Kenn Fleischer, EPRI.
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| 13 MR. SHUDAK: Tom Shudak, Nebraska Public 14 Power.
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| 15 MR. PLETZ: Rod Pletz, American Electric 16 Power.
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| 17 MR. SALLEY: Okay, and we also are doing 18 this on a webinar. Who do we have on the webinar?
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| 19 (Off-microphone introductions.)
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| 20 MR. MELLY: Thank you. All right, mute 21 the line. We will have a few people joining in 22 occasionally at the webinar, like we mentioned 23 earlier. There are some time differences and some 24 meetings going on in Europe right now. Many of the 25 members for the OECD Program are -- have that NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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| 12 1 conflicting meeting. So they will be joining in 2 occasionally throughout the meeting.
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| 3 MR. SALLEY: So, again, we are doing it 4 with -- live here. Sorry the room is small. We had 5 a little trouble booking it, but I guess it will be 6 -- it will be comfortable. But we are doing this via 7 the webinar. You folks on the webinar, if you would 8 email your information to Tom Aird and he will get 9 that for you there. Also, this meeting is going to 10 be transcribed. We figure there is going to be a lot 11 of discussion, especially tomorrow. So we wanted to 12 make sure that we captured everything. So as we look 13 at the test plan moving forward, we can go back to 14 remember what was said and to get the input. So 15 again, we are going to transcribe this. So when we 16 do get to the discussion piece, if you could 17 introduce yourself before you speak, it would be 18 easier for the court reporter to do the 19 transcription. And again, our end goal is -- we've 20 got a lot of good presentations. And I look at some 21 of the stuff form EPRI and the NFPA, and I am sure 22 the stuff from KEMA is going to be top-notch. So we 23 wanted to capture that. We are looking at doing a 24 NUREG/CP. A NUREG/CP is a conference proceeding. So 25 it would be a standard NUREG with all our NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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| 13 1 presentations and anything that comes out of this 2 meeting in there. So again, we can capture this and 3 use this moving forward with the HEAF Program. Next 4 slide, Paul?
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| 5 MR. MELLY: And like Mark said, we do 6 have a microphone in the back of the room. It would 7 be beneficial today if anyone -- any -- for any 8 discussion -- so the people on the phone can hear you 9 if you use that microphone when -- while asking any 10 questions today.
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| 11 MR. SALLEY: So, the purpose of this 12 meeting, again, we have a number of things we would 13 like to accomplish. We would like to share with you 14 what we've learned to date. Different people coming 15 into this -- this program at different points, so 16 we'd like to bring everybody up to speed with what 17 we've got, what we've done and where we're at. As 18 Mike said, very important -- as the NRC is a 19 transparent agency, we'd like to solicit your input 20 as we move forward. That's very valuable to us. You 21 guys are the ones who read the plans, doing the work 22 and that information is very valuable as to how to 23 move forward.
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| 24 Again, we want to learn from each other.
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| 14 1 have done a lot of work in this area. I think we can 2 gain some of that. FM Global is here and I hope we 3 can get some insights and information from you also.
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| 4 Again, we have the meeting going on in Europe at the 5 same time. We look to move forward with our partners 6 as we did in the first phase, which we will talk 7 about in a little bit. And again, the Generic Issue 8 Program -- you know, you guys are familiar with plans 9 with generic letters. Generic Issue is a different 10 thing. We haven't done one in Fire for a while. So 11 it is going to be worth a little time that Tom Boyce 12 and Stan are going to walk us through the process.
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| 13 I know there is -- when we issued the information 14 notice, there was a little bit of apprehension --
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| 15 okay, what comes next? What do we have to do? And 16 again, we put this into the Generic Issue Process, 17 which is a very formalized process the NRC has had 18 since the 1970s and I think it's worth Stan walking 19 you through, so that will explain how this is going 20 to work out in the long term. Next slide?
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| 21 So we broke this presentation down, 22 basically, into two days. We could have done it in 23 a week, there was so much to cover. But we thought 24 two days would be about right. They're going to be 25 long days, so I hope you're all up for that. The NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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| 15 1 first day we wanted to really share a lot of 2 information with you -- wanted to get you up to speed 3 where we're at. The information we've done to date 4 and get a lot of those presentations.
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| 5 The next day -- the second day -- the 6 second day we look for a lot of interaction with you.
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| 7 And that's where we really want to have -- after 8 loading everything up today, you think about it 9 tonight, then tomorrow we have a lot of good 10 discussion as to how are we want to look at that test 11 plan, and how do we want to move forward? So today 12 is going to be a fair amount of getting 13 presentations, getting information down. Second day 14 we'd -- like I said, we would really engage for a lot 15 of discussion.
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| 16 Path forward, again, we've put our test 17 plans out. You've seen them in the Federal Register.
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| 18 We've gotten a number of comments on them. We've 19 also got some small-scale testing we're looking at 20 doing with the lightening research out at Sandia.
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| 21 And that test plan is also out there again. Again, 22 we're soliciting information, comments from you on 23 that so we can get the -- the best product we 24 possibly can. And again, we'll work with our 25 partners over in Europe and Asia in the second phase NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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| 16 1 of OECD Program. But again, we want to -- we want to 2 do this in a methodical manner. So, we'd like to 3 have this well thought out and well planned.
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| 4 We haven't procured our equipment for the 5 second phase of testing too much yet. We've got a 6 little bit from some of our European partners. We 7 haven't drawn and done that. And again, the second 8 day, tomorrow, I hope there are a lot of electrical 9 engineers who can really give us some insights as to 10 what we need to look at for the -- for the biggest 11 bang from our buck as far as doing the testing. We 12 were hoping to get a test off in the fall, that was 13 our target -- it still is. However, with the 14 international agreement, the OECD -- OECD, the NEA 15 and our legal departments, there's some questions on 16 some wording that changes with the international 17 agreements that truthfully -- like everything, our 18 lawyers need to work out before we can move forward.
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| 19 So, right now, our agreement with working with the 20 international group is with the lawyers. So, we 21 would have worked that through the process.
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| 22 Again, at the end of the day, in the long 23 term, what do we want to do? In the nuclear area --
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| 17 1 and that's who we like to do things. I don't see the 2 HEAF issue as anything different -- with the elements 3 like we do in Fire Protection and other areas, we 4 always want to do the preventive activities if we 5 can. If we can't prevent it, we want to detect it 6 and mitigate the hazard. And if we can't do that, at 7 the end of the day, we need to start a safe shutdown 8 for the reactor. So again, I see this process as it 9 evolves over time with different parts of the testing 10 feeding into different parts of this, operating 11 experience, et cetera -- as we develop a defense in 12 depth process moving forward.
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| 13 Last line as we get started here is the 14 NRC -- our mission is safety, you know. So there's 15 our statement. And again, it is about protecting the 16 public, the environment. Safety is our business.
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| 17 But I will tell you something else about -- that I've 18 learned doing fire research is fire research is 19 bigger than the NRC, it's bigger than the nuclear 20 community. Things that we learn in fire protection 21 we can reach out and share with our other partners.
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| 22 For example, one of the things Nick and I do with 23 this program is the thing called the Federal Fire 24 Working Group. So all your three- and four-letter 25 agencies belong to that -- NASA, DOE, DoD. And we NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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| 18 1 get together once or twice a year and we share what's 2 going on in our area. The last two years Nick and I 3 have been sharing what we've been learning about the 4 HEAF with that larger federal community with the idea 5 that these HEAFs are not -- or, these arc flashes are 6 not unique to power plants. Anybody who is using 7 electricity has this same thing. And we see a lot of 8 this in the general industry as Mark Earley is going 9 to share with us later. So again, if we can benefit 10 the greater area and greater good, we are all for 11 that. Again, partnering with those NIST and that --
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| 12 we can get this information out to different areas.
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| 13 So, with that being said, the first thing 14 we'd like to do is a quick review of what we've got.
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| 15 MR. TAYLOR: Yes, while Nick brings that 16 up. One thing I did want to mention, for those on the 17 webinar, if you have questions -- and this is a 18 category three public meeting, so it's kind of a 19 free-for-all. There is no designated time like a 20 category two. But for those on the webinar, if you 21 have a question, there's two ways to bring it up.
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| 22 One, you can text a question into the webinar box and 23 our webinar controller will then bring that question 24 up. Or, two, you can raise your hand. And then the 25 webinar controller will un-mute your line and you can NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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| 19 1 then ask your question that way. For those on the 2 webinar, two ways to bring up questions.
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| 3 MR. SALLEY: Thank you, Gabe. So 4 quickly, moving forward here, we are going to give 5 you a Reader's Digest of what we've done over the 6 last six, eight years and where we're at with -- with 7 this program. A key to this presentation is that 8 this really is -- is the roadmap of where we're at 9 and this is the reference. There is a lot of links 10 in here to different reports. If you want to 11 download them, they're all publicly available on the 12 web. You'll also see a thing -- ML. And when you 13 see that ML, that ML number is the NRC's document 14 control system. We call it ADAMS. And those are the 15 identifiers for the documents to bring it up. So 16 again, you can find us on the NRC's public web page.
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| 17 Any of the ML numbers will be the identifier that 18 will bring that report, that memo or whatever that 19 document is for. So again, the key to this is to do 20 a review for you and it's also the Reader's Digest 21 version of all the references of where we're at.
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| 22 Next one, Nick.
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| 23 So, when we started this, we first looked 24 at getting going for this, we looked at the document 25 NUREG/CR 68-50, this is EPRI 1011989. It was a joint NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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| 20 1 project we had done with EPRI a number of years ago.
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| 2 Francisco is here. He was very intimate with that 3 back in the day when that was written. He can answer 4 a lot of your questions.
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| 5 But again, this was a chance for the 6 industry and the NRC to work together to develop a 7 five PRA method to do a five PRA for a nuclear power 8 plant. So it's a very big document. It's got a lot 9 of different things in it. And it was one of the 10 first times where we really identified the HEAF and 11 said, hey, this is a -- a hazard that you need to 12 look at when you're doing your risk analysis for your 13 power plant. And they had done some work on it. And 14 looking at the enclosures, as we're going to see here 15 in a little bit, that we had postulated two types of 16 failures. You could have the thermal failure where 17 an electrical enclosure caught on fire and caused 18 damage. Or you could have the explosive force of the 19 HEAF. So it was a -- a binary thing.
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| 20 Cutting ahead a little bit, as we've 21 looked at that and we started down that road, we've 22 kind of put it in neutral for a little bit and we 23 stopped because some things that we're going to talk 24 about here in a little bit, that Nick's going to 25 discuss, is that -- and again, this gets to the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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| 21 1 testing. Not every time we have an electrical 2 failure does it immediately go to a HEAF. There's 3 other things that happen in there and things we're 4 learning from the NFPA where they have arc flashes, 5 arc blasts and HEAF. And we're going to get into a 6 discussion on that.
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| 7 So this is a point where we've learned 8 something going through the process, kind of want to 9 slow it down and stop it for a second and get a 10 little more resolution.
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| 11 Next slide? This is a slide that Kelly 12 Gosing (phonetic) presented at our RIC conference 13 this year. She's from EPRI. And it looked at the 14 hazard that we see in the power plants from the 15 different risk drivers. And you can see in the back, 16 you can call this is a skyscraper -- skyline?
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| 17 MR. MELLY: Skyline, skyscraper chart.
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| 18 MR. SALLEY: Yes, skyline chart -- you'll 19 notice that we see the big risk driver is from the 20 thermal fires in the electrical enclosures. That's 21 the lines in the back. Moving forward a little bit 22 you'll see that, I think, number three on there is 23 the high energy arc faults. So again, as far as the 24 risk in power plants, this is something that's 25 important in a risk-informed environment this is NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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| 22 1 something we want to look at. This is something we 2 really want to understand. Next slide, Nick.
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| 3 MR. MELLY: Moving forward we kind of 4 wanted to provide the background, history of all the 5 links and things like that that Mark mentioned. And 6 you'll see here that we provide a link to all the 7 documentation that we're going to be discussing 8 throughout the workshop. Starting with NUREG-6850, 9 it provided the methods for doing the Bin 15 10 electrical fires as well as the Bin 16 -- the high 11 energy arcing fires. One of the lessons that we 12 learned is that our -- Bin 15 is fairly broad. It 13 encompasses all electrical enclosures. And for the 14 Bin 16, the high energy arc faults, it's a one size 15 fits all model. So having a very broad BIN for all 16 electrical cabinets, using a one size fits all model 17 proved to be a problem when there's not much that you 18 can do to mitigate the effects of the high energy 19 arcing faults. So one of the things that we're kind 20 of focusing on with a couple of our presentations as 21 well as -- YMPA is here and the discussions that 22 we've been having with them -- is to really define 23 what we mean by the high energy arc faults and 24 separate them into appropriate BINS with the 25 appropriate frequencies that you can use in your NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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| 23 1 PRAs.
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| 2 One of the other major efforts that we've 3 done recently is the HELEN-FIRE work as well as our 4 RACHELLE-FIRE work. It was a focus on looking at Bin 5 15 and creating realistic heat release rate profiles 6 associated with them so that we could advance the 7 main risk driver that we saw from that skyline chart.
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| 8 A lot of this work was done with EPRI and it has been 9 done as relatively -- a success in advancing the 10 state of knowledge. And that focused directly on the 11 thermal fires associated with electrical cabinets and 12 did not take into account the electrical energy 13 associated with the fire itself. It may have started 14 the fire, but it wasn't a prolonged electrical event.
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| 15 This is the second part to that. The 16 HELEN-FIRE report that was on the previous slide was 17 the actual testing program, which was done with NIST, 18 testing over 100 electrical cabinets to evaluate the 19 heat-release rate profiles. And the follow-along was 20 done as an expert panel to create appropriate Bins 21 and do the application of that research. And as we 22 discussed earlier, we are really going to try and 23 focus a lot of our effort on the subdividing Bin 16 24 into the appropriate Bins. As we'll see in our 25 further definition -- or, further presentations, we NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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| 24 1 are going to be looking at separating the terminology 2 for arc flash, arc blast and the high energy arcing 3 fault. And we want to link that with how we are 4 going to be doing the modeling.
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| 5 So again, we are going to have another 6 presentation from NFPA on their work in this area.
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| 7 A lot of it is primarily focused on personnel 8 protection where we have a little bit different 9 mindset moving into the protection of a plant and 10 plant equipment in PRA models.
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| 11 MR. SALLEY: And keep your -- keep your 12 eye on these slides, this pictures, in the back of 13 your mind because, you know, the picture is worth 14 1,000 words. When Kenn Miller does his talk about 15 these differentiating -- how we are going to 16 differentiate the categories between an arc flash and 17 a HEAF, this will be in -- a lot of this in more 18 detail in Kenn's presentation. So keep these 19 pictures in mind as Nick goes through it.
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| 20 MR. MELLY: Yes, and to kind of explain 21 these pictures at a high level is that, whenever you 22 have the breaker trip or these flash events, a lot of 23 them go into the Bin 15 fires where it may have --
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| 24 you failed circuit protection, or you had a short or 25 a fault in your cabinet, but it doesn't lead to this NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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| 25 1 large damage state that we're seeing. It can just 2 generate a small fire in the cabinet, or no fire at 3 all. Typically, that's going to be in Bin 15.
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| 4 Another category that you can see is that 5 you have this blast -- where you have the pressure 6 effect damaging things in the room. What you're 7 seeing on the screen right here is the event that 8 happened in 2017 at Turkey Point where you don't see 9 that large cabinet damage. There was a pre-phase 10 fault in this cabinet, lasted for approximately half 11 a second, which was a success of their circuit 12 protection -- or, operated as designed. But you 13 still saw that we had -- that there was a breach of 14 the fire door from the over-pressurization in the 15 room. This fire door was located 15 feet away from 16 the cabinet of origin -- so clearly outside the 17 three-foot horizontal distance that's currently in 18 6850, but again, you saw that breach of the door into 19 the 4B switch gear room. So essentially, you -- you 20 had a area breakdown between a 4A and a 4B, which can 21 be a potentially serious problem.
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| 22 Again, another instance of this, you see 23 Brunswick in 2017. You see that severe cabinet 24 deformation from the pressure wave, but you didn't 25 see this large damage effect that's in 6850 upon NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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| 26 1 exam, and you don't see then, during fire condition.
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| 2 So these are the things we kind of want to focus in 3 on moving forward, how we create the frequency of 4 these events occurring.
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| 5 Some of the more classical examples of 6 what you do see as HEAF is the San Onofre fire in 7 2001. This is a SONGS event. This is essentially 8 what was used to model what's in 6850, Appendix M.
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| 9 This event was well documented and gave the authors 10 of 6850 a good picture of what they were trying to 11 prevent with this damage state. So that's kind of 12 what led to the three-foot, five-foot and the caveats 13 that is in Appendix M of 6850. You see on the right-14 hand side, this is the damage associated with the 15 Onagawa event in 2011. From the earthquake itself, 16 they had a hanging magnet blast breaker that created 17 -- stads (phonetic) got crossed up from the shaking 18 of the earthquake itself. This plant was the closest 19 to the epicenter, so it did have the highest ground 20 fall acceleration, and you saw that problem. This 21 fire lasted for seven hours because the onsite 22 brigade couldn't get into the room. It damaged seven 23 pieces of equipment and it was a very difficult fire 24 to fight. If Fukushima wasn't occurring, this is 25 probably what would have been in the news headlines.
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| 27 1 And again, it's not only the electrical 2 cabinets that we're worried about. It's also the bus 3 ducts. You see these two events from Diablo Canyon 4 and Columbia, where you see the large damage states.
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| 5 There was approximately eight feet of bus ducts and 6 four feet of the bus bars inside the bus duct that 7 were damaged here. And you also see that this kind 8 of brings up the problem of aluminum that we're 9 currently facing and looking at in the generic 10 issuing program. You can see in the Columbia bus 11 duct event, you have that -- everything looks like it 12 is white-washed around the event, and that's because 13 in this event the bus ducts themselves, as well as 14 the enclosure, was made of aluminum. And again, I 15 mentioned four feet of the bus duct conductors and 16 eight feet of the enclosure was vaporized during this 17 event, and it had a lot of people scratching their 18 heads in the root cause analysis.
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| 19 The center picture you see is the Zion 20 bus duct that we tested in 2016 where we vaporized 21 seven inches of the enclosure material and one-and-a-22 half inches of the conductor. We will see a video of 23 that moving forward that you can kind of keep in your 24 mind -- the energy associated with the release of 25 this amount of material. One of the other important NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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| 28 1 aspects that we're going to really dive into tomorrow 2 during our discussion is the duration that's 3 associated with how we test these events. Electrical 4 protection comes into play -- it's extremely 5 important in the durations of -- a primary driver for 6 how much energy is released during the event. We are 7 trying to base it off operating event history that we 8 actually see in these plants, and this is one piece 9 of information that we want to do better on in the 10 future at collecting how long these events actually 11 last in the plant. Some of the information is a 12 little hard to find on -- in LER information and the 13 condition reports. But it's something we want to do 14 better on and dig deeper into so we can inform the 15 testing program.
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| 16 This is just a sampling of some of the 17 events that constitute the Bin 16 high energy arcing 18 faults. And you can see the duration of these events 19 is longer than you would normally expect if your 20 circuit protection works. Like we talked about at 21 Turkey Point, that was half a second, which is fairly 22 long for a successful operation of a breaker, but we 23 do see these events occurring. We range anywhere 24 from two seconds that we typically see, to the Fort 25 Calhoun, which is a little weird of an event. It was NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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| 29 1 a low-voltage system that was holding in on an 2 upstream transformer that did last for 42 seconds 3 until operators actually manually terminated the 4 event. And we can look at some pictures of the 5 damage associated with that event moving forward.
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| 6 Again, that was an aluminum event and there's some 7 indication that it may have led to some -- a 8 conductive environment that led to later faulting.
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| 9 MR. SALLEY: So duration is going to be 10 one of the topics, I guess, that we're going to 11 discuss a lot tomorrow. And then we will be looking 12 for a lot of your input. Swinging back to the 13 regulations a little bit on how we -- the NRC 14 regulates the plants -- the safety significance of 15 this, is we have a thing, Appendix A to 10 CFR 50, 16 which is a code of federal regulations. Appendix A 17 is the general design criteria. And there's two of 18 them that apply to this area, GDC 3, of course, is 19 fire protection. And for the fire hazards analysis 20 done by the Fire Protection engineers, one of the key 21 things is that you'd postulate the fires and 22 explosions. I guess the question comes of how 23 rigorous in that FHA were you at postulating 24 explosions from electrical equipment? And it was 25 easy to do the hydrogen and different things in the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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| 30 1 plant, but the question comes up, do we consider --
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| 2 consider the heat for the electrical?
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| 3 And the other area, GDC 17, that's for 4 our electrical engineering colleagues. And again, 5 that's the single failure that should prevent these 6 type of events. So again, this is codified in the 7 regulation. And again, it will tie back to the work 8 Stan's doing with the Generic Issue Program.
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| 9 So how do we -- how did we get into this, 10 and you know, what brought this up? And I like to 11 think of this with what we're doing as almost 12 connecting the dots. We belong to the international 13 group we talked about, the OECDNEA. And we work a 14 number of programs internationally sharing safety 15 information. One of the things we look at is the Fire 16 Events Database. And it's a -- it's a fairly 17 inexpensive program. It's a good program for the 18 NRC. The part that I like about it is that we can 19 look at the events that we've had -- the LER, 20 licensed event report fires, which are typically 21 between three and nine a year. We can look at those 22 fires. We can take that to the international 23 community and say, hey, we've had this, this and 24 this. What are you seeing in your plants? Is there 25 something we're doing wrong or unique in the United NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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| 31 1 States that you've done better in Japan or Korea or 2 Germany or France? Or, are you seeing the same type 3 of events that we are?
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| 4 And when we first brought up the high 5 energy arc faults, it was interesting because all of 6 the sudden, everybody started saying hey, we've had 7 one or two of those. And we all started exchanging 8 information. So we saw it that this wasn't something 9 that was unique to the United States nuclear plants, 10 but we were seeing this worldwide. And then when we 11 started tallying it up and we started seeing that, 12 hey, of all the fires that we're talking about in 13 this group, ten percent of them are HEAFs. Wow, how 14 much do we know about this? Not that much. This is 15 a significant issue. Do you think we ought to do 16 some research to do something with this? And 17 everybody, pretty much, around the table agreed, yes, 18 this is a -- this is a risk driver that we need to 19 think about and we need to do some work on. So this 20 was the genesis for bringing the High Energy Arcing 21 Fault Program and why we went with the international 22 approach in what we saw here.
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| 23 MR. MELLY: And in the most recent 24 database update that we're going to be completing 25 later this year, that number has jumped to 64 out of NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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| 32 1 a -- I believe it -- we're at 475 events. And again, 2 it may be skewed a little bit in this ten percent 3 because everyone reports these events. There's no 4 chance you're missing a high energy arcing fault 5 occurring in your country because they're typically 6 the larger fires that have severe consequences and 7 difficult plant shutdowns associated with these 8 events as we see in our history as well.
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| 9 MR. SALLEY: So we started doing some 10 work in that area and one of the other groups picked 11 it up -- one of the risk groups -- and they started 12 looking at the methods. Okay, so you see these 13 events, how do we postulate this event? How do we do 14 the analysis? And basically you can read the report, 15 but it all comes back to what we had done with 16 Francisco and company and 6850 and the Appendix M.
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| 17 And that seems to be about the state of the art, the 18 best information that's out there. A little 19 additional work the Canadians put into this report, 20 and again, the key here is for you, there's the 21 links, and you can download all this.
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| 22 Again, with our testing we hear realism.
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| 23 You know, everybody wants realism in PRA -- realistic 24 tests, realistic -- so that's kind of where we're 25 going with this. We're not trying to do worst case, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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| 33 1 conservative tests, but again, something that's 2 realistic that we can get a realistic model, an 3 accurate model and we will be discussing that at some 4 of the later presentations as to -- to what that is 5 going to take.
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| 6 MR. MELLY: Again, we are going to 7 quickly go over these because we are going be 8 touching on them later -- primarily in the discussion 9 phase. But a lot of the comments that we've 10 received on the initial Phase I of testing was that 11 we -- plants do not see these three-phase faults like 12 we are initiating in the program at KEMA using the 13 IEEE standard wire to initiate the faults. We went 14 back and reviewed the LERs and we do see that while 15 the event may occur phase-to-phase, or phase-to-16 ground initially, that the ones that last for a long 17 period of time quickly progress to a three-phase 18 fault because of the ionization with the cabinet 19 itself.
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| 20 So we do see these three-phase faults 21 occurring in event history, and that's what we're 22 trying to recreate in our test program. Again, the 23 over-pressurization is something we're going to be 24 taking an enhanced look at in the second phase. We 25 did collect pressure information in the first phase NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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| 34 1 of testing. However, there was little that could be 2 drawn from the pressure information that we collected 3 to extend to how it would affect a enclosed room. So 4 that's something we're going to be looking at moving 5 forward because of the Turkey Point event, as well as 6 some events that we've seen internationally where we 7 have breached fire doors. We did see this in 6850, 8 one of the -- I believe it's Event 3 in Appendix M --
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| 9 did breach a fire door. However, there was -- again, 10 no associated enduring fire with that event, so it 11 wasn't a main area of focus.
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| 12 Mr. SALLEY: So, let's talk about how 13 we're going to do this testing. And in this testing, 14 it's quite interesting -- it fits kind of where we 15 are in our money and research. This isn't something 16 that I can take NFPA 2519 and say I am going to test 17 a firewall or an assembly and we have a well-18 established standard on how to do that testing -- for 19 fence seals, fire doors, building construction. For 20 looking at things like the HEAF, we have no standard.
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| 21 So we are kind of venturing off in the unknown here.
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| 22 The closest thing that we could find -- a lot of the 23 work that was done by the IEEE and the NFPA was done 24 for personnel safety. And again, the goals are 25 personnel safety versus reactor safety are somewhat NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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| 35 1 different. And in their test they had to be a little 2 a shorter. Again, they were looking mainly at the 3 things you guys are familiar with -- the PP that the 4 electricians wear when they are servicing the 5 cabinets in the plant. And that's where we've seen 6 all the research. And it's good research. I mean 7 this is a significant hazard. You can see a lot of 8 different numbers out there if you're reading the 9 safety journals where I think there's -- they 10 postulate -- the last journal I looked at, two people 11 a day -- two workers a day in the United States die 12 because of electrocution. So that could be in the 13 plants working, and it also got the guys who are 14 working on the high-tension lines outside.
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| 15 So it's a significant number. It's 16 something that needs research. And that's where the 17 work was done. Of course, with reactor protection, 18 we're looking at something different. We're looking 19 at protecting the plant. We're preserving the 20 diversity and redundant systems. And we have a 21 different problem in the nuclear environment. So we 22 set our tests up a little bit. And again, we're 23 inventing as we go. And we hooked up with our 24 partners in NIST. Tony and Scott are here. They've 25 done a lot of the testing with us as well as the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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| 36 1 expertise from the labs like KEMA to help guide us.
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| 2 And a lot of the things we tried didn't work. And we 3 moved along as we went. We also had Sandia work with 4 us a bit.
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| 5 So here was our basic set up that we came 6 in for the first days of testing. You'll notice the 7 piece of equipment is in the center that we're going 8 to fail in the test. We put up racks and we set the 9 racks up specifically at three foot. Why three feet?
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| 10 Because our model in 6850 says that anything within 11 that three-foot window should be damaged. Anything 12 three-foot-one-inch should be safe. So we set our 13 instrument racks with our slug calorimetry on it to 14 get a measurement at three foot.
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| 15 We also did some things that we thought 16 would be observable. For example, you will notice 17 the cable tray that we set above the top. You know, 18 you can equate this to ASTM E-119, how we used the 19 cotton waste on back of the firewall to make sure 20 that we don't get emission during the test. The same 21 thing here. We says, hey, typically we find that the 22 enclosures -- you'll find cable trays above it. What 23 do you say we put some cables above it and see if we 24 get emissions in the cables. That will give us an 25 indicator of the -- of what's coming off the HEAF.
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| 37 1 One area that we tried real hard was the 2 collection hood. And this is something, again -- us 3 being fire protection engineers, we fall back to what 4 we know. We like to talk in terms of heat release 5 rate to describe the power of a fire. The way we do 6 that is we put the capture hood up. We capture the 7 energy that comes off and we can go and say how big 8 the fire was in terms of it. So we set a portable 9 hood up and we tried to capture that.
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| 10 Final thing we did was a lot of cameras.
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| 11 And we've got a lot of high-speed videos we tried.
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| 12 We've got some infrared stuff that we're working with 13 NIST to -- we'll have a report coming out shortly 14 this year that shows some of the IR work we'd done.
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| 15 And just the regular camera work. And that tended to 16 be some of the most valuable stuff we saw. So again, 17 it was very much of a learning experience for us as 18 to just how do you do this test? So this is a basic 19 setup you're going to see. We're going to run 20 through a number of videos here, and Nick is going to 21 show you what we learned in the first phase of 22 testing.
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| 23 MR. MELLY: I'm trying to get this set 24 back up because we can hardly hear it. Okay, so let 25 me walk you through this before I do show the video.
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| 38 1 As Mark did mention, you see the heat-release rate 2 hood that you have there. You're going to notice 3 from the test immediately that this hood is 4 completely overwhelmed by the amount of smoke that's 5 created initially on the event. So, while the hood 6 was valuable in collecting heat release rate 7 information for the enduring fire, the initial blast 8 -- there's just no way that we can create it at a --
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| 9 a non-fully enclosed laboratory that has a much 10 larger hood.
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| 11 There were also some limitations at the 12 KEMA facility of what we can do. Again, this is open 13 air in -- right outside of Philadelphia in a suburb, 14 and there's a Metro line running directly behind the 15 facility. Whenever we tested, coincidently, the 16 train was always there. We got a lot of calls to the 17 fire department and a lot of shocked people. So this 18 test -- this is test 3, one of the first tests that 19 we ran on a Korean-donated piece of equipment. We 20 initiated the arc in the back of the center cubicle 21 using the three-phase, IEEE guide wire -- it was a 22 10-gauge wire that we used for this test for a low-23 voltage power standard.
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| 39 1 vintage. The insulation material is actually 2 mahogany wood. This thing was battleship grade. So 3 you will see this test was run at 35 kA for eight 4 seconds. This was a low-voltage, 480-volt cabinet.
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| 5 Again, all copper material inside the cabinet. The 6 sound is not coming through quite well. Do we need 7 to do something to get it to come through the room?
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| 8 All right, we'll just role.
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| 9 So you can see it's an impressive looking 10 test. You see the flames and everything shoot out.
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| 11 The arc did hold in for eight seconds, which was a 12 problem for some of the low-voltage cabinets. You 13 see the amount of smoke that's initially created.
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| 14 And you can see the problems that that would case in 15 a switch gear room itself. You're immediately 16 filling the entire volume with smoke. It's very 17 difficult to fight these fires.
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| 18 Again, that is the color of the smoke.
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| 19 It was a dark black smoke with this event. And you 20 will notice the difference when we look at the 21 aluminum. For this event, and other low-voltage 22 cabinets that we saw with copper -- for this specific 23 event we did not breach the cabinet itself, even 24 though the arc was fairly close the exterior barrier.
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| 40 1 damage. Again, this was early on in the test program 2 when we were thinking this is a good sign, we have a 3 very clear way to differentiate low voltage and 4 medium voltage, potentially, moving forward.
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| 5 Moving on you'll see some of the -- this 6 is a German cabinet. We tested 10 kV, 15 kA, three 7 seconds. This was an oil-filled breakers that were 8 donated. We did have to remove the oil for concerns 9 of the explosion associated with vaporizing the oil 10 itself during the event. Again, copper bus bars and 11 we have the cable tray above this cabinet. And the 12 three seconds was very close to the KEMA limit on 13 what their generator can perform for this type of 14 voltage test. There's some wiggle room. We've been 15 talking with them about what we can do. But again, 16 that three seconds is close to what we can do. So 17 when we talked about the operating experience at the 18 Robinson, eight to eleven seconds at this type of 19 voltage level cannot create that at the KEMA 20 facility.
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| 21 (Pause.)
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| 22 MR. MELLY: Again, this test was one of 23 the medium voltage. You see that immediate fire 24 condition. We immediately ignited everything within 25 the cabinet. The cable tray that was above the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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| 41 1 cabinet reached full ignition within 30 seconds after 2 the event. So we had a fully involved fire 30 3 seconds after this event.
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| 4 PARTICIPANT: What was in the cable tray?
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| 5 MR. MELLY: I don't know off the top of 6 my head what type of material. I believe that it was 7 -- is Gabe in the room? I think it was thermo-set 8 cable above the cabinet. But I'd need to confirm 9 that.
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| 10 MR. SALLY: Scott, Tony, you guys know?
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| 11 (Simultaneous speaking.)
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| 12 MR. MELLY: PEPVC.
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| 13 MR. SALLEY: It was some new PEPVC.
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| 14 MR. MELLY: So now we are moving on to 15 some of the later testing. This was the cabinet that 16 had aluminum in it. This was tested 480 volts, 40 kA 17 for seven seconds. We initiated the arc in the 18 center of the cabinet -- right about there. And we 19 did see the arc migrate to the more substantial 20 portion where there was more aluminum. Again, our 21 rack is located right here at three feet.
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| 22 (Pause.)
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| 23 MR. MELLY: So I am going to pause it 24 here, and you can see the color of the smoke is 25 completely different than we saw in the other events.
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| 42 1 After this event itself, you see -- we saw the entire 2 KEMA facility essentially white-washed. We have some 3 picture of moving forward, but there was a lot of 4 damage to the KEMA facility itself, which we 5 apologized for. But we're learning as we move 6 through this.
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| 7 Again, we did see the arc migration, and 8 after the test itself, we saw that we had vaporized 9 a lot of the equipment on the test stand itself. So 10 all of this material over here was completely white-11 washed and it was a little bit of a shock for us in 12 the control room. We were not expecting this type of 13 damage. Like I said, for some of the previous 480s, 14 it was even difficult maintaining the arc itself. We 15 would have extinguishment almost immediately and not 16 be able to maintain it for the full seven seconds.
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| 17 We did not see that with this test. Again, aluminum 18 inside the enclosure, pull up some pictures.
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| 19 MR. SHUDAK: I think after that one, 20 Nick, we had to stop, right? Because the -- the 21 facility was completely coated.
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| 22 MR. MELLY: Yes, we -- you will notice 23 that there is not heat release rate hood. In this 24 next test I will show -- because after that test we 25 had to shut down for a week because we couldn't NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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| 43 1 perform any more testing in that test cell because of 2 the damage that was caused from that event and the 3 aluminum coating all of the --
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| 4 MR. SHUDAK: Yes, we had to basically 5 scrub the cell.
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| 6 MR. MELLY: Yes, and for quite a while it 7 was still -- problems. This is the bus duct test 8 that was designed -- bus that could be pulled out.
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| 9 This had copper conductors, but an aluminum enclosure 10 -- which we did not realize before we ran the test as 11 an important factor knowing. We squeezed this in 12 with some of the Japanese test program that occurring 13 at the time. We didn't have the hood. We thought, 14 copper material -- this shouldn't be a big deal for 15 testing for a short duration. We thought we knew 16 what was going to occur for the test. This was 17 again, 4160, 26 kA for three-and-a-half seconds.
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| 18 (Pause.)
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| 19 MR. MELLY: And again, we saw that white 20 smoke. It's difficult to explain the violence of 21 this event. People in the control room were running 22 away from the viewing screen during this event 23 because it was so explosive -- an interesting event.
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| 24 We weren't prepared for that at the time. And that's 25 really -
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| 44 1 (Simultaneous speaking.)
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| 2 MR. CIELO: DEP showed up an hour later.
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| 3 MR. MELLY: What?
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| 4 MR. CIELO: The Pennsylvania DEP showed 5 up an hour later.
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| 6 MR. MELLY: Yes, they did. There was a 7 lot of smoke involved with this event. So this is 8 kind of what led us to kick off the Generic Issues 9 Program is that we'd -- we've ran two tests. The 10 only two tests that we ran with aluminum during this 11 test series showed the extreme difference from the 12 ones that we ran with copper -- much larger damage 13 zone, much -- there were many more consequences at 14 the facility itself with coating material, damaging 15 cables further away and a major disparity.
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| 16 MR. SALLEY: And again, with the 17 aluminum, that -- that's what we're kind of seeing 18 here. We really have two data points. We did have 19 some aluminum in some of the early tests with -- like 20 tests 4, 5 and 6, which were very well separated 21 buses. And we didn't see that. As a matter of fact, 22 we had trouble trying to hold an arc in. So there's 23 a lot here that we need to learn as to where the 24 hazard exists. So just because something is 25 aluminum, doesn't immediately mean failure. But NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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| 45 1 based on these two data points, we've seen something 2 here that clearly warrants additional resource --
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| 3 research, excuse me.
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| 4 MR. MELLY: So again, what we saw was 5 that there's potentially much larger zone of 6 influence associated with events with aluminum. Here 7 you can see, of course, the amount that was in the 8 cabinet that was from the two tests. And the top 9 pictures are from the test 23, the low-volt cabinet, 10 and the bottom are the bottom are the bus ducts, 11 higher risk of propagation and potentially the 12 greater likelihood of maintaining the arc at lower 13 voltages. Again, there's a potential new failure 14 mode that's associated with the conducting material 15 release during the event itself. You can see the 16 white-washing effect that I saw -- that I was talking 17 about earlier. The entire facility was coated in 18 this white material. We will be taking efforts to --
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| 19 to analyze that material in future testing. We also 20 have NIST as well as Sandia looking into methods for 21 evaluating products --
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| 22 MR. SALLEY: And again, that's another 23 reason for us to put this into the Generic Issue 24 Program because we potentially are identifying a new 25 failure mechanism. Okay? Where the material is --
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| 46 1 if it's conducted in the aluminum form -- you can 2 envision in your mind micro switches and such that 3 would be shorting out due to that. Or, if it's 4 aluminum oxide, it would be an insulator that would 5 be insulating the conduct. So again, that's another 6 reason we want to put this into the Generic Issue 7 Program and get a better understanding.
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| 8 MR. MELLY: Yes, and if you can see this 9 panel here that's on the wall that's slightly at an 10 off angle, we did melt the hinges off that panel that 11 was 26 feet away from the bus duct itself. And this 12 bus -- or, you see this ventilation fan which was 13 newly installed for our testing. You can see the 14 color variation from the event itself. That one 15 still is white and despite the cleaning efforts.
