ML17296B131
| ML17296B131 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 09/25/1980 |
| From: | ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR |
| To: | |
| Shared Package | |
| ML17296B130 | List: |
| References | |
| NUDOCS 8012160506 | |
| Download: ML17296B131 (329) | |
Text
SYSTEM REVIEW of the PALO VERDE NUCLEAR GENERATING STATION EQUIPMENT QUALIFICATION Before the EQUIPMENT QUALIFICATION REVIEW BOARD VOLUME II OF III Pages 214 389 Phoenix, Arizona September 25 a 26, 1980 GRUMLEY REPORTERS PIIOENIX, ARIZONA j
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VOLUME II September 26, 1980 I N D E X Participants Design Criteria,(cont'd)
Seismic Qualification Criteria PVNGS Seismic Classifications 214 Standard Revieor Plans 3.9.2, 3.9.3, 3.10 237 10 General Desiqn Criteria 1, 2, 4, 14, 15 and IEEE Standard 344 261 Reg. Guides 269 12 Equipment Qualification Process and Documentation 274 13 Example Qualifications 14 Environmental 288 Seismic 335 16 f Qualification Problem Areas 17 Environmental - 340 18 Seismic 354 19 1 Recapitulation of Open Items 382 20 21 22 23 25 GRUMLEY REPORTERS Phoenix, Arizona
VOLUME II September 26, 1980 3 BOARD MEMBERS 4 EDWIN E. VAN BRUNT, Jr.'-
APS Vice President 5 Nuclear Projects Management ANPP Project Director JOHN M. ALLEN Nuclear Engineerin'g Manager Arizona Public Service Company A. CARTER ROGERS Nuclear Engineering Manager Arizona Public Service Company 10 JOHN T. BARROW Supervising Electrical Engineer Arizona Public Service Company 12'3 EDWARD C. STERLING III Supervising Instrumentation and Controls Engineer 14 Arizona Public Service Company 15 NORMAN L. HOEFERT PVNGS Operations Engineering Supervisor Arizona Public Service Company 17 ROGER W. CLARK Supervisor of Electrical Design 18 Generation Engineering Department Arizona Public Service Company 19 JOHN A. ROEDEL 20 Manager, Quality Assurance Ar'izona Public Service Company 21 PETER C. NEWCOMB 22 Supervisor of Equipment Qualification Instrumentation and Control 23 Engineering Department.
Combustion Engineering, Inc.
24 PAUL WOLFE PVNGS Assistant Project Manager Combustion Engineering, Inc.
GRUMLEY REPORTERS Phoenix, Acizona
~V DR. GEORGE SLITER Coordinator of EPRI/Utility Equipment Qualification Owners Group Electric Power Research Institute VINCENT S. NOONAN Assistant Director for Materials and Qualification Engineering Division of Engineering Nuclear Regulatory Commission DR. ZOLTAN R. ROSZTOCZY Chief, Environment'al Qualification Branch Nuclear Regulatory Commission PARTICIPANTS 10 WILLIAM G. BINGHAM PVNGS Project Engineering Manager Bechtel Power Corporation 12'3 DENNIS KEITH PVNGS Assistant Project Engineer Bechtel Power Corporation GERALD KOPCHINSKI 15 PVNGS Nuclear Group Supervisor Bechtel Power Corporation 16 ROBERT CARSON 17 Electrical Staff Engineer Bechtel Power Corporation 18 BRUCE LINDEBIIAN 19 Bechtel Civil/Structural Staff Seismic Qualification Working 20 Group Leader Bechtel Power Corporation 21 KENNETH SCHECHTER 22 Deputy Civil/Structural Group Bechtel Power Corporation 23 ROBERT STIENS 24 PVNGS Assistant Project Engineer Bechtel Power Corporation 25 TERRY P . QUAN Licensing Engineer Ariz a ORUMLEY REPORTERS Phoenix, Arizona
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J. GOUVIER Electrical Engineer Arizona Public Service Company MARTIN L. RAINES Electrical Engineer Arizona Public Service Company MARK L. HYPSE Electrical Engineer Arizona Public Service Company 16'DWARD RICHARD A. VOLLMER Director, Division of Engineering Nuclear Regulatory Commission JOHN BERGGREN CESSAR Project Manager 10 Standardization and Special Projects Branch Division of Licensing Nuclear Regulatory Commission 12 HERMAN E. LaGOW 13 Systems Consultant Nuclear Regulatory Commission 14 ARTHUR C. GEHR 15 Attorney at Law Snell' Wilmer 17 OBSER VERS 18 THOMAS C. GROZAN 19 Florida Power and Light Company 20 DENNIS J. CHIN Florida Power and Light Company 21 LEON ICARD 22 Arizona Public Service Company 23'4 ED REIS Nuclear Regulatory Commission WILLIAM H. WILSON Bechtel Power Corporation PAUL GROSSMAN Ebasco Services, Inc.
GRUMLEY REPORTERS Phoenix, Arizona
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214 Phoenix, Arizona September 26, 1980 8:15 a.m.
MR. ALLEN: Let's go on the record and start the meeting.
Bill, why don't you go over basically what we plan on covering today and then proceed with your presentation.
I believe we are about ready to start the seismic portion of the presentation.
10 MR. BINGHAM: We will cover today the seismic qualifca<<
tion criteria, go into the equipment qualification process, 12 we will cover the documentation, and then we are going to 13 review some example qualifications. After that review, we will then discuss with you qualification problem areas, and 15 we are prepared to get into whatever detail is necessary with the board on that subject. Ken Schechter will make the 17 presentation on the seismic criteria.