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| 16 MR. SALLEY: So, you can think back to 17 those earlier pictures we showed -- especially of the 18 bus duct. And you can see that the operating 19 experience with that bus duct, the damage was much 20 greater than we could reproduce in the laboratory.
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| 21 So just looking at what we did in this video with the 22 test, you can envision what this -- this looked like 23 in the plants. And again, you know, as we learn 24 things from the research and the testing, it helps us 25 better understand what the plants were dealing with.
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| 47 1 Reading their LERs they'll talk about conductive 2 smoke, okay? And now we kind of get an idea, okay, 3 what that conductive smoke was and why it was doing 4 what it did. So again, we gained that from the 5 research.
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| 6 So with all this material, what do we do 7 with it? Again, working with our international 8 partners, we took all the tests, we brought them 9 forward -- worked very closely with NIST and KEMA and 10 we published this report, which you can download 11 here. One of the things I wanted to have for you 12 today was the DVD with all this stuff on it. And we 13 have a lot more test video that we made public. But 14 we had a problem with RIFO (phonetic) and we'll see 15 if we can get that taken care of here and get those 16 redone and I will give you those videos. Anybody on 17 the webinar, just send your mailing address to Tom 18 and we'll be happy to mail it. Like I said, we made 19 that all public. So anyhow, the report is published 20 and this is our Phase I results of the research we've 21 done to date.
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| 22 MR. MELLY: Moving forward, some of the 23 things that we've talked about was that this is a 24 one-size-fits-all model that's in Appendix M and 25 there's difficulty dealing with it. There has been NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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| 48 1 some postulation of mitigating these events with what 2 are called HEAF shields, referred to in some 3 applications for the transition to NFPA 805, which is 4 proposed shielding to limit the damage from a HEAF 5 event.
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| 6 Typically what we've seen is postulated 7 metal barrier installed above an electrical cabinet 8 to protect the cable trays that are above, usually 9 leaving the -- or, driving the risk calculation of 10 the CCPD. Some of the questions that have arisen 11 during this testing is, what's needed to make those 12 HEAF shields successful? What's design basis, 13 acceptance ratings? The typical things that would be 14 associated with ensuring that these can work the way 15 that they're designed.
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| 16 MR. SALLEY: And again, I think we've --
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| 17 lessons learned from things like thermal lag and 18 penetration seals that you've got to have a clear, 19 you know, test standard and acceptance if you're 20 going, you know, credit this equipment. So again, 21 that piece needs to be developed here and it's just 22 something we want to flag that we've learned from 23 operating experience.
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| 24 MR. MELLY: And what we've seen through 25 testing is that potentially a metal barrier may not NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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| 49 1 be the most effective at limiting these events 2 because you, again, can breach that metal barrier 3 directly with the products of the arc itself, or lead 4 another part to anchor on that barrier itself.
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| 5 MR. SALLEY: And this next slide is to 6 why we get to the testing, which Nick is going to 7 describe to you here that, you know, as engineers we 8 can sit down and think things through and say, okay, 9 hey a solid top is going to stop it, or we're going 10 to have this nice laminar flow-off event for the 11 cabinet. And as engineers, we want to think that way 12 and postulate that. But when we run the experiments, 13 we see something different. Rich, Nick?
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| 14 MR. MELLY: Yes. So that gets to another 15 effect that we've seen in some applications that we'd 16 -- a louvered design cabinet will direct the flow of 17 energy away from the cables that are above. Or, a 18 solid top will always stop the event from damaging 19 cables because the cabinet itself is serving as a 20 barrier. What we see from this test is that once the 21 event occurs, we can breach directly through the 22 louvers like they're not even there. And can breach 23 the cabinet top. In the event that we see here, this 24 was test 11, when we do the videos -- where the arc 25 is generally directed upward, or follows the magnetic NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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| 50 1 path of the event itself -- the power direction --
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| 2 and in this event a bend occurred there and directed 3 all the energy upwards. We actually lifted the cable 4 tray which we, at this point, had not bolted down --
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| 5 lifted it, moved it and knocked all the cables out of 6 the tray during that event. But we see that these 7 are things we need to think about that general 8 engineering judgment typically is not always correct 9 when dealing with something as energetic as this 10 event.
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| 11 So we discussed a little bit about the 12 Generic Issue. We are going to have two 13 presentations on that moving forward. It's 14 specifically focused in on the enhanced damage states 15 potential from the aluminum. And we are going to 16 discuss how we want to move that forward using a two-17 phase approach, short-term actions and long-term 18 actions, as well as trying to get some feedback on 19 how to tackle this problem. So I am not going to 20 touch on it much here today because we have a few 21 presentations later today that will go over the whole 22 framework as well as how we want to move forward with 23 our fire protection program.
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| 24 MR. SALLEY: So as a regulator, if 25 there's one thing we've learned Three Mile Island, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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| 51 1 it's the importance of communication and how we have 2 to communicate what we have and get it out into the 3 public. As Nick and I sat down and started looking 4 at this, and the work with the internationals and 5 going back in time and pulling all the different LERs 6 that were coming out of the plants, basically, for 7 us, it was almost a connect-the-dots exercise. And 8 that's kind of how I refer to looking at that OpE.
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| 9 So again, going through that OpE, we see a number of 10 these events. And we thought it was important that, 11 if we're seeing a trend here, that we communicate 12 that.
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| 13 So the whole purpose of this information, 14 though is, with the aluminum HEAFs, was that we get 15 this together. This is what we're seeing and do we 16 have a trend here? And this is why we need to move 17 forward looking at this form of research. So again, 18 the whole purpose of that information was -- as you 19 know, there's no actions required by that information 20 notice -- but it was to communicate to the larger 21 nuclear community of what we're potentially seeing 22 here as a trend. Again, that was obviously last year 23 we issued that.
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| 52 1 events. And we are all reading the LERs and the CRs, 2 you see them scratching their heads during the root 3 cause as to why was this as damaging as it was? Why 4 did we see more damage than we would expect? And 5 what is this white material that's coating everything 6 in the room? There's also postulation as to where 7 did the -- were the bus ducts themselves -- were the 8 conductors thrown? Where did they go? So you see a 9 lot of questions being raised in the root cause, and 10 looking at the full picture, we wanted to communicate 11 that effect.
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| 12 MR. SALLEY: So, moving forward in the 13 processes that we work, one of the tools we use for 14 expert elicitations is a thing is a thing called a 15 PIRT. A PIRT is a phenomena identification and 16 ranking table. And again, it's to look at something 17 like this in an expert elicitation and try to rank 18 the different things -- the different phenomena that 19 we're involved with. Kenny Hamburger, one of our 20 young engineers, ran this and what we did was we 21 brought all the international partners in, we spent 22 a week here. KEMA was with us, NIST, over in the 23 ACLS hearing rooms, and we had this discussion. From 24 that we documented the report. You can take a look 25 here. And again, the whole purpose of this was to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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| 53 1 start giving us a roadmap and to start guiding us 2 forward into the next areas of research and what we 3 needed to do. So again, that's a somewhat unique 4 process that we use in the nuclear industry and 5 moving forward with the expert elicitation.
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| 6 Another important piece that we've got is 7 Japan. Japan has been a very powerful partner with 8 us. Steve Turner who is here, he has worked a lot 9 consulting with the Japanese. They have gone through 10 some regulatory changes here, post-Fukushima, as you 11 can well imagine. I know Dan, Dan Funk is here. He 12 has spent a lot of time over there working with them.
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| 13 But they have a whole HEAF program that they are 14 trying to really understand what happened in Onagawa.
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| 15 And they've been very gracious with us in inviting us 16 to come to KEMA with them, stick some additional 17 instruments in, get the data and learn from what 18 they're doing. Of course, the work is done and it's 19 in Japanese, which doesn't buy us much. But we do 20 have a vehicle, and it's a NUREG/IA through our MOU 21 with Japan. We're able to take this, write the 22 reports with them -- again, put it in English and 23 then put it out as publically available in the open 24 literature. So again, we can learn from the work 25 we're doing. And like I said, Japan has been a very, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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| 54 1 very gracious partner to work with on this one.
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| 2 MR. MELLY: Yes, their initial insights 3 moving forward is they're going to be handling this 4 in Japan in a regulatory aspect requiring plant 5 changes to protection schemes rather than 6 understanding the PRA -- or, rather than focusing on 7 the PRA impact and dealing with it in a PRA 8 terminology.
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| 9 MR. SALLEY: Again, so they're going to 10 work it out in their nuclear environment and they're 11 looking real heavy at the prevention piece, like we 12 showed earlier in the defense-in-depth approach.
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| 13 So the next thing is, we went to the next 14 phase and getting close to where we're at right here 15 today. The test plan -- we put the test plan out for 16 public comment. You can see we got quite a bit of 17 comment on it and tomorrow Dave and Nick are going to 18 have a lot of discussion, but we want to understand 19 the comments and we want to understand the best way 20 for us to move forward. You can see we had 64 21 comments received through the public process. EPRI 22 liked it so much, it commented twice. So, thank you, 23 Ashley. And we've also got some small-scale testing 24 that we've come up with. And again, we're getting 25 some comments on that. I know we've extended the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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| 55 1 period of comment a little bit here for additional 2 comments. And again, we want to get involvement and 3 we want to get input and we want to move forward that 4 way.
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| 5 MR. MELLY: And again, we have updated 6 the test plan that was first put out on June 30th, it 7 has been made available for this public workshop. I 8 believe it's -- the ML was put on the website 9 associated with this workshop, and it will be updated 10 again based on feedback from this workshop. So it's 11 an iterative process that we're working on. We want 12 to make sure that we have the parameters dialed in 13 that we need to test, and this is -- the primary goal 14 of this workshop is to have the discussion on the 15 current duration and things that we're going to be 16 testing so we can update this test plan.
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| 17 MR. SALLEY: So, in conclusion -- and 18 whoa, we're just right on time. That was purely by 19 accident. In conclusion, this is where we're at 20 today. We've seen things and again, with research 21 like this, sometimes you're -- you're on a path and 22 you have to realize maybe you need to change the path 23 a little bit. That's one of the things we're 24 thinking. And again, it's so important, our 25 discussions we've had, the webinars with the NFPA, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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| 56 1 that we just don't jump -- everything becomes a heap 2 and it becomes that worst case.
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| 3 We are going to change direction a little 4 bit and Kenn Miller is going to have a good 5 discussion hopefully this afternoon on how we want to 6 do this. And also, we want to stay in process and 7 make sure we do this in a very methodical manner, 8 which is going to be the driver of the Generic Issue 9 Program. So with this document, it kind of -- like 10 I said, use it as a Reader's Digest version of where 11 we're at. And it's also got all our references in 12 there that if you want to take a look at some 13 particular issue, you can go through the ML number or 14 the link. So, if anyone has any questions? If we 15 don't have any questions, it will be time for a 16 break. Then we can pick it back up. Any questions?
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| 17 Comments? Concerns? Complaints?
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| 18 MR. MELLY: And again, this is -- we're 19 kind of just -- everything has come at you, a lot of 20 information here on what we did. Tomorrow, when we 21 go over the comments as well as some of the 22 information that Gabe put out for testing information 23 and things of how we're going to be testing, it is 24 going to be much more of a discussion format where we 25 really would like input moving forward.
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| 57 1 MR. SALLEY: Any questions on the 2 webinar, Tom?
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| 3 MR. AIRD: No.
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| 4 MR. SALLEY: No questions, so with that 5 --
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| 6 MR. TURNER: I have a question. On the 7 bus duct test, did we actually check if the white 8 stuff was conductive? You say in your slide ---
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| 9 (Simultaneous speaking.)
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| 10 MR. MELLY: We did not material testing 11 afterwards or collect the particulate from the test.
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| 12 The indication came from the KEMA facility ---
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| 13 (Simultaneous speaking.)
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| 14 MR. CIELO: Yes, we didn't do any -- any 15 material testing either, Steve, we just ---
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| 16 MR. MELLY: It is being done during the 17 small-scale testing, as well as -- we're going to be 18 doing it across --
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| 19 MR. SALLEY: Yes, Gabe is going to have 20 a good thing. And that's something Sandia can look 21 at -- and it's really going to be fascinating what 22 you see when they start looking at it at the 23 microscopic level. And Gabe is going to get into 24 that in his presentation on small scale.
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| 58 1 leveraging Jose Torero from the University of 2 Maryland to try and look at the potential for 3 creating a model of the conductivity versus distance 4 of the cloud -- mix up. Anything else?
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| 5 (No audible response.)
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| 6 MR. MELLY: Take a fifteen-minute break 7 and I guess we'll see on the schedule. Be back in 8 here at 11:00.
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| 9 (Whereupon, the above-entitled matter 10 went off the record at 9:47 a.m. and resumed at 10:12 11 a.m.)
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| 12 MR. GARDOCKI: Well good morning. I'm 13 Stanley Gardocki. I'm one of the program managers for 14 the Generic Issues Program at the NRC. I've been in 15 the program for about two or three years now. I want 16 to give you a quick, high-level viewpoint of the 17 Generic Issues Program on this presentation. And then 18 the next presentation will go into a little bit of 19 specifics on this individual generic issue.
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| 20 All right, next slide.
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| 21 The purpose of the Generic Issue Program, 22 it was started a long time ago by Congress, mandating 23 the NRC to come up with a program to evaluate issues, 24 as they come in, for generic implications across the 25 board of problems. We've been doing it a long time NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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| 59 1 and we've gotten pretty good at it and we've got a 2 good process down.
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| 3 I would say the Generic Issues Program 4 itself, right now, is designed to take an issue, 5 screen it, assess it to see if it's significant enough 6 for the NRC and industry to spend money and time to 7 put it in what we call the last phase, the Regulatory 8 Office participation stage.
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| 9 Right on time. We're way ahead of it.
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| 10 You walked in -- perfect timing.
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| 11 This is our supervisor of the Generic 12 Issues Program, Tom Boyce. So he is responsible for 13 the program and the branch chief.
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| 14 MR. SALLEY: Tom, we got a little bit 15 ahead of schedule. So I apologize for that and you're 16 up.
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| 17 MR. BOYCE: Well, thanks. If I had waited 18 a longer, I could have had Stan do the whole thing.
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| 19 Unfortunately, I called him.
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| 20 Well good morning. I'm Tom Boyce. I'm a 21 branch chief in Research. My branch does regulatory 22 guidance on generic issues.
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| 23 The project managers, that's our core 24 capability. I don't know whether I should be sitting 25 down or standing up but you've already done the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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| 60 1 intros.
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| 2 MR. TAYLOR: I think if you move away from 3 the SharePoint and put a mike on.
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| 4 (Simultaneous speaking.)
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| 5 MR. BOYCE: Well all right, so we're on, 6 I guess. Can you go to the first -- maybe this is the 7 first slide.
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| 8 MR. TAYLOR: That's the first slide.
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| 9 MR. BOYCE: All right, let's see.
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| 10 Fundamentals -- sorry. It'll take me a second to get 11 caught up with you guys.
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| 12 All right, well this is what we're going 13 to cover here in a little bit. We are going to cover 14 fundamentals and you'll see that on the next couple of 15 slides. Then we're going to look at the screening 16 criteria for proposed generic issues, and then we'll 17 look at some of the documentation that will come out 18 of the program.
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| 19 This is really a process discussion. It's 20 to tell you where the HEAF with aluminum issue is in 21 the process. I'll try and field questions, process-22 type questions. If you want to ask me something 23 technical, I'll definitely defer to my colleagues.
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| 24 So the Generic Issues Program has been 25 around at the NRC for a long, long time. It NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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| 61 1 originally came from when we were licensing a lot of 2 nuclear power plants in the '70s. And what would 3 happen is is that we'd be going through the licensing 4 process and issues would come up, a variety of issues, 5 because it's the first time we've really done such 6 large-scale development of nuclear power in the U.S.
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| 7 And as a way to manage these issues that 8 came up, the licensing process moved forward. Plants 9 were being built and the issues were put, I'm going to 10 call it a parking lot but they were put into the 11 Generic Issues Program so that they could be worked 12 aggressively. And as solutions developed over time, 13 they would be I'll call it backfitted onto the current 14 generation of plants in whatever stage of construction 15 that they were in. So, that's the origin of the 16 program.
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| 17 There's been -- I may be getting ahead of 18 myself -- maybe close to a thousand generic issues 19 over the three decades that we've been running this 20 program. We're down to a handful, which is an 21 indicator of the maturity of the industry, as well as 22 I would give credit to the NRC staff, the 23 aggressiveness of us trying to work the issues off.
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| 24 Okay, so there's now three stages of the 25 Generic Issues Program. The first stage is a NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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| 62 1 screening stage. In general terms when we get an 2 issue, what we're trying to do is validate that the 3 issues is worthwhile spending resources on. We'll 4 make a determination whether it's an allegation and we 5 need to deal with it in allegation space, or make sure 6 that it's got some kind of connection to safety. It's 7 not a very high-level comment like NRC should license 8 plants faster. That would be something that we would 9 screen out. We're looking for more technical content.
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| 10 And we'd be trying to make an early 11 determination of the risk significance. Like a meteor 12 strike would have high consequences but would have a 13 low initiating event frequency. So that would 14 probably screen out a meteor strike. I'm just trying 15 to set the stage.
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| 16 All right, once it passes the screening 17 stage and we say this has got sufficient risk/safety 18 significance, now we need actually to do some work to 19 develop the issue. What does it really mean?
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| 20 Technically, what is the phenomenon that we need to be 21 concerned about? What are the systems that are in 22 place to address the issue? What are the potential 23 consequences? And what is the -- what are the 24 potential ways that we could take regulatory action?
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| 25 Backfitting is not the ultimate answer. There's a NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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| 63 1 variety of ways that we can address the issue, perhaps 2 working with industry.
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| 3 Implementation, that's where we've 4 actually decided okay, after all this development 5 work, we've decided this issue actually does need to 6 be addressed in some way. And so examples of 7 regulatory actions may be as simple as an information 8 notice.
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| 9 For example, there was an information 10 notice that we issued about a year ago, I think, where 11 we identified the HEAF with aluminum issue to 12 industry. It may be, after all development work, that 13 an IN or nothing is the answer. It could be a generic 14 letter. It could be a plant-specific order, or even 15 some kind of generic order across industry. It really 16 depends on what comes out of the assessment stage.
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| 17 So here are some of the roles and 18 responsibilities. First of all, the Director of the 19 Office of Research, who is Mike Weber, provides 20 overall strategic direction for the program and 21 overall management. The Generic Issues Program 22 Manager is myself. And the responsible Project 23 Manager is, in this case, Stan Gardocki.
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| 64 1 issues. Stan, to his credit, has worked off the 2 backlog. So he's an army of one at the moment. I do 3 have capability of hiring more, if we get more issues.
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| 4 Okay, so how does this process really 5 work? It's not just up to Stan and me to say here's 6 the risk significance. We actually need to bring in 7 people that are more expert. So we bring in a variety 8 of different people and we call the panel that is 9 formed a Generic Issues Review Panel. It's got this 10 acronym called a GIRP. We might have done better if 11 we had thought about it but GIRP is what we came up 12 with.
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| 13 So the purpose is really to bring the 14 resources to bear on the problem. In Research, we can 15 research an issue to death but that isn't really the 16 goal of this project. The whole point is to bring in 17 regulators, technical people, and bring the issue to 18 a state of maturity that we need to take regulatory 19 action. It's not a long-term research project. So 20 we're actually trying to drive resources to a decision 21 here.
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| 22 So the GIRP panel includes people from 23 across the Regulatory Offices and Research but they 24 aren't necessarily the people who are doing the day to 25 day work in the assessment stage. They will meet NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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| 65 1 periodically and provide direction, say what are we 2 missing, but there is a core group of people that are 3 actually doing the work who are the experts. I think 4 it's going to be Nick or maybe some other people that 5 are on the Assessment Team. These are the people who 6 are actually developing the information and will be 7 providing it to the GIRP for more robust 8 consideration. More robust, in this case, might be a 9 more robust risk analysis, for example, that the GIRP 10 would bring to bear.
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| 11 If we get to the end of the assessment 12 stage and the decision is made to take some kind of 13 regulatory action, the GIRP just doesn't provide a 14 report and throw it over the fence to, in this case, 15 NRR probably, we actually expand the GIRP and form a 16 transition team so we don't lose knowledge as we shift 17 over into the regulatory arena.
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| 18 So basically, the core group of people who 19 are involved in the assessment stage will form a 20 transition team and then we'd say okay, NRR, you take 21 the lead. The Generic Issues Program doesn't have the 22 lead anymore because we are in the Regulatory Office 23 implementation. And they're into more understood 24 processes between the utilities and NRR as far as 25 actual regulation.
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| 66 1 Next slide.
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| 2 So everything I just said we tried to 3 capture in one slide. It's a little bit of an eye 4 chart but this is what we think is -- if we have to, 5 we can talk from one slide.
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| 6 So if I work from the top, the three 7 stages that I just talked about are on the top line.
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| 8 The organizations that are responsible are on the 9 second line. And you can see that in the proposed GI, 10 that's a terminology issue, in the proposed GI, and 11 this is a proposed GI right now, that stays a proposed 12 GI through the screening and the assessment stage if 13 we decide to take regulatory action. Then it becomes 14 officially a generic issue. Okay? That's just how --
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| 15 our parlance that we use.
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| 16 The next level down is who are the 17 decision-makers at each stage, try and identify that 18 so it's clear who is doing what.
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| 19 And then the next stage down is who is 20 actually doing the work. Okay? So hopefully, it's 21 clear, based on what I had said previously.
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| 22 Now the next level down, it gets a little 23 more detailed and we try and outline what are the 24 specific deliverables that are coming out of each 25 decision point.
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| 67 1 I may end up needing to walk around. Can 2 I just pick this up and hold it for a minute?
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| 3 So this right here below the colored 4 blocks, for those who are on the bridge, is the 5 milestone documentation. And you'll notice that it 6 says it's publicly available. And I'm pointing that 7 out because the question comes up are we going to see 8 it and the answer is yes. Okay, we tried to make the 9 process as transparent as possible.
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| 10 So we get a proposed GI. We put that in 11 ADAMS and make it publicly available. And by the way, 12 this is all up on the website, also. I'll get to that 13 in a second.
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| 14 Then there's a memo from the GI Program 15 Manager, saying hey, we're starting the initial review 16 and oh, by the way, we need resources to form this 17 Generic Issues Review Panel so please identify 18 resources.
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| 19 The formality of the process actually 20 ensures that we get the resources from the Regulatory 21 Offices to work on it because they are very busy 22 taking care of operational issues at the moment.
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| 23 And then we, at the end of the screening 24 stage, there's a memo from the GRIP panel to the 25 Director of Research saying this is what we found and NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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| 68 1 we recommend either discontinuing further work on this 2 issue or continuation into the assessment stage. That 3 has been issued. So you are about right here in the 4 process, meaning just past that third arrow down, 5 again, for those on the bridge.
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| 6 When we get to the assessment stage, the 7 documentation gets a little more robust because we're 8 heading into the potential to take regulatory action.
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| 9 So here's a -- we have a summary memo and here's the 10 more specifics of what you might see in that memo.
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| 11 One of the critical things is -- well 12 first of all, you've got to have enough technical 13 information to support any kind of regulatory action 14 but one of the things that we identify here is 15 something called a limited regulatory analysis. And 16 what that really is is a discussion of various options 17 for regulatory actions. Should we do an IN? Is that 18 sufficient? Should we do an order? Should we do a 19 generic letter? What is the form of regulatory action 20 we're talking about? Maybe it's simply inspections.
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| 21 Maybe NEI might have stepped up to the plate and said 22 we would like to do some various things and maybe run 23 a pilot. Those are the types of pros and cons that 24 would be in a limited regulatory analysis. Okay?
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| 69 1 in the Regulatory Office implementation stage, this is 2 where they finally the Regulatory Office says okay, we 3 understand this issue. Thank you, Transition Team, 4 we're taking the regulatory action and we're moving 5 forward with it. Okay, that's where -- that's this 6 far right arrow.
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| 7 So coming down here, the bottom line says 8 stakeholder engagement. Where can stakeholders 9 provide input? Well first of all, I think this 10 workshop is one of the primary means of providing 11 input. So I haven't been around but I hope you're 12 providing your opinions and insights along the way.
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| 13 So here, public proposes a GI. The ACRS 14 has an opportunity to engage right here. The ACRS has 15 not indicated that wanted to engage just yet. I would 16 expect them, at some point, to engage.
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| 17 They have another opportunity at the end 18 of the assessment stage. This is probably more likely 19 before we actually get into Regulatory Office 20 implementation.
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| 21 And then here, before we take regulatory 22 action, our typical practice is to hold public 23 meetings and talk about it. In the case of generic 24 communications, we have in the past but not 25 necessarily required issue draft generic NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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| 70 1 communications and invited public comment. So those 2 are the types of opportunities for public engagement.
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| 3 And this is just in our formal process.
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| 4 I think Mark and his team may provide other 5 opportunities, such as this workshop, to provide 6 additional opportunities to engage beyond just what 7 the GI Program is offering here as our standard 8 approach.
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| 9 Yes?
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| 10 MS. WETZEL: Will the limited regulatory 11 analysis go out for public comment?
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| 12 MR. BOYCE: So the question is would the 13 limited regulatory analysis go out for public comment.
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| 14 And it wouldn't be public comment, per se. This memo 15 would be made publicly available right here but it 16 wouldn't be out for public comment, per se. And I 17 would envision it just to be a pro-con type argument.
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| 18 So the extension of your question then is 19 okay, when do we get to engage. And I would say that, 20 although it's not shown on this chart, the transition 21 team, when we get to the Regulatory Office, would 22 decide how much input they want into that regulatory 23 decisionmaking.
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| 71 1 not rulemaking. An Advanced Notice of Proposed 2 Rulemaking lays out concepts and invites comments.
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| 3 That's one path the Regulatory Offices could take.
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| 4 I would expect that they would actually 5 say this is the path we're choosing, here is our draft 6 whatever, and put the draft whatever out for public 7 comment. But I'm actually projecting what the 8 regulatory offices might do and they might choose a 9 different path.
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| 10 So I hate to be fuzzy. We just, 11 everything seems to have a unique nature.
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| 12 Other questions?
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| 13 Okay, next slide and I'll stay standing.
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| 14 So here are the criteria that the Program 15 uses. And this is really our screening criteria. If 16 an issue doesn't meet these criteria, we will actually 17 take it out of the Program. And so if we take it out 18 of the Program, there is a question about where it 19 goes but it generally would go into additional 20 research until it's ready for primetime if it warrants 21 it.
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| 22 But to continue on in the Program, it's 23 got to meet these criteria at each of the stages and 24 I will try to go over them briefly.
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| 25 First of all, the issue affects public NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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| 72 1 health and safety. So the example I give is when 2 somebody says go faster in licensing. Okay, good 3 comment. Doesn't meet the first criteria. We would 4 not take that comment and pursue it in the GI Program.
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| 5 The second issue, it applies to two or 6 more facilities. A lot of times somebody says I found 7 a problem at Plant A and I think it applies to Plants 8 B and C. Well, maybe, maybe not.
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| 9 But if we can establish that it applies to 10 Plants B and C, actually just B, now we have a generic 11 issue. So it's two or more plants, okay? It's not a 12 plant-specific issue is the point.
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| 13 Number three, the issue is not being 14 addressed using other regulatory programs. So this 15 issue isn't being addressed in any formal regulatory 16 manner right now. That's why it meets this criteria.
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| 17 If NRR, and I'm picking on NRR, had said I want to 18 move forward and do something, then we would say NRR 19 is doing something and it would not stay in the GI 20 Program because the Regulatory Office has assumed 21 dynamic control of the regulatory action associated 22 with it.
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| 23 The issue can be resolved by a new or 24 revised regulation. It's not enough that we study it.
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| 73 1 else it belongs in some other process. We don't want 2 to just study something to death. We want to focus 3 resources and arrive at a conclusion.
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| 4 The issues of safety significance can be 5 adequately determined. I don't know if this is the 6 best example but I used the meteor strike as the 7 example. Can we really assess the risk and safety 8 significance of a meteor strike? We can come up with 9 these qualitative estimates and maybe even put numbers 10 on them but it's probably not something that I would 11 say would meet this criteria right here. We're 12 looking for something more tangible. I could probably 13 do a better example, if I had more time.
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| 14 Then the issues is well-defined, discrete, 15 and technical. Again, people tend to broad-brush 16 topics but if it can't be brought down to something 17 that is researchable and tangible, we would say okay, 18 this is interesting academically. It belongs in an 19 academic argument. When it's ready for prime time and 20 we can talk about nuts and bolts, then it meets the 21 criteria for the program.
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| 22 Okay and then number seven is can we 23 actually do something with it. Again, that's the 24 specificity. Do we have enough of a nugget of 25 technical information that we can actually research?
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| 74 1 In the case of Al HEAF, I think Stan is going to talk 2 about some of the long-term, short-term test programs.
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| 3 And we think it can clearly meet number seven.
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| 4 Now going up to the next level up, the big 5 picture. Why did we put these screening criteria in?
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| 6 Well, like I said there were about a thousand issues 7 in the Program and what happened is is that early on 8 we needed to get on with the business of licensing 9 plants and we were learning. So a lot of issues were 10 dumped into the GI Program.
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| 11 And the problem is is that everyone felt 12 good because it was in a process but no one devoted 13 sufficient resources to bring in the issues to 14 resolution quickly. So then the problem became we had 15 issues that were just stuck in the program and not 16 moving forward and we realized that we weren't able to 17 apply enough resources and these were the types of 18 reasons why they were not coming to fruition.
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| 19 So we took these screening criteria in 20 place to avoid the situation where somebody dumps an 21 issue into the program and doesn't address it 22 themselves. Like if an inspector in the field has an 23 issue, if a member of the public has an issue, there 24 are ways that need to be -- that should address it.
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| 75 1 everything. It's intended to be just those issues 2 that merit doing research and working on.
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| 3 Next slide.
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| 4 Okay, the repository of knowledge for this 5 approximately thousand issues is in NUREG-0933. It's 6 available on the web. We do periodic updates of it as 7 we -- as issues are brought to maturity. We document 8 what we did as an agency here. So, I don't know, 9 Stan, you might be getting more into this in your 10 presentation. But this is available up on the web.
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| 11 Okay, so if at any time you wanted to see some 12 examples of what we've done in the program, here it 13 is. Provide suggestions, anything like that. We'd 14 definitely like to get better.
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| 15 Next slide.
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| 16 This tells you -- this is also on the web.
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| 17 It's a nice presentation. It's got some visuals.
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| 18 These needles move like a speedometer when you 19 actually bring the page up. They kind of go over to 20 the far side, come back. It looks really cool. Works 21 like you're starting the engine. So we like it.
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| 22 But the main point is is it tells you 23 about where you are in the process, and the process 24 being we've taken regulatory action. How many plants 25 have actually implemented changes to their plants? So NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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| 76 1 that's what the big needles are for.
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| 2 So GI-191 has been around for a while.
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| 3 And if you look visually, we're a little over halfway 4 at trying to implement changes at all the plants.
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| 5 Now, there's a lot of plants that are 6 affected by GI-191. So this is a nice high-level look 7 but usually not actionable. So if you click on these 8 details -- we're actually doing a demo. That's great.
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| 9 If you click on details, you get a 10 description of the program. For those on the bridge, 11 we're at the bottom of one of the dials. There's a 12 word called details and that's where we are. And what 13 it gets into is a description of the issue, a 14 description of the status at the end of the high 15 level.
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| 16 And then somewhere down here, if you pull 17 down, there should be individual plants that are 18 affected. And then keep coming down. And then 19 there's milestones.
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| 20 There's plants. You can pick each plant 21 and you can say what's the status of each plant. Now, 22 I'm further down the road than the Al HEAF issue at 23 the moment. Okay? Let's assume that something needs 24 to happen on the plants. This is where you'd find out 25 what's the status of each plant.
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| 77 1 And then there's another section on 2 milestones. And the milestones would say okay, for 3 this group of BWRs, it doesn't apply to GI-191, but in 4 this group of BWRs, they're expected to submit their 5 initial response to the NRC by spring of 2019. And 6 I'm totally making this up.
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| 7 The next stage would be GE completes a 8 study of the generic effects and issues topical 9 report, fall of 2019. The plants take action based on 10 topical report 2020. That's the kind of thing you'd 11 see in the plans of actions and milestones.
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| 12 Anything else you think I ought to point 13 out, Stan?
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| 14 Okay, so if you have questions on this, I 15 love it, Stan the Man, he's the guy to talk to. Stan 16 worked with our office as Chief Information Officer to 17 develop this. And so there's an awful lot of 18 information here. We're trying to be as transparent 19 as possible. If there's information that's not here, 20 again, please ask u.
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| 21 MR. MELLY: Again, for those on the phone, 22 this is the Generic Issues dashboard on the NRC public 23 website.
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| 24 MR. BOYCE: Thank you. Next slide.
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| 78 1 recent proposed generic issues. If you remember the 2 process slide I put up before, proposed generic issues 3 are not issues that have transitioned over to 4 Regulatory Office implementation.
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| 5 So if you look, there's 20 proposed 6 generic issues. The one in bold -- the ones in bold 7 are the ones that are still open. Okay? So many of 8 these actually did not make it past assessment into 9 Regulatory Office implementation, for various reasons.
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| 10 The documentation of the staff's assessment of the 11 issues is also available publicly. Okay?
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| 12 Can you get to it on the dashboard, Stan?
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| 13 I don't think --
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| 14 MR. GARDOCKI: Publicly, no.
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| 15 MR. BOYCE: Publicly, no. So if you want 16 to know anything about these, they are publicly 17 available and we can certainly get you the 18 information. But the message out of this slide is is 19 that actually the majority of the issues actually 20 screen out and don't make it into Regulatory Office 21 action. Okay?
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| 22 Next slide.
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| 23 So, if you ever want to know more, I 24 didn't tell you everything that you needed to know 25 today, we have some references. These are also NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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| 79 1 publicly available. We have the ADAMS ML number.
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| 2 They are available in the NRC Library under document 3 collections. I find that a little easier to find than 4 the ML number. We have a Research Office instruction 5 that provides the next level of detail down in the 6 program. And it's also got that one-pager chart, 7 which I find useful.
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| 8 Just to tell you how NRR looks at issues 9 in the short-term, they have an office instruction 10 called LIC-504. Remember I said sometimes an issue 11 should be addressed by the Regulatory Office directly?
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| 12 This is the process document that NRR uses. Okay?
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| 13 So if we aren't addressing it in the GI 14 Program, NRR should be evaluating it in an analogous 15 process in-house.
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| 16 Okay and I already talked about NUREG-17 0933, where the repository of knowledge is. That may 18 be my last slide.
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| 19 MR. GARDOCKI: Yes.
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| 20 MR. BOYCE: Are there any questions in the 21 room? Beth.
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| 22 MS. WETZEL: So where is the backfit 23 process for the GI Process?
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| 24 MR. BOYCE: So the question, for those on 25 the line is where does the backfit process show up.
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| 80 1 And it really would come in in the Transition Team.
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| 2 After we get past the assessment stage, let's assume 3 that the Transition Team decides that they're actually 4 going to take action, like a plant-specific, a generic 5 order, let me say, or a rule. Those individual 6 regulatory processes would engage the backfit process, 7 as appropriate.
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| 8 Like in the case of rulemaking, there is 9 a backfit analysis that is already built into the 10 rulemaking process. If we went with an order, that 11 backfit process would also be part of the development 12 of the order. So, it would be part of the regulatory 13 process. It's not part of the generic issues process.
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| 14 In the case of generic communications, not 15 all generic communications go through Our Committee to 16 Review Generic Requirements, or CRGR, but generic 17 letters, I believe, do for example, bulletins do. So, 18 if the agency decides to take regulatory action and 19 chooses that vehicle, then CRGR would be engaged early 20 on before issuance of those documents.
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| 21 Did I get to what you needed?
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| 22 MS. WETZEL: Yes.
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| 23 MR. BOYCE: Other questions in the room?
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| 24 Questions on the bridge?
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| 25 Okay, then thank you very much.
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| 81 1 Stan.
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| 2 MR. GARDOCKI: Okay, thank you.
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| 3 All right, so now you've heard what the 4 whole program is about. So where are we at with this 5 specific issue?
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| 6 All right, first slide, we already did a 7 screening. So we accepted the GI into the Program 8 last year. We did the initial screening. We did what 9 they call a quick shot to see if there's an immediate 10 safety concern. And NRR looked at it and says do we 11 need to act on something immediately right now. And 12 they said no, not right now. You know take the time 13 to do an in-depth analysis and come back and let us 14 know what the analysis is and make the determination 15 a little bit later. But we do what they call an 16 immediate safety determine to see when somebody 17 identifies an issue if there's an immediate concern to 18 the plant safety, to take action right there in the 19 very beginning. We don't wait around for the process 20 to go through its churning of wheels.
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| 21 So we did the NRR safety determination and 22 they found out, no, it's not an immediate concern but 23 you need to do something. And that's available on the 24 public documents called ADAMS in the ML numbers.
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| 25 MR. MELLY: It is as well referenced in NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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| 82 1 the screening report that was issued. We reference 2 the ML associated with that NRR review.
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| 3 MR. GARDOCKI: Correct.
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| 4 Now you saw the dashboard on the public 5 side but we have a dashboard on the internal NRC side 6 and we list a lot of these documentations on that. We 7 don't put it on the public side because it's not ready 8 for GI yet. We're still in that determination stage.
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| 9 So we put everything on the internal site until we're 10 ready to launch into the GI, per se, and then 11 everything will go onto the public dashboard.
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| 12 But all the documentation that you saw on 13 that overall screen, those are all ML numbers in 14 ADAMS. So you can see all the documentation, the 15 screening report, the receipt inspection, the 16 immediate safety concern. All that is available, you 17 just have to go through ADAMS at the point to get 18 that. You don't have the quick links that the 19 dashboard provides.
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| 20 So as far as this PGI, we screened it in 21 and we wrote a screen report. And you're available to 22 get that off of ADAMS. And now we're in the 23 assessment stage.
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| 83 1 through the screening. We've got the proposed. We 2 did the screening report. We presented it to the 3 office manager. He says, good report; go to 4 assessment. He makes the final determination. And we 5 actually brought in the office's, NRR, office director 6 to make our joint decisions on important issues like 7 this.
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| 8 So now we're into the assessment stage.
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| 9 Okay -- we've got the screen review. Go back one.
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| 10 There you go. Okay, there it is.
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| 11 There's the screening review is complete.
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| 12 Like I said, it's publicly available. It met all the 13 seven criteria. And we did a little bit extra work on 14 this so it can be more defined in the screening report 15 and we came up with some action plans, not just say 16 put it in assessment but our GIRP Committee says well, 17 when you go to assessment, here's a plan on how to 18 resolve the issue. Here's some short-term milestones 19 that we think you need to do in a two-phased approach 20 to get this assessment done to determine if it's risk-21 significant enough to go to NRR. Okay?
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| 22 And then at the very bottom, you'll see 23 the ADAMS number at the bottom of the screen.
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| 24 Okay, like I said, the GIRP report and the 25 screening identify what they call short-term actions.
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| 84 1 Now the short-term actions we generally say they're 2 going to be done in the assessment stage, which 3 usually takes between one and two years. We're into 4 what six or eight months into the assessment. So 5 we're getting a good kickoff what this means.
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| 6 And I'm not going into every individual 7 task here. If you have specific questions on the 8 task, Nick is the coordinator for developing all the 9 actions needed to achieve all these tasks. But the 10 Generic Issues Committee said these are important 11 enough to identify them on the screening report as a 12 logical progression to resolve this issue.
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| 13 And again, in the full report, the 14 screening report that was issued, some of these tasks 15 you'll see in parentheses if needed. So the 16 determinant, the development of an interim guidance, 17 to perform additional testing, and proceed to the 18 Regulatory Office implementation stage. These are 19 tasks if it's needed. If our assessment and 20 determination sees that we need to do these things, 21 we're going to move them forward.
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| 22 The perform additional focused HEAF 23 testing, we have decided to move forward on that and 24 that's the purpose of this meeting. Again, with some 25 of the task 3 here, you'll see determine electrical NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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| 85 1 fault characteristics. We're handling that in a 2 public manner through these workshops, as well as 3 through comments on the Draft Test Plan that has been 4 developed.
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| 5 Again, there was a time table associated 6 with typical GIRTH assessment phases and we're trying 7 to move things quickly because test programs take a 8 while to get contract employees following the NRC 9 program. So we're moving in parallel and we're trying 10 to get as much industry involvement as possible.
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| 11 MR. TAYLOR: If I can just add to that a 12 little bit.
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| 13 Some of these actions aren't NRC-sole 14 actions. You know some of them we're looking for 15 participation with EPRI or other stakeholders to help 16 us work through the process. So, you know developing 17 a ZOI, we'd like to solicit some input from industry 18 to sort of help support that. But if we don't get any 19 support from stakeholders and whatnot, then we'll go 20 ahead and do that on our own.
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| 21 So there are some actions that aren't sole 22 NRC responsibility.
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| 23 MR. MELLY: Yes, in the next presentation 24 that I'll actually be giving on the potential to 25 involve pilot plants and have industry involvement for NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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| 86 1 the risk-safety determination is going to be a large 2 area where we're going to be looking for involvement 3 from the industry to have a robust assessment.
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| 4 I'll give an example of some of the things 5 that we can do without industry involvement but it's 6 going to be beneficial for everyone involved to have 7 as much participation as possible.
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| 8 MR. GARDOCKI: And I'll reiterate what 9 Nick and Gabe said. We're looking for industry 10 involvement. If industry doesn't get involved, the 11 NRC will gladly go out there and help you get it done.
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| 12 Okay?
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| 13 All right, long-term actions. I use the 14 word commonly here because it's a flexible program.
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| 15 The Generic Issues is made to handle such a wide 16 variety of issues, we sometimes deviate from the 17 process a little bit.
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| 18 So in this action here, regulatory action, 19 we typically send out generic communications during 20 this stage called Regulatory Office implementation.
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| 21 But in this case, we sent out an IN last year. So we 22 actually issued an IN to the industry prior to getting 23 into the Regulatory Office implementation stage.
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| 24 So the flexibility of the program is there 25 and we use it and utilize it to our benefit.
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| 87 1 The long-term actions of the GIRP 2 identified -- you can see continuing on is those steps 3 revising technical guidance, as necessary, issuing 4 additional generic communications or orders, or 5 rulemaking. All that is going to be done in the long-6 term actions in the next stage called regulatory 7 office implementation.
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| 8 Okay, go to the next one.
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| 9 There's a couple more long-term actions 10 that are identified in the report. I think the PERT 11 has been completed, is the publicly --
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| 12 MR. MELLY: The PERT has been completed 13 and is publicly available. We don't have the ML on 14 this slide but we will provide -- or the ML is 15 publicly available in our ADAMS system. It was 16 published in August of this year.
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| 17 MR. GARDOCKI: August?
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| 18 MR. MELLY: Last year. It's been a long 19 year.
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| 20 MR. GARDOCKI: So in the Generic Issue 21 Program, we try to be very transparent and make just 22 about everything publicly available at the appropriate 23 time. So if the screening report says they're being 24 developed and reviewed are not publicly available 25 until they are approved by the Office Director of NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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| 88 1 Research and made publicly available.
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| 2 Any more from Gabe or Nick on the long-3 term actions?
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| 4 MR. MELLY: So the long-term actions we're 5 going to discuss here. There's some overlap between 6 the short-term and long-term and that's based on the 7 level of effort that's going to be involved with them, 8 and specifically on how the test is performed and the 9 assessment of risk. There's different options of how 10 we can tackle that program, as well as the amount of 11 resources that's going into it. So that's why you see 12 some overlap between the short-term and long-term 13 actions is time line of when we can get things done 14 and what level of detail we can get them done to.
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| 15 That's associated with the documentation that you saw 16 on the overall process of the Generic Issues Program.
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| 17 We're here today and tomorrow to talk 18 specifically about the focused HEAF testing, as to 19 what parameters are of importance. What's realistic?
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| 20 And what's representative of out there in the plants?
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| 21 The assessment of risk, again, we're going 22 to be talking about the potential to have pilot plants 23 to work with, which I'll talk about next, but we see 24 that when we do get pilot plants and we get industry 25 involvement, everything tends to be much more NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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| 89 1 successful moving down the road, rather than fighting 2 of what was done or what could be done.
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| 3 MR. GARDOCKI: Okay, these are some 4 actions that are in progress or completed. Like I 5 said, the report was published by a GIRP. These said 6 these are our actions that we need to complete to get 7 the assessment done correctly and it's a phased 8 approach, stepped approach. And like I said, the 9 Regulatory Office implementation, those are projected 10 actions. We don't know for sure, until we get to that 11 stage, whether we'll do all those actions, some of 12 those actions, or additional actions. But the GIRP 13 will kind of think in advance in the future what 14 possibly could come out of the assessment stage. So 15 those are kind of proposed.
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| 16 But here you can see how far we are in the 17 process and what some of the things that we have 18 completed. The dates and times are starting to get 19 developed. I think Nick and Gabe can talk more about 20 when actually the tests are proposed and dates.
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| 21 MR. MELLY: Yes, in the Phase II 22 presentation that I'll be giving, we have some time 23 lines associated with testing and things moving 24 forward.
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| 90 1 now, there was an informal survey performed by NEI, 2 essentially questioning how much aluminum is out 3 there. Again, that was informal, voluntary-based and 4 NEI performed that.
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| 5 I have an ML in a later slide. It is 6 public. We have made that publicly available, what 7 has come in. The plant names are anonymous in that 8 report but that is one area where it was important to 9 our assessment for this issue is understanding how 10 much aluminum is out there in the fleet, to see how 11 big of a problem this is or could be.
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| 12 Again, the next stage, also, is to invite 13 personnel to potentially join NRC expert elicitation 14 solicitation process, which will help determine the 15 zone of influence that will be used for that risk 16 assessment moving forward.
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| 17 So essentially, the high level in 6850 18 Appendix M right now is the three-foot horizontal 19 five-foot vertical and the expert elicitation would 20 lead down to what it would potentially be for this 21 aluminum issue, taking into account the potential of 22 both conductive material as well as enhance the zone 23 of influence.
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| 91 1 open and with a semi-formal or some level of expert 2 elicitation to capture that issue.
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| 3 Again, we're here to develop the future 4 test plans and this is the workshop that is on the 5 screen right now.
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| 6 MR. GARDOCKI: Okay. As far as the 7 initial testing that was done, they identified an 8 issues with the aluminum in the cabinets or bus bars, 9 or even the enclosures. So we said okay, now we have 10 to additional testing to find out what extent of 11 aluminum causes what extent of damage. And we can't 12 really do any kind of regulatory actions until we know 13 that knowledge and that's why we're developing these 14 other test plans.
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| 15 So that's why we're kind of developing our 16 assessment right now and we need further testing to 17 get further in the process.
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| 18 MR. MELLY: And we also did focus on the 19 fact that this is an international program that we're 20 working with, the OECD and the NEA. We will discuss 21 the members who are going to be potentially in the 22 Phase II and we've also been doing these actions in 23 parallel with them, trying to figure out is aluminum 24 an international issue. And what we found is that not 25 very many other countries consider the -- or have NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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| 92 1 aluminum within their plants, either in the enclosures 2 for bus ducts or the cabinets themselves. It's very 3 country-specific what material was available at the 4 time and what they were requiring to put in the 5 plants.
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| 6 We do see a large amount of aluminum in 7 Japan, specifically within their enclosures, however, 8 they do not have aluminum for the enclosures of their 9 bus duct material, due to seismic concerns during 10 their design phase.
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| 11 So as we've learned more, we've seen that 12 the aluminum may be a U.S.-specific problem, rather 13 than the larger OECD international community. For 14 instance, Germany has found one plant that had 15 aluminum and it shut down.
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| 16 So we're trying to tailor the next stage 17 of the program to take into account both this issue 18 and we may be taking the heavier lift, in terms of 19 resources, to solve the aluminum issue, rather than 20 the international countries.
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| 21 MR. GARDOCKI: All right, I think that's 22 the last slide there.
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| 23 There's not a lot of dates associated with 24 these steps right now because were still developing 25 the dates to perform the additional testing. And NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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| 93 1 based on some workshops, participation from industry, 2 we'll be doing some site visits and hopefully get out 3 and do an actual realistic PRA inside of a plant to 4 say if you extend the zone of influence from 10 to 15 5 or 20, what's the change in risk to the plant.
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| 6 So we're actually looking for some plant 7 involvement and that kind of aspect. And Nick will 8 get a little bit more into that in our workshops. So, 9 I just put a plug in now that it would be very helpful 10 in developing what they call the risk significance of 11 this specific generic issue if we can get some actual 12 plant data, say.
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| 13 MR. MELLY: Yes, in my next presentation, 14 I'm going to discuss some of the potential options 15 moving forward. This is the first time that we're 16 really engaging EPRI as well as industry on this path 17 forward. And we would like to -- we'll discuss some 18 of the pitfalls with doing it in-house and the 19 resources associated with moving forward to do this 20 risk assessment. And it will be something that we 21 definitely further engagement and potentially more 22 meetings to discuss how these pilots and things will 23 work.
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| 24 MR. GARDOCKI: So that's a very detailed 25 approach on how we're getting to this issue. I know NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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| 94 1 it sounds like it's going to take a while but we want 2 to make sure we get it right before we make the 3 industry or regulations applicable. We don't want to 4 drive costs up anywhere that we don't have to or we 5 want make sure safety is important.
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| 6 Any questions? Kenneth.
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| 7 MR. FLEISCHER: Yes --
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| 8 MR. GARDOCKI: Hold on one second.
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| 9 MR. FLEISCHER: Yes, sure. Kenneth 10 Fleischer with EPRI.
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| 11 So the item regarding international, what 12 was the level of rigor and detail into that 13 assessment, whether they have or don't have aluminum?
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| 14 Did they do similar to like an NEI study, where you 15 got down to the actual individual engineering 16 organizations that really do their plant well or is 17 that just a high-level regulatory assessment?
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| 18 MR. MELLY: It varied on country to 19 country. Germany held a workshop much like this with 20 their industry and it was a questionnaire form that 21 went out. But if very much varied from country to 22 country as to the level of detail they went into to 23 figure out if they had aluminum in their plants and to 24 what extent.
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| 25 For instance, the cabinet we received from NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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| 95 1 Finland did have the aluminum in it and they 2 identified aluminum as being an issue for their 3 plants. However, it's very country-specific and there 4 was no formal process in figuring out how much 5 aluminum is out there.
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| 6 We provided each country that was a part 7 of the OECD program with the questions and 8 questionnaire form that we provided to NEI and it was 9 up to each country specific how they wanted to engage 10 their fleet.
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| 11 So that is something we will most likely 12 try and enhance in the Phase II of the program working 13 with the internationals is conducting the formal 14 surveys as to the extent possible.
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| 15 MR. VERHOEVEN: Hello. Bas Verhoeven from 16 KEMA Laboratories.
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| 17 The discussion about aluminum versus 18 copper, the use, it was my global experience when I 19 see it, and I traveled to many countries worldwide, 20 you see that use of aluminum in the sectors, not only 21 the neutral but overall, the use of aluminum is 22 increasing very rapidly at the cost of copper because 23 of lower rate and the cheaper design. That means that 24 much more systems generically will include aluminum 25 instead of copper. That's a trend that you see NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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| 96 1 happening everywhere.
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| 2 So an exhibit in Saudi Arabia, they 3 changed overnight, basically, that whole distribution 4 transformers should have aluminum wirings rather than 5 copper wirings. Cables are being transferred to 6 aluminum conductors instead of copper.
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| 7 So it's happening everywhere. And 8 primarily, cost-wise, that's been the main reason and 9 secondary is the lower weight.
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| 10 MR. MELLY: Yes, so we have seen some 11 international evidence of these high energy arcing 12 faults occurring as well as at different types of 13 facilities. However, for a different facility, if 14 they lose an entire room, the plant is shut down for 15 a day, rather than the risk -- the potential risk that 16 we have within the nuclear industry of larger 17 consequences.
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| 18 Any other questions in the room?
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| 19 MR. CHEOK: This is Mike Cheok from Office 20 of Research.
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| 21 So when Nick talked about the risk 22 assessment, and so one parameter of it was the zone of 23 influence. So that's something that we want to look 24 at plant-specific data on.
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| 25 The other element of it is the frequency.
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| 97 1 So we also talked about this in the beginning. So we 2 talked about trying to you know characterize the arc 3 flash better, characterize what HEAF is and not all 4 arc flashes result in HEAFs.
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| 5 So in a lot of this, we all try to get a 6 lot more information about this as part of the Phase 7 II testing and as part of the expert elicitation, as 8 part of looking at Op E and things like that. So 9 that's the other part of the risk analysis, which we 10 will be looking for a lot of input on.
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| 11 MR. MELLY: Yes, and as Mike said, that is 12 the other piece, rather than we've kind of separated 13 it right now. We have the zone of influence part of 14 this and we have everything else, which is the 15 frequency, the circuit protection, some of the 16 durations, plant-specific design. And we plan on 17 capturing all of that.
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| 18 Right now we have a memorandum of 19 understanding with EPRI and all of that, hopefully, 20 will roll into the work that we were planning to do 21 with Ashley and EPRI on the heat. If we're going to 22 be looking at frequency, 1E equipment versus non-1E 23 equipment and things like that will all be captured 24 under the MOU work that is planned for later this year 25 and next year.
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| 98 1 Francisco.
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| 2 MR. JOGLAR: So what you just said on 3 probabilities and frequencies, is that what that last 4 bullet means when you said the NRC will calculate 5 potential risk increase?
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| 6 MR. MELLY: No, so the calculation of the 7 potential risk increase, that's what we're going to be 8 discussing next is the pilot plants and the risk 9 assessment associated with the GIRP and the assessment 10 work phase that we're in.
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| 11 What we were discussing with frequency and 12 the definitions is currently the bin 16 is split bus 13 ducts, the electrical cabinets, as well as on the low 14 voltage and medium voltage equipment in Supplement 1 15 to NUREG-6850. We're talking about potentially 16 increasing that and doing more -- a little bit more 17 refined work there as to splitting out the arc blast 18 type occurrence versus the high energy arcing fault, 19 as well as the potential to roll in the safety-related 20 versus non-safety-related, and refining the 21 frequencies associated with those in our work under 22 the MOU.
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| 23 But the calculation of the potential 24 increase I'll get to next as to an example of how we 25 would like to do that and through the potential of NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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| 99 1 pilot plants.
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| 2 MR. GARDOCKI: And just to add on to that, 3 the Generic Issue Program, like you said, the seven 4 screening criteria, there's risk aspect of it.
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| 5 So when we calculate the risk here in the 6 assessment stage, if it doesn't meet a threshold, it 7 will not go to Regulatory Office implementation. So 8 it's not risk-significant enough to go to that stage 9 to require regulations or industry to do any action on 10 it.
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| 11 We use the threshold very similar to 12 what's in the Reg. Guide 1.174 for plant changes. If 13 a plant requests a change to the NRC and say we're 14 going to change something in our plant, they do a risk 15 analysis and says it's safe to do. Well, we reversed 16 that philosophy. If that risk is unacceptable, then 17 it should proceed as a generic issue into the 18 Regulatory Office.
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| 19 So we use the same kind of screening in 20 that Reg. Guide but we use it in reverse. If it's not 21 safe to implement the design change, then it's 22 something -- a threshold that would go to Regulatory 23 Office for generic issues. So we use the risk in this 24 stage of assessment to go Regulatory Office, not just 25 -- we don't do it just qualitative. We try to do a NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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| 100 1 quantitative analysis to get this risk increase.
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| 2 Okay?
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| 3 MR. JOGLAR: Thank you.
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| 4 MR. GARDOCKI: Bridge line or more?
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| 5 MR. FUNK: Can I just get a little 6 clarification on one point? I think it was in one of 7 Mark's earlier slides. He had highlighted general 8 design criteria 3 and then the single failure criteria 9 collection of blood and guts electrical engineering.
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| 10 But in the generic issue right up to what 11 has been presented by Michael and what I see here 12 today, so far, it looks this problem is only being 13 approached strictly from fire PRA perspective or are 14 you back questioning is Class 1E traditional 15 separation criteria acceptable?
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| 16 MR. MELLY: It is -- we have been focusing 17 on a lot of discussion on the NFPA 805, the 18 probabilistic aspect. However, the deterministic is 19 also identified in the safety evaluation, as well as 20 the information notice, as a potential area where this 21 can affect.
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| 22 So it is both. It's not just 23 probabilistic. We have been focusing in on the zone 24 of influence and things like that for the 25 probabilistic design and the frequencies as well. And NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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| 101 1 we're still trying to tackle how we are going to 2 assess the issue for the deterministic plants, the 3 separation criteria, as well as some exemptions to 4 that separation criteria that are in regulations.
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| 5 So that is all still on the table at this 6 moment in time.
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| 7 MR. FUNK: And by deterministic, do you 8 mean Appendix R deterministic or Class 1E Reg. Guide 9 1.75 determination?
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| 10 MR. MELLY: I was referring to the 11 Appendix R right now. But again, I haven't given that 12 much -- I haven't looked at the overall picture to 13 know exactly what's going to be affected. But the 20-14 foot separation criteria from Appendix R is what comes 15 to mind right now.
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| 16 MR. FUNK: Thank you.
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| 17 MR. PELLIZZARI: Francesco Pellizzari, 18 EPM.
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| 19 Following along that line of thought, my 20 understanding of Appendix R was that it was generally 21 based on consideration of hazards that were floor-22 based, where the floor area burned but it really 23 didn't consider explosive hazards.
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| 24 So just a thought in terms of a concern 25 and the plants that are deterministic is like a fire NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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| 102 1 barrier wrap that would be within the zone of 2 influence for ZOI. Essentially, that wouldn't afford 3 any protection from an explosive hazard. So I think 4 that's somewhere. That needs to be, obviously, 5 explored.
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| 6 MR. MELLY: Yes, I agree and those are all 7 areas that we're going to be looking into, as well as 8 the other additional concern is that intervening 9 combustibles were generally as floor-based whereas, if 10 you have a bus duct, it typically would not have been 11 considered an intervening combustible because it's not 12 combustible. However, if you have a bus duct running 13 through your separation or across, this potential 14 issue can occur.
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| 15 So these are all areas that we are going 16 to be investigating, as part of this program.
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| 17 MR. GARDOCKI: In the screening report, 18 also, you can see there's a little differentiation 19 between the NFPA 805 plants and the Appendix R. So 20 there's a little bit of difference there and we 21 identified that difference in the screening report and 22 tried to come up with some different tasking to how 23 we're going to address those different aspects. So 24 some plants are Appendix R and some are NFPA plants.
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| 103 1 also addressed in the NRR assessment to the immediate 2 safety risk and I believe it's in the communication 3 plan moving forward.
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| 4 Mike? Oh. Do we have questions from the 5 phone?
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| 6 MR. AIRD: No, we just got a message that 7 if you're using a microphone, speak kind of loudly 8 into it because some people are having a hard time 9 hearing you.
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| 10 MR. MELLY: We'll also start repeating the 11 questions.
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| 12 MR. AIRD: That would help.
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| 13 MR. MELLY: All right.
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| 14 MR. SALLEY: Nick, before you move on, a 15 couple things.
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| 16 MR. TAYLOR: Hold on Mark.
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| 17 MR. SALLEY: So before we move on here, a 18 couple things before we get to the next presentation, 19 as you close this one out.
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| 20 Dan, your question is on the electrical 21 engineers. That's specifically why we requested a lot 22 of the electrical engineers to come to this. And 23 we're doing that internally in Research also. You 24 notice Kenn Miller is here and we've got Ronaldo 25 Jenkins, and Tom Koshy, Bob Bailey. So we're trying NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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| 104 1 to also, we see if this is a bigger issue and we 2 wanted to involve the electrical engineers. It 3 started out in fire protection but, again, we're 4 looking to bring the other ones on.
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| 5 The question of aluminum, as we see, you 6 know we're taking the biggest problem first, and we 7 see the aluminum as the first place we really want to 8 go. And we are seeing that most of it is in the 9 United States, which would kind of beg the question if 10 I was German or a country that didn't have any 11 aluminum, why do I want to continue on with the 12 research. And I think talking with them and the other 13 countries is we can do a more accurate zone of 14 influence model for the copper ones and we can learn 15 more about it.
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| 16 So I think everybody wants the most 17 realistic, most accurate model. So I think that's a 18 lot of the reason that we'll do it.
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| 19 What you'll see here is probably parallel 20 pilot testing, where we do the bigger OECD program and 21 then we have some specific aluminum stuff that we need 22 to solve in the U.S. and Nick's discussion will get 23 into that.
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| 24 And one final thing. I noticed our Office 25 Director, Mike Weber, has stopped in. Mike, if you NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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| 105 1 had any words or anything you'd like to say to the 2 group, we'd appreciate it.
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| 3 MR. WEBER: May I have a microphone?
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| 4 Thanks.
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| 5 The only thing I would add is I'm happy to 6 see a crowded room. So this is good. You know we 7 really, as has been emphasized several times, we 8 really benefit from your participation, not just here 9 in the room but also on the phone.
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| 10 We want this to be the kind of 11 experimentation, testing, and analysis that we do 12 where when we come up with our conclusions everybody 13 says well, yes, of course; we all agree this is 14 reasonable, this is appropriate, and it's focused on 15 safety. We're not trying to impose additional burden 16 that's not justified but we are trying to ensure that 17 the results of our experiments, or our analysis are 18 credible and that they ensure that we support the 19 overall Program results in accomplishing safe and 20 reliable operations.
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| 21 So, that's the only thing I would add.
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| 22 Thanks for participating.
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| 23 MR. MELLY: Next?
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| 24 MR. MILLER: This is Kenn Miller. Just to 25 piggyback a little bit on what Nick and Mark talked NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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| 106 1 about, the deterministic separation criteria, from an 2 electrical perspective, from electrical design GDC 17, 3 it's been an issue in my mind as well but perhaps 4 drives us to issues with separation criteria and 5 division separation. Of course, that tempered with 6 the required criterion defined in GDC 17 but certainly 7 I would agree that that's on the table as well, 8 depending on what we find out from this research.
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| 9 So, I just wanted to put that out there.
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| 10 MR. TAYLOR: Any other questions from the 11 room?
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| 12 Tom, is there anything on the Webinar?
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| 13 Okay, so I think, Nick, you're up next.
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| 14 MR. MELLY: All right, thank you, Tom.
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| 15 So we eluded to this a little bit in the 16 previous presentation. This is a look at how we --
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| 17 how I envisioned the pilot plants coming off for this 18 risk assessment. Again, overall, we are in the 19 assessment stage and, as part of that assessment, we 20 want to look at what the potential is and understand 21 what the risk from these events is to the current 22 fleet.
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| 23 This is a very difficult problem because 24 the zone of influence, as well as the potential damage 25 is very scenario-specific, very plant-specific. It's NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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| 107 1 a problem that can't be broad-brushed. We need to 2 kind of run sensitivity studies, and things like that, 3 and have an appropriate model when we get to a pilot 4 plant.
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| 5 As we have looked at the risks from this 6 from a larger picture, we have the skyscraper chart 7 that EPRI has done as part of a study to look at the 8 risk drivers. And what you're seeing is primarily on 9 -- down the side here you see the different 10 categories. You have electrical cabinets, transient 11 heat, and you do see that HEAF is the third largest 12 risk driver. It kind of mirrors the electrical 13 cabinets, in that the overhead cables are a large area 14 of concern. They drive a lot of the risk and the 15 conditional core damage probability.
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| 16 So this is one tool that we've used to 17 kind of try and understand what the current risk to 18 the fleet is. And if we focus in on just looking at 19 the HEAF, we see that it can range anywhere from 37 20 percent of the overall -- the total plant contribution 21 to risk to zero or to a little bit -- to a very low 22 value. So you can kind of see that it's all over the 23 board. It's a very scenario-specific problem and 24 we're trying to understand it without the broad brush.
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| 108 1 it and we'd like to work with industry to accomplish 2 this and select appropriate plants to use as pilots, 3 whether it be by design, PWR, BWR, or we use a tool 4 like this to look at three different risk drivers, or 5 a number of different risk drivers. It's selecting 6 one with a high level of risk, a medium level of risk, 7 and a low level or risk and adjusting our zone of 8 influence of damage for these aluminum-specific 9 components.
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| 10 Some of the important drivers is also 11 going to be does that plant even have aluminum? Maybe 12 for these larger risk drivers, it's an all-copper 13 plant, all copper design, this isn't even an issue.
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| 14 So it becomes a larger picture, one that 15 we want to work with industry hand-in-hand, as a pilot 16 program to really understand the risks.
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| 17 There are ways that we can do it in-house 18 but they may be conservative or take a larger picture.
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| 19 I hate to use the word conservative. It's a red 20 button word but if we're going to be trying to solve 21 this in-house without the resources that the industry 22 can provide of their plant models and things like 23 that, that is a fairly appropriate term.
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| 109 1 programs to give you an idea of where we are trying to 2 head with this, some of the options, as well as why we 3 would really like industry involvement with this 4 program.
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| 5 So one of the ways that we can do this is 6 we can use the SPAR All Hazards models that the NRC 7 has in-house. There are several plants that we have 8 fires associated with. We've used plant fire models 9 to enhance the SPAR models and give us an idea of fire 10 risk. In doing that, with the information that we 11 have in-house, I ran one of these assessments and I'll 12 run through some of the assumptions that I had to make 13 to come out with results, as well as the conclusions 14 of that analysis.
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| 15 So we had a plant model in-house. And 16 when I went through this, I had to assume that every 17 component that had a HEATH identifier was aluminum, 18 without -- that every single cabinet had aluminum 19 inside of it. And I had to do that because I had no 20 way to differentiate whether it was copper internals 21 versus aluminum internals for the conductors or the 22 enclosed material.
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| 23 Again, I say that's potentially 24 conservative. However, from the survey that's listed 25 here in the ML, there were a large number of plants NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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| 110 1 that had aluminum components.
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| 2 The next assumption that I had to make is 3 that I had no way to determine where components were 4 located in the plant to come up with an increases zone 5 of influence. So from changing to the three-foot 6 horizontal to five-foot vertical, I had no way to 7 determine what components were four-foot, five-foot, 8 six-foot away with the internal information that we 9 have.
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| 10 So I, instead, mapped every single HEAF 11 scenario to a hot gas layer scenario for that 12 compartment, which essentially involved all of the 13 components within the compartment that were not 14 protected by some other -- by some means of protective 15 barrier. That brings me much closer to an Appendix R 16 type analysis that is total room loss. So that is 17 inherently conservative. It essentially says that 18 everything within the room is damaged and I have to do 19 that in-house in lieu of performing the plant walkdown 20 or doing an evaluation of what equipment would be 21 damaged.
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| 22 If we wanted to do this just in the NRC, 23 there are potentials that we could do walkdowns. We 24 could work with the inspectors and try and bring this 25 forward but right now, for illustration purposes, this NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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| 111 1 is what I did. I mapped everything I did to a hot gas 2 layer scenario.
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| 3 I also had to take away credit for the 4 automatic suppression or manual suppression. We had 5 no way to alter those within the current model. So 6 all non-suppression values were set to one. We had no 7 way to evaluate whether the sprinkler systems or any 8 suppression methods would be damaged by the event 9 itself.
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| 10 The one area that is potentially non-11 conservative is that the model that we had to work 12 with in-house had no bust duct scenarios listed. In 13 that scenario, at the time that we received the 14 information, the bus ducts were screened out of the 15 analysis using a sensitivity study. So there was no 16 way for me to map a bus duct scenario to any specific 17 room hot gas layer. I didn't know where the bus ducts 18 were in the plant.
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| 19 So you can see from the SPAR model results 20 themselves, these are the rooms where you would 21 typically high energy arcing faults. We have our V 22 switchgear room, our turbine building room, the A 23 switchgear room, and HEAF identified scenarios in the 24 reactor auxiliary building.
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| 112 1 fire CDF. You can see this was the core damage 2 frequency identified in the SPAR model prior to me 3 altering these events. And you can see the difference 4 compared to when I did change the event to a hot gas 5 layer damaging scenario which, essentially, would take 6 out the entire room. And you can also see the total 7 difference down here.
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| 8 I only listed the compartments that had 9 HEAF scenarios identified and my change to the plant 10 model. But you can see prior to my alterations, the 11 total plant CDF was three to the minus -- or 3.06 E to 12 the -5. And with the increased zone of influence or 13 the mapping to a hot gas layer, we're down in the area 14 of 1.95E to the -4.
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| 15 As you can see this large increase in 16 risk, which I necessarily don't believe is true or 17 realistic, based on the way that I had to make 18 assumptions and model it but, without eliciting help 19 from the industry through either EPRI or the 20 individual plants themselves to establish a pilot 21 program where we can work to really understand a 22 realistic risk increase, we're limited with our 23 ability to recreate these events without a larger, 24 more robust model.
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| 25 So this is where we currently sat -- sit NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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| 113 1 right now with our level of analysis and what we can 2 do in-house. We can make this a little bit better 3 with plant walkdowns and working with the Regions and 4 actually going out to plants but I see that as Plan B.
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| 5 Plan A is much more can we work collaboratively. Can 6 we leverage the plant models themselves and move 7 forward in a way that's really going to capture what 8 that interim zone of influence and that interim risk 9 could be?
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| 10 So that's really what I wanted to stress 11 here with this presentation is that there are some --
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| 12 as part of the Generic Issues Program, we must do this 13 risk evaluation and it would be much more beneficial 14 to do it with the industry as a collaborative effort, 15 rather than being potentially conservative on our own.
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| 16 It will help understand the realistic risk associated 17 with the events involving aluminum and we can leverage 18 the existing plant PRA models with the use of pilot 19 plants.
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| 20 How we select those pilot plants becomes 21 very important and we really need to work together on 22 how we do that selection. Again, we'd be following 23 the technical office instruction that Stan mentioned 24 earlier as to the threshold levels for if this --
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| 114 1 progress forward in the generic issues process.
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| 2 So this is kind of what I wanted to 3 discuss is how we can select these pilot plants. So 4 we wanted to get volunteer pilot plants that have 5 identified aluminum components. As I mentioned 6 previously, the NEI survey that we have has anonymous 7 plant names. So right now, we cannot determine which 8 plants did have the aluminum from that survey.
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| 9 And we also want to have volunteer pilot 10 plants that have modeled HEAF scenarios within their 11 PRA. What I mean by that is we need the volunteer 12 plants that have done a zone of influence approach 13 following Appendix M of 6850 as well as the bus duct 14 guidance that is in Supplement 1 to 6850, which is FAQ 15 07-0035.
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| 16 That becomes very important because if 17 plants went and did a scoping approach, where they 18 already modeled their high energy arcing fault 19 scenarios to a hot gas layer, selecting them as a 20 pilot plant will not be beneficial because it will 21 show absolutely no change because they've already used 22 conservative methodology in their approach. And there 23 are several plants that did that because if they could 24 live with the risk, they did not move into further 25 stages of going to zone of influence approaches.
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| 115 1 Additionally, as I've mentioned before, 2 these may involve plant walkdowns and some NRC 3 interaction will be decided on the as-needed basis.
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| 4 If we can receive all the information we need just 5 from interaction and meetings through GoToMeeting or 6 some other needs, we won't need specific walkdowns.
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| 7 And we're trying to limit the amount of resources 8 necessary to perform a robust risk analysis.
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| 9 Are there any questions on the pilot plant 10 approach? Rob.
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| 11 MR. CAVEDO: Go ahead.
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| 12 MS. LINDEMAN: So how many pilot plants do 13 you need? I thought you mentioned three but --
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| 14 MR. MELLY: That's still up for 15 discussion. Our initial thought was that three may 16 provide a good picture, if we can get three that are 17 different enough where it would show us a range of 18 risk. As we've said, it's very plant-specific. It's 19 very scenario-specific. So we're still making the 20 determination of how many pilots do we need to really 21 understand what that risk will be on a broad brush.
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| 22 Because, again, this assessment is 23 supposed to give us an idea of what the overall risk 24 and the assessment of risk for everyone, for not just 25 one plant-specific. So we need to select as many as NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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| 116 1 possible to have a comfortable feeling of what the 2 plant risk is.
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| 3 Three is our initial idea.
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| 4 MR. CAVEDO: So I have a couple of 5 questions on this. I agree with you -- is this 6 causing the sound?
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| 7 MR. MELLY: I don't know.
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| 8 MR. CAVEDO: So I agree that we want to 9 get a realistic estimate of this and I also agree with 10 everything that you've been saying about it's very 11 important that we get the frequency right when we're 12 doing these bigger zone of influences.
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| 13 Is your vision that this pilot effort will 14 be done when you have the frequencies corrected or did 15 you envision just putting in these conservative zone 16 of influences without adjusting the frequencies?
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| 17 MR. MELLY: That comes down to a timing 18 issue. I believe the frequencies are going to be 19 handled in several stages. What I mean by that is the 20 safety-related versus non-safety-related is currently 21 being addressed in an FAQ. If that is ready in time 22 for the pilots, we can roll that in.
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| 23 Additionally, if we can make the 24 differentiation with the definitions to frequency, 25 that can be rolled in as well.
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| 117 1 MR. CAVEDO: I don't think it's a binning 2 issue, as much as a breaker performance issue.
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| 3 Because if the breakers are going to work, then 4 they're going to be smaller. If they're going to be 5 failed and they're going to be larger, and those would 6 seem like they would be a much lower frequency, and if 7 that's not being addressed in here and you're asking 8 for people to volunteer and you're telling them 9 they're going to put conservative results in and see 10 big number changes, what's the reaction going to be to 11 the plant's management and among the NRC when they see 12 big number changes where they forced conservative 13 evaluations to be done?
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| 14 So if we're doing frequencies at the same 15 time, then it's realistic, nobody can argue, and then 16 the results are what the results are. But if you 17 force conservatism in and you haven't addressed all 18 the conservative issues on the frequency side, that 19 seems like there could be some concerns.
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| 20 MR. MELLY: I agree with you and I think 21 it's still down to a timing issue.
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| 22 Now even before we get to the pilot 23 plants, there will be that expert elicitation that we 24 would like to perform with industry as to what that 25 zone of influence or what the increased area of damage NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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| 118 1 will be for the aluminum events. If the frequency is 2 also an issue that we want to touch on in that work 3 prior to going out to the public or to the pilot 4 plants, that is something that is up for discussion in 5 that effort.
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| 6 MR. CAVEDO: I think that it would be 7 important to get that frequency thing done before you 8 go to the pilot plants because I don't know how other 9 industry members feel but I don't think you're going 10 to have a lot of volunteers who are going to be 11 interested in showing super high numbers for 12 conservative evaluations. That's a downside across 13 the board. I don't know if any other utilities want 14 to comment.
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| 15 MR. CHEOK: So this is Mike Cheok again.
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| 16 So I guess we all know that the risk 17 analysis has several elements, consequences and the 18 frequency. So I think it makes sense for us to, you 19 know when we present the risk numbers they come with 20 the correct frequency numbers.
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| 21 And so also I think as we do more tests to 22 develop the characteristics of a potential HEAF 23 phenomenon that might also define what kind of plants 24 or what characteristics you're looking for in the 25 pilot plants. So it makes some sense but you know, we NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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| 119 1 build a discussion.
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| 2 MR. MELLY: Yes.
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| 3 MR. AIRD: We also have a comment from Ken 4 Z from Jenson Hughes.
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| 5 He says it would be important to have an 6 understanding of any latent sources of conservatism in 7 the pilot results before further decisions are made 8 related to the GI treatment.
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| 9 MR. MELLY: I agree.
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| 10 MR. AIRD: And he also says there needs to 11 be some level of assurance limitations related to the 12 schedule, which are not driving the GI action.
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| 13 MR. MELLY: Agreed.
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| 14 MR. TAYLOR: Any other questions?
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| 15 MR. MILLER: First one back.
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| 16 MS. WETZEL: I may have missed it, but 17 what kind of schedule are you looking at to get these 18 pilot plants?
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| 19 MR. MELLY: Stan, can I lifeline you on 20 that one?
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| 21 So this is part of the generic issue 22 process, which has a defined schedule and time --
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| 23 milestones that are supposed to be met as part of that 24 process. And those milestones are in place so that a 25 generic issue process does not last for 10, 11, 12 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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| 120 1 years, as some of them have in the past.
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| 2 So the milestones are fairly aggressive, 3 which is where the timing issue that I was discussing 4 with Rob come into play but Stan can elaborate a 5 little bit.
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| 6 MR. GARDOCKI: Typically for the 7 assessment for generic issue, we like to get it done 8 within a two-year period. It's pretty important. You 9 saw it was done within 6 to 18 months. So if it's 10 going to extend past the two-year mark, we would start 11 taking some action on the management level. That's my 12 role as the Generic Issues Manager -- Project Manager 13 for Generic Issues, make sure it doesn't drag on 14 forever.
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| 15 So we would start taking actions. Well, 16 we can't get the pilot plants, we can't get this done.
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| 17 Then, we start doing the conservative analysis and 18 that would maybe accelerate the process a little bit 19 and the other actions to say well, if we're not ready 20 to go the regulatory action, we could kick out of 21 generic issue, and put it into research, and then come 22 back, and then we're done five or ten years later.
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| 23 So the time frame we're basically looking 24 for is try to get the assessment done before the two-25 year mark. I mean that's not set in concrete but NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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| 121 1 that's kind of a target for the program.
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| 2 So within the next year and a half, I 3 would say, we would try to get that pilot stuff done 4 so we can wrap up the assessments.
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| 5 MR. CAVEDO: And I understand the need for 6 meeting the schedule. That's very important. But you 7 have accelerated the testing because you recognize 8 that we don't have a lot of insight as to what that 9 damage should be. And so you made that a high 10 priority and you're going to accelerate that within 11 the process.
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| 12 All I'm saying is the frequency and the 13 damage go hand-in-glove. So whatever acceleration 14 you're planning on applying to the testing, put that 15 same level of acceleration on the frequency. Don't 16 just say we're going to use a conservative frequency 17 because that expedites things for the same reason you 18 don't want to -- you want to do the testing. You want 19 to have -- make sure you have correct insights and a 20 realistic evaluation.
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| 21 MR. GARDOCKI: I understand that and I 22 think we got pretty much the testing done for 23 expanding the zone of influence. So you get the mark 24 to say go to the plant and say okay, the zone of 25 influence is 12, 15, 18, or 20 feet.
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| 122 1 Now as far as establishing the criteria 2 for --
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| 3 MR. MELLY: And let me clarify. He's just 4 using those numbers off the top of his head. They 5 don't have any basis for what it potentially could be 6 coming out of that expert elicitation. So don't run 7 from here and scream 20. It's not where we're at.
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| 8 MR. GARDOCKI: The only thing we see now 9 is the testing and you saw videos yourselves how far 10 the zone of influence has gone past what we saw when 11 we set up for the testing. So we need to do 12 additional testing to get a defined expansion of the 13 zone, if it's going to be expanded.
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| 14 As far as the frequency, I don't think we 15 have an exact milestone in our plan for this frequency 16 evaluation. I thought we --
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| 17 MR. MELLY: It's identified in the 18 screening report as a task. There's no set milestone 19 for it right now. It is an area where we'd like to 20 focus in on because I think that it can be done in a 21 quicker time frame. There are like limited events for 22 high energy arcing faults. And if we can establish 23 the correct definitions and what goes -- what's 24 considered the blast versus the HEAF, we may be able 25 to accelerate the frequency as well.
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| 123 1 Ashley or -
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| 2 MS. LINDEMAN: I think it was Brenda 3 first.
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| 4 MR. GARDOCKI: Brenda, yes.
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| 5 MS. SIMRIL: So I think I know at least an 6 overview of this or a little bit about it. But just 7 to be blunt from the industry perspective, can you 8 give a little bit of a what's in it for us type of 9 feel for being a pilot plant?
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| 10 MR. MELLY: I can give my perspective. I 11 don't know -- I'm not giving an NRC perspective at 12 this moment in time. And based on the initial 13 assessments that I have done using what we have in-14 house, the results do not look very appealing to where 15 if I was to do this assessment as an analyst in-house 16 without plant resources as to what modeling changes I 17 can make, the numbers would look fairly dire, which 18 will then potentially lead to the risk -- the office 19 implementation stage, leading to regulatory changes.
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| 20 Wherever we end up, I believe from having 21 done this assessment, that if we do have plant 22 involvement, we'll get a much better picture of the 23 risk, which will enhance things moving forward.
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| 124 1 about the interim ZOI. And to me, this dovetails on 2 Rob's question. If you don't define the scenarios, 3 what are you defining the ZOI for the worst case? So 4 I guess they all need to be thought out in a parallel 5 manner.
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| 6 I know we're working on it but to me I'm 7 just not sure of the schedule. I think that would 8 really help going forward is communicating all the 9 pieces and stuff.
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| 10 MR. MELLY: Yes. And like I said at the 11 beginning, I think that this whole effort, the expert 12 elicitation that we are potentially doing, the 13 frequency, that all will come before pilot plant 14 selections. And we would like to get moving on that 15 in a relatively short time frame to have further 16 discussion on this potential.
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| 17 MR. TAYLOR: What I started to put on the 18 board up here is action items for us to help clarify 19 issues or bring information. And the few things I've 20 put up there right now is GI milestones for all the 21 short- and long-term. It would probably be a good 22 idea to put something together that we can track 23 ourselves to and also communicate clearly on what our 24 expectations are from that program. And Stan 25 mentioned that earlier as well.
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| 125 1 And the other thing is just what Rob 2 brought up about the frequency, as well as what Nick 3 brought up on the classification to make sure that the 4 assessment that we do complete is as realistic as we 5 can with the information that we have.
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| 6 Any other questions?
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| 7 MR. MILLER: And I'm not hip on all this 8 stuff at all. So on the GI milestones part, is it 9 also the logical linking between the GI milestones, 10 how they're related and have to be scheduled together?
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| 11 MR. TAYLOR: Yes, right. So that's a good 12 point. There will be. It would make sense to provide 13 some linking to that.
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| 14 Obviously you guys weren't there during 15 all the deliberations but there was quite an extensive 16 discussion within the group of when they came up with 17 that, those milestones, the action plan, the short-18 and long-term of how things would work. And I'm not 19 sure it got documented or report that well.
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| 20 So I think we'll take that back and try to 21 come up with the milestones, the linking, and other 22 things to help support the GI Program -- proposed GI 23 Program.
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| 24 MR. AIRD: We go to comments from the same 25 commenter before, Ken Z from Jenson Hughes.
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| 126 1 His first comment is the current industry 2 of PRA results are constrained by methods acceptable 3 to the AGH. I hope the methods that are used to 4 address this GI do not impose the same constraints.
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| 5 And then his second comment is I am not a 6 licensee but it is my belief that in order to get 7 licensees to volunteer, there needs to be some level 8 of assurance that constraints on acceptable methods 9 are not going to be driving results.
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| 10 MR. MELLY: I think that we may be outside 11 of the acceptable methods for this endeavor because, 12 again, this is going to be a risk assessment for the 13 Generic Issues process that's going to be used --
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| 14 that's going to use a zone of influence to predict 15 damage from an expert panel. It's going to be 16 conducted much more in terms of a sensitivity study, 17 rather than something that's going to drive any plant 18 changes for these pilots or things like that.
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| 19 This is only for the Generic Issue Program 20 trying to do a risk assessment. It's going to be much 21 more of a sensitivity study than anything else.
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| 22 MR. TAYLOR: Yes, if I could just add to 23 that. You know kind of what Tom Boyce brought up this 24 morning, I look at the GI Program as basically you're 25 walking a tight line and anything that's going to kick NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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| 127 1 you out of it, you're going to go somewhere else and 2 do it.
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| 3 So the way that it got structured for the 4 short- and long-term, we want to do this interim 5 review, this interim risk assessment to see whether it 6 is significantly risk significant to take it off into 7 the Regulatory Office for their implementation. So, 8 getting to the question, then, you know the method 9 that we do that interim review in, I wouldn't expect 10 it to be extremely detailed or high level because we 11 just don't have that much information right now to 12 advance the model or the methods that are currently 13 out there.
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| 14 So it would probably be somewhat course.
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| 15 Hopefully, it will be a little more refined than what 16 we currently have but it wouldn't be the final end 17 product that we would then expect licensees, in the 18 end, to implement in their PRA as an approved method.
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| 19 So I guess you kind of look at it as a 20 tool for us to assess risk from an interim standpoint.
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| 21 Any other questions from the room?
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| 22 MR. MELLY: Or any follow-ups from Ken?
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| 23 MR. AIRD: Yes, he has two follow-up 24 comments. It's more than ZOI. It's everything else 25 associated with the examination of the progression of NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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| 128 1 the event. For example, the HGL event is driven 2 because of the burning secondary combustible but we're 3 forced to use the HEAF NSP rate.
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| 4 MR. MELLY: Yes, we're going to be 5 evaluating which aspects of the current zone of 6 influence that's in Appendix M of 6850 or the FAQ on 7 bus ducts as part of that expert elicitation.
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| 8 So anything for the interim risk 9 assessment that we think would need to change from the 10 currently accepted methods will be evaluated from that 11 expert elicitation, moving forward to the sensitivity 12 study. That is the planned path forward.
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| 13 MR. TAYLOR: And just to add you know 14 we're going to be focusing a lot on ZOI because that's 15 your initial explosive area, where you get damage from 16 the initial event. But there is also other 17 assumptions in Appendix M that we need to look at, 18 too. Assuming you that you have peaking release rate 19 as soon as the event occurs, you know that is 20 something that I view as being conservative and 21 there's probably room there to make some improvements, 22 especially from the first phase of testing, where we 23 had the calorimetry equipment taking measurement.
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| 24 Anything else from the webinar? Okay, I'm 25 going to turn it over to Mark Salley.
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| 129 1 MR. SALLEY: Yes, so we're all like thank 2 you. We understand the relationships and that and 3 what we're trying to work through with a lot of this, 4 it's kind of one equation and five unknowns and we're 5 trying to bring that together, as well as what comes 6 first on this. It would be nice if we had all the 7 testing done, we had a lot of the side pieces of it 8 and we could bring it.
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| 9 Frequency, yes, I mean that's a big one.
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| 10 That's kind of what you're going to see the 11 presentation this afternoon with Kenn Miller, where 12 we're changing horses a little bit and saying not 13 everything is a HEAF and we need to get it into the 14 correct bins for our arc flash, arc blast, and HEAF.
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| 15 And I think that's going to be your biggest driver for 16 frequency so that we can get it right.
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| 17 Again, we're seeing these kind of things 18 as we're moving on. And Ashley, I guess we got the 19 fire events database and we can go back and harvest 20 anything out from that to improve that. So, again, 21 there's a lot of different pieces that we're working 22 toward. These will be the discussions we have this 23 afternoon.
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| 24 We're a little ahead of schedule, which is 25 --
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| 130 1 MR. MELLY: Well Mark, on that point, we 2 realized we needed additional work in this area 3 because in briefing our internal management, when 4 we're discussing an event, it's well, was this a HEAF.
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| 5 And the answer was it depends. It depends on the 6 damage states and things like that.
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| 7 So the event that we discussed earlier, 8 that Turkey Point event, in the classical way that 9 we've defined it previously for Bin 15, Bin 16 fires, 10 yes, it was an arc. Yes, it held in for half a 11 second. Yes, it created that pressure wave that 12 opened the door. However, there was no fire.
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| 13 So if that event came in for the event 14 review that we've done for NUREG-2169, yes, there was 15 an arc flash. Someone was damaged or someone was 16 injured during the event but there was no fire. So 17 that would have come close to being screened from the 18 event reporting in entirety.
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| 19 So we wanted to find with these 20 definitions how do we bin these better so that we can 21 answer the question of and link it to how we model the 22 events.
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| 23 MR. LOVVORN: Shannon Lovvorn with TVA.
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| 24 I'm at the Browns Ferry Plant.
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| 25 I'm just going to kind of tag on. I think NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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| 131 1 the idea of getting a pilot plant and helping with 2 sensitivity to help you with realistic is a good idea.
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| 3 I think there's certainly conservatisms in what you 4 did.
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| 5 For those of us in the industry that might 6 be -- it would help with that -- you know it would be 7 really important for us to make sure we think about 8 where we model ZOIs for HEAFs versus boring burns.
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| 9 I think at Browns Ferry we have a mixture 10 of some places we did one or the other but it wasn't 11 consistent with every HEAF. So that could greatly 12 influence even the impact result for that pilot plant 13 in a conservative or non-conservative way. In other 14 words, it wouldn't necessarily be representative if 15 you always modeled a HEAF as a boring burn in places 16 where you didn't have a large CCDP and vice-versa.
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| 17 And so it will be important to us on the 18 industry side to think about who has the right 19 modeling and the insights to be a pilot plant to maybe 20 help give you best information.
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| 21 MR. MELLY: Yes, I agree.
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| 22 MR. MILLER: Did you have a comment, Rob?
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| 23 MR. CAVEDO: So I just want to be clear.
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| 24 I'm not expecting the final frequencies that are going 25 to go into a NUREG. But I think for a pilot effort we NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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| 132 1 can do exactly what you suggested, which is we have 2 fairly good insight about what the HEAF definitions 3 are. And if they are at Turkey Point, then that 4 wouldn't be the one that has the larger zone of 5 influence. That would just be the traditional.
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| 6 So if we could just get the reduction 7 proportional to what we've seen in industry 8 experience, then that would be something that is 9 realistic and would be more easily sold to our 10 management as being able to volunteer for a pilot.
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| 11 Because as I said, I don't think you're 12 going to be able to get anybody in the industry to 13 volunteer for a conservative pilot plant unless 14 they've done something where they always assumed that 15 it was a full room burn and they're going to show no 16 delta risk. And that's not going to give you any 17 insight.
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| 18 MR. MELLY: Exactly.
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| 19 MR. CAVEDO: So anyone who knows that 20 putting in this conservatism is going to show 21 unrealistic results isn't going to want to do it. But 22 if you've got something that's at least in the 23 ballpark of realism, then people will probably 24 volunteer because they want to see how things are 25 going to go early before it becomes something in the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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| 133 1 NUREG that we have to put in.
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| 2 MR. MELLY: I agree and that's how I 3 envision the pilot program going, as a collaborative 4 effort so that we can understand the risk and instill 5 realism into the process with the expert elicitation.
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| 6 Like I said, this is a sensitivity study. It's not 7 going to be a hard-in-stone NUREG or telling plants to 8 do something. This is just an effort to understand 9 where the current risk is.
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| 10 So we do have the flexibility to have a 11 collaborative working process here where we can take 12 into account these things.
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| 13 MR. SALLEY: Yes, so again, for the 14 discussion, Gabe's going to have a little bit I guess 15 this afternoon, Gabe, on the zones of influence or are 16 you tomorrow?
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| 17 MR. TAYLOR: The modeling today.
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| 18 MR. SALLEY: The modeling. So yes, this 19 afternoon Gabe's going to talk a little more about the 20 zone of influence.
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| 21 And also don't forget about where we lock 22 into that three-foot, five-foot, some dimensional zone 23 that when we're talking about the conductive cloud, 24 that may be a whole different type of zone of 25 influence we need to keep an open mind to is the right NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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| 134 1 way to do it. So again, don't put yourself in a 2 corner.
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| 3 With that, I guess we're ready to take a 4 break for lunch here. It's ten to 12:00. We've given 5 I think an hour and 15 minutes for lunch. So if 6 people could be back at 1:15 downstairs in 2 White 7 Flint and we'll get back up here and get started at 8 1:30.
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| 9 Now, if you're not familiar with the area, 10 a couple places you can go. When you go out the front 11 of the building, there's fast food across the street.
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| 12 There's a McDonald's and Arby's. Then there's a 13 Mediterranean place.
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| 14 Going the other way, there is a Harris 15 Teeter. Nick, you're going down to Harris Teeter?
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| 16 MR. MELLY: I've got to do this here.
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| 17 MR. SALLEY: Gabe is going down. So if 18 you guys want to go down to Harris Teeter with Gabe, 19 he can walk you down. We've got a few escorts here to 20 get you there.
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| 21 And Mark Earley, if you could hang around 22 for a minute and talk with Kenn and I, we're going to 23 do some changes on the next presentation.
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| 24 So with that, let's take a break. Let's 25 pick it back up at 1:30 Easter Time. And we're off NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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| 135 1 the record.
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| 2 (Whereupon, the above-entitled matter went 3 off the record at 11:50 a.m. and resumed at 1:40 p.m.)
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| 4 MR. SALLEY: Are you guys ready?
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| 5 MR. MELLY: All right. If everybody's 6 ready, hold on a minute. You're going to want the --
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| 7 MR. SALLEY: What do I want? Oh, the 8 microphone.
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| 9 MR. MELLY: Yeah. The dead microphone.
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| 10 MR. SALLEY: All right. For those on the 11 webinar, we are going to get started again very 12 quickly. I'm Mark Salley, and I'm going to open it up 13 real quickly.
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| 14 Again, I'll have clarification on that 15 power plant discussion.
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| 16 (Off-microphone comments) 17 MR. SALLEY: Okay. So, we'll welcome 18 everybody back here in the second half after lunch.
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| 19 And we'll get started again.
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| 20 A little clarification this morning on the 21 pilot piece. And we understand your concerns on that.
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| 22 And we're looking at some of the questions 23 especially what Kenny had sent in via the webinar. As 24 we're talking about the pilot, you could actually 25 think of two pilots, okay?
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| 136 1 The pilot that Nick is referring to is the 2 piece that we need for the generic issue program. So, 3 that's the pilot there.
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| 4 As far as if we develop the new method or 5 a new way to address the zone of influence or 6 whatever. That would be a totally different pilot.
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| 7 And that's three years out.
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| 8 So again, with the piece that Nick was 9 talking to here, was the piece that we need for Stan 10 to do the risk assessment and the generic issue.
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| 11 So, they're two different pilots there.
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| 12 MR. MELLY: Yeah. And with the part 13 associated with the generic issues process, it's much 14 more of a sensitivity study to look at the risk.
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| 15 When we're looking at down the road after 16 the test program is complete, and potentially piloting 17 a new method for evaluating higher arc for both copper 18 and HEAF in a more dynamic approach that's not one 19 size fits all.
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| 20 That's down the road three years for in 21 align -- it will be on the line with a new 22 methodology. An improvement upon 6850 Appendix M, as 23 well as the guidance that's in the back contract.
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| 24 MR. SALLEY: And you know, a lot of these 25 programs, a lot of these ideas, a lot of these NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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| 137 1 concepts, a lot of these things that we're working on, 2 they're really moving in parallel.
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| 3 I mean, the testing is a big one. And 4 that's a big part of it. But it's moving in parallel 5 with a number of other issues.
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| 6 You know, case in point, the talk that 7 Kenn Miller is going to give you right now is 8 something that we alluded to earlier in Nick and 9 mine's presentation that you just don't have thermal 10 fires and HEAFs, okay.
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| 11 There's a whole spectrum in between here 12 with arc flash and arc blast. And this is something 13 we really want to redefine it, so that we get things 14 properly identified.
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| 15 And then we can get the proper frequencies 16 to it. And once we get that, we can then develop the 17 appropriate risk to the zone of influence.
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| 18 So these are things that we've learned 19 from some of the fire PRA realism workshops. Some of 20 the thing we saw with 1015 and the ZFI plant, going 21 through it. And a number of those things.
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| 22 So again, this program is dynamic. And as 23 we see something and we learn something, just like we 24 did in the testing, you know, we stop it. And we make 25 the correction and we move on.
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| 138 1 So again, when we looked at Bin 15 and Bin 2 16, we saw that wasn't going to get it. We reached 3 out to the NFPA, Mark's going to have a -- Mark 4 Earley's going to have a talk a little later.
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| 5 And this is where we want to get the 6 refinement. So, to be able to do that one of the 7 first things we said, you guys all work from codes and 8 standards.
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| 9 You've got to be able to define it to 10 understand it. If you can't define it then it's hard 11 to move forward. So definitions become very, very 12 important.
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| 13 Any standard you pick up, any NFPA 14 standard or code, the first thing you see in the first 15 chapter is what? Definitions. When I say AHJ, this 16 is what I mean. When I say fire resistant, this is 17 what I mean.
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| 18 So again, as we move into this high energy 19 arc faults and the arc flash, I think we need a real 20 clear definition so we know what we're talking about 21 and what we mean. Especially when we tie that to 22 risk.
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| 23 So, without further ado, I'm going to turn 24 it over to Kenn Miller. And Kenn's going to take it 25 from here.
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| 139 1 MR. MILLER: Yeah. Thanks Mark.
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| 2 MR. SALLEY: Um-hum.
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| 3 MR. MILLER: That's slide one. So as Mark 4 said, we took a stab at several items to define, again 5 for the purpose of common understanding.
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| 6 First five up there. You can go to the 7 next slide. And then the three different, you've got 8 fault arc. Arc fault severity classifications.
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| 9 And so again, I'm going to present to you 10 some proposed that we've come up with so far, proposed 11 definitions for these terms. And the idea is to 12 gather input from you folks, from the industry, from 13 our counterparts, and hopefully get to a good 14 definition that we all agree to.
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| 15 And then if we can use as terms of 16 understanding and directing the research we're talking 17 about here. Go to the next slide.
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| 18 So the first one here, arc or electric 19 arc. And you see the definition we've got here. An 20 arc is a high temperature luminous electric discharge 21 across a gap through a medium such a -- such as 22 charred insulation.
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| 23 This term does happen to be defined in 24 NFPA 921. One of its definitions. Next slide.
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| 25 The next one is arc flash. Arc flash is NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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| 140 1 a release of energy caused by electric arc, 2 characterized by a rapid release of thermal energy to 3 the vaporization and ionization of materials by the 4 arc.
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| 5 This one was developed from NFPA 70E out 6 of the definition of an arc flash hazard. The term 7 itself wasn't defined. But kind of pull it from that.
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| 8 Another note about it, when electrical 9 protective systems as designed, the arcing event is 10 typically loaded to a flash on the order of cycles 11 rather than seconds, depending on breaker subpoints, 12 or protective relay subpoints.
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| 13 Arc flashes typically are associated with 14 self-extinguishing fire events.
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| 15 MR. MELLY: That means these things that 16 you're seeing under here in the notes are our takes on 17 trying to match the classification and the definition 18 that we have with somehow how we treat them in PRA 19 space or modeled space.
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| 20 So how we bend these and how we put them 21 put them on the report in the model mode.
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| 22 MR. MILLER: Yes. Next slide. And we go 23 to arc blast. An arc blast being a rapid release of 24 thermal, mechanical, and acoustical energy caused by 25 a rapid heating and vaporization and ionization of NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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| 141 1 materials resulting from sufficiently energetic arc 2 flash.
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| 3 Arc blasts are more energetic then flash 4 events depending on electrical characteristics of the 5 system during the initiation event. Such as phase 6 angle current voltage characteristics.
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| 7 This definition was also developed out of 8 NFPA 70E, although it wasn't defined specifically.
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| 9 There's an affirmative Annex K4 that talks about 10 blasts.
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| 11 Again arc -- and again, going back to the 12 PRA factors for it, arc blast can cause room over-13 pressurization effects that could potentially lead to 14 missile damage effects from thrown equipment or 15 enclosure material.
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| 16 Arc blasts are associated with flashes.
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| 17 But not all flashes are blasts. And arc blast events 18 still occur when electrical protective systems work as 19 designed.
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| 20 Next slide we've got goes to the HEAF. We 21 see our HEAF here, we've got a high energy arc fault, 22 it's a type of arc flash that persists for an extended 23 duration.
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| 142 1 flaw. One of the comments we had early on, we had set 2 in there typically two seconds or less.
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| 3 And it's kind of hard to, you know, pin 4 down an actual time. So, I changed the definition 5 just to say tying back to the premise that, you know, 6 the HEAF is probably due to some failure in the 7 protection circuit.
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| 8 High energy arc faults are typically 9 associated with events contingent with a failure or 10 lack of circuit protection or adequate circuit 11 protection coordination.
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| 12 High energy arc faults are associated with 13 arc flashes. But not all flashes are high energy 14 arching faults.
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| 15 High energy arching faults may produce 16 varying levels of arch blast.
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| 17 MR. MELLY: Yeah. And this issue of 18 duration that Kenn was talking about has come up on 19 several of our phone calls with NFPA, IEEE, and other 20 folks because the duration is very important to the 21 overall damage sustained.
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| 22 In a lot of literature and for safety 23 personnel protection you'll see two seconds listed in 24 a lot of places. And we've been kind of digging into 25 where that two seconds comes from. And it's nowhere.
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| 143 1 It was generally defined from certain 2 people that were talking about is that's the typical 3 reaction time for a human hearing a blast event and 4 being able to react. And it was a general time frame.
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| 5 So, there was no duration that we could 6 pinpoint as to what duration ties back to the amount 7 of energy released. And that's still something that 8 we're kind of working towards right now.
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| 9 And that ties direct specs into the test 10 program as to what's the minimum duration that we are 11 going to be testing it at now. It gets to a lot of 12 the comments that we'll discuss tomorrow for the test 13 program.
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| 14 MR. MILLER: You know, and again in terms 15 of, you know, protection system functioning, you know, 16 we're used to those kind of systems performing in 17 cycles versus seconds.
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| 18 So, you know, a long duration is typically 19 indicative of some failure of some kind. A relay 20 failed, or a breaker's stuck, or the design itself is 21 flawed.
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| 22 So, again that being a -- that failure 23 being a contributor to the creation of the HEAF. Next 24 slide.
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| 144 1 different classes. The Class 1 damage is contained 2 within the general confines of the component of 3 origin.
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| 4 These events are associated with minor 5 damage and minimal bus bar degradation from melting or 6 vaporization. So this will be the lowest level HEAF.
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| 7 Next one, Arc Fault Class 2, at arc blast 8 or HEAF.
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| 9 (Off-microphone comments) 10 MR. MILLER: This damage is contained 11 within the general confines of the component or 12 origin. However arch blasts have to the potential to 13 damage surrounding equipment through pressurized 14 effects, sever equipment defamation for doors to 15 create fire barriers.
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| 16 Typically, they do not create ensuing 17 fires. Typically associates with the design and 18 electrical coordination breaker performance.
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| 19 Pressure effects are highly dependent on 20 route configuration and electrical characteristics of 21 the event. So that's the medium level.
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| 22 And the Arc Fault Class 3, damage includes 23 the component of origin as well as spread to 24 surrounding equipment within the fire zone.
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| 145 1 on a severe equipment deformation from doors, degraded 2 fire barriers, which protect -- potentially can affect 3 equipment in other fire zones or in an electrical 4 world, other separation groups or divisions.
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| 5 These events are typically contingent with 6 ensuing fire conditions. Typically indicative of a 7 level of circuit protection failure and/or design flaw 8 allowing for extended duration arc events.
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| 9 And pressure effects are highly dependent 10 along the room configuration and electrical 11 characteristics of the event.
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| 12 MR. MELLY: And in terms of what we've 13 been discussing earlier as to redefining these per 14 PRA, like right now we are trying to overall create a 15 definition that's not just nuclear specific.
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| 16 But in terms of how we would use it in the 17 PRA community as well as nuclear. You can think of 18 Class 1 being -- Arc Fault Class 1 typically those 19 events would be included in the Bin 15 fire events, 20 where it's just the component of origin.
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| 21 Class 2 and Class 3 are typically right 22 now how we look, or how we're classifying HEAFs. And 23 we want to make a specific effort to separate those 24 events which do not have this larger zone of influence 25 of damage from the ones that have potential pressurize NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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| 146 1 effects.
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| 2 So hopefully that will marry up with the 3 methodology on how we treat these events. We want to 4 be able to split the frequency, align the frequency 5 definition and the methodology.
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| 6 And this is our attempt to do that and 7 align with the definitions.
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| 8 MR. MILLER: So this next slide shows the 9 three arc fault classes and some pictures of, you 10 know, examples of each type. And some description of 11 the two levels, three levels.
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| 12 MR. MELLY: Yeah, and again, you can tell 13 from the pictures here, we actually pulled these 14 events directly out of the fire events that constitute 15 the frequencies currently.
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| 16 You can see that -- I pulled some of these 17 from Bin 15 fire events. And you see that there's 18 largely damage to the internal components.
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| 19 There's some material degradation of the 20 bus bar stubs itself from the fault. But usually, 21 very limited duration of protection scheme works.
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| 22 So you'll see smoke damage and potentially 23 the initiation of a small fire which may or may not 24 self-extinguish.
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| 147 1 these ones that can have the pressure effects to the 2 room. Possibly contingent with a fire as well.
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| 3 However, the fire that would be associated 4 with these Class 2 events, we wouldn't initially say 5 that it's at the 98th percentile of the heat release 6 rate curve at time T equals zero. So that's another 7 differentiation that we'd want to do to the method.
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| 8 Then these Class 3 fires are what you 9 typically associate with how you're thinking of higher 10 arching faults that make Appendix M methodology. And 11 the -- and Supplement One to NUREG 6850 in the FAQs 12 for bus ducts.
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| 13 So these are the larger damaging events 14 that have the ensuing fires. And the classical zone 15 of influence of damage outside the cabinet.
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| 16 And so, visually it helps to picture what 17 these types of classifications look like.
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| 18 MR. MILLER: And the last slide. Then the 19 last definition, electrical enclosure thermal fire.
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| 20 Thermal fire is an electrical enclosure 21 fire in which the electrical unit does not 22 significantly contribute to the heat release rate of 23 the fire. Rather, the heat release rate is determined 24 solely by the chemical energy released by combustion 25 of the cabinet's contents, and classical fire NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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| 148 1 dynamics.
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| 2 MR. MELLY: And these would be the type of 3 fires handled through the Helen Fire work and the 4 Rachel Fire documentation.
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| 5 MR. MILLER: So, again, our intent was to 6 put these up on the board for you all to see. And I 7 guess if there are any comments that you wanted to 8 provide to us at this point.
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| 9 Or, you know, a day to think about them.
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| 10 As we're doing stuff tomorrow, we can also revisit the 11 definitions once you've had a chance to think about 12 it.
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| 13 But, that was the purpose of the 14 presentation. Yes?
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| 15 MR. RHODES: Yeah, I'm Bob Rhodes from 16 Duke Energy. On your definitions, you need to put a 17 clarifier on there.
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| 18 Because I can read your first one there 19 for the arc flash, and get down to an electrical 20 failure on 108 or 122/40 to a 36/18 volt transformer 21 inside a Hoffman box that nothing ever came out except 22 a little whiff of smoke.
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| 23 And by that definition, I'd have to call 24 that an arc flash.
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| 149 1 currently do not have voltage electrical 2 characteristics built into this.
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| 3 But that maybe something that we want to 4 do for threshold limits.
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| 5 MR. RHODES: Voltage and power -- I'm 6 sorry. Voltage and power release or something like 7 that. Because I'm dealing with one of those right 8 now.
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| 9 I'm trying to decide if that's an IMPO 10 reportable. And with that I'd have to classify it as 11 at least an arc flash.
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| 12 MR. MELLY: That's a good comment.
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| 13 MR. TAYLOR: Yeah. And I think their 14 original definition in 6850 is 440?
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| 15 MR. MELLY: The original definition for 16 HEAF 440, we have seen indication from OPE 17 internationally that there was a higher arching fault 18 as they classified it in a 380 voltage piece of 19 equipment in Germany.
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| 20 That is in the International Operating 21 Experience topical report. That was also one of the 22 larger comments from the international community, to 23 try and investigate the threshold of how low we can go 24 and actually create one of these events.
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| 150 1 because of the amount of resources you have to put in 2 for one test. That performing lower and lower test 3 voltages to get a threshold, eats up a lot of our 4 budget for actual testing.
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| 5 So, it's something that we're considering.
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| 6 But I don't know if it's necessarily going to be part 7 of this next test phase.
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| 8 MR. FUNK: Dan Funk, I have a question.
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| 9 Just a couple of points. On the two second that you 10 had brought up, I think I could be wrong here, but 11 that the basis of that was for IEEE applicable, IEEE 12 standards, mainly C37.
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| 13 That's the basis for everything. For the 14 withstood rating of all the enclosures. So if you go 15 beyond two seconds with high energy, basically you're 16 out of warranty if you will.
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| 17 MR. MELLY: We have --
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| 18 MR. FUNK: And no guarantee that 19 mechanically that the switch here is going to stay 20 together. And then all bets are off.
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| 21 MR. MILLER: Yeah. That's kind of getting 22 to what we were -- what I was saying earlier about 23 that, you know, in the protection world, two seconds 24 is an eternity.
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| 151 1 seconds is the upper bound.
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| 2 MR. FUNK: And that's the second -- in 3 cycles, a few cycles, five to ten cycles --
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| 4 MR. MILLER: Right.
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| 5 MR. FUNK: For your primary trips. So if 6 you're at 120 cycles, something's really, really 7 wrong.
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| 8 MR. MILLER: so C37.
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| 9 MR. FUNK: ANSI C37.
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| 10 MR. MILLER: Yeah. Okay.
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| 11 MR. FUNK: I would suggest getting 12 familiar with those. They will probably be fairly 13 helpful.
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| 14 MR. MILLER: Yeah.
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| 15 MR. FUNK: One other quickie on the 16 threshold. It could be -- again, I was not on this 17 committee, but the Arc Flash Committee, 1584 for IEEE, 18 and I know going all the way back to the 1970s when 19 they started requiring arc fault protection for large 20 load centers.
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| 21 MR. MILLER: Um-hum.
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| 22 MR. FUNK: There was a tremendous amount 23 of research that was done on the threshold for a 24 sustained arc. And so instead of retesting, you might 25 do a good literature search on that.
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| 152 1 And I know there's some really, really 2 good information out there.
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| 3 MR. MELLY: That's a good comment. Any 4 more questions?
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| 5 MR. MILLER: There's one up here. He was 6 next. This guy here was next. Mark was next.
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| 7 MR. TAYLOR: Mark Earley, NFPA?
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| 8 MR. EARLEY: Yeah, thank you. This is one 9 aspect of our program that we're doing a little bit 10 more work on.
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| 11 Because we've done some tests at the lower 12 end. And had situations where we couldn't sustain it.
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| 13 And now we're just trying to explore the 14 floor. And that is in the -- coming into the next 15 phase of our program.
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| 16 So, we weren't convinced that the material 17 already out there in, was conclusive enough. Thank 18 you.
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| 19 MR. MILLER: By floor you mean voltage or 20 energy?
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| 21 MR. EARLEY: Yeah. The floor at which you 22 could sustain an arc. And I recognize that, you know, 23 there might be some qualifying conditions that make it 24 sustainable. Thank you.
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| 25 MR. MILLER: Um-hum. Oh, Ken Fleischer NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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| 153 1 had one.
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| 2 MR. TAYLOR: Next comment from Kenneth 3 Fleischer.
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| 4 MR. FLEISCHER: Yes. This is Ken 5 Fleischer from EPRI. I wanted to just leverage off of 6 what Dan Funk said.
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| 7 Actually, there are switch gear standards.
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| 8 They're two seconds. And circuit breakers are three 9 seconds.
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| 10 And I can trace back to some of the IEEE 11 standards to help support that. That was actually in 12 our official comments on the draft test plans. So 13 they're also in there as well.
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| 14 The second item too, in regards to the 15 high energy arc flash definition, I offer up that for 16 consideration when you talk about typically related to 17 lack of protection or circuit protection failure, I 18 recommend saying multiple circuit failure protection.
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| 19 Because typically, when you start getting 20 into seconds, it means both your primary and your 21 backup probably failed.
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| 22 MR. MILLER: Um, yeah.
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| 23 MR. FLEISCHER: So, I would consider 24 multiple. In fact it gets into other things about 25 what are HEAF events.
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| 154 1 Most of what I read appeared to be failed 2 multiple barriers on multiple accounts. And failed 3 protection, failed -- inadequate maintenance design 4 flaws, and human operator events.
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| 5 So, I would think that even maybe adding 6 that as well considering multiple -- a failure of 7 multiple barriers.
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| 8 That's all I have.
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| 9 MR. MILLER: thanks Ken. Anybody else?
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| 10 MR. TAYLOR: Bob Daley, Region II.
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| 11 MR. MILLER: Mr. Daley.
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| 12 MR. DALEY: Mr. Miller.
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| 13 MR. MILLER: Be good now.
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| 14 MR. DALEY: I'm just looking at your --
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| 15 you've got these -- you've got the different 16 classification.
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| 17 Then you go to the very last slide, which 18 talks about electrical enclosure of thermal fire.
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| 19 MR. MILLER: Yep.
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| 20 MR. DALEY: Well, what do we -- what was 21 your -- what was the purpose for including that? And 22 what are we talking about?
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| 23 Are you talking about like low, or very 24 low energy and control circuits? Is that what we're 25 talking about there?
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| 155 1 Or are we talking about something else?
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| 2 MR. MELLY: No. The --
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| 3 MR. MILLER: I think this more about the 4 fire then --
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| 5 MR. MELLY: Yeah. The reason that we 6 included this was just to be all encompassing for all 7 of the ends that we're talking about. What can happen 8 in an electrical enclosure.
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| 9 And the regular thermal fire the way that 10 we treat it through the fire growth, heat release rate 11 profiles. We were trying to clean up and make sure we 12 had a definition or all our treatments.
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| 13 This one may or may not be necessary in 14 the overall definition if we're going to focus in on 15 the arching behavior.
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| 16 MR. DALEY: Yeah. Because the only --
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| 17 really, I mean, a lot of this has. But if you're 18 talking about low energy control circuits and that, 19 then you're probably talking primarily just, you know, 20 talk about insulation type fires.
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| 21 But when you start getting into anything 22 that's got something with higher energy on it, you're 23 getting into some combination of, you know, insulation 24 and electrical. Even if it starts with the 25 insulation.
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| 156 1 MR. MELLY: Right.
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| 2 MR. DALEY: You know, or a combination of 3 both.
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| 4 MR. MELLY: This was more trying to get to 5 that image that was during Mark's presentation of the 6 two potential paths for an electrical enclosure fire.
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| 7 You have your thermal typical fire 8 associated with Helen fire, Rachel fire, as well as 9 the 6850 heat release profile treatment. Then you 10 also have this separate risk driver, which is the high 11 energy fault -- the faulting cases.
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| 12 So this one may or may not be necessary.
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| 13 But to be all inclusive, we included it here.
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| 14 MR. MILLER: Other comments at this point?
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| 15 MR. TURNER: I have a comment on it.
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| 16 MR. MILLER: Okay.
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| 17 MR. TURNER: I'm Steve Turner. I do a lot 18 of testing work. And we struggled with this a lot 19 too. How bad can things get and how to classify it.
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| 20 I think one of the things you guys might 21 want to consider is you touch on a couple of things 22 here like this. Let's go back to hazard analysis 101.
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| 23 I'm trying to figure out how bad the 24 hazard is with the potential. We can always relate it 25 to energy. Right?
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| 157 1 And ask for every height, how high is the 2 brick off the floor? If you can relate these to 3 energy somehow and you captured it some with the 4 duration thing here.
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| 5 This makes something happen. But as 6 they're defined now, I can sort of see how to Bin it 7 in this category once it has occurred.
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| 8 If I'm trying to analyze my plant, I've 9 got to think about the potential in some other way.
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| 10 These kinds of subjective, this has been, that's been, 11 doesn't work.
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| 12 So if you can relate it to energy, I think 13 that would help. Because for example, it relates a 14 little bit to Kenn's question. My energy is this by 15 the time the primary circuit fails.
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| 16 But the secondary circuit that's in two 17 seconds. Now the energy is higher. And my HEAF is 18 worse. But my frequency is a lot lower.
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| 19 So if we can get back to where we're 20 talking about energy, I think that helps a lot. And 21 your one definition for high energy arching fault, you 22 mentioned the duration.
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| 23 But you could be having an arc maybe just 24 because a contact didn't close. So my arch's over two 25 inches. And my arc voltage is going to be so low that NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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| 158 1 my energy is going to be pretty small.
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| 2 And so duration itself doesn't capture it.
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| 3 What we found after testing, I'll need to drop back 4 one.
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| 5 The hard part about calculating what the energy 6 is, is we all know how to do a short circuit 7 calculations to figure out what our shorting current 8 is. So current's easy.
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| 9 The hard part is, it's harder to do the 10 duration. And it's really hard to do the voltage.
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| 11 Because the voltage really depends on the gap or 12 whatever decides to be arching.
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| 13 And you can't predict that very easily.
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| 14 And you can find that even in the tests where we set 15 it up a certain way. Predictably, I don't get the arc 16 voltage I'm looking for.
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| 17 So the arc energy calculation is hard to 18 do. But even as random as arcs were, one of the 19 things we found out in our Japanese tests, and I think 20 they're leaning toward classifying what do we do about 21 this?
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| 22 When is this a problem is, when we ran a 23 bunch of tests and what the point that we get internal 24 fires in the ca -- inside the cabinet.
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| 159 1 sorts of configurations. And all sorts of currents 2 and all sorts of supply voltages, and ended up being 3 arc voltages too.
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| 4 We pretty much found out if you didn't 5 have at least 25 megajoules in the cabinet, you 6 couldn't set the cables on fire.
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| 7 Now so to them what they're doing, is 8 they're going back and they say okay everybody, don't 9 calculate your protective circuits. And if you get to 10 25 megajoules, you have to do something.
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| 11 But if you're below 25 megajoules, we 12 don't think you get the cabinet for fire on this.
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| 13 Kind of simplistic. More deterministic and not quite 14 what we need for the PRA world.
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| 15 But, you've got to give us something to 16 calculate. These definitions I think are great once 17 we look at the picture and say oh yeah, that's a Class 18 2 because this happened and that happened.
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| 19 Well, I'm trying to put down predicting 20 something in the PRA.
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| 21 MR. MELLY: Yeah, but --
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| 22 MR. TURNER: If you just go back to 23 energy.
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| 24 MR. MELLY: I think you're two 25 presentations ahead of us right now.
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| 160 1 MR. TURNER: Okay.
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| 2 MR. MELLY: But we're going to be 3 discussing how we are going to be potentially using 4 the information of the test two and test one program 5 to create a dynamic model based on the parameters, 6 energy duration that configure to your plant.
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| 7 That is absolutely where we're potentially 8 going to go with this. However, for the definitions 9 piece, I'm not sure about if we want to tie in the 10 energy levels there.
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| 11 We can look at that. However, this is 12 more for binning the frequency once the event has 13 already occurred. We were in that mind set.
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| 14 But it maybe something we can look into 15 whether an energy level can be directly tied in here.
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| 16 MR. TURNER: If you're doing your binning 17 kind of based on this and looking to experience base 18 out there, you may not have enough duration data.
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| 19 But, can you go back and calculate the 20 energy for those events? And be able to put on these 21 slides these were generally 25 megajoules to 40 22 megajoules in the --
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| 23 MR. MELLY: Not from the operating 24 experience data.
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| 161 1 experiments containment.
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| 2 MR. MELLY: Right.
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| 3 MR. TURNER: But I think -- I think you 4 might end up having something a little fortuitous like 5 we had on our internal cabinet fires. Like hey, 25 6 megajoules seemed to be the magic number to fit.
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| 7 We've got enough data points now that 8 they're actually regulated to that. But, I just feel 9 like when we're doing actual analysis and having this 10 sustaining effect that hazards 101 and say hey, what's 11 the energy you're dealing with?
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| 12 That's how you look at the severity of any 13 hazard you have.
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| 14 MR. MILLER: So you have an energy value 15 for Class 1, Class 2, and Class 3.
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| 16 MR. TURNER: Yeah.
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| 17 MR. MILLER: Successfully higher.
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| 18 MR. TURNER: Yeah. And then that way when 19 people can -- that's actually something people can 20 calculate, because I think you'll get enough data 21 where even though it's very difficult to predict what 22 the arc voltage will be, probably for certain sizeable 23 equipment.
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| 162 1 a distribution if you wanted to.
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| 2 And the duration you could relate back to 3 the failures that we're taking about. You know, your 4 primary system this fast. And now your secondary 5 system acted that fast.
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| 6 So, regardless of what the arc wanted to 7 be in duration, you can just let it go. As long as 8 you're protected from circuit response that everybody 9 knows how to do.
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| 10 Let that be your duration. Give the 11 energy levels, put in these bins. That's why I was 12 commenting on cancelling.
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| 13 When you look at your secondary system, 14 that might let it go three seconds. But that's a much 15 lower frequency.
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| 16 So you might still be on the good side of 17 analyzing HEAFs. So, let's just go back to energy if 18 we can.
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| 19 I think it just makes me feel like it's 20 more bounded in something quantitative then just these 21 observations of well, that was a lot of energy, and it 22 hurt this more than this. Or this door blew open.
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| 23 If you relate it to energy I think that it 24 won't override the standby. And things that people 25 can kind of calculate.
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| 163 1 MR. MELLY: Yeah. Thank you.
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| 2 MR. TURNER: Ahead of time.
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| 3 MR. MILLER: One of these presentations 4 will be touching on that.
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| 5 MR. TURNER: All right.
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| 6 MR. MILLER: I think it's two 7 presentations.
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| 8 MR. TAYLOR: Any comments on the webinar?
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| 9 MR. MELLY: Just speak louder.
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| 10 MR. MILLER: So any other comments or 11 input? Like I said, when we get into the other 12 sessions, if something comes up on definitions, we can 13 always take additional as you think, had a chance to 14 think about it.
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| 15 MR. MELLY: And for this specific topic, 16 we have provided the full working list right now of 17 what is in here. And I know that we have had previous 18 calls with NFPA and IEEE. FM has also been included.
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| 19 If we -- if you have any written comments 20 or anything that you would like to provide on this 21 Word document or a write up in either pdf or Word 22 format, that would be greatly appreciated. And we 23 would take those and try to work with those comments.
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| 24 MR. MILLER: Let's see, I guess next we've 25 got small-scale testing. That's next? Is that next?
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| 164 1 MR. MELLY: Yeah. That's good.
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| 2 MR. MILLER: Okay.
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| 3 MR. TAYLOR: Okay. I'm going to stand up 4 if that's all right. My name is Gabe Taylor. I'm in 5 the Office of Research.
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| 6 And what I want to go over here is the 7 stuff that we're doing out at Sandia National 8 Laboratories. And it's the small-scale testing 9 program.
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| 10 It's a little different than what we 11 typically do in the fire research area where we do 12 testing. On account of especially when we look at 13 circuit analysis, we do small-scale and a lot of data 14 all effectively.
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| 15 And then we go too large-scale and make 16 sure that the small-scale results match up with more 17 realistic type of thermal environments and what not.
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| 18 So, here it's a little different. And 19 really, you know, why -- why are we looking at small-20 scales? It really comes into the aluminum aspects of 21 these events.
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| 22 The exothermic energy that we're getting 23 from the aluminum, we want to better understand that.
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| 165 1 perform small-scale.
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| 2 Large-scale is not saying we can't control 3 experimental variables like voltage, current, or 4 duration, those sorts of things. But when you look at 5 the large-scale testing, we'll talk a little bit about 6 this tomorrow, our instruments have to be in the right 7 spot.
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| 8 All right, so if your instruments on the 9 front of the gear and the arc blows out the side and 10 you don't have instruments there, well then you're 11 missing what you really want to capture.
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| 12 So when we go small-scale, we can really 13 focus our instruments and get in closer to the arc.
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| 14 And characterize not necessarily the arc itself, but 15 here we're more interested in the particles.
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| 16 The aerosol and the different types of 17 vapor and molten material that's coming out of the 18 possible material. And the real reason why we're 19 interested in that is we want to understand what is 20 causing this extra energy from the -- when aluminum is 21 involved in these types of events.
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| 22 So, it's a little different from what 23 we've been doing in the past where we're trying to --
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| 24 we use scale experiments to try to get the same 25 results.
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| 166 1 Here, what we're doing is we're trying to 2 work with the University of Maryland, Dr. Jose 3 Trojero. And to develop a model that can predict or 4 estimate the amount of energy coming off of these 5 events from the aluminum reaction due to the particle 6 morphology and size of the particles.
| |
| 7 So what we're trying to learn from the 8 experiments is listed on slide three. We're trying to 9 understand particle sizes, the distribution of 10 particle sizes.
| |
| 11 How fast we're producing the particles at 12 a certain rate. Composition, morphology, degrade of 13 oxidization, as well as the trajectory.
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| 14 One of the thoughts with the model was 15 that as the -- as you get further and further away, 16 the particles change. They coagulate. The morphology 17 is different than when they're close into where the 18 arc is.
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| 19 And as they get out there's going to be 20 less and less energy that they're going to contribute.
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| 21 So the trajectory is also important.
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| 22 From this we're also going to take some 23 mass loss measurements that may help identify how much 24 mass is lost that can then be correlated to an energy 25 release. Probably need a small-scale event.
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| 167 1 So, how are we going to do this? Sandia 2 National Laboratories has a lightening simulator where 3 they've been looking into different types of 4 electrical discharges.
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| 5 And they have a lot of toys out there that 6 are very high speed sophisticated that can 7 characterize the materials and the particles. So, 8 we're going to collect high speed videography, up to 9 five hundred -- or five million frames per second.
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| 10 We probably won't need that type of 11 capability. But one million frames, maybe two hundred 12 thousand frames per second with neutral density type 13 filters so we can actually see the particles that are 14 coming off of the arc and off the bus bars.
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| 15 And then they come right after their super 16 computers and come up with the trajectory speeds for 17 the different particles.
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| 18 We'll also have a proof of concept type of 19 program with this small-scale. Is out there.
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| 20 And I'll show you later one, but there's 21 black carbon tape and silicon aerial gels that will be 22 used to capture the particles. And once they capture 23 the particles they can then take it to their type of 24 spectroscopy and scan electron microscope tools to 25 then analyze the particles.
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| 168 1 So what we want to do here is test out 2 those processes, those post-test analytics to see if 3 they work. If they can characterize the particles.
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| 4 If they do, then we want to employ it when 5 we go up to do the full-scale testing. To capture 6 that -- those particles and make sure it's the one to 7 one comparison.
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| 8 To help support the model that we hope to 9 have from the University of Maryland. Next slide.
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| 10 So here it is a picture of the 11 experimental stuff as well as the illustration that 12 was in the test plan. I'll get to the test plan in a 13 few slides.
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| 14 But basically from the photo you can see 15 two vertical bus bars there. So, the arc will occur 16 near the top.
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| 17 Because they're vertical, the thermal will 18 quickly shoot, you know, off and away. So, the arc 19 will be initiated there by a thin film -- or a thin 20 filament, it's basically a shoring wire that we use in 21 the full scale. But a thin filament here.
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| 22 And then they have cameras at different 23 angles. So you can see a camera there. There's one 24 looking down. Here's one looking in this direction.
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| 169 1 cameras. And then what's not shown here is where 2 they'll do the particle collection.
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| 3 They usually get it pretty close to the 4 bus bars. They ran some shakedown tests, we like to 5 call them, just to make sure that they can capture the 6 particles, their systems are working and get the 7 information that we really want to do before we go and 8 actually do the tests.
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| 9 The testing's not the expensive piece.
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| 10 That we may can do probably 20 or 30 tests a day. The 11 expensive piece is the post-test analysis for the 12 material and their high tech equipment and post-13 processing. Next slide.
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| 14 So now we talk about some of the 15 experimental variables. We can -- now I have a test 16 matrix later on that I want to spend a little bit of 17 time on, getting your feedback on.
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| 18 But, we can get a wide range of voltages.
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| 19 Right now we're proposing those voltages, 48kV and 20 then some medium voltage, .48kV up to 10kV. And 21 currents at any range from .35kA up to 29kA.
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| 22 One thing that we're limited on is 23 duration. So unlike the two plus seconds that we 24 probably be in authority at the KEMA facility, here 25 we're limited to milliseconds, is what they can do.
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| 170 1 And they're also making some modifications 2 to their power system to be able to get a tenth of a 3 second duration. So, it is quite limited on what the 4 duration is.
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| 5 But, those durations, even with the 40 6 milliseconds, it's long enough to create the plasma.
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| 7 And to emboss on aluminum from the bus bars.
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| 8 And from their analytics they can then 9 look at the particles and tell whether it's the 10 filament or the actual bus bar that they're analyzing 11 on the particle side.
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| 12 Bus bar material, we want to -- the focus 13 of this is on aluminum. But we want to also include 14 copper to get some comparisons.
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| 15 Here's the current text matrix. And this 16 is what you've seen in the test plan. I basically 17 went over these on the previous slide.
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| 18 But again, about 20 tests in total.
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| 19 Varying voltage current, time and materials. Has 20 everybody been able to see this before? Are you 21 familiar with this?
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| 22 So, here we can just get into this right 23 now. Going for a little bit due back and after the 24 meeting, or even tomorrow, you guys are welcome.
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| 171 1 came in towards the end of the development, the test 2 point is looking at DC.
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| 3 Now on the DC case they're limited only 4 300 amps. Basically what kind of, you know, welding 5 type apparatus to perform that.
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| 6 If you look at the Op E, there's not much, 7 if any, information on DC arcs. I'm not saying that 8 they can't happen or they aren't significant when they 9 do happen that that lasts awhile.
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| 10 So you know the question that I'm 11 basically posing is, is it worth our time looking at 12 DC? And if it's not, can we reposition some of those 13 tests to get more replicates in other areas?
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| 14 MR. VERHOEVEN: Hello, Bas Verhoeven from 15 KEMA. You talk about on durations of four 16 milliseconds. And how do I prepare that? Because you 17 call around as an AC.
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| 18 Good. But in this time frame it is just 19 some kind of DC like current?
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| 20 MR. TAYLOR: Right. Yes It is a DC 21 current. So these are -- these voltages are scale.
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| 22 So basically on the wave form you're not 23 getting any so at least for these short durations.
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| 172 1 running things?
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| 2 MR. TAYLOR: So they have an MD set. And 3 they have a conductor and capacitors set up to provide 4 the source.
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| 5 Question from EPRI?
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| 6 MR. FLEISCHER: Yeah. Ken Fleischer here.
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| 7 This maybe just more of an observation on the table.
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| 8 It looks like items 8, 12 and 16 don't --
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| 9 doesn't say which one's an AC or a DC test. The 10 columns are empty.
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| 11 MR. TAYLOR: Yeah. That's a good point.
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| 12 We'll get that fixed. So, it should have been AC in 13 there.
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| 14 But as far as, you know, these tests here, 15 does anybody in the room at least see a need for 16 performing them?
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| 17 MR. FLEISCHER: For performing DC?
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| 18 MR. TAYLOR: Correct.
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| 19 MR. FLEISCHER: It has been a very long 20 time, but I worked with an IEEE professor out of Rome, 21 Italy where DC arching faults can have severe damages.
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| 22 And telephone substations that rely 23 heavily on batteries have been known to completely 24 burn down buildings from arching faults. But they may 25 be of a different nature.
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| 173 1 So from an -- if we're in experimental 2 space and exploratory, it may be worth trying those to 3 see what we get.
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| 4 MR. TAYLOR: Okay. And again, you know, 5 this isn't a scaled program. So it may be worthwhile 6 just on -- from the particulate aspect to see there is 7 a major difference between the two.
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| 8 MR. FLEISCHER: Right. The thing I forgot 9 to clarify. With a DC arching fault, the reason why 10 they can be so catastrophic is you don't have the zero 11 crossing as you do in AC current.
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| 12 So therefore, you don't have that 13 momentary extinguishing and restriking the arc. In DC 14 they can persist.
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| 15 MR. FUNK: Yes. This is Dan Funk. I just 16 want to second what Ken said.
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| 17 I think from -- or it's pretty soft 18 testing. You know, the desert retesting we have 19 pretty good evidence that the DC can be pretty 20 damaging.
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| 21 The other thing is, nuclear plants have 22 very large batteries. So the available fault arc can 23 be extremely high.
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| 24 And you just work the energy numbers like 25 Steve was pointing to. You know, 10 thousand amps of NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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| 174 1 DC with no zero crossing, and once we have those, a 2 tremendous amount of energy.
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| 3 So, I think it's a good test to run. The 4 fact that you're limited to three hundred amps, I'm 5 not sure about that. That may not be great.
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| 6 MR. TAYLOR: Okay. So I'm not hearing any 7 feedback to get rid of those tests. Any other 8 opinions in the room?
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| 9 MR. MILLER: We just had -- we don't have 10 any OP B on DC events, right?
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| 11 MR. TAYLOR: None that I'm aware of.
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| 12 MR. MILLER: So Nick's the OP B man on 13 HEAF. So, he's shaking his head no. We don't have 14 any OP B for HEAF in plants.
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| 15 But, you know, that doesn't mean it can't 16 happen or that it would be catastrophic.
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| 17 MR. TAYLOR: I agree with that to some 18 levels.
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| 19 MR. FLEISCHER: There was years ago an 20 AT&T -- I'm trying to think of when it was. Maybe 21 about in the mid 90s there was an AT&T. It's not 22 nuclear.
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| 23 MR. TAYLOR: Right.
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| 175 1 batteries that burned down from a DC arcing fault that 2 would not -- that was -- that did not self-extinguish.
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| 3 If I can remember or find that OE, I'll 4 see if I can bring it up.
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| 5 MR. TAYLOR: I guess the other thing that 6 I wanted to mention, and I don't think I have a slide 7 on it, is that -- could we go back to the diagram of 8 the set up? Right there.
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| 9 So these were kind of the shakedown tests.
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| 10 And you see the bus bars. They're fairly big.
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| 11 I can't remember the size they used here.
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| 12 But you know, you're basically looking at a 13 centimeter, by four or five centimeters, a rectangular 14 bus bar.
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| 15 The one thing that they identified was 16 that when they tried to go and do the Raman 17 spectroscopy to look at how much material had been 18 lost or eaten away from the busses, they were having 19 some difficulty.
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| 20 So one of the things that they wanted to 21 do, and it's in the test plan. But there are some 22 errors with the test plan associated with it.
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| 23 Is basically scale down the bus bars to 24 make them smaller. And by doing that they should be 25 able to get better measurements of the mass loss.
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| 176 1 So what they proposed and the test when it 2 went out, is to do a one millimeter by three 3 millimeter bus bar. So that's pretty small.
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| 4 And you know, I questioned them. You 5 know, is that so small that it's just going to deflect 6 away? Or, you know, blow apart and then you don't 7 have anything to go and measure anyway, because you're 8 picking pieces up and, you know.
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| 9 So we're still working on that. They're 10 going to actually run a few more shakedown tests to 11 see if that is the case.
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| 12 But again, we're trying to scale down the 13 bus bars such that we get a better, more accurate 14 measurement. So I know Ashley brought that up. And 15 Jeff Wagner from Southern Company brought that up as 16 well.
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| 17 The other thing is that arcing -- in the 18 test plan there's an error in the arching wire. It 19 said we used six American wire gauge. We're actually 20 using a filament.
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| 21 So a filament is like 10 to the minus 6 22 millimeters. Like it's really thin wire. It's what 23 we use in these experiments.
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| 24 It's a copper filament. So, again, on the 25 post-test analysis we'll be able to make the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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| 177 1 difference between a copper filament and aluminum bus 2 versus -- and vice versa for when you have the copper 3 bus for the particle analysis.
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| 4 Keep going. Go back to that test plan.
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| 5 So again, if there's any comments or 6 feedback, we have three medium voltage that we're 7 testing. I don't really see too much 10kV at least in 8 the US plants.
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| 9 International plants, I think there's 10 more. But you know, obviously we have 12, 13kV plants 11 out. Again, we're looking for some feedback here.
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| 12 If you want to give it to me now that's 13 fine. If later after the meeting, send me an email.
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| 14 The time line, which I'll get too later, 15 we're looking to do these tests sometime in late June.
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| 16 This bar count.
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| 17 So, we need that feedback fairly, fairly 18 soon. Also scale currents. Any feedback on that one 19 too.
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| 20 Shannon Lovvorn from TVA.
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| 21 MR. LOVVORN: Yeah. This is Shannon 22 Lavvorn with TVA. And I was just curious, do you guys 23 think that you're going to be to try to project 24 different voltages from this data?
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| 25 Well, one thing that comes to mind is like NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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| 178 1 isophase bus, for example, you know, it's most plants 2 will be higher than 10kV. And sometimes with the 3 aluminum bus and trying to model isophase bus faults, 4 not exactly sure if we can project what this looks 5 like for those who are being thought and put in that.
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| 6 MR. TAYLOR: That's a good comment. I 7 don't have the answer to it.
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| 8 MR. LOVVORN: Okay.
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| 9 MR. TAYLOR: We can take that back to 10 Sandia and see. Obviously the guys that work in the 11 lightening simulator have a lot more experience at 12 modeling.
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| 13 And the extrapolation, it might be 14 possible. I just don't have a good answer for you.
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| 15 MR. MELLY: That's also something that 16 we're looking for in the larger test program. If we 17 can do extrapolation across both of this incurrence 18 that we are -- have selected to test at.
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| 19 And that's why we're trying to get a range 20 of currents and voltages in the test program. In 21 hopes that maybe we can do extrapolation beyond it.
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| 22 MR. CAVEDO: So, we spend a lot of money 23 on 125 OTC coordination, evaluations, and I was 24 wondering from the electrical folks, because that's 25 not my background, but how difficult is it to have NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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| 179 1 these higher current and volt allowed plant on 25 volt 2 DC system?
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| 3 Because it seems like it would be much 4 less likely then at some AT&T station where they don't 5 have to do all the detailed evaluations. Is that 6 something where it's just not practical to happen in 7 a nuclear power plant?
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| 8 Maybe we don't need to do this? Maybe we 9 could do testing in other areas that's more important?
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| 10 MR. TAYLOR: Anybody want to answer that?
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| 11 MR. FLEISCHER: Ken Fleischer from EPRI.
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| 12 Yeah, historically I haven't seen a lot of arcing 13 faults in DC systems.
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| 14 Usually they've been more three phase 15 bolted for three phrase. They've been more like a 16 bolted or a low resistance fault.
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| 17 But if we're in an exploratory space right 18 now, this would be the time to get it. We finally, or 19 if we want to go back to it, we'd have to re-contract 20 the facility, rewrite the test plan and all that.
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| 21 But the thing is that when you do have an 22 arcing fault in a DC system, they're very nasty. So, 23 I'm not sure if I'm answering your question though.
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| 24 (Off-microphone comments) 25 MR. FLEISCHER: Some -- there are -- the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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| 180 1 newer DC systems do. Older DC systems may still only 2 have one fuse.
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| 3 MR. MELLY: And since we are in DC, 4 everyone can look at the metro failures and problems 5 that we continuously have on our DC system.
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| 6 MR. FLEISCHER: Yeah. No, no, you're 7 right. You're right. The single fuse are typically 8 in the 120 volt control power transformer fuses.
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| 9 But yeah. Yeah, usually there's two 10 fuses.
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| 11 MR. MILLER: Usually it's two.
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| 12 MR. FLEISCHER: Yeah. Usually it's two.
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| 13 MR. DALEY: Yeah, I don't -- I guess that 14 you'd almost have to look and see if they've done some 15 OA and see if they've actually had these type of 16 events.
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| 17 I know Kenn Miller. I work with Kenn a 18 lot. We did a -- there's a NUREG and what's the 19 number on it? We gave it a number.
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| 20 MR. MILLER: 6778 21 MR. DALEY: 6778, what we did. Because we 22 found out that the -- through a plant event that the 23 DC system was not coordinated properly.
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| 181 1 at the actual charger.
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| 2 So we went through at Brookhaven and did 3 a lot of short circuit testing. And you know, so we 4 got amperages, we got, you know, time to trip the 5 clear the -- yeah, clear the fault.
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| 6 But I kind of agree with what you were 7 saying. I mean, if we -- if it's not that difficult 8 to do, why not do it?
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| 9 So when the event actually comes up, we 10 can actually, I mean, we could actually -- we have 11 something. Right?
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| 12 But I mean, if it's really a big problem, 13 then I think you'd almost just have to look and see 14 how many events we've had. If we've had no events, 15 then we just go from there.
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| 16 MR. MELLY: That may bring up another 17 question. Is that the current large-scale, full-scale 18 HEAF program does not have any DC systems for planned 19 arcing.
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| 20 Whereas we can do this. And this is 21 currently going to investigate the particle size 22 things and everything that Gabe went over as outputs 23 of this test program.
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| 24 We have nothing in the large-scale 25 program, whereas it could be an option to add it in.
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| 182 1 And again, we'll have larger discussions tomorrow.
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| 2 But, it may, if we feel like it's 3 worthwhile to do, we may want to do a few.
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| 4 MR. DALEY: It was not easy. As a matter 5 of fact I remember it wasn't really easy to get 6 batteries and to get everything, the equipment and 7 all.
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| 8 MR. MELLY: We will have -- I believe KEMA 9 can speak to it a little bit. But they have the 10 capability of doing a DC system.
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| 11 So, we can run the test without getting 12 the battery banks and things like that.
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| 13 MR. DALEY: We don't -- yeah, we don't use 14 those.
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| 15 MR. MELLY: Right.
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| 16 MR. MILLER: Yeah. I guess to answer your 17 question, Bob, we had batteries and charges set up for 18 some other types of testing events. And we already 19 had the infrastructure in place to do this additional 20 fault test.
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| 21 I guess the other thing too is that going 22 back too again, to the nature of a DC event versus an 23 AC event. And again, with the small-scale we're 24 looking at the physics of what goes on in the fault.
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| 183 1 think, the difference being able to compare AC and DC.
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| 2 So again, I too would make the case that doing some 3 DC, I think, is worthwhile.
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| 4 Plus, along with all the energy it's --
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| 5 again, at a nuclear plant, they do have very large 6 batteries with many amp hours of capacity. So their 7 potential to drive an energy event is huge.
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| 8 MR. FLEISCHER: Yeah. I used to do DC 9 short circuit ops. I've seen them go as high as 17, 10 18 thousand amps.
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| 11 But again, we're talking -- that's a low 12 resistant fault. We're talking arcing faults which 13 have a characteristic in nature much different than a 14 low repeating fault.
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| 15 MR. MILLER: But the energy is there.
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| 16 MR. FLEISCHER: Yeah. That's going to 17 come back.
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| 18 MR. TAYLOR: I think we'll go ahead and go 19 on the next slide. Again, looking for feedback on any 20 changes.
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| 21 I haven't heard any yet. But if you do, 22 please get in touch with me.
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| 23 Measurements, we went over this a little 24 bit. Videography, taking the high speed imaging. And 25 then they can put that in their computer system and NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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| 184 1 actually track particles. You're already seen some of 2 that from the shakedown test.
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| 3 Aerogels to collection, again, proof of 4 concept. If it works here we'll probably do it full 5 scale.
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| 6 And then from those collection techniques 7 there are a bunch of different post-processing 8 analysis tools that they can use to characterize what 9 the aerosol is. So, I'm not going to get into all of 10 those.
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| 11 But you see here, well it's small, but the 12 photograph to the left is basically showing you what's 13 the arc. For one experiment on the shakedown test.
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| 14 And from that they can all use it. So, 15 one thing I found interesting with that is that they 16 can then look at that, put it in their system -- in 17 their tool, and they can look at the soot deflector.
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| 18 And because it has a characteristic 19 similar to graphite, they can actually -- they say 20 they can predict what temperatures that the bus bar 21 has reached from the residual carbon on the bus bars.
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| 22 You can go to the next slide now. And 23 then using our scanning electron microscopy, they can 24 then get into see what type of diameters.
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| 185 1 can look at was it a vapor, was it a molten material?
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| 2 Because of the characteristics of this, 3 they're seeing a lot of molten material in the 4 particles. So, it melted and it re-solidified.
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| 5 So again, you know, surface area 6 oxidation, trying to understand what contributes to 7 that extra energy from the aluminum type of events.
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| 8 Next slide.
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| 9 Just touch briefly on the modeling.
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| 10 Again, we're trying to collaborate with the University 11 of Maryland, College Park, Dr. Jose Trojero to develop 12 a fundamental energy model.
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| 13 And some of the -- we met with him about 14 18 months ago. You know, the things that he needed 15 were really the particle characteristics that we're 16 trying to get from this experimental program.
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| 17 So really, he has a model he's developing.
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| 18 And we're -- this is the input that's going into the 19 model to help further develop that approach to 20 characterizing it.
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| 21 And then towards the end here. You know, 22 there's advantages and limitations to everything that 23 we do.
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| 186 1 very close.
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| 2 From that cost, it's a pretty cheap 3 experimental program from a, you know, the other types 4 of experiments that we've run in the past. You know, 5 it's probably less than one percent of what we spend 6 on HEAF in general.
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| 7 So far a lot of different tools they can 8 use. They take the measurements and we control the 9 variables a little better.
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| 10 Limitations. The biggest limitation is 11 duration. You know, milliseconds compared to what 12 we're trying to do full-scale, you know, it's much 13 shorter.
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| 14 And also, we're only using a single phase.
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| 15 So, you're going to get one or the other. In a three 16 phrase system, we get multiple arcs starting in the 17 same path.
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| 18 Touch on the Federal Register Notice. We 19 put the draft test plan out for public comment 30 20 days.
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| 21 The draft comment period closed April 4.
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| 22 There's a Docket ID, NRC-2018-0040. You go to 23 regulations.gov you can find that information. The 24 direction notice has a plan.
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| 187 1 receive two comments. On April 2 we got comments in 2 from an engineer at Beaver Valley .
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| 3 And then on April 3 we got a request from 4 NEI to extend it an additional 45 days. We haven't 5 received anything from our admin or Federal Register 6 Notice Office on the extension.
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| 7 So, because of limitations on our 8 contract, it can't be extended anymore. And also 9 budgetary constraints.
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| 10 What we plan on doing is we don't want to 11 shut you off. So we're going to basically add another 12 30 days.
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| 13 So if you can get me any comments on the 14 test plan by May 4, next month, I'll go ahead and add 15 those comments to the Adams. I'll make it publically 16 available.
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| 17 And then we'll treat them just like we 18 treat any other comment that would have come in on the 19 Federal Register Notice. So again, my email is up 20 there.
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| 21 And anything you have, you want us to 22 address, please send it to me by that date. And then 23 that gives us the team, the NRC and the Sandia team 24 enough time to thoroughly review the comments, access 25 them, make changes as needed.
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| 188 1 And then start the testing at the end of 2 June. And then the test plan -- our contract ends at 3 the end of September. So there's a lot of back and 4 forth and report generation.
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| 5 And because we couldn't -- we tried to 6 extend it, and we couldn't extend the contract anymore 7 that's kind of our hard stop on this.
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| 8 So again, basically a total of 60 day 9 public comment period. Get your comments to me if you 10 haven't done so so far.
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| 11 And that's it for me. So are there any 12 questions on the small-scale testing? Anything on the 13 webinar?
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| 14 MR. MELLY: We have one question.
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| 15 MR. LOVVORN: Shannon Lovvorn with TVA 16 again. Looking over the test plan, I saw a discussion 17 of some of the testing being phase to ground. And 18 obviously the voltages we're talking about here are 19 phase to phase.
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| 20 So, is it because of the test set up 21 you're going to do a say a 480 volt test, a 480 volt 22 phase to ground? Is that how you're doing the test?
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| 23 Or is it just -- sometimes I'd read, you 24 know, voltages and phase to phase voltages. And then 25 I'd read, you know, phase to ground testing NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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| 189 1 discussion.
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| 2 I got a little confused in the test plan.
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| 3 MR. TAYLOR: So the question is, is it a 4 phase to phase or -- is it a line volt or a phase to 5 phase volt?
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| 6 MR. LOVVORN: Yeah. Well, is it -- yeah, 7 I guess I'm trying to understand why we're talking 8 about phase to phase voltages and phase ground 9 testing.
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| 10 And is it just simply the test setup 11 that's driving that? Or --
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| 12 MR. TAYLOR: So it is -- that's a good 13 question. It is the test setup. So the voltages that 14 we have here will be the voltages across the two 15 processes.
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| 16 So basically a phase to phase voltage.
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| 17 And not a phase down, or a line voltage. Okay.
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| 18 Any other questions? Any other on 19 background? Bob Rhodes from Duke?
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| 20 MR. RHODES: Yeah. This is Bob Rhodes 21 from Duke. Is your 480 volt test plan going to bound 22 the plants that have 600 volt weather control centers?
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| 23 MR. TAYLOR: I'm not sure it will bound 24 it. You know, it does provide some data point at low 25 voltage.
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| 190 1 MR. MELLY: Yeah. That's going to be 2 another question for extrapolation.
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| 3 MR. RHODES: Can you extrapolate on that?
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| 4 MR. TAYLOR: I think I'll have to take 5 that one back. I'm not sure. So, we can add that to 6 that.
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| 7 MR. TURNER: What they're talking about 8 here is the supply voltage. That really makes a 9 difference in what amps are the plasma and melting 10 things is the arc voltage.
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| 11 And that's generally set by the gap. So 12 whether you get it at 480 or 600, it probably isn't 13 going to change the arc voltage very much.
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| 14 And I don't know what their predicted arc 15 voltage is. But that's really where you get the 16 energy from.
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| 17 The same with the medium voltage tests.
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| 18 You'll probably get close -- if you don't change the 19 gap, you're going to get about the same arc voltage on 20 those tests.
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| 21 MR. TAYLOR: Okay.
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| 22 MR. TURNER: You really look at the gaps 23 is what you're looking at.
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| 24 MR. MELLY: Right. And for the full-scale 25 testing where we did low voltage, 480 volt tests, our NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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| 191 1 arc voltage was on average around 380 volts.
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| 2 For a medium voltage, our average was 3 right around 830 volts for the arc voltage itself.
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| 4 MR. TAYLOR: Yeah. So that, I mean, that 5 brings another good point. And I have some slides to 6 get to what Mr. Turner's brought upon arc voltage and 7 separation distance, at least from our phase one 8 testing.
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| 9 But, and I don't want to go too long, 10 because I'm already over my time. But, you know, 11 maybe that's another variable. Gap space.
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| 12 Because right now, I don't think, they 13 plan on changing their gap spacing. So your arc 14 voltage is going to be what it is.
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| 15 So, given that, you know, it might not 16 even be worth adjusting your medium voltage. Right?
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| 17 It might be more worth where you have low voltage 18 testing, you have a medium voltage set point, and then 19 you do some variation in your gap spacing.
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| 20 So, good feedback. Okay. I think we need 21 to move onto the next one.
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| 22 Okay. I don't think this one's going to 23 take too long. Basically, you know, trying to look at 24 where we want to go with this. And why we're doing 25 all these -- this testing.
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| 192 1 You have to look at -- I say PRA modeling, 2 but what I really want to get at on this is the HEAF 3 modeling.
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| 4 You know, what -- when I talk about HEAF 5 modeling, zone of influence is really what we're 6 concerned with right now.
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| 7 So how -- how are you going to go and 8 improve upon the current method for the ZOI that we 9 currently have in 1650 to make it more realistic? To 10 maybe be more representative of the plants' 11 configurations.
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| 12 So we need to just do a quick review of 13 the existing models. In 1650 you have two models.
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| 14 You have the one that's in Volume Two, which looks at 15 the electrical enclosure.
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| 16 And basically anything within the zone of 17 influence, which is one and a half meters in the 18 vertical direction, or five feet. And then .9 meters 19 or three feet in the horizontal direction.
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| 20 You assume it's both damaged. Physically 21 damaged and it's also functionally failed.
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| 22 And then you've got the fire that occurs 23 after that. So you assume ignition and then you 24 follow the typical, you know, classical fire modeling 25 approach that's in Appendix E and G of 1650, Volume NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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| 193 1 Two. Next slide.
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| 2 In Supplement One of 1650 we also have 3 segmented bus duct HEAF event. And in that you 4 basically assume that you have a failure.
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| 5 You have the sphere that goes around the 6 bus duct that's one and a half feet. I think that's 7 -- is that a radius? I'd have to double check.
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| 8 MR. MELLY: Yes. It is.
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| 9 MR. TAYLOR: You have a sphere. And then 10 you also have this cone of death that has been 11 referred to.
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| 12 And it's basically a cone with a 30 degree 13 down cone, or 15 from the vertical. And it goes down 14 until your diameter is, you know, you hit the ground 15 and your diameter is 20 feet or a total drop of 37 16 feet below the fault if you have that much room in 17 your configuring.
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| 18 So those are the two ways that we model 19 ZOI right now. It is -- the next slide, it's 20 bounding. It's conservative. It's based off of, you 21 know, what they've seen from operating experience.
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| 22 And with the aluminum, you know, the 23 question that comes to mind is, does aluminum fit this 24 model? Or is it something larger then this model?
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| 194 1 know, let's assume we exclude aluminum, you know, this 2 doesn't capture all the variability that's in the 3 plant.
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| 4 You know, you have a HEAF event, it 5 doesn't mean you're going to get this much damage.
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| 6 And a lot of other events you look at, you don't have 7 that much damage.
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| 8 Or you don't have some of the other 9 assumptions that go into the modeling of a fire 10 occurring. So, what we're trying to do here is 11 advance or improve the models to make them more 12 realistic. Next slide.
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| 13 So, kind of the way that we've broken it 14 down, is potential pass forward. Is that we've been 15 sticking with the current approach and just refine it 16 to include aluminum, you know, bounding worst case.
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| 17 That's one way that we could do.
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| 18 Another thing that we could do is we could 19 start looking at what variables impact the heat and 20 the ZOI. Whether it's power energy volts, or voltage 21 current, the protection scheme that's being used for 22 the circuit material, safety class, what not.
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| 23 I listed all the variables that could 24 potentially influence the categorization of the 25 equipment. But, for each of those categories then NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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| 195 1 you'd have your own type of ZOI determination.
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| 2 And again, this would be somewhat similar 3 to what was -- is currently modeled. You know, it 4 would have that, you know, physical dimension around 5 the equipment.
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| 6 But based on the influencing plan or what 7 category it is, you have different ZOI dimensions. So 8 that's kind of the second, you know, way that we could 9 break it down.
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| 10 And the third way that I've listed there, 11 it's similar to what they do in the arc flash 12 calculations in IEEE 1584. Where basically you have 13 system information on duration, voltage current, and 14 cap weight and incident energy.
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| 15 And because that standard's worried about 16 human safety or physical protection, personal 17 protection, anything, you know, below 1.2 collars per 18 centimeters squared, I think that's the units, you 19 don't need protection. And anything above that, you 20 do, to alleviate second degree burns.
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| 21 So, something like that, you know, could 22 be extrapolated to what we need here. You know, some 23 -- we'd probably follow something similar to what's in 24 IEEE or even the Lee approach that came out of the 25 80s.
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| 196 1 And I think that's achievable. The one 2 thing that we still have to do on the back end then, 3 is what's your target fragility?
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| 4 When are your cables going to be damaged?
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| 5 When are you, I don't know, your pump or whatever 6 other equipment that's important to plant safety, when 7 is that going to be damaged?
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| 8 And we do have current thresholds for 9 damage. But again, we're talking here about something 10 that's a high intensity, short duration.
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| 11 And we're using the temperature thresholds 12 for possible fire, heat transfer. Do those match up?
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| 13 Are there ways that we can use that information to 14 develop a target fragility for these HEAF type of 15 events?
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| 16 That's something that we're looking at 17 what possible solutions or methods to try to 18 characterize that. But, we're not there yet.
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| 19 So that's one of the -- one of the aspects 20 there for the dynamic ZOI.
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| 21 MR. MELLY: And for the larger scale test 22 program, you'll see when we discuss how we plan on 23 instrumenting, as well as what information we're going 24 to collect, how we are heading down that path of 25 trying to create this dynamic zone of influence model.
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| 197 1 Where you can take the idea that that 2 Steve was discussing earlier, of going more scenario 3 specific. Of, I know what my voltage level is. I 4 know what my current is. I know my circuit 5 protection, my secondary circuit protection.
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| 6 And I can postulate how long this arc will 7 hold in for. And what type of energy will be 8 released.
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| 9 And trying to be eventually leading to 10 link that up to a scenario-specific zone of influence.
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| 11 MR. TAYLOR: And I guess the other 12 question is, and I have a slide later, but you know, 13 how much time and effort do you want to put into 14 applying the method or even developing the method?
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| 15 You know, if you can get away with a 16 bounding approach, then, you know, doesn't that work 17 for your plant? If you can't, you might want to 18 sharpen the pencil and have this approach available.
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| 19 You know, if that doesn't work you might 20 even be able to use something like this. So, you 21 know, picking where we want to go.
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| 22 We haven't said this is the route we're 23 going. We want to understand where we can do with it.
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| 24 And make sure that we are collecting information that 25 will support any event.
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| 198 1 MR. MELLY: Yeah. And it's important to 2 realize that in the larger scheme of how we plan on 3 doing things in that if we are testing one piece of 4 equipment in the next test program at two seconds or 5 four seconds, we're doing it within mind that the 6 possibility to get to this dynamic zone of influence.
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| 7 Rather than just slapping this is the 8 worst case that we saw. At an eight second duration 9 arc you have to then use this for every bounding case 10 in your analysis.
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| 11 That's not our intention with the longer 12 duration events and the test program.
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| 13 MR. TAYLOR: Yeah. And just to add on the 14 dynamic piece. Steve Turner brought it up earlier.
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| 15 Is that if you look at both of these, this 16 is -- I modified it slightly just to make it more 17 anonymous. But this is the lead equation.
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| 18 This is that accurately. And basically 19 you've got similar terms. You have voltage. You have 20 current. You have time and you have distance.
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| 21 And down here you have the same thing.
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| 22 You have time, distance, current, and they use the gap 23 spacing to estimate their arc voltage.
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| 24 So, you know, those are the parameters we 25 know that's important. And we're capturing those in NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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| 199 1 our testing.
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| 2 We're trying to work with everybody here 3 in the room as well as other stakeholders to make the 4 testing realistic to support this. Next slide.
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| 5 So, just getting into, you know, kind of 6 the pros and cons, worst case, the bounding current 7 model worst case. One size fits all.
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| 8 Your damaging the right components in the 9 ZOI. And you assume you have your peak heat release 10 rate as soon as you have hertz.
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| 11 So, if you don't think that is 12 conservative, I must have missed something. Or Nick 13 missed something when we talked about it earlier.
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| 14 Although this is -- would be one of the 15 more simpler models of the approach. You need the 16 least amount of information to apply it.
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| 17 It's not really that realistic. The 18 majority of the cases out there, at least from the 19 operating experience that we've reviewed, if we look 20 at, you know, a lot of the events like the Brunswick 21 event or the Turkey Point event, you know, it really 22 doesn't match what this model's doing.
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| 23 So, you know, not much realism there. And 24 however from both the application as well as the 25 development costs, it would probably be the cheapest NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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| 200 1 approach. Next slide.
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| 2 The refined bounding ZOI. Again, you have 3 to break down equipment types, power, all the 4 different variables and understand how those affect 5 your ZOI.
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| 6 So, you know, looking at the testing that 7 we're doing, as well as the testing that's been done 8 in the past, we have to collect a lot of information 9 to help us develop those ZOIs.
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| 10 Because of, you know, you're basically 11 getting more information, you can make it more 12 realistic. However, as far as more information from 13 -- to apply the methods to your PRA, and also your 14 time to develop it.
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| 15 And then the last piece is the most 16 complex, most costly to develop. But it also could 17 potentially provide the most realistic results.
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| 18 I mentioned the fragility of being one 19 part of the equation that we're still working on. We 20 don't have a clear path forward for addressing that.
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| 21 I'm not saying that it can't be. But I 22 don't want an obstacle we'll have to attack. And you 23 have a more physics of failure type relation to the 24 model.
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| 25 So, it's not just the worst case. So, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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| 201 1 pretty self-explanatory. Next slide.
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| 2 So what do we need? You know, the NRC is 3 here concerned with this. Plant safety, reasonable.
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| 4 You know, realism versus cost and time.
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| 5 That's what we're really weighing here. You know, we 6 can't -- we want to wait and come up with a ZOI and 7 spend all this time and effort if the bounding one is 8 going to meet our needs.
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| 9 So, we want to make sure we're aware of 10 what we can do. We're collecting data to meet the 11 needs of those categories.
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| 12 And you guys are going to help us with at 13 least or the middle one. Especially making that one 14 realistic on equipment types, powers, you know, 15 maximum currents or realistic currents, all currents.
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| 16 So, that's really where we'll weigh in 17 here in trying to figure out in the end what we'll 18 develop.
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| 19 Any question about the modeling?
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| 20 (No response) 21 MR. TAYLOR: It's not to say that there's 22 not other ones out there. But, these are just what 23 we're looking at right now.
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| 24 And if there are others, that would be --
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| 25 we'd be interested in learning more about those.
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| 202 1 MR. TURNER: If I could just make a 2 comment on the state of the art of these models, 3 reflecting on the other models he was talking about.
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| 4 He's right. It's really expensive.
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| 5 There's a lot of stuff out there that he hasn't 6 covered yet that the NRC could probably leverage off 7 of. There's been a lot of development. CFP models 8 for example.
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| 9 Not that we would expect utilities to go 10 do CFP models of all their campus while their flux is 11 two feet away.
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| 12 But there are two factions in the IEEE 13 publications that are out there, the published works.
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| 14 A great number of them relate to the IEEE 1584 in 15 protecting people.
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| 16 But there's a whole other school that does 17 nothing but computational fluid dynamic modeling. And 18 matching it to high energy arcing models.
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| 19 Or developing fairly simple energy balance 20 models, which have the level of ability. A bunch of 21 manufacturers in Europe got together and put together 22 a pretty good model that all are actually duplicating 23 what we see in these experiments, the high energy 24 experiments.
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| 203 1 they all are just maybe a 14th of a second or half a 2 second. They don't go for longer durations.
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| 3 But, I've been modeling with Japan now on 4 longer durations and matching it up to data. So there 5 are CFP models out there that may help you predict 6 these things.
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| 7 And I think we share that stuff with EPRI.
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| 8 So they'll be able to leverage off of that. And 9 that's in addition to even the empirical models you 10 see.
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| 11 And both factions in IEEE work just fine.
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| 12 It's just a different direction that each one of them 13 have.
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| 14 But just -- we're using hands as fluent.
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| 15 And we're not even using the plasma physics model.
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| 16 And we're coming up with some pretty good results.
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| 17 So, the state of the art of the modeling 18 is actually pretty far along. And it is being shared 19 with the NRC. So they can leverage off of that.
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| 20 MR. TAYLOR: I guess the last thing I 21 wanted to mention, and it's a very important point, is 22 that a lot of this modeling is looking at the thermal 23 aspects.
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| 204 1 distance away from the arc. As Nick mentioned from 2 the experiments, you saw the conduct of byproducts.
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| 3 That cloud of material.
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| 4 It's not like in any conductivity issues 5 associated with that. It's also -- and it's also not 6 looking at pressure, although there are models out 7 there that can estimate pressure.
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| 8 And another thing that it's really not 9 looking into, and it's an important piece, and we 10 might only be able to capture it through uncertainty, 11 is the actual characterization of the arc.
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| 12 There's a lot of parameters that affect 13 the arc. So, you know, we're not really looking into 14 that too much right now that support these, any type 15 of model development.
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| 16 We're trying to make it applicable without 17 having to, you know, consult with CFP type -- I was 18 not saying that those aren't valuable.
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| 19 I think if, you know, from some other work 20 that we've done, we may be able to leverage some of 21 the CFP work to support what we're doing here.
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| 22 But again, you know, I don't think I would 23 expect the NRC to say -- or do CFP type analysis to 24 come up with the supporting PRA. That's just my 25 opinion.
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| 205 1 Any questions from the room? Tony Putorti 2 from NIST?
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| 3 MR. PUTORTI: So, Mr. Turner talked about 4 one side of the modeling. So, if you think about the 5 concept of the HEAF or the phenomenon making the 6 threat, making the thermal environment that threatens 7 other pieces of equipment, and you think about the 8 vulnerability, you could model both sides.
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| 9 So he talked a little bit about trying to 10 model the generation of a thermal environment. But, 11 we can also use models to take a look at how those 12 thermal environments, what affects they have on the 13 targets.
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| 14 And so there's been modeling and other 15 types of modeling you can do to take a look at what 16 the result is to the target. And some of that's 17 already been done, with cables, for example, and in 18 other areas.
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| 19 MR. TAYLOR: Yeah. So, I think that's 20 getting into more of a -- at least from the zone of 21 influence or fragility side of assessing the nuclear.
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| 22 MR. PUTORTI: I will put them both 23 together.
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| 206 1 okay, this is how big the events can be. We want to 2 tie it together to the actual targets.
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| 3 Any questions in the room? Again, this is 4 kind of just high level. There's a lot of good 5 research out there on a whole variety of things 6 related to this event.
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| 7 But, if you look at the IEEE 1584, they 8 provide a lot of good information. But there's other 9 publications as well that get into the nuances of it.
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| 10 Anything on the webinar? No questions on 11 the webinar? So I think we're a little --
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| 12 MR. MELLY: A little behind. But we can 13 take a break.
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| 14 MR. TAYLOR: No, we're ahead still. About 15 ten minutes, right?
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| 16 MR. MELLY: Yeah. We are.
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| 17 MR. TAYLOR: All right. So, let's go 18 ahead and take a break until 3:15. We'll get back on 19 schedule then.
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| 20 So we're on break. Thanks.
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| 21 (Whereupon, the above-entitled matter went 22 off the record at 2:51 p.m. and resumed at 3:16 p.m.)
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| 23 MR. TAYLOR: All right, we will go ahead 24 and start. If everybody could take their seat. It 25 should be on now. Is the webinar running?
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| 207 1 MR. SALLEY: Okay, so we have the webinar 2 back up, and we'll get ready. Like I said, this 3 afternoon is about a lot of information we want to 4 share with you and exchange, and we're lucky to have 5 three guests to present with us.
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| 6 The first one will be Mark Earley with the 7 NFPA, and Mark is the Chief Electrical Engineer there.
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| 8 So he's going to present us some work they're doing 9 with the NFPA. It's interesting that we've been 10 working a little bit through some webinars trying to 11 share some information. It's been very profitable for 12 the NRC and also for the NFPA, and we want to continue 13 that exchange moving forward after this workshop.
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| 14 We're also going to have Ashley Lindeman 15 from EPRI with the EPRI perspective, a presentation 16 after Mark. And then we've got Bas from KEMA from the 17 Netherlands, and he's going to give us some 18 information that they got from KEMA. Okay? So with 19 that, I'll turn it over to Mark, and you can take it.
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| 20 MR. EARLEY: Thank you. It's great to be 21 here. Starting off with a new generic slide that we 22 have that shows our new theme, which is, it's a big 23 world, let's protect it together. However, I also 24 included this one, because this first slide is 25 uniquely unreadable. But it's a nice slide.
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| 208 1 I'm going to be presenting the report in 2 place of Dr. Wei-Jen Lee who is responsible for a lot 3 of the scientific part. He is a Professor at 4 University of Texas at Arlington.
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| 5 So who are we? The National Fire 6 Protection Association is a global non-profit 7 organization established in 1896 devoted to 8 eliminating death, injury, property and economic loss 9 due to fire, electrical, and related hazards. We are 10 the worlds' leading advocate of fire prevention, and 11 we are the sponsor of Fire Prevention Week.
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| 12 We are primarily a publisher of codes and 13 standards, and we publish more than 300 consensus 14 codes and standards that are all about minimizing 15 possibility and the effects of fire and other risks.
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| 16 We have a membership of about 50,000 from around the 17 world.
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| 18 The National Electrical Code was also 19 founded in 1896. It did not become an NFPA standard 20 until 1911. But from its very beginnings in 1896, we 21 have included representation from around the industry, 22 including IEEE and the utility industry has been with 23 us for a very long time.
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| 24 The first edition was published a little 25 over a year later in 1897. We are currently working NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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| 209 1 on the 55th edition of the NEC. We've been published 2 on a three-year cycle for 65 years.
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| 3 When OSHA was first formed, the first 4 electrical standard that it adopted was the 1971 5 National Electrical Code. That presented some issues 6 for them, because the National Electrical Code has a 7 lot of installation requirements in it that have 8 nothing to do with safety in the workplace. They are, 9 for example, requirements for residential electrical 10 construction.
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| 11 So, OSHA, along with IEEE, asked NFPA to 12 consolidate its electrical requirements into a new 13 standalone document. The original concept was that 14 they wanted something that was timeless and adoptable 15 by them. And what we found over time is that 16 nothing's timeless. That as experience is gained, 17 standards need to evolve to stay up to date.
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| 18 So the result of this was NFPA70E, the 19 title of which was Electrical Safety Requirements for 20 Employee Workplaces, which is a title you can't recite 21 after you've had a few drinks. It has now been 22 renamed as Electrical Safety in the Workplace. It 23 has, however, become far more known as 70E than it is 24 by its name.
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| 25 And that kind of puts it in the company of NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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| 210 1 most of the other NFPA documents, other than the NEC.
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| 2 The NEC is known by its name, or by its acronym of 3 NEC, and rarely ever referred to as NFPA70 outside the 4 walls of NFPA.
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| 5 NFPA70E evolved into four parts. The 6 biggest part is now gone. The biggest part was just 7 a regurgitation of electrical installation 8 requirements, but most specifically those that are 9 related to worker safety.
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| 10 The entire standard is important, but most 11 of what you need to know for most installations and 12 most work is in chapter one. The arc flash phenomenon 13 has been in NFPA70E since about the 2004 edition. And 14 right around that time, IEEE formed a working group.
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| 15 Actually, it dated back a little bit 16 earlier than that, but they formed a working group to 17 provide a method to quantify the phenomenon. And this 18 working group developed IEEE 1584.
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| 19 What we know about arc flash phenomenon is 20 that over time, we've been noticing, or had noticed, 21 an increase in the number of arc-flash related 22 incidents. When NFPA70E was first developed, it was 23 all about electric shock. If you look out there in 24 the international community at IEC, most of what they 25 do is about electric shock in the 60479 series of NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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| 211 1 standards under TC64.
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| 2 And actually, calling those IEEE standards 3 --- excuse me, those IEC documents standards is 4 actually a misnomer. They are actually technical 5 specifications. They are not standards, because they 6 have not gained the required consensus in the 7 international community to be classified as standards.
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| 8 But they are none the less widely recognized.
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| 9 So what we've found happens with arc flash 10 incidents is they produce burn injuries, they produce 11 injuries from ejected materials, they produce in some 12 cases arc blasts with an accompanying pressure wave, 13 an intense amount of light, and rather intense sound, 14 as well as toxic metal dust.
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| 15 And I found it interesting watching the 16 videos of the tests this morning, they were very 17 impressive, and you would get a sense of how loud they 18 are. But when you're in the booth next door and these 19 tests are going off, even though you know you're going 20 to hear it, you're rather shocked at just how loud 21 that event is. And they are very convincing of just 22 how much of a problem it is.
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| 23 The IEEE standard was initially designed 24 around a series of about 300 tests that were valid 25 over somewhat limited range, and over time, it became NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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| 212 1 necessary to extrapolate that out. And when one is 2 doing that, one wonders just how valid that 3 extrapolation is. So they were developed based on 4 some statistical relationships and seemed to work well 5 within that limited range.
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| 6 But there were differences of opinion 7 between the members of the IEEE committee and the NFPA 8 committee on how to protect workers. So both 9 committees became concerned about the technical basis 10 for the analysis, and they both decided to pursue arc 11 flash research projects. Each committee recognized 12 that this was going to cost a lot of money, and that 13 they did not want to do it on a shoestring.
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| 14 The first round of the tests, the 300, was 15 certainly done on a shoestring budget. NFPA was going 16 to pursue this project through our Fire Protection 17 Research Foundation, and IEEE was going to do things 18 a little differently by forming their own task group 19 to do it.
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| 20 After a while, we both recognized that we 21 were going to be knocking on the same doors, asking 22 the same people to contribute to this project. It was 23 unlikely we would get any sponsor who would support 24 both projects. We also recognized how important it 25 was going to be to get industry buy-in and industry NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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| 213 1 would not be well-served by competing arc flash 2 projects.
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| 3 So the IEEE staff person contacted me and 4 asked whether or not we would be interested in 5 collaborating with them. We concluded that we were 6 both well-recognized in the industry for a number of 7 things, us for the National Electrical Code and 8 NFPA70E and IEEE for a whole series of electrical and 9 electronic standards and the code that affects the 10 utility industry, the National Electrical Safety Code.
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| 11 For both of us, it's all about protecting 12 people, and we recognized the conflicting viewpoints 13 of committee members. And some of those were very 14 strongly-held positions. We chose a totally neutral 15 party in this to chair this research test planning 16 committee, Mike Callanan, who is Executive Director of 17 NJATC, which is now the Electrical Training Alliance.
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| 18 What that is, is it is a training 19 organization that is jointly owned by the National 20 Electrical Contractors Association and the 21 International Brotherhood of Electrical Workers.
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| 22 These members, with their strongly conflicting views, 23 were told to check your guns at the door. The 24 membership represented a number of different 25 constituencies from IEEE and NFPA committees.
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| 214 1 And we developed a pretty comprehensive 2 research plan, which formed the basis of the research 3 project. I believe the research plan was about 128 4 pages long. And we had unanimous consensus for the 5 research plan.
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| 6 Chances are you don't recognize many of 7 those names, but we had here IEEE people, Underwriters 8 Laboratories, DuPont, Snyder Electric, more DuPont.
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| 9 We had Ferraz Shawmut, which is now Mersen. We had 10 various American Chemistry Council members, and a few 11 different folks from the utility industry. So a very 12 broad group of people put this thing together.
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| 13 So the primary goal was to work together 14 collaboratively so that we could capitalize on all 15 these various industry groups working together and 16 also, all these industry groups willing to punch holes 17 in it if they found them.
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| 18 We're very pleased to get the sponsors 19 that we got. Platinum sponsors contributed 20 $500,000.00 a piece, and the one at the top is a 21 Canadian utility, Bruce Power, and we had Cooper 22 Bussmann, which is now Eaton, Ferraz Shawmut, which is 23 Mersen. Wait, there's one missing. Oh, okay, yeah, 24 Eaton came in separately merged with Cooper Bussmann 25 later, so they are in effect a $1 million contributor.
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| 215 1 And Underwriters Laboratories, and a 2 variety of gold contributors and silver contributors.
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| 3 And one of the things that we talked about earlier 4 that was a big contribution from Bruce Power was they 5 had done some DC research. And so that is forming the 6 basis of some of the later research that we're 7 planning on doing.
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| 8 So, okay. When did all this stuff happen?
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| 9 The formation of the collaboration up through the 10 fundraising started between 2003 for the challenges to 11 the status quo up to 2006 for the fundraising stage.
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| 12 And for the fundraising stage, we were fortunate to 13 have two people who were Vice Presidents of their 14 companies who were just uniquely positioned to go out 15 and meet with CEOs of organizations to ask them for a 16 lot of money.
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| 17 It's one of those things that a lot of us 18 just, it's not in our psyche. I'm not likely to be 19 able to ask anybody for $500,000.00.
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| 20 The initial research phase had a couple of 21 PhDs working on it, Dr. Tammy Gammon and Dr. PK Sen.
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| 22 Dr. Tammy Gammon is an independent consultant and PK 23 Sen is a Professor at the Colorado School of Mines.
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| 24 For the testing period, we had Dr. Wei-Jen 25 Lee from University of Texas at Austin, and he has NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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| 216 1 worked with some various PhD candidates who did some 2 of their thesis based on this work.
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| 3 Between 2013 and 2016, we have had the 4 model intensely reviewed by the 1584 committee. So 5 this has had quite a bit of a scrutiny. And so we've 6 met the criteria of the test procedures and protocols 7 committee. We hired a test manager. We contracted a 8 research manager. We've actually used a couple of 9 different laboratories.
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| 10 And we conducted over 2,000 tests. And 11 they were all based on the RTPC task group work, and 12 we conducted low-voltage and medium-voltage tests. So 13 the test range was from 208 volts up to 14.3kV.
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| 14 So the initial cost projections were $6.5 15 million. We did not raise that much money, and so we 16 found a way to get most of it done a whole lot less 17 expensively. We estimated a fair number of laboratory 18 days. We got some used equipment for some of the 19 actual equipment tests.
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| 20 And some of the --- and so we did focus on 21 the whole range of tests. We planned on LV, MV, AC 22 tests, and some DC tests. The good news was we had 23 that contribution information from Bruce Power, which 24 is helpful. But we are planning the DC tests at our 25 next stage.
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| 217 1 So we estimated some personnel costs. We 2 had we figured about 520 actual lab days, and we came 3 up with estimates based on how much money we were 4 likely to have in the program and what we would be 5 able to accomplish with that.
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| 6 And so the good news is we've been able to 7 accomplish most of what we set out to do. So I know 8 this is another one of those pie charts, but this is 9 the range of tests. At the low end, 208 volts, we ran 10 67 tests. At 480 volts, which by the way is the most 11 common voltage where electricians are injured, at that 12 level, we ran 369 tests. Up at the top end, 14.3, we 13 ran 274 tests.
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| 14 We ran tests in a couple of different 15 configurations. They were vertical tests with the 16 vertical electrodes in a cubic box, vertical 17 electrodes in a cubic box with a bottom insulated 18 barrier, vertical electrodes in open air, horizontal 19 electrodes in a cubic box, and horizontal electrodes 20 in open air.
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| 21 And as far as publishing the researching, 22 well, there's been a number of papers published over 23 time, mostly in IEEE's industry applications 24 transactions. So we published on the visible light 25 intensity viewed from human eyes, and of course, when NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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| 218 1 you're concerned about the hazard to eyes, you're 2 concerned about the potential of being blinded by the 3 light, but also the shrapnel is a huge hazard.
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| 4 And despite all the requirements for 5 safety glasses in the workplace, we frequently see 6 people not wearing them. But with a real intense 7 blast, safety glasses could be easily punctured.
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| 8 So we've published on that, the 9 magnetohydro. I will pronounce it. 3D 10 magnetohydrodynamic modeling of DC arcs in power 11 systems. DC arc model based on arc simulation. Arc 12 flash pressure measurement system design.
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| 13 And in talking about system design, one of 14 the interesting things about this is when you consider 15 that you're measuring the effects of a big electrical 16 incident, you essentially have lightning in an 17 enclosure.
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| 18 And so it creates some unique problems of 19 trying to make sure that you can measure the 20 phenomenon you're trying to measure without the 21 outside interference from this little thunderstorm 22 that's taking place in the box. And so Professor Lee 23 and his team had to come up with some unique ways of 24 measuring that phenomenon and filtering out all of the 25 interference.
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| 219 1 So again, the list continues. I won't 2 read all of these off, because you all have a copy of 3 this presentation. But we generated a lot of 4 information, and there is a summary of the DC work to 5 date. But we know this is an area that we have more 6 work yet to do in.
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| 7 And this is the committee that we have 8 today. So we have some of the same organizations 9 represented. There's actually only two people on this 10 list from the original committee, but continuing to 11 move that forward. And now we want to do a 12 comprehensive DC arc flash model.
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| 13 We believe we're seeing some things 14 telling us that we may be able to establish some 15 correlation between the AC tests and the DC tests, but 16 there are some factors to consider with DC. The 17 source can make a real difference. Rectified DC and 18 DC from a battery in terms of its, one of the fuse 19 people classified it as its stiffness, can be a 20 factor.
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| 21 With rectified DC, you may wind up 22 destroying the rectifiers. And certainly, when you're 23 doing any of these tests, there's a lot of hazard to 24 equipment, and you usually wind up damaging quite a 25 bit of it along the way. And as in the case of KEMA, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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| 220 1 the test cells as well.
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| 2 So, that's a factor. The voltage and 3 current ranges are a big factor. And sometimes, the 4 voltage and current ranges are limited by what the 5 laboratory can provide, and sometimes by what they're 6 willing to sacrifice because of the potential damage 7 to equipment.
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| 8 Gaps between electrodes and materials 9 certainly make a big different, as has been discussed 10 earlier today. So the hypothesis that we're working 11 on is that the incident energy is proportional to the 12 arc energy during the arc flash event for DC, and it's 13 possible to establish a relationship and use the AC 14 arc flash model for DC incident energy and arcing 15 current estimation.
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| 16 So we want to do some initial scouting 17 tests based on about three to four days of testing and 18 see --- or I could have just asked Siri. And that was 19 mine. I don't have it set up to do that. Oh, it 20 actually came up with a website, okay.
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| 21 Okay, so the proposed approaches are to, 22 according to the test configurations, perform some 23 computer simulations to obtain the estimated arcing 24 current, arcing voltage, and arc energy and see what 25 we can do about comparing the simulation between the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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| 221 1 two models and see if we can get reasonable results to 2 determine whether or not there is a good relationship 3 between the two.
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| 4 If the proposed study does yield positive 5 results, we'll design some additional laboratory 6 testing and perform some more DC simulations. So if 7 we can get some good lab work, it will certainly 8 expand our ability to do modeling, which is a whole 9 lot less expensive than actual lab time.
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| 10 So, where are we? We developed ten AC 11 models that we've been able to integrate into one 12 using five electrode configurations. We've done low-13 voltage and medium-voltage AC tests. We have some 14 test results already and are looking at doing a few 15 more tests at the 208 volt level to see where the 16 floor of the model is.
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| 17 Initially, when we ran some of the lower 18 tests, we would report them as failures, and later on, 19 it was decided, well, no, maybe those weren't 20 failures. What that was, was we were feeling around 21 for the floor. And so we have those results, and 22 we're going to be doing some further analysis to 23 determine where that floor is.
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| 24 We developed instrumentation for 25 measurement of the thermal effects, the light effects, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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| 222 1 the pressure and sound effects, and came up with a 2 portable instrumentation unit. And as I indicated, 3 there are a number of IEEE papers, so there is a 4 myriad of research that is available.
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| 5 So, mission of the collaboration was to 6 develop one model to ensure worker safety. I think 7 we've been successful with that. We have a working AC 8 model. Our next goal is to explore that lower 9 boundary, and the next step is a correlation of the DC 10 model with the AC model.
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| 11 That's it.
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| 12 MR. TAYLOR: Any questions in the room?
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| 13 Dan Funk?
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| 14 MR. FUNK: Are we -- I see this is 15 working. I guess it is. Obviously the reason we're 16 here today is because of the unexpected result of 17 aluminum conductor, and as Mark and Gabe and Nick and 18 the other folks familiar with their test program 19 relayed, copper behaved in a way that they feel 20 confident enough to characterize, but this aluminum 21 situation right now tagged as aluminum oxidation is 22 problematic. And that's obviously where a lot of the 23 focus is going to be for their test program in the 24 future.
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| 25 What I struggled with, and I think some of NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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| 223 1 us that have bene looking into this, is 1584 and 70E 2 don't make a distinction between the conductor. And 3 as you put it, you ran over 2,000 tests. Is there 4 some concept that you could help us with as to how you 5 didn't see any difference between the conductors in 6 all your tests, or if you did, how they were dealt 7 with?
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| 8 MR. EARLEY: Most of our tests were 9 actually conducted with copper. We do know that 10 copper does splatter as well. In fact, we have a 11 photograph in the report of an arc flash involving 12 copper electrodes where you can see the pieces 13 spreading out.
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| 14 Now, in discussion with the folks in the 15 fuse and circuit breaker industry, they are in fact 16 very well aware of the aluminum issue and where it can 17 go. I am less schooled with that, so I would have to 18 direct that question to Dr. Lee. But we are aware of 19 how aluminum can behave.
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| 20 MR. FUNK: Thank you.
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| 21 MR. EARLEY: You're welcome.
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| 22 MR. TURNER: Okay, I have a comment on 23 aluminum. There's not as much mystery about why 24 aluminum behaves the way that it does. As a matter of 25 fact, we first saw the effect, we knew when we NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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| 224 1 inspected. I don't want to get too much into just 2 metal chemistry, but if you look at something called 3 the Born-Haber cycle, this is a number that's produced 4 or how much energy does it take to go from a mole or 5 gram of a bust bar to melt it, vaporize it, and 6 oxidize it, what's the resulting energy? And for 7 oxidizing aluminum, that number is somewhere in the 8 range of 30 kilojoules per gram. And for copper, it's 9 about four.
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| 10 So we very well expect it from the 11 chemistry. I actually talked to Jim Billups a bit 12 about have you seen this aluminum oxidation, and he 13 felt they hadn't run enough tests. But if you read 14 some of the IEEE reports, and it's all good work, some 15 of the aluminum tests support it.
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| 16 They did come out and say, wow, that was 17 a little better than we thought, so we might need to 18 look at that more. So I think there is an awareness, 19 and I think that they're considering it, but they just 20 want to be careful about how they approach it. But 21 there's no mystery about what the phenomenon is in 22 terms of basic physics.
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| 23 MR. FUNK: Yeah, no, I agree. I mean, and 24 that's in all the papers. My point is, it doesn't 25 show through the standards. Right. So my point is it NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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| 225 1 doesn't show up in the standards after spending $6.5 2 million. So it seems like you've got a discontinuity 3 of it didn't make the front page, and now this is all 4 we're going to focus on. That's my point.
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| 5 MR. TURNER: And that's what I said. I 6 called his colleague Jim Billups and said, are you 7 guys looking at aluminum, and he said we're thinking 8 about it. So I think we'll hear more of that.
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| 9 MR. FUNK: Understood. But they do good 10 work. It's great work.
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| 11 MR. EARLEY: Yeah, just a point, our 12 budget, our goal was $6.5 million. We got a little 13 over $3.5 million, and so we had to scale back some of 14 our expectations, because there was only so much we 15 could do, and you know, just like we had the 16 discussion here today about DC testing, there's a lot 17 of debate right now as to how much more we should do 18 in that are as opposed to making sure that we have 19 that AC floor well established, because know that the 20 AC floor is a real issue for us from a practical 21 standpoint.
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| 22 DC tends to be less of an immediate 23 problem, but on the industrial side, it's becoming 24 more of a problem because of all of the green energy 25 systems out there with lots of energy storage coming NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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| 226 1 online, and of course, what do PV panels generate?
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| 2 They generate DC.
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| 3 So that's certainly an issue. All the UPS 4 systems out there in the field are certainly an issue 5 for DC. But right now, it's become less of a 6 priority, again, because we didn't get $6.5 million, 7 so we had to do what we could.
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| 8 MR. TAYLOR: Question in the back.
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| 9 MR. EARLEY: Yes?
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| 10 MR. LEJA: I was just curious, I was 11 looking at the summary of the test. How did you guys 12 develop the gap range population?
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| 13 MR. EARLEY: How did they develop the gap 14 range population? I think that's another one I would 15 have to direct back to Dr. Lee.
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| 16 MR. LEJA: Okay, thank you.
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| 17 MR. EARLEY: Thank you.
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| 18 MR. TURNER: Okay, thank you. All right, 19 thank you. Ashley?
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| 20 MS. LINDEMAN: Okay, I'm going to give a 21 little bit of the EPRI perspective on the HEAF issue.
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| 227 1 plants. And really, just put everything in one or two 2 spots to characterize the state of the arc.
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| 3 So there's two papers. The first one is 4 focused on the testing observed to date as well as the 5 operating experience with a focus of United States 6 events. The second paper is really focused on the 7 electrical distribution system and how these systems 8 are designed to tolerate a fault.
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| 9 So it was a collaboration not only within 10 EPRI. We used Tom Short who is in the power, 11 delivery, and utilization sector. He works heavily 12 with the arc flash work for personnel protection, but 13 we also used Penn Engineering and Ken Fischer and Dan 14 Funk have played in their contributions to the paper.
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| 15 So, due to the importance of the subject, 16 EPRI normally doesn't make their research available to 17 the public, but in certain circumstances, we do. So 18 if you go to EPRI.Com, you can download the paper. So 19 you just need to memorize a really long number. So 20 it's 3002011922 and 1923. So these white papers form 21 the basis for my presentation, and feel free to 22 download and read the gaps.
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| 23 MR. MELLY: And in a few minutes, we will 24 have all of the presentations available in ADAMS.
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| 25 That will be the ML number associated with all of the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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| 228 1 slides that have been presented today and tomorrow.
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| 2 Gabe's working on that right now.
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| 3 MS. LINDEMAN: Okay. So one thing that we 4 haven't talked a lot about is the different types of 5 electrical and distribution systems. Something that 6 we really haven't talked about is where we have seen 7 some of the more severe HEAF experience. So what 8 we've found is that the main generator can feed a 9 fault for several seconds.
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| 10 And in a lot of instances, this is where 11 we've seen the long duration faults. So Ken and Jim 12 and his team, they went through a variety of station 13 diagrams and identified seven common power 14 distribution configurations and ranked their 15 importance most vulnerable to lease vulnerable to 16 generator-fed HEAF risk. And we'll talk a little bit 17 specifically what a generator-fed HEAF is in a few 18 slides.
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| 19 But out of the 19 sites we reviewed, we 20 found 14 of the 19 have low risks, designs five 21 through seven. So these were sites that either employ 22 a generator breaker, have good electrical separation, 23 or feed off-site power from the station transformer.
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| 24 So this is what I mean when we talk about 25 the unit-connected design. This is specifically the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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| 229 1 power system downstream from the main generator. So 2 it includes the main generator, the step-up 3 transformers, and the breakers in the switchyard, the 4 auxiliary transformer, and then the connection to the 5 medium-voltage switchgear.
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| 6 In this case, it's the class for the 7 safety division, but another station systems that it 8 could be in the non-class. So faults in this system 9 are this scheme. If there's a stuck auxiliary 10 transformer, there may be a longer duration fault or, 11 you know, any other location.
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| 12 So, from our experience, this is where we 13 found the longest duration events from experience.
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| 14 So, as I foreshadowed, we looked at about 15 30 events, and we found that the most severe ones had 16 a very common theme, and that was the main generator 17 played a role in extending the duration of the fault.
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| 18 So in this case, we found that the faults can last 19 several seconds, and as we talked about earlier, 20 normally we think about things in cycles, which are 21 very quick, and now we're talking about routines that 22 last several seconds.
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| 23 We did find a few instances where the 24 plants had a generator breaker thus they can isolate 25 the energy source from the fault during the generator NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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| 230 1 coast down. So that was a way to mitigate some of the 2 main generator-fed HEAF risks.
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| 3 Some of the good news is --- maybe not 4 good news --- is each HEAF event is obviously a sever 5 event, but the ones that we've observed in the United 6 States that are generator-fed HEAFs impacted only non-7 class equipment and non-class 1E locations, and they 8 all occurred in the medium-voltage range. So 9 typically, limited to turbine building and areas like 10 that.
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| 11 We did find that a fire occurred in all 12 the instances. Of the 30 events, there was nine 13 generator-fed HEAFs. Fires in all of them. In eight 14 of nine events, we found that the equipment extended 15 beyond the equipment origin, which in Fire PRA, that's 16 really what we're interested in, is when the equipment 17 can cause damage to other targets. And again, the 18 events caused significant damage and were challenging.
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| 19 So, the next paper really focused on 20 looking at the event review. What did the data tell 21 us? So we have a lot of well-documented fire event 22 history at U.S. nuclear power plants. I maintain 23 what's called the Fire Events Database, and it's a 24 collection of fire events occurring within the U.S.
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| 25 industry.
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| 231 1 So, I review a span 1980 to 2017, and it 2 was roughly 32 events. So what we found is that the 3 HEAF events represent around two percent of the fires 4 within the U.S. nuclear power plant fleet, and you 5 know, this is not just the LER fires. It's the 6 potentially challenging and greater.
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| 7 So we found that the HEAF experience 8 within the United States does not follow some of the 9 trends from the international data, which may have a 10 different reporting threshold.
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| 11 We found that no flavor of a HEAF was 12 identical. We found a wide variety in the severity of 13 events. Not all of the events resulted in a fire, and 14 most of the events damaged only the equipment itself.
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| 15 We did identify some key factors, and I'll 16 go over those in a minute. But similar to the thread 17 of the presentations early, we do believe that there 18 is refinements to be made in both the frequency and 19 the zone of influence based on the data that we 20 reviewed.
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| 21 So this is some of the statistics we tried 22 to look at the information that was available on the 23 events and characterize them. So, the first thing we 24 did was look at if the equipment that initiated the 25 HEAF occurred in a class or safety-related or non-NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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| 232 1 class equipment. And what we found is that most of 2 the events were in the non-class or non-safety-related 3 system.
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| 4 There was one or two events in the class 5 system. And then there was an unusual event, and that 6 was a switchgear that was both class and not-class.
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| 7 But anyway, 91 percent were in the non-class system.
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| 8 We also found that 84 percent of the 9 events were in the medium-voltage range. So our 10 takeaway is the HEAFs that we see are primarily non-11 safety-related medium-voltage concern.
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| 12 So what about zone of influence and 13 damage? So we found that most of the events, two-14 thirds, did not impact equipment beyond the equipment 15 of origin, and similarly, not all the events resulted 16 in a fire. Two-thirds of the events did result in a 17 fire.
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| 18 We also found that no one equipment type 19 dominates the events that we've seen. It is quite 20 divided between busses and switchgear and circuit 21 breakers. So not one general prevalent trend of 22 equipment type.
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| 23 We did find that a lot of the HEAF events 24 did involve preventable shortcomings. In other words, 25 the HEAF could have been prevented. So, human error, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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| 233 1 maintenance, design, installation, construction.
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| 2 Those were all ways that we could have mitigated.
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| 3 I know Ken has brought up multiple fail 4 barriers, and in a lot of instances, it wasn't just 5 one thing that went wrong. There was a series of 6 events that led to the severity of the event.
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| 7 And circling back, we did find that one-8 third of the events were associated with this unit-9 connected design. So I think that's significant, and 10 we discussed that it probably deserves its own special 11 attention and treatment in the PRA.
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| 12 I don't want to spend too much time 13 talking about the testing, but I think it's important 14 to characterize that the tests that were run, over-15 current protection, which is typically there in the 16 plant was not in place for the test.
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| 17 So kind of what has been characterized in 18 the test is pretty much the most severe and violent 19 that we can see. And in the real world, we over, we 20 design that over-current protection or some type of 21 protection will work, and the fault energies will be 22 considerably lower.
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| 23 And if I had to summarize the tests that 24 have been done to date, the low-voltage testing, I 25 think we found the arcs didn't always sustain. Tests NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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| 234 1 with durations of two seconds usually didn't result in 2 fires, and that may line up with how the equipment is 3 rated and some of the IEEE standards. I think Steve 4 Turner said 25 megajoules was the threshold for a 5 fire. Yeah, I think we kind of agreed when we looked 6 at the tests, that that seemed to be the threshold.
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| 7 When we look in the medium-voltage testing 8 insights, the threshold was higher. I think the 9 equipment at the medium-voltage range is more rugged.
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| 10 And once initiated, the arcs sustained themselves for 11 a longer period of time.
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| 12 We did observe a wide variety of damage in 13 these tests. There was external ruptures and breaches 14 between compartments, and I think the NRC has 15 demonstrated that in some of the pictures that they 16 showed this morning.
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| 17 So the involvement of aluminum on this is 18 a primary reason why we're here, and I think the 19 testing to date has identified that as a significant 20 contributor to the total energy release. I just 21 wanted to stress that it wasn't always observed.
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| 22 I think there was more than the two tests 23 that had aluminum, and I think in the new reg, that 24 was with the Japanese. At first, I think they tried 25 to take a cut of estimating the arc energy from NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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| 235 1 oxidation, and we compared it to the arc.
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| 2 And in the most severe tests, the release 3 from the oxidation was 2.6 times the estimated energy 4 released from the arc. So that was the most severe, 5 but we found it range from 0.34 to 2.6, so the high 6 oxidation scenarios were less common.
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| 7 This was brought up in the last 8 presentation, but you know, why haven't we seen this 9 involvement of aluminum before? We have all these, we 10 have 1584, C37, 70E. I didn't want to answer your 11 question, Mark, but some of the theories that we came 12 up is, right, there may not have been aluminum tested.
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| 13 The testing that's been conducted to date 14 outside of the nuclear industry typically tests of 15 shorter durations, so there's less melting of the 16 conductors. And that was kind of our best guess of 17 why this hasn't become a major factor.
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| 18 But really one of the open questions is 19 that the threshold at which this oxidation of aluminum 20 occurs is really undefined. I'm not sure if we have 21 a rhyme or reason, is there a duration or a voltage or 22 an energy where this gets much worse? And to me, that 23 was a big open question that we had. So maybe 24 hopefully you guys can figure it out, because it just 25 didn't seem like it occurred in everything that we NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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| 236 1 saw.
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| 2 MR. GARDOCKI: In your database, did you 3 discriminate or were you able to discriminate events 4 that involved aluminum or no?
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| 5 MS. LINDEMAN: So that wasn't one of the 6 factors we looked at. I think upon reading the event 7 reports, we noticed there was some mention of 8 aluminum, but it wasn't something that we specifically 9 looked for. So getting into Fire PRA.
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| 10 We definitely suggested and we've worked 11 with the NRC to really redefine --- maybe not 12 redefine, but refine the ignition frequencies and the 13 scenario definition of what we will term a HEAF, which 14 has been 16.a, 16.b, 16.1, and 16.2.
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| 15 And based on the data review, we believe 16 that there is subgroups and split factions to do a 17 better job of characterizing the risks. Right now, we 18 pretty much have low-voltage and medium-voltage which 19 is existing. And we also have bus ducts, but we 20 believe that adding in the safety classification, that 21 seemed to be a significant finding from our white 22 papers.
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| 23 We also feel that there was also room for 24 split fractions on the extent of damage, if there was 25 a fire or not. And again, special treatment for a NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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| 237 1 vulnerability such as the unit-connected design where 2 protection may be absent or unprotected zones.
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| 3 So we also did a sensitivity study to see 4 how the impact of a larger zone of influence from 5 aluminum might impact the PRA results. Obviously I 6 think as Nick said, it's definitely plant and scenario 7 configuration dependent. Obviously if you have a 8 well-separated plant with two different switchgear 9 rooms and good electrical separation, I think the 10 numbers will come out to a lower impact.
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| 11 So the sample plant that we used had that 12 safety-related switchgear in separate rooms, and what 13 we found was the impact was minimal, which is in stark 14 contrast to the numbers that we saw. We ran it with 15 a lot of similar assumptions. We assume that the 16 oxidation failure resulted in a hot gas layer. And 17 for those not familiar, a hot gas layer essentially 18 damages everything in the room.
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| 19 So that's what we did. I think we did 20 credit suppression and everything, but anyway, we 21 found that the impact was certainly less than 1E-4.
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| 22 But obviously scenario and plant dependent.
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| 23 So one thing I don't think we really 24 talked about is I think we do want to work on 25 understanding why these events happen, because I'm not NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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| 238 1 sure if the answer is, well, the ZOI is 7.3 feet. It 2 seems that we want to make sure we have a strong PM 3 program and we're not deferring that maintenance, 4 because really, I think it's better to prevent the 5 events than to find out what the ZOI is.
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| 6 These events are not only a safety concern 7 but may be an economic consideration of a large event 8 that could keep a plant offline for months, in 9 addition to the nuclear safety aspects that we 10 frequently worry about.
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| 11 But the testing highlighted the importance 12 of making sure the protection schemes are optimized.
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| 13 We do, if we have electrical abnormalities, we would 14 want to rapidly detect and clear the fault such that 15 it doesn't get to the severity of a HEAF.
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| 16 Proper maintenance is prevention. The 17 white paper ending in 23 identifies several 18 maintenance practices. Refurbishment, testing, and 19 lock-downs to ensure that the equipment is operating 20 properly.
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| 21 So that is kind of a summary of what we've 22 been doing. Our white papers are really a cut at 23 characterizing the issue and not to do any PRA type 24 numbers, although we can kind of see that as 25 definitely an area that we can work on.
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| 239 1 MR. TAYLOR: A question from Bob Daley, 2 NRC.
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| 3 MR. DALEY: It looks like there's a lot of 4 really good stuff, and I haven't looked at the 5 documents, but I'm going to make sure I read them, 6 because I like Dan's fluid writing style. But I do 7 have one question. You talk about HEAF events 8 represent approximately two percent of fires within 9 the U.S. nuclear power fleet. Is that two percent of 10 all fires, or two percent of challenging fires?
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| 11 MS. LINDEMAN: All fires. Well, so the 12 fires that court towards frequency, so the potentially 13 challenging and challenging. So all those events.
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| 14 MR. DALEY: So it's not all.
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| 15 MS. LINDEMAN: Yeah.
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| 16 MR. DALEY: It's just 4:17:01. And the 17 4:17:03.
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| 18 MS. LINDEMAN: Yes.
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| 19 MR. JOGLAR: A quick clarification. It 20 would be very rare to find one of these fires to be 21 not challenged.
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| 22 MS. LINDEMAN: What we were saying, well, 23 I think Bob was asking -- so, if you looked at 2169 --
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| 24 MR. DALEY: I agree.
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| 25 MS. LINDEMAN: Yes.
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| 240 1 MR. DALEY: That's why I was asking the 2 question.
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| 3 The second, you have another thing in 4 there that said wide variety and severity of events.
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| 5 And it goes, "Not all HEAFs result in post-event fire.
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| 6 Most HEAF events damage only the equipment suffering 7 the failure."
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| 8 Were we able to extract, just based upon 9 plant that this happened at, whether the cable would 10 be thermoset or thermoplastic?
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| 11 MS. LINDEMAN: No, we don't have that 12 clarity of data. And I should mention, when we drew 13 the box around the HEAF events, we tried to include 14 everything that had kind of the arc blast event. So, 15 things like the Palo Verde event, the Turkey Point, we 16 added those in just because, as Nick and Gabe said, we 17 actually really don't have any definitions of what's 18 a Bin 15 fire or what's a Bin 16 fire. And we felt 19 that if we were doing this data review, it would be to 20 our advantage to put those all in and deal with them, 21 and see if there's similar characteristics. So, we 22 did include those.
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| 23 MR. SALLEY: Yes, this is Mark Salley, 24 while I'm here.
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| 25 Actually, on your slide you had the PRA NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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| 241 1 and the risk, I think a couple of slides back. There 2 you go, PRA treatment.
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| 3 MS. LINDEMAN: This one?
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| 4 MR. SALLEY: Yes. That was some of the 5 stuff that Nick talked about earlier with the pilots.
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| 6 Is there, I guess, something like a question you could 7 take back to EPRI? If there is some way we can work 8 with you on that to support the generic issue for 9 Stan, moving forward with that, I think that would 10 kind of meet your pilots and it would kind of get us 11 where we need to be, if we can work with you on that.
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| 12 So, if you would please take that back, Ashley?
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| 13 MS. LINDEMAN: Yes, I'll figure out 14 whether it's Victoria or me.
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| 15 MR. SALLEY: Yes, that would be great.
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| 16 MS. LINDEMAN: But I think we can 17 certainly help you out with the study.
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| 18 MR. SALLEY: And, Stan, that would kind of 19 be what you're looking for to move us forward?
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| 20 MR. GARDOCKI: Well, for generic issues, 21 we're trying to figure out across the board the 22 impact. And I know every plant has different 23 configurations. I saw your limited scope was 24 safeguards were in different rooms. So, that kind of 25 like zeroes out applicability to what we're looking at NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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| 242 1 where that would go across either two trains or impact 2 a certain train as the initiator, and then, the single 3 fire would take out other important equipment --
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| 4 MS. LINDEMAN: Yes.
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| 5 MR. GARDOCKI: -- if we go that far with 6 it.
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| 7 MR. MELLY: Right. So, I think it's 8 important, when we do eventually decide what our pilot 9 plants are going to be, is that we have this 10 discussion as to what are we picking that can cover 11 the range of possible plant designs as well as what 12 we're looking for. So, I think it will require a 13 follow-up meeting with EPRI, and potentially the 14 industry as well, as to how we're selecting and what 15 pilot plants can cover the range of these possible 16 very plant-specific questions.
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| 17 MR. PELLIZZARI: Francesco Pellizzari, 18 EPM.
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| 19 In doing the assessment, did you consider 20 these HEAF events when they occurred, what operational 21 state the plant was in where there would be a shutdown 22 or a power operation?
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| 23 MS. LINDEMAN: We may have considered 24 that.
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| 25 Dan, I don't know if it became a factor, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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| 243 1 but --
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| 2 MR. FUNK: Yes, I think most of them were 3 at power.
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| 4 MS. LINDEMAN: I think most of them were 5 at power, though.
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| 6 MR. PELLIZZARI: And then, another 7 question, it appears you're leading to a distinction 8 between 1E and non-1E switchgear buses. Is it 9 possible that the distinction you see might be due to 10 the normal loading of some of the buses as opposed to 11 true dedicated Class 1E buses? They might be get 12 particularly heavily loaded during power-ups.
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| 13 MS. LINDEMAN: We discussed this a little 14 bit. I think it's the care and maintenance and some 15 of the operational practices. I'm not sure if Ken or 16 Dan has anything to add. But we did discuss that.
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| 17 MR. SHUDAK: Tom Shudak from NPPD.
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| 18 I'm curious on some of your data support, 19 numerous subgroups. It's not up there. I was 20 wondering if you looked at insulated or uninsulated 21 buses. Do you see any correlation there?
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| 22 MS. LINDEMAN: I don't think we looked at 23 that.
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| 24 MR. FUNK: No. Again, the LER data wasn't 25 ideal. We could get back into the 1980s and the early NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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| 244 1 1990s. So, we were going from what data we had 2 available. And, of course, for a project like this, 3 you want more than what you generally wind up having 4 to work with. As part of the second phase, I think we 5 looked at, tried to do a drilldown on some of these 6 features, as we get smarter on what's driving the 7 equations.
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| 8 It's a good comment.
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| 9 MR. FLEISCHER: Ken Fleischer from EPRI.
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| 10 I wanted to try to answer what I heard as 11 a part of maybe that question on the Class 1E buses 12 being maybe lightly loaded or the configuration.
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| 13 Can we go back to slide 4 for just a 14 moment?
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| 15 Although that's really intended to be very 16 simplified diagram, that's not the most common 17 diagram. As you can see, coming right out of the 18 auxiliary transformer and the station transformers, 19 you go immediately to a Class IE division bus. That's 20 not typical of those plants. Most plants, there's 21 what we call the intermediate non-Class 1E bus and, 22 then, it goes to a Class 1E bus. There's also other 23 non-Class 1E buses that are maybe bifurcated and 24 dedicated to balance plant equipment. But, typically, 25 there is an intermediate non-Class 1E bus division NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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| 245 1 before you get there.
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| 2 So, when the paper gets into the seven, 3 what I call, scenarios, if I have an H-E-A-F or a HEAF 4 in zone 1 or 2, under those different seven 5 circumstances, we walk through how the protection 6 system is designed to work and what the ultimate 7 outcome is going to be.
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| 8 The more common designs are an 9 intermediate bus, and almost 50 percent of them don't 10 even operate operationally off of the unit auxiliary 11 transformer. They're dedicated to offsite power at 12 all times.
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| 13 So, we still evaluated those HEAFs, but 14 they were not generator-fed. I don't know if that 15 sheds any light on this.
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| 16 MR. MILLER: Yes, you said "generator-17 fed". The classification was only those that didn't 18 have generator breakers. If it had a generator 19 breaker, that doesn't mitigate that.
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| 20 MR. FLEISCHER: The generator breaker will 21 mitigate that because that operates in cycles.
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| 22 MR. MILLER: Right.
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| 23 MR. FLEISCHER: And it will immediately 24 isolate the generator from both the unit auxiliary 25 transformer and the main power train.
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| 246 1 MR. MILLER: Those were not -- eventually, 2 you would save on those and generate a breaker --
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| 3 MR. FLEISCHER: Yes. Okay, yes. But what 4 we also get into those scenarios are the multiple 5 barriers that fail. So not only do you have the 6 initiating event, which the HEAF, but now I also 7 postulate stop breaker. A lot of these designs have 8 a bus transfer system, as you can see. I show the 9 breakers normally closed, normally open. If I have a 10 HEAF in either fault zone 1 or fault zone 2, 11 particularly fault zone 2, and that breaker is slow to 12 respond or gets stuck, I will transfer over to the 13 station power or station transformers. And in this 14 case I just have one.
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| 15 What will happen is that let's say 16 division 1 fails and that breaker sticks. Division 2 17 has a successful bus transfer, but it is going to 18 backfeed into that fault. Now I lose both divisions 19 to the diesels. So, that's kind of the thing that 20 you've got to worry about. And a lot of the HEAFs 21 that occurred were during bus transfers, so they were 22 complicated by that.
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| 23 In fact, we leveraged off of the NRC 24 paper. If you're familiar with the Monshon (phonetic) 25 paper, you actually covered similar -- I think there NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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| 247 1 was a Monshon event and you covered five or six other 2 scenarios with that. So, that was a good paper, and 3 we leveraged off of that. If you need, I can get you 4 the ML number. But we got a lot of our research out 5 of that.
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| 6 If you read the paper, particularly if you 7 avoid the paper on anything else, read the seven 8 scenarios. I think as I walk you through them in 9 those scenarios you will see how each HEAF is treated 10 differently by a different configuration protection to 11 system design.
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| 12 MR. TAYLOR: Any other questions? Yes?
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| 13 MR. CAVEDO: I just had a comment. I 14 don't see how that could have caused the loss of the 15 two divisions. That doesn't make any sense. The 16 diesels aren't going to come back on until the feeder 17 breakers are open there. There's an interlock there.
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| 18 So, I don't see that it could have the fault propagate 19 to both divisions. Now you could have damage that 20 goes across the proximity, but not through the 21 breakers.
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| 22 MR. FLEISCHER: There are two bus transfer 23 schemes up there for each division. If I have a fault 24 in zone 2 and that breaker sticks, the one that says 25 "normally closed," okay, and that normally-open NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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| 248 1 breaker now closes as part of the bus transfer design, 2 I have now connected that to the station power 3 transformer. I'm now feeding that fault with that 4 station power transformer.
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| 5 MR. CAVEDO: Then, that other normally-6 open breaker pops open and it must be energized. So, 7 then, the diesel cuts off. You don't lose --
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| 8 MR. FLEISCHER: It can. It can become a 9 race at that point, and you may or may not. And I 10 think that's the way we wrote it, "may or may not".
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| 11 We cover different scenarios in different -- I covered 12 different scenarios and different fault scenarios.
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| 13 There are several of them in there. But you could 14 ultimately go to both diesels.
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| 15 MR. CAVEDO: Not without that other 16 normally-open breaker there.
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| 17 MR. FLEISCHER: Well, actually, that was, 18 in the Monshon paper, there was an actual event where 19 that did occur.
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| 20 MR. CAVEDO: Where the breaker failed?
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| 21 MR. FLEISCHER: Where the breaker failed.
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| 22 MR. CAVEDO: So, it is possible --
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| 23 MR. FLEISCHER: Yes.
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| 24 MR. CAVEDO: -- but it is not likely.
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| 25 MR. FLEISCHER: Yes, it is not likely, but NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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| 249 1 it happened once.
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| 2 MR. MELLY: Then again, in frequency 3 space, one event is one event.
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| 4 MR. CAVEDO: Yes, one event is one event.
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| 5 MR. MELLY: It's handled in frequency.
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| 6 MR. TAYLOR: Any other questions or 7 comments for Ashley in the room?
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| 8 (No response.)
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| 9 So, I'm going to check the webinar real 10 quick.
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| 11 It doesn't look like there's any 12 questions.
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| 13 So, I did have one quick question.
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| 14 MS. LINDEMAN: Okay.
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| 15 MR. TAYLOR: Nick did a lot of work when 16 he put together the information notice, Notice 17-04, 17 which was the one that Tom talked about, identifying 18 operating experience or test data on aluminum aspects.
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| 19 We tried to do justice to come up with durations for 20 those events. So, on the second paper that you had, 21 were you able to find any additional or new 22 information on durations that we didn't already 23 identify? Was there any feedback on that aspect?
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| 24 MS. LINDEMAN: So, we didn't focus so much 25 on the event review of duration. But what we did NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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| 250 1 characterize is how the protection schemes performed.
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| 2 So, I'm not sure if that provides you the duration 3 answer, but at least insights on what scheme actually 4 did and if there was failures in the primary or the 5 backup.
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| 6 MR. TAYLOR: Okay.
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| 7 MR. MELLY: This is very interesting work 8 in looking at this and how these faults persist for a 9 long time with unit-connected designs. We also do see 10 the situations like Fort Calhoun where the fault 11 persisted for 42 seconds and was postulated to have 12 released 80 megajoules of energy during that period of 13 time on the root-cause analysis. It was a very low-14 current event, but it was stuck in and had to be 15 manually turned off by the operators themselves by 16 switching a breaker. So, there are several cases 17 where it doesn't require that many levels of failures 18 in order to have these events hold in for long 19 durations.
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| 20 MS. LINDEMAN: So, I think that event as 21 also an instance where there are multiple fail 22 barriers.
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| 23 MR. MELLY: There was one.
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| 24 MS. LINDEMAN: There was more than one, 25 yes.
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| 251 1 (Laughter.)
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| 2 I mean, I think there was design 3 deficiency and there was more than one thing that --
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| 4 MR. MELLY: It was 42 seconds.
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| 5 MS. LINDEMAN: Yes.
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| 6 MR. TAYLOR: Okay. Thank you. Thank you, 7 Ashley.
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| 8 Bas, I think you're up.
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| 9 MR. EARLEY: Just one more question?
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| 10 Thank you.
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| 11 I was asked a question about what was the 12 basis for the gap spacing in the tests that were run.
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| 13 And the gap spacing was based on the product standards 14 for equipment of a certain voltage category and the 15 basic impulse level required. And there was a 16 specified minimum and maximum spacing for that.
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| 17 MR. CIELO: I just want to do a real quick 18 introduction for Bas. He's actually visiting the U.S.
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| 19 between travel to India last week and Dubai this next 20 week. Yes. So, he is our Global Director of Business 21 Development and Innovation for KEMA Laboratories.
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| 22 KEMA Laboratories -- he's going to tell you a lot 23 about -- is a division of DNV GL.
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| 24 We don't design, build, or operate 25 anything other than our test labs. But we test for NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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| 252 1 every manufacturer on the planet between our three 2 laboratories. So, we see, basically, all the 3 equipment that you have and any other industry has.
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| 4 We've got decades -- we've been around 5 since the early 1900s. And Bas ran the High Power 6 Test Lab, the largest high power test lab in the 7 world. He ran it in the Netherlands for a number of 8 years.
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| 9 He's also a member of the IEC, the Dutch 10 IEC Standard Committee, and he's one of the managing 11 directors of the Short Circuit Test Lab, or liaison, 12 STL, which is kind of a confederation of short-circuit 13 test laboratories all over the world that not only 14 work to the standards, but develop test protocols to 15 have common results from these labs.
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| 16 So, I just wanted to do a quick 17 introduction. He's here from the Netherlands. He's 18 going to present a lot of data. There's a lot of 19 information here. It's a little bit of a long 20 presentation, but, hopefully, I think you'll get 21 something out of it.
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| 22 So, thanks.
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| 23 MR. VERHOEVEN: Yes, Frank, thank you very 24 much.
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| 25 First of all, it is my pleasure being here NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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| 253 1 talking to you. And, also, the information I got from 2 all the discussions this morning and the afternoon so 3 far is really interesting.
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| 4 I would like now to bring you a little bit 5 more a global approach. There are some global things 6 that I see happening or in our work we see happening 7 in the world.
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| 8 Like you said, I do travel a lot. So, I 9 have a lot of frequent miles for my family. But, at 10 the same time, I talk very often to utilities. Just 11 last week, I was in India talking to the utility and 12 the former Secretary of the Indian Ministry of Energy, 13 talking about power system reliability, power system 14 performance, and all that kind of stuff. We'll do the 15 same next week in Oman, Qatar, and, then, Dubai. Week 16 four on that, it will be in London.
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| 17 So, I have quite a bit of a background of 18 knowing what was happening in the world. There are a 19 few items that are generic, and I will address these 20 and, also, on other things with some data, what was 21 happening over there. Hopefully, it will give you 22 some additional information in your scheme of 23 discussion.
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| 24 So, what I would like to do, very shortly, 25 is just an introduction of KEMA, KEMA Laboratories, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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| 254 1 let's say our mother company. Then, we'll talk a 2 little bit about certification, a global approach. I 3 think all the world is dealing with the word 4 "certification," independent testing and 5 certification. It's slightly different than it is 6 normally done here in the U.S. So, maybe there are 7 some things to learn there.
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| 8 Then, we will talk a little bit about 9 statistics on testing and certification of the 10 components, circuit breakers, cables, and instruments 11 as well as transformers, and so forth. And in that 12 statistical data, because we have a time spent of 20 13 to 30 years, there are some lessons. And then, we 14 will take some summaries and takeaways.
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| 15 So, KEMA Laboratories, the name KEMA is 16 very well-known in the utilities all over the world.
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| 17 It was established originally in 1927 when we started 18 building the High Voltage Laboratory and, later on, 19 it became the Short Circuit Laboratories. In 2012, we 20 were, let's say, acquired by DNV GL, and that's a 21 Norwegian-based company. Actually, it is a 22 foundation, fully independent. And that is dealing 23 basically to save lives, property, and the 24 environment. So, we do not serve any -- there are 25 printouts of my presentation? Can we share it --
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| 255 1 thank you -- for people who want to make notes? So, 2 everything that we do, we do not produce anything.
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| 3 Only we provide services to ensure the safety of life, 4 property, and the environment.
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| 5 Basically, it's what we call an industry 6 consolidation. So, let's say the mother company is 7 DNV by itself, a Norwegian foundation, over 150 years 8 old. We grouped with Germanischer Lloyd, also a 9 company active in the field of the maritime sector and 10 the gas and oil sector and safety-related matters.
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| 11 So, the company KEMA, the Dutch company KEMA, was 12 integrated in the system as well.
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| 13 And we have here some background. KEMA 14 has been in the gas world. So, a lot of our people 15 knowing about gas, gas behavior, wind field areas, and 16 also within the piping industry.
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| 17 So, again, a lot of disciplines over here.
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| 18 Like I said, 150 years old. With our maritime 19 background, we are in over 100 countries globally, 20 mainly at the main ports, and 100,000 customers, 12.5 21 thousand employees.
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| 22 These are our business areas. Maritime 23 sector, basically, the ships, and they can be normal 24 ships, special ships, special laying ships, or 25 containers, or whatever, to ensure that the ships are NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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| 256 1 up to the class.
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| 2 Oil and gas, that is basically to 3 safeguard lives and the property in the environment of 4 rigs in the sea or on gas rigs in the sea. I think 5 here, with the discussion I've overheard this morning 6 and this afternoon, it is here we can make a 7 connection between the experience and the knowledge we 8 have -- oil and gas, where we have a lot of people 9 available and they have the expertise and the 10 calculation methodologies to see how, let's say, if 11 you have a gas explosion on a rig, how it is being 12 protected with safety barriers, and so forth, in that 13 field. I think when you talk about long-term 14 durations and propagation of heat and fire, there 15 could be a connection. So, that's an invitation to 16 you all to work on that.
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| 17 And also, we have in this field of play 18 special laboratories in the UK where they are able to 19 have real gas, real high-pressure gas, gas explosions, 20 and to study these also.
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| 21 So, I think that is already, Frank, 22 included in the proposal. That is something to look 23 at because there is a lot of information available 24 there that we need to combine.
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| 25 So, energy is there. Business assurance NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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| 257 1 is taking care of the management, accreditations, and 2 so forth, that we talk about.
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| 3 Let's jump to KEMA, KEMA Laboratories.
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| 4 There are, basically, three of them. The main 5 laboratory, one laboratory, you could say, here in 6 Arnhem. This is the Netherlands. It's on the German 7 border. You could say it's the same as Amsterdam, 8 but, then, a one-hour drive to the east.
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| 9 This is the largest laboratory for short-10 circuit testing and dielectrical testing in the world 11 in terms of power. No laboratory is bigger in terms 12 of how we perform. And you can see from actual size, 13 it's a very large facility. Total estimate is maybe 14 even 600 million euros to make this happening.
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| 15 This part over here is the short-circuit 16 part where we test the circuit for short-circuit 17 performance. The generators, the switchyard, the test 18 facilities and test base, and here on the top we have 19 the High Voltage Laboratory, and so forth, 20 dielectrical testing.
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| 21 As you can see over here, we are located 22 to the River Rhine and with our own harbor, where we 23 are able to dock ships in with large power 24 transformers, so the big ones up to 800-kilo class 25 power transformers, the real big ones, so stationary NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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| 258 1 transformers, where we can test these transformers for 2 their ability to withstand short circuit passing 3 through the transformer. Every power network has 4 several short circuits in a year, and these short 5 circuits pass through all the components, including 6 the power transformers. And then, we determine how 7 well this transformer behaves for those currents 8 passing through.
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| 9 So, that's the largest one. We have two 10 more or less comparables, one in Chalfont -- that has 11 been referred to by this board already -- where we 12 have here the test cells where we did the execution of 13 the test in the last years. So, one of these was, 14 let's say, it can be vaporized by the dose particles, 15 generator hull, and the train passing by that was 16 referred to this morning. Comparable laboratory like 17 that we have in Prague, in the Czech Republic.
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| 18 How does a High Power Laboratory look 19 like? Because the short-circuit testing, whether it's 20 for an for a durable arc or an explosion arc or the 21 physical performance test of the circuit breaker, you 22 need to have a huge amount of energy. And that amount 23 of energy is basically you cannot get it from the 24 network without having the network going up and down 25 a little.
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| 259 1 Especially when we talk about here in our 2 facilities, like I showed here, we are able to test 3 circuit breakers on their functional performance to, 4 let's say, switch of the short circuit current and 5 failure, at the same time having 800 kilovolts or even 6 1,000 kilovolts as the feeding network. If you do 7 quickly the math, the number of power that you need 8 for that is huge. You cannot take it from that way.
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| 9 So, what we do, we do it differently.
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| 10 Basically, we have here short-circuit generators, and 11 these generators, we bring them up because they are 12 using the power network energy. But we accumulate the 13 energy in rotating energy in the rotor. So, each 14 generator has a rotor with a mass of 55 tons of steel 15 spinning at 3,000 RPM, or if we have to do the test at 16 60 hertz, it will spin at 3,600. And that's basically 17 an energy storage. By the time we do this, we 18 energize the rotor winding here in the generator hull, 19 and the energy comes back out again as this electrical 20 energy.
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| 21 So, that's basically how we generate the 22 power, our step-up transformers to perform this to any 23 level that we need. Or we can connect even the 24 generators from their 10-kilovolt supply in parallel 25 for testing the certification of generator circuit NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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| 260 1 breakers.
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| 2 Switch our test base, several test bases 3 over here. The harbor is there, in there for the test 4 certification.
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| 5 Here is how such a generator looks like, 6 and this is a generator. It's about 10 meters long 7 and diameter, overall diameter of about 4 meters.
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| 8 This generator can make a short-circuit power of 2,500 9 MVA.
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| 10 For that power class, this generator is 11 very small, because we do not have the limitation of 12 the thermal properties. We run this generator. We 13 speed it up, of course, but the actual short-circuit 14 test normally takes about, let's say, max 1 second.
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| 15 So, we don't have an issue with the thermal continuous 16 operation mode. That's why we can get really energy 17 out of this generator of 2.5 kilovolts.
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| 18 Then, have a look at the power rating. We 19 installed six of those generators, which can be better 20 now. So, basically, our continuous power rating we 21 can make is 15 gigavolt or better. Basically, that is 22 sufficient to power the whole of the Netherlands for 23 about 180 seconds. You get a feeling of what kind of 24 numbers we're talking about. These are big numbers.
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| 25 Our laboratory in Chalfont that I've NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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| 261 1 already referred to, we have two generators, a bigger 2 one and a little bit smaller one, T-1 and T-2. They 3 can't be parallel. So, the maximum power we have in 4 the Chalfont is 2.2 MVA, or a thousand MVA available.
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| 5 We have two generators that can be parallel.
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| 6 That means that, if you are running tests 7 or you need the ultimate power and our Chalfont plant 8 is not available, there is this lab in the Netherlands 9 that is six times the size of Chalfont. The question 10 is, is that needed? Most likely, the power rating 11 that can be supplied by Chalfont is sufficient for 12 your kind of testing certifications. But, if you run 13 into limitations, don't worry, there is a backup, a 14 big one.
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| 15 What is important, and that's why I added 16 it over here, that's laboratories that people use 17 normally have to have, let's say, a decent 18 accreditation. And normal accreditation is the 19 ISO 9000 series. I think everybody's familiar with 20 it. But there is a special one that is 17-025, so 21 that IEC 17-025, which is a generic certification 22 scheme for laboratories, any current laboratory. It 23 can be a short-circuit lab. It can be a high-voltage 24 lab, but also a lab for the testing of clothing or 25 blood samples, or whatever. So, it is a generic NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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| 262 1 management organization for laboratories.
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| 2 If you make use of a laboratory, ensure 3 that it is certified by 17-025 for sure, and that's 4 also the connection here with the NRC, I believe, that 5 there is a simplified method of using laboratories as 6 long as they have that form of 17-025 accreditation.
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| 7 Many the laboratories in our field of 8 play, where you look around the world in the power 9 sector laboratories, most of the laboratories are 10 manufacturer-based laboratories. So, they use it for 11 their own testing and certification. These are 12 typically not certified by 17-025. They're just run 13 by themselves. The commercial, good, independent 14 operation laboratories, of course, all have the 15 17-025. So, also, our three laboratories at all 16 locations are accredited to that system.
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| 17 And basically that means in the end that 18 you are connected to basically the methodology as pre-19 described in ILAC. That is the informational 20 organization for accreditation of laboratories.
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| 21 So, let's look a little bit about the 22 global approach of certification. Basically, the 23 certification is what we call a means of mitigation of 24 risk. And there are, of course, several ways how to 25 mitigate risks. And so, the global approach that I NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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| 263 1 see happening in the world over and over again is 2 basically a two-step approach.
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| 3 First of all, you have to assure that the 4 design of your power network or your powerhouse, or 5 whatever, basically, the conceptual design is okay, 6 that you have selected the proper voltage classes, the 7 proper single circuit or double circuits, having 8 managed work and managed tools, or whatever. That's 9 basically the design that will give you the function 10 that you need. And you need to balance that with the 11 criticality of the component and on the system.
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| 12 Again, I expect for a nuclear power 13 station the reliability issues are even at the higher 14 level than a normal substation in the queue. So, 15 that's one.
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| 16 The second, if you have designed the 17 system, and you go to build it, you have to buy in 18 components. You have to ensure that these components 19 are up to the task, that they will be able to 20 withstand the voltages, the currents, and that the 21 circuit breaker will open when it is supposed to open, 22 and so forth and so forth.
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| 23 So, what is important? A good design.
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| 24 Secondly, make use of components that have proven to 25 be suitable for it.
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| 264 1 And maybe a little bit of difference in 2 understanding between the U.S. and the rest of the 3 world or other bigger parts of the world. Many 4 utilities in the world want to see the proof upfront 5 at the development process. And by saying, well, the 6 manufacturer says, well, yeah, this is one design; it 7 will work definitely, it's on the specs. So, when it 8 is off, you can sue me, or whatever.
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| 9 Well, people or utilities in the world --
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| 10 especially next week I will be speaking to SUN, SUN-11 ELECTRIC Company, that simply said, every component 12 that will go to tender must have at the tendering 13 phase already the certified, independently-certified 14 performance check. That means an independent 15 laboratory, like KEMA or some other companies, have 16 tested those components to a standard. Most of the 17 time, it is IEC-based.
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| 18 And that's basically what you see 19 happening quite often, that in the global market, 20 where you say, okay, when I'm tendering, I am going to 21 demonstrate with the type of documents, that it is 22 tested in an independent laboratory, not in the 23 country of origin. That's how the global play is more 24 or less conducted. And that independent laboratory 25 can be an STL member.
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| 265 1 So, what is the STL? STL is a voluntary 2 group of laboratories that operate globally, where 3 they said, okay, many of the standards that are out 4 there, whether it is IEEE, ANSI, or the IEC, sometimes 5 these documents are still political documents. That 6 means that they are not -- let's say the working 7 committee was not able to design really, okay, these 8 are the tests that have to be done, or there are 9 options. And every political solution in the test 10 standard, basically, it can be shown that you have a 11 clause for a certain performance criteria and that 12 you may choose between test 1, 2, or 3. That means 13 the committee could not decide what the real test 14 should be because the stakes of the people was too 15 high.
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| 16 All STL was doing, the short-circuit 17 testing result, is basically doing a harmonization of 18 the implementation of the standards. So, if IEC 19 standards, basically, are given options, STL will say 20 to the testing laboratories, we will always go for 21 option 1 or 2, and this and this is the way how to be 22 executed. That means that the members of STL will 23 always perform the best in-depth specific guide.
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| 266 1 in the IEEE and the ANSI there may be different 2 approaches, but we do see that both those standards 3 are becoming more and more closer. So, a lot of IEEE 4 standards that are there on a day-to-day will take 5 over sometimes even 100 percent IEC. I think that's 6 a good development.
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| 7 So, who are STL members? There are 8 currently quite a few. But, basically, all these are 9 what's now shown on the graph, I understand. There is 10 a membership here, STL, the source of the test 11 liaison, "NA," this North America, that's a group of 12 laboratories there. KEMA Laboratories is over here, 13 and we are, of course, members, even a founding member 14 of the STL. But you can see our general approach and, 15 also, you can see here our laboratory, that it is part 16 of the STL.
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| 17 That means that they work and operate, 18 they have to work and operate exactly in accordance to 19 the STL guides. And when you talk about STL, not any 20 laboratory can become an STL member, because you have 21 to prove that you are up to the task, that you're 22 knowledgeable, that you have been maintaining that 23 knowledge for a longer time. That's one of the 24 criteria of the laboratory. That's why the number of 25 laboratories that you see is limited.
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| 267 1 When you look at the STLNA, so the 2 American version, it's comprised of several 3 laboratories, manufacturers' laboratories, but also 4 independent laboratories. I mean, Eaton is there.
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| 5 Cooper is there. LAPEM in Mexico is also part of this 6 group. S&C is there, Eaton, and then Gelfem 7 (phonetic) is there as well. So, it is important to 8 delegate, and the influence of STL is becoming much 9 more important globally.
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| 10 So, how do many of the utilities look at 11 certification? They said, like I said just before, 12 they need to at least ask for an independent 13 certificate upfront in the tendering process. In the 14 IEC, and I think also in the IEEE, or many in the IEEE 15 standards, there's a section which is called five test 16 or design test. And basically, that comprises the set 17 of tests that components should be tested to, and when 18 these tests are done, basically, it will say, hey, 19 this component is up to its stuff; it can be used by 20 itself.
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| 21 And this is a prospect that many utilities 22 demand that full type test to be executed upfront or 23 even during the delivery, depending on the 24 methodology. That is typically how it is done. That 25 means that the majority of the work we see in our labs NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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| 268 1 in the Netherlands are always certification tests.
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| 2 When the manufacturer is ready with the design, he 3 thinks, okay, I'm done, I'm ready, let's go to the 4 independent test and hope that I will receive it, and 5 with that, I can release it and do my marketing, and 6 so forth.
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| 7 Also, a thing that came across with some 8 discussions I had with American manufacturers as well 9 is that the liability of the component is not 10 transferred by certification. Although we, as KEMA 11 Lab, said, okay, this circuit breaker is up to the 12 task, it fulfills the requirements as stated in the 13 IEC, I will not be responsible for that circuit 14 breaker. That remains with the manufacturer, of 15 course.
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| 16 Also, a thing that's often discussed, 17 modeling in place test. The feeling is such that 18 modeling are important tools for the design of 19 components, very important tools. And it can be rules 20 of thumb. It can be numerical calculations or finite 21 elements, or whatever kind of calculations or models.
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| 22 But always a model is just a simple presentation of 23 the real-life situation.
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| 24 And especially in those areas when you are 25 in a phased transition from solid to plasma, your arc, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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| 269 1 that is where modeling becomes extremely difficult.
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| 2 Modeling is extremely difficult. There are models for 3 the arcing parts. There are models for the stationary 4 solar part, for the transition between those two, and 5 the phenomena, especially when you talk about zero 6 crossing of a current, when you go very quickly from 7 a plasma state, hopefully, through a solid state, and 8 then, if you have a retrigger to a plasma state again, 9 that kind of modeling is extremely impossible. And 10 computers, even the big super-computers, are not able 11 to calculate that kind of stuff.
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| 12 Also, to prove that little bit, CIGRE 13 designed several years ago and said, okay, I'm going 14 to make a circuit breaker in a certain design, and 15 that design was given to several manufacturers, Real 16 Global, Abrandt (phonetic), and manufacturers. They 17 were asked, hey, calculate this circuit breaker when 18 it will seem like the goal breaker. And a simple 19 electrical breakdown on AC voltage, the most simple 20 thing you can imagine.
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| 21 So, every one of those manufacturers start 22 to calculating, and the super-breaker was also built 23 and tested. And then, all the results were compared.
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| 24 It showed that there was a very big scattering of the 25 results. We had a physical result of the test was, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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| 270 1 let's say, 100 percent, and there were calculations 2 weighed.
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| 3 And why? Basically, it is also very 4 simple. Why? Modeling is so difficult to represent 5 the real-life situations. The majority of the cases 6 when something, let's say, has a breakdown or a 7 dysfunctionality, it is because of slight 8 imperfections in the materials.
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| 9 If you have a pencil, you can calculate if 10 I squeeze it and put it under pressure. You can 11 calculate the stresses in the wooden pencil, but you 12 never can calculate where it will snap, on my left 13 thumb, right thumb, or in the middle. Because it will 14 snap at the point where it has a small imperfection.
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| 15 And I push with my fingertip in the wood, or an 16 imperfection will do it. That is something that you 17 cannot calculate.
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| 18 Then, let's go to some experience about 19 reliability numbers and statistics and failure rates.
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| 20 This graph that I got from Eaton here in the U.S. --
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| 21 and if you Google out Eaton's blackouts record, that's 22 a study being done by Eaton, and they calculate the 23 number of outages that is happening in the U.S.
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| 24 What's the root cause of that? They do it year on 25 year.
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| 271 1 So, this is the 2016 graph; '17 is being 2 calculated, will be published, hopefully, in a month's 3 time or so.
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| 4 But this is a very interesting picture.
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| 5 Basically, it shows that in the U.S. there are, in 6 2016, almost 2,900 outages in that year. That means 7 the outages today. And they are trying to find out, 8 hey, what is the root-cause analysis of that failure?
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| 9 It appears to be -- and this is basically, of course, 10 the data that is looking at the transmission and 11 distribution networks -- it means also the median 12 voltage lines throughout the city and the countryside.
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| 13 So, it is the exposed system, medium voltage and the 14 lower and higher voltage.
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| 15 So, 33 percent of the outages was caused 16 by weather incidents, a storm hitting over, snapping 17 a pole, or that kind of stuff. And 4 percent was 18 animals, the deers and the raccoons that climb into 19 the poles and there may be short circuits. Cars 20 hitting the poles and the pole snaps and breaks the 21 line. About 5 percent was planned. So, when you have 22 the radio feeder and go into an area -- and they had 23 to do some prepare; it was a planned outage. Because 24 the people were in the way, it could not be switched 25 over.
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| 272 1 More importantly is this number here, 24 2 percent. Twenty-four percent of the outages in the 3 West here is basically arrangement by faulty equipment 4 or human error, the mistakes made to maintenance, or 5 whatever. But that basically means that the circuit 6 breaker who receives the trip amount will not trip.
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| 7 Twenty-four percent.
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| 8 I'm talking about reliability of 9 components where you just put components in the 10 network without knowing that these are of decent 11 quality. You're demanding something from the network.
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| 12 And I think the discussions here was, yeah, yeah, that 13 can be so, that we have circuit breaker that doesn't 14 trip or we have multiple layers of handlers. Well, 15 yes, it's 24 percent. And I think that's quite a high 16 number. I think that number that can be influenced by 17 the utility assuring that what you put in your network 18 is of proven technology, that it's up to the 19 standards, up to the task that it is designed for.
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| 20 Then, when you look at that 24 percent, 21 historically, over the years, then you see this graph.
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| 22 Basically, this is not percentwise, but an actual 23 look. So, in 2008, it was about 650 outages caused by 24 faulty equipment, and that is going up to now just 25 over 900 incidents.
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| 273 1 That means that more is happening. And a 2 few reasons are here on the left. One of the main 3 reasons is by interconnecting of power networks to 4 stiffen the network, to make it stronger, so that the 5 short circuit performs better and the voltage 6 fluctuation in the networks are slower. And you have 7 better, let's say, availability in terms of -- but it 8 also means an increase of short-circuit performance, 9 of short-circuit currents, can go from maybe 20-30 10 kilograms up to 40, 60, and there are already power-11 nets working in the new world with short circuits' 12 current values of close to 90 kilograms, 9, zero; 9, 13 zero. That's a big one. That means that all of these 14 stresses are put on the components and are sitting 15 there. So, you see an increase of those parts.
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| 16 I talked about CIGRE. I will refer to 17 CIGRE a little bit more. That's why I put this slide 18 on, because I do not know if everybody is aware of 19 CIGRE, because that's an international organization 20 from 1921, which basically it's voluntarily an 21 academic environment where they do a lot of studies, 22 a lot of imports, and working groups, in the power 23 sector. So, technology outlooks, but also a lot of 24 statistical data is there from how the power-nets are 25 performing.
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| 274 1 Also, people from the U.S. are, I think, 2 a member of CIGRE. But I definitely would advise you 3 to please have a look. And there's quite some 4 information freely available. A little information is 5 available. For some, you have to become a member.
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| 6 So, you can sign up, become a member yourself or find 7 somebody in the U.S. who is a member, and then, get 8 that data.
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| 9 One of the three datas that came out from 10 the Working Group A2-37 was to perform a reliability 11 study. That's basically looking at power 12 transformers, the bigger ones, all over the world, and 13 how do they function. What is the overall experience 14 in terms of reliability?
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| 15 And here you see the graph that was coming 16 out. Here in the white/blue blocks, basically, the 17 step-up transformers. And depending on the voltage 18 class, that means that in the step-up transformers 1.3 19 percent failure rate per year. And the step-up 20 transformers, of course, are the most critical 21 component in a power station, where it jumps up to 22 power. So, if you have an issue in the step-up 23 transformer, your unit is out for, let's say, a year 24 or half-a-year, or a considerable amount of time. The 25 normal power transformers that are at substations NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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| 275 1 always have a little bit lower tendency to have 2 issues.
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| 3 But that means one out of two of the 4 transformers has an issue in its performance. That's 5 quite a high number, obviously. So, things happen, 6 and we don't expect it, or things that were not, real 7 importantly, does happen.
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| 8 This report, by the way, it's a long 9 search, but this report is freely available. I can be 10 downloaded by anybody.
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| 11 Another graph from the report is basically 12 looking at, hey, what are the root-cause the analysis 13 of the failure of power transformers? Basically, it 14 was 11.6 percent of the cases the failure was caused 15 by an exterior fault, and this, the next general short 16 circuit. The short circuit passing through the 17 transforming, shaking the windings, and a lot of force 18 on the windings, and that was basically the root cause 19 of the failure of the transformers.
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| 20 So, design issues, a big chunk on aging, 21 of course, here. And after time, power transformers 22 are often 20, 30, 40 years old, or longer, and then, 23 the aging becomes an issue. But well before aging, 24 the external short circuit kicks in in this case.
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| 25 And that was a study we found from EPRI on NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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| 276 1 the performance of power transformers, a reliability 2 study. And also there, inadequate short-circuit 3 strength was the major cause of failure.
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| 4 The funny part is, if you look at how many 5 utilities are demanding short-circuit testing of 6 distribution of power transformers, that's relatively 7 low. They all think, well, my network is good; 8 there's no issues for me, or that the manufacturer 9 says, no, no, I don't want this test because it's too 10 risky. That's a very, very odd situation there, what 11 I see globally, but it is changing.
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| 12 Here again from CIGRE, an overview, 13.08, 13 and the number of faults that are happening in power 14 systems. Because many people in our own industry say, 15 aw, short circuits hardly even occur, at least not in 16 my network; it's not an issue. But, if you look at it 17 from a global basis, basically, depending on the 18 voltage class, you have two to three short circuits in 19 the line. That means, if you have an extended power 20 network, you do have issues, things happening in the 21 power network that will have an effect on the overall 22 performance. So, that can happen.
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| 23 Before I start on this part, this is the 24 part of the experience we have in the last 20 to 30 25 years with time testing of components. What is NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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| 277 1 important is to understand the following: that is 2 data when the manufacturer comes to our laboratories 3 for a time test. It means the full time test as it's 4 in the system for that specific component. Mostly, 5 it's to set a different course. That needs to be 6 short-circuit performance, dielectric performance, 7 temperature-wise, and sometimes also mechanical or 8 circuitry.
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| 9 The manufacturers that come to us have, 10 let's say, completed their R&D phase. They are ready 11 with the design. They don't come to us for R&D tests 12 because we are too expensive. So, when they come to 13 us, they are ready with the design and say, hey, this 14 transformer or this circuit breaker is of high 15 standard, high quality. Okay, yes, please come and 16 miss the circuit breaker or miss the transformer.
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| 17 And then, we will start with the time test 18 sequence. And then, we don't basically look -- when 19 there is one of the tests in that sequence of tests 20 fails, then we call it initial failure. That means, 21 although the manufacturer thought it is okay, it did 22 not at some point during the certification process.
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| 23 Of course, he can do redesign and come back, and then, 24 maybe hopefully for him, it will be successful. But 25 we only count the first time and we see if there is an NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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| 278 1 initial failure rate or if this is successful.
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| 2 Before I show an overview, I would just 3 like to ask the question, out of, let's say, the 100 4 percent, out of all of the components that we started 5 time testing, how many is your rough feeling of 6 samples have that initial failure rate problem? How 7 well is this sector in this case doing? Or do you 8 think that the initial failure rate is 5 percent, 10 9 percent? So, five components out of the whole group 10 are not going well? Or is it a little bit more, 20 11 percent, 30, 50?
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| 12 MR. FLEISCHER: Are you talking prototype 13 or production?
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| 14 MR. VERHOEVEN: The real one, the real 15 production type.
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| 16 MR. FLEISCHER: Oh, the real production 17 types?
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| 18 MR. VERHOEVEN: No, no, no, no, not R&D, 19 no.
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| 20 MR. FLEISCHER: Ten percent?
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| 21 MR. VERHOEVEN: Twenty-five. So, all the 22 components, the experience we have -- and it doesn't 23 matter when you talk about circuit breakers, power 24 transformers, cables, enginators, or medium-voltage 25 panels or low-voltage power panels, they all hover NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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| 279 1 around the 25 percent.
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| 2 And if you compare that with another 3 industry, we're not so good. If you compare it to the 4 car industry or the computer industry, or some other 5 industries, this number normally in all industries is 6 around 3 to 5 percent. We are, as a sector, 25.
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| 7 Then, the question is, how come? Are we 8 not smart enough as people? No, I think we are 9 educated persons. We have a lot of smart people. No, 10 I think one of the reasons -- and I will give you some 11 more proof later on -- but, basically, this 25 12 percent, it is happening that these components that we 13 are using in our power networks, and whether it was a 14 circuit breaker or a panel or a transformer, or 15 whatever, these are what I would call high-tech 16 components. It has to be built in good condition. It 17 has to be designed in good condition. Because they 18 are up to the task, and that is a strong task. A 19 circuit breaker normally has sit in the closed 20 position waiting for the trip command. Maybe it has 21 to wait five years for that. It has to come, and 22 within 2 mini-cycles it has to open. That's a very 23 special product that we are designing in our sector, 24 and that is basically reflecting the number of 25 25 percent.
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| 280 1 Let's look at some statistical data. So, 2 large power transformers, 20 MVA or larger, we started 3 testing these transformers in '96 up to last year.
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| 4 Basically, this is the trend. So, the total number of 5 these big transformers we test and the individual 6 year-on-year performance. And you see that in this 7 case our average is 22 percent. So, one out of four 8 transformers fails to meet for short-circuit 9 performance. That exhibits how that will look like.
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| 10 But we mention that you order power 11 transformers and you don't test for short-circuit 12 performance, you could say. If this is true for the 13 whole population of transformers, if you have four 14 power stations, one of the power stations is at risk.
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| 15 If that's completely true, I don't know, but roughly 16 to get your mindset a little bit in this way.
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| 17 Also, you see an increase in the number of 18 tests we performed over the last power transformer.
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| 19 That is showing of the world, and these are utilities 20 basically in India, China, or in Europe it's France 21 and the Netherlands, that are more and more and more 22 asking for short-circuit performing testing.
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| 23 MR. TURNER: Is some of it because the 24 standards are requiring testing at 100 percent of 25 expectations whereas in a real application it may only NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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| 281 1 be running at 60 percent of that? Is some of it 2 because the standards have --
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| 3 MR. VERHOEVEN: No. I will go through the 4 standards.
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| 5 MR. TURNER: So, what you're saying there, 6 in effect, if I build something, I can put four of 7 these things in there. When I try to commission the 8 plant, one of them is going to go down. That's just 9 not the experience people will have.
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| 10 MR. VERHOEVEN: No?
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| 11 MR. TURNER: So, where's the disconnect?
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| 12 Are the standards too tough or people just aren't 13 running it near the standard limits, or something of 14 that nature?
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| 15 MR. VERHOEVEN: It's complex. It is very 16 complex to answer that question very directly, but I 17 think a lot of data on the physical performance of 18 networks does not come together. And that's why I put 19 this graph here for power performance. These numbers 20 are quite higher than people expect. So, a lot of 21 data or information on things that are happening out 22 there is not, let's say, accumulated to today's 23 experience.
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| 24 This is a time test on the short-circuit 25 performance of a transformer. It goes very fast.
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| 282 1 Where there is a secondary short circuit, together in 2 here we feed in, and here you see what is happening 3 due to the mechanical forces inside the power 4 transformers that are creating a short wave in the 5 transformer and starting vibrating of the -- then, you 6 start to vibrate. And basically, a leak inside the 7 transformer is pooling in the transformer on the 8 enginator, and you have the snapping moment in the 9 engine as it breaks. In normal life, it would be a 10 big fire.
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| 11 The other one, it is also a transformer.
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| 12 This will have, due to the short-circuit movements 13 inside of the core, and then, the windings, there's a 14 short wave in the well. The safety valve breaks open, 15 and here even the oil catches on fire due to 16 evaporation of the oil. Since we are able to 17 disconnect the transformer very quickly from our 18 feeding generator, we don't have an issue here.
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| 19 MR. TAYLOR: Do you want your next slide?
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| 20 MR. VERHOEVEN: Yes. So, what is 21 happening there -- and, also, this is in Exhibit 4 --
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| 22 the power transformers, to explain a little bit more 23 what's happening and why this is so crucial, this kind 24 of testing. It just also popped to my mind, this is 25 also maybe applicable to the things that you were NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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| 283 1 talking about, those sparks that are seeing short-2 circuit curves. It's basically mechanical forces out 3 there, and this is the basic force of the curves. And 4 two curves, depending on the propulsion actions 5 happening inside, the winding order, parallel 6 conductors in the bus box.
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| 7 Especially when you talk about this as 8 global, the distance between the crossbar is becoming 9 smaller and smaller, and the forces go up. Since it's 10 a short-circuit test, it's clear of the current. So, 11 it goes up very fast.
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| 12 The issue in the exhibit of what can 13 happen, so this is normal rate of currents, and this 14 is basically a short-circuit current going to the 15 stationary in back. And this is the DC offset.
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| 16 Especially in networks that are getting close to a 17 generator failure, the DC component becomes quite 18 high. And you can have, let's say, between a normal 19 curve condition and short circuits, it goes up to a 20 factor 10 times or a little bit more.
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| 21 But, if you looked into the forces, it 22 goes up and, then, it doubles in size because it goes 23 up. It means that the peak goes in the force maybe up 24 to 400 per unit in force in total. And that's a 25 tremendous amount of force.
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| 284 1 And what is even more critical, that is 2 not a steady-state force. That is a pulsation, 3 constantly hammering with each going up and down. And 4 actually, what is happening, the frequency also 5 changes during the decay of the DC component. So, it 6 goes from 150, slow, to a 50 or 60 hertz, the 7 vibration.
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| 8 And this can create a huge amount of --
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| 9 you can see in the exhibit where the inner lining of 10 the control and the outer lining of this, there was a 11 leak going out where the complete winding was 12 basically rotated. So, this length normally should 13 have been straight from the inner lining. And here, 14 you can see it was twisted. And that twist basically 15 will end up in the short circuit.
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| 16 The force was on the left, and the 17 righthand picture shows the forces on the inner lining 18 of the transformer due to the electromechanical forces 19 that wants to make the inner lining smaller in 20 diameter. And then, it build this out here in the 21 linings.
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| 22 On this slide, on the left -- we'll play 23 a movie -- this is what you see is a winding. It 24 actually is a line core that we tested for short-25 circuit performance. You can see, when we applied the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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| 285 1 short circuit, you see that the core will start 2 vibrating. And that's the pulsating force of the 3 current passing through.
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| 4 You will also observe that the motion 5 decays over time. And carefully look also to this 6 part where you see some of the support was just moving 7 out. Yes?
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| 8 You see the pulsating force. The 9 frequency is changing, and there is no support of this 10 going out.
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| 11 That means that over time -- maybe in the 12 first time it remains okay -- but the second time it's 13 gone. So, maybe the half unit or when the next short 14 circuit comes, it will create an effect. And also, it 15 can be possible, like I said, for burst bars, high-16 energy burst bars, where they are chemically 17 supported, but where the forces are also there, you 18 have to pulsate your forces. Then, the suspension 19 engine may snap or will start cracking. At some point 20 of time, it will evolve from, say, a normal fault to, 21 at a completely different location, a secondary fault.
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| 22 Things to look at: yes, I was a little 23 bit surprised by it when I first was introduced to 24 this high-energy arc fault. I was really shocked, as 25 I said, at those 6 seconds or 40 seconds of what has NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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| 286 1 happened, extremely high in time.
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| 2 So, while the displacement is over here, 3 let's move on a little bit. I will go to the 4 standards. If you look at 444, that's volume 5 transformers and that's developing the standard. It 6 is that it allows in the IEC -- you have to, let's 7 say, demonstrate the ability for short-circuit 8 performance by either a test or by calculation.
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| 9 That's also applicable in the IEEE standard C75, which 10 also allows calculation of mechanical forces.
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| 11 Well, ladies and gentlemen, these kinds of 12 forces that was just shown in the movies cannot be 13 calculated. What can be calculated are static forces 14 inside the core. There's usually an ideal treatment 15 of the core, perfectly symmetrical, and all kinds of, 16 let's say, transpositions in the core cannot be 17 calculated. Leaks from the winding to the online 18 depth changer or to the enginators cannot be 19 calculated, impossible.
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| 20 That means that the standard is changing, 21 and not only for power control, it's also for arc 22 reports. They are saying, hey, you cannot calculate; 23 you must perform the test. So, the IEC and the IEEE 24 will change -- most likely, it will be done in 2019 --
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| 25 where the option of testing is ruled out.
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| 287 1 Let's look at another component, 2 distribution transformers. So, up to 2000 kVA across.
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| 3 Where you see power class, the initial failure rating, 4 on average, is 25 percent. And here, for the bigger 5 transformers, 2000 kVA or larger, there you see an 6 observation that the failure rate doubles the size of 7 the normal sized transformers.
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| 8 When you go back to the manufacturer and 9 ask, "Hey, how come; is this about double bit stops?",
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| 10 basically, it's, yes, it turns out their production is 11 here in the moments, in the skills. For 2000 kVA 12 transformers, they don't make that many of them. So, 13 there are much more design flaws in there or there's 14 much more, let's say, effect of people making it are 15 having less knowledge in making it. So, you 16 immediately see a high increase in the number of 17 initial failure rate. So, that's an interesting 18 observation, I would say.
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| 19 Cast resin transformers, most of the time 20 these transformers are used in high-rise building due 21 to their fire properties, where you don't want to put 22 oil or an oil-filled transformer in a high-rise 23 building due to the fire things. So, you put in a 24 cast resin, and they are a little bit more expensive, 25 but, basically, it is assumed that there's no oil.
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| 288 1 So, there is no issue with fire.
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| 2 And one of the tests is a volt, and if 3 this cast resin transformer is heated by a secondary 4 fire, will it catch fire and start to accumulate extra 5 fire damaging to the part? Or can itself ignite when 6 it is heated up? That's what we call the fire 7 protection clause in IEC.
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| 8 And strangely, from the prior transformers 9 we test for the fire properties, half of them is not 10 meeting specs. And it seems a simple thing. And you 11 buy those transformers for their fire properties. You 12 put it in high-rise buildings.
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| 13 And what happens? Our experience, 50 14 fails. It means that there's a special component.
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| 15 You can't name it. You cannot use it any kind of 16 resin for making this transformer. You need to have 17 special resin that has the right properties for fire; 18 also, the right properties for the thermal things that 19 are happening inside the core, but also the electrical 20 fire. So, it is not that easy as it seems.
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| 21 The cables, medium voltage and high 22 voltage. So, medium voltage, between 1 kV and up to 23 36 kilovolts. Cables, medium-voltage cables, 11 24 percent of the cables has initial failure rates. So, 25 that's unacceptable, as you know. But, if you look at NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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| 289 1 high-voltage cable, it's 26.
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| 2 And also here, how come? Because the 3 cable manufacturing problem is basically the same for 4 a medium-voltage cable or for a high-voltage cable.
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| 5 The same making equipment is what you need.
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| 6 But what we see happening -- and we've 7 talked to many cable manufacturers in the world --
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| 8 basically, the result was somebody has an idea. Okay, 9 I'm going to start to build a cable manufacturing 10 plant in country XYZ. They call one of the German, or 11 Finnish cable extruder manufacturers. You order such, 12 and you will get it. Within one year, you are a cable 13 manufacturer.
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| 14 And then, these people are there and 15 producing cable, selling cable. Then, they find, oh, 16 the margins, my financial margins are not extremely 17 well. I want to earn more money. And then, they 18 look, hey, the high-voltage cable sector. So, 66 or 19 32, or 50 kV and 500 cables are very more lucrative in 20 designing. So, they call the supplier of the 21 manufacturer and get some additional components, put 22 it on, and the next day they are a high-voltage cable 23 manufacturer. But they are still in the technology, 24 in their methodology of working and quality 25 surveillance, and feeling this process, they are still NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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| 290 1 a medium-voltage cable manufacturer. That's why this 2 number is more than double. Very practical, simple, 3 and maybe just, yeah, it's understandable. But this 4 is really what was happening out there.
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| 5 Fifty percent of the medium-voltage cable 6 terminations fail. That's the heat shrink technology, 7 a very simple, easy-to-use technology. If you use the 8 right materials and the right components, it is very 9 good. But what you see happening -- and that's why 10 this 53 percent -- these termination kits, and you see 11 an exhibit of these kinds of the termination types, if 12 you don't take the right materials, it will start to 13 decay due to the electrical field that is over the 14 tube. So, you need to have a special tube that can 15 withstand electrical stress, and that sort of stuff.
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| 16 That means it is a little bit more 17 expensive. So, a lot of push on the market to show a 18 step that there's a lot of, let's say, not suitable 19 materials out there that show this high level of fill 20 rates.
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| 21 If you look at, for the cables, medium-22 voltage and high-voltage cables, here is data year on 23 year. In the graph, these are the results. The blue 24 square, the performance year on year for medium-25 voltage cables and here for high-voltage cables. And NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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| 291 1 the yellow triangles are the accessories, meaning for 2 high voltage year on year. And the lines are 3 basically the trendlines from these data points.
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| 4 And what you see, that the trendlines are 5 flat or even erode, although everybody would expect 6 that the trendlines should grow. We have better 7 materials. We have better design rules. We have 8 better experience. We have better production 9 facilities. We know more. So, all, let's say, the 10 competence and the technologies that have become 11 available over the years are not put into the 12 components. Otherwise, these trendlines would go 13 down, go into the 5 percent, which is maybe more a 14 normal value. No, it's flat, and it stays flat.
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| 15 Actually, it's even going up.
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| 16 Then, the question becomes, how come? How 17 come is it that the trendlines are flat or, let's say, 18 do not go down significantly while we have better 19 performance of materials, we know to calculate, we 20 have the experience, we have the improved production 21 facilities, dah-de-dah, dah-de-dah? And there's only 22 one answer to that question, ladies and gentlemen.
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| 23 Who knows?
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| 24 So, everything that we learned and gained 25 is not going into performance improvement. Otherwise, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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| 292 1 the lines would go down. It's all that knowledge and 2 experience is put into one thing only, into cost 3 reduction.
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| 4 MR. PUTORTI: How many different cables 5 are within each year's dataset? In other words, some 6 years there's zero; some years 100 percent fail.
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| 7 MR. VERHOEVEN: Yes. The total dataset is 8 900 samples.
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| 9 MR. PUTORTI: I meant for a year.
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| 10 MR. VERHOEVEN: That will be --
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| 11 MR. PUTORTI: For most years, like maybe 12 one cable was tested?
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| 13 MR. VERHOEVEN: No, no, no, no, it's 14 always at least 10-50. So, statistically, this data 15 is okay, although the correlation for the trendlines 16 is a little bit down. It's scattered. That's why you 17 see the scattering. That's why I call it the 18 trendline. The trendline is basically -- it is not in 19 the statistical correctness of this data.
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| 20 Because I wanted to learn what the result 21 was, and just because there were many factors, and 22 basically, like I said, everything that we learned and 23 gained and improved so far is put into that one single 24 thing. It's cost reduction. It's simple.
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| 25 And I think even I was talking to the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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| 293 1 Indian people last week, and they said, yes, it is 2 becoming even worse. And the problem of purchasing 3 departments is becoming so strong, and the amount, 4 they are very open because they have to do an open 5 tendering. So, the specifications, let's say the 6 technical specifications have to become more simple 7 and easy, because you have to go into an open 8 international tendering.
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| 9 So, in the past you could say, if you 10 would order a medium-voltage cable, you described the 11 cable and the technical requirements. Nowadays 12 purchasing departments says to their own technical 13 people, what's the most simple way of describing a 14 medium-voltage cable? Well, simply it's photographs.
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| 15 You have in kV three-phase proper conductor of 250-16 millimeter scrap. That's sufficient to order a 17 medium-voltage cable, but it has nothing to do with 18 the technical requirement and, thus, performance.
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| 19 But sometimes it is said with a provision, 20 if you compare this with Windows, now we have Windows 21 10 for power-computers. If we would transfer this, 22 what we have done in our sector with this craft, and 23 to make that a comparison to Windows, we still, as a 24 sector, are using Windows 3.1 and the same stuff that 25 was put in the computer 20 years ago.
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| 294 1 And they I say in an open discussion to 2 the industry, are we doing well as an industry? Or 3 should we be ashamed a little bit as an industry? I 4 think the latter is possibly it.
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| 5 Let's move on for time's sake. Circuit 6 breakers, really the real course in the sector is to 7 disconnect the short circuits. Within the IEC, there 8 are many, many different duties a circuit breaker has 9 to comply to. So, it has to be capable of switching 10 in short faults, long faults, capacity switching, log-11 to-log switching, inductive switching. So, a lot of 12 different tasks that the circuit breaker may see, and 13 all these tasks have a specific duty.
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| 14 And here you see in the graph the 15 performance of the average of circuit breakers. Where 16 we have over 4, over 50 tests, you see the numbers 17 even go up very high, depending on the type of duty.
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| 18 So, also, on average is the 20-25 percent.
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| 19 And this is the one we are relying on in 20 a protection system. This has to clear the fault in 21 the end. After the typical response from the 22 protection system, the circuit breaker has to trip.
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| 23 Then, let's move on a little bit to 24 closely what I've seen within the sector on a global 25 scale with regards to the internal arc test of medium-NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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| 295 1 voltage panels. I would say what I have seen in my 2 experience is that most of the utilities see a growing 3 importance of this test for the safety of their own.
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| 4 Too many, let's say, people have been doing switching 5 actually in substations all over the world and too 6 many have died. So, the utilities are more taking up 7 their, let's say, responsibility to ensure that their 8 assets are, let's say, sufficiently protective for 9 their people.
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| 10 But, if you look at the IEC, but also I 11 know for internal protection with safety-related 12 matters, it's quite often it is the current value and 13 the duration. Quite often, in the standards you see 14 duration of .1 second, .2, or .5, and in extreme cases 15 1 in time, because they expect, if you go to 1 or 2 16 seconds, basically, the second or third stage of the 17 protection must have cleared fully.
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| 18 But I hear in the discussion today here in 19 this room a different kind of discussion. So, I think 20 this is for sure something that we have to study and 21 look at. What's the origin that you come to these 22 incredibly long times?
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| 23 How do these components -- first of all, 24 we do test them for the performance of the internal 25 arc, assuming that there is a guy standing in front of NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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| 296 1 it and that the guy should not, let's say, be hit by 2 fumes or gases. Maybe he still dies of a heart attack 3 or of the sound, but that's something different.
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| 4 Also, here we are learning the statistical 5 data of how many of those cabinets fail to meet the 6 internal arcing test. I can't show you a graph yet 7 because we are still data-crunching here, but it looks 8 that it is, again, in the famous 25 percent. So, 25, 9 one out of the four cabinets that is being sold on the 10 market basically has a rating or at least you are 11 buying with the hope that it will protect, but it 12 doesn't.
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| 13 So, how do you test it? Depending on 14 what's put in here, you have those racks a short 15 distance from the panel. These indicators, there's 16 specific cloth, how basically you do the test, and 17 these clothes should not have burn marks. You put it 18 on the sides where people could operate.
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| 19 Here you have the test that is running.
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| 20 It is difficult to see, but now it is starting. And 21 then, you see the exhaust. Over here's the pedals, 22 and going through the exhaust of the whole gases and 23 the smoke coming out, protecting the people that are 24 basically here.
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| 25 We have another one. You see the opening NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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| 297 1 of the shutter. Did you see it going in the 2 beginning? You see the shutter opening. The shutter 3 is opening, but this is a complete failure, of course.
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| 4 So, the cabinet was not able to divert, let's say, the 5 fumes through the lid that was opening as an exhaust 6 escape. But it has fully blown out the doors here.
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| 7 Another one, also, a lot of fire, I think, 8 but the guy that was standing here not affected by the 9 arc. Of course, surrounding materials can be, let's 10 say, for the personal safety, it is not very good.
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| 11 Yes, what we see happening here with the 12 statistics, 25 percent, and I was referring, also, to 13 the cost pressure in the market. What we are starting 14 to observe, that the cabinet builders are basically 15 trying to reduce the cost of the cabinets. Thinner 16 materials, hinges lighter, simpler designs. But, 17 basically, they are just increasing the risk of having 18 a real big issue with the internal arc. So, there the 19 cost pressure is eating up this space already.
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| 20 And also, more pressure reflection, seeing 21 these tests which have arcing times of maybe 1 half a 22 second, but I think most of it is .2. You see a lot 23 of fume and fire in this case the more you talk about 24 seconds. I cannot imagine the panel that can withhold 25 internally 30 KA for that amount of time. It has to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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| 298 1 be like tank think; you can't pay for it. There is 2 also no design there. So, you have to find a way to 3 make sure that the gases can go out in a safe place, 4 and that the cabinet by itself is sufficiently strong 5 and capable of doing that.
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| 6 Another thing that struck me was what I 7 recall, and during the discussions this morning it 8 came to my mind, I know of one case where a utility 9 somewhere in Asia had also an issue with these kinds 10 of faults. Basically, what they put into the panels 11 was, you could say, sort of a crowbar system. So, it 12 was a switch sitting at the terminal. Basically, when 13 it saw an arc, bang, it shot an arc, both three-phase 14 short circuit and the panel. So that you have a 15 strong short circuit, protection will pick it up, and 16 the result, you have an arc in the panel. And that 17 arc, we see that; we test it. Yes, it's a crowbar.
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| 18 So, these components are on the market, 19 and we have tested those on their effectiveness. So, 20 how quick can they pick up and how sensitive or 21 insensitive they are? But it might be something to 22 look at, although it, of course, is just introducing 23 a risk of failure as well. So, yes, it was done.
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| 24 Some other components, here, disconnect 25 the circuit breakers, switches. Again, the failure is NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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| 299 1 25 percent. Arcing norms and arcing times, again, the 2 same numbers.
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| 3 Basically, to close down this presentation 4 for this more global overview, the 25 percent is what 5 we see for all the components. All the increase in 6 technical skill and processing, everything is put 7 basically in one thing, the cost reduction.
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| 8 Where I have the idea of, are we doing 9 well as an industry, utilities, manufacturers, and 10 then, users? Modeling calculation is extremely 11 difficult, especially when you are talking about 12 phased transitions from a solid state to a more plasma 13 state, difficult transitions. And we believe that in 14 the end it is the test, the real test, that shows we 15 have compliant entities and specifications.
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| 16 And by that, I would like to conclude.
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| 17 So, just three minutes over time. Maybe we can have 18 some questions?
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| 19 MR. TAYLOR: Any questions in the room?
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| 20 On the webinar?
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| 21 All right. So, in the last few minutes 22 here, we will open up the lines for public comment.
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| 23 Can you unmute everybody?
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| 24 One second while we unmute those on the 25 phone line.
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| 300 1 If there are any comments, raise those 2 now. So, the questions can be from this presentation 3 or anything else that was brought up during the 4 workshop today. So, feel free to ask questions, for 5 those on the phone line.
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| 6 And while we wait to hear from the phone 7 line, if there's anybody in the room for any of the 8 presentations?
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| 9 Okay. So, not hearing any, Mark, do you 10 want to make the closing?
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| 11 MR. SALLEY: So, it was a long day, a lot 12 of information, a lot to think about.
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| 13 Bas, thank you very much for traveling 14 over. A great presentation.
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| 15 A busy day tomorrow, a lot of discussion.
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| 16 So, again, let's figure 8:00, 8:30, getting through 17 Security, getting up here. And again, tomorrow we'll 18 look for a lot of, hoping for a lot of interaction and 19 a lot of discussion in the path we move forward.
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| 20 So, with that, we will call it a day.
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| 21 MR. TAYLOR: I've got one last thing.
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| 22 MR. SALLEY: One last thing?
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| 23 MR. TAYLOR: So, for those on the line and 24 for those in the room, the slides will be made 25 publicly available. I've put the ADAMS session number NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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| 301 1 up here on the tablet. So, if you're not here 2 tomorrow, please feel free to look up that ML number.
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| 3 They won't become public until like Friday. So, if 4 you go home tonight, you're not going to see that ML 5 number be brought up, but this is the ML number. For 6 those on the phone line, it's ML18108A210. And we 7 will also make note of that in our meeting summary 8 that we put to document this meeting. So, again, the 9 ML number is, the session number is ML 18108A, as in 10 apple, 210.
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| 11 So, with that, we will see everybody 12 tomorrow. Thank you.
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| 13 (Whereupon, at 5:50 p.m., the above-14 entitled matter went off the record.)
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