18 MR. SCHECHTER: Thank you, Bill.
19 Good morning. I would like to begin with a brief 20 description of the seismic design criteria'for the Palo Verde 21 Pro)ect and how it is incorporated into the equipment 22 spec if ica tion.
Figure 14 shows an overview of the first part of 24 my presentation. It shows the steps involved in developing 25 the seismic criteria. I will be covering the different steps GRUMLEY REPORTERS Phoenix, Arizona
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215 1 involved in the first part, of the presentation. Extensive 2 regional and site investigation provided the basis for select 3 ing the magnitude of the safe shutdown earthquake. As can 4 be seen in Table 9, the ground level motion for the safe 5 shutdown earthquake corresponds to a .2G response spectrum.
6 The operating basis earthquake was defined as one-half of the 7 safe shutdown earthquake or .1G. However, for additional conservatism, the dynamic analysis of Seismic Category I 9 structures and equipment. was performed using as input .25G 10 for the safe shutdown earthquake and .13G for the operating 11 basis earthquake. This corresponds to the zero period accelera tion in the design response spectra.
13 Exhibit IIIC-1 Reg. Guide 1.60 contains the criteria 14 for the development of the ground design response spectra. The 15 Palo Verde Project is in compliance with this Reg. Guide, as can be seen on the next figure. Figure 1.60-1 represents the 17 figure from the Reg. Guide normalized to 1G and it has the spectra curves for the various damping values ranging from 19 .5% to 10%. ,I superimposed on this curve the Palo Verde free t
20 field design response spectra normalized to .25G. These curves correspond to the 2% damping value. As can be seen, it follows the shape in the Reg. Guide. It has the same turn 23 ing points and the amplications used are from the Reg. Guide.
The free-field design response spectra was used to develop the synthetic earthquake trace that was required for the dynamic GRUMLEY REPORTERS Phoenix, Arizona
C. A of Category I structures and equipment.
Structural damping values for the time history analysi were obtained from Regulatory Guide l. 61 shown in Table 10.
For example, in the time history analysis of the structures, for the safe shutdown earthquake, 7% damping was used for the reinforced concrete structures and for the OBE, 4% damping.
I might add that the equipment vendors also made use of this regulatory guide using, for example, for equipment the 2%
damping value for the OBE and 3% for the SSE.
10 The time history analysis generated in-structure time histories and the in-structure floor response spectra. Figur 12 15 represents a typical in-structure floor response spectra.
13 This figure is for the auxiliary building. It is an SSE re-sponse spectra. It is for the roof elevation, Elevation 156, 15 and it is typical of the in-structure floor response spectra 16 for the project. The zero period acceleration is .56g.
17 In addition to the floor response spectra, the 18 project developed required response spectra for use with 19 equipment that is located'n several areas of the plant.
20 Figure 16 shows an example of a required response spectrum.
21 This one happens to be for the control panel assemblies, and 22 it is interesting to note that the zero period acceleration 23 is 1.6g. Similar required response spectra were developed 24 for other generic type equipment such as valves.
25 Exhibit IIIC-2, Regulatory Guide 1.29. This regulatory guide provided the criteria for deciding what GRUMLEY REPORTERS Phoenix, Arizona
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217 structures, systems, and components are required to be r
classified as Seismic Category I and, as such, required to 3 withstand the effects of an SSE while remaining functional.
4 For the Palo Verde Project, a listing of all Seismic Category I structures, systems, and components 9.'s provided in the FSAR Table 3.2-1. The pro)ect is in compliance with this reg. guide.
The next two slides, Exhibits IIIC-3 and IIIC-4, g are a list of the standardized seismic qualification appendice 10 for the project. One or more of these appendices is made a part of every Seismic Category I equipment specification.
These are used by the vendor to give him acceptable methods 13 to be used and set up the requirements that he has to meet 14 .in order to qualify his equipment.
15 MR.'BINGHAM: Are there questions on this section?
16 MR. ALLEN: I have a question, Ken. Let's go back to your acceleration spectra there. Assume we have a pipe 18 with a valve on it with a large actuator on it halfway 1g between the floor above and the floor in the room. What 20 acceleration would you use for that?
21 MR. SCHECHTER: For valves, we have required response 22 spectra that envelope the different buildings and we would 23 use the required response spectra, which would be higher than 24 the next elevation.
25 MR. ALLEN: Any further questions? Ed.
GRUMLEY REPORTERS Phoenix, Arizona
MR.'TERLING: Just for clarification, could you on the appendices delineate between what you mean by active and 3 nonactive equipment.
MR. SCHECHTER: I'm sorry, I 'meant to go into that.
5 An active mechanical equipment is one that has parts that are 6 required to move in order for it to function such as a motor-7 operated 'valve. A nonactive mechanical equipment, examples 8 of it would be a vessel or a tank, HVAC duct, piping.
9 It is able to perform its function without any moving.
10 parts.
MR. ALLEN: I thought active meant it had to act durin 12 an accident.
13 MR. SCHECHTER: That is true, too. It has to be able 14 to perform its function during a seismic event.
15 MR. ROGERS: Is a check valve considered an active 16 component or not7 17 MR. BINGHAM: The answer is no, they are not classifie as active.
19 MR. ALLEN: Ed, do you have a further questions 20 MR. STERLING: Yes. On Figure 16, you say that that 21 is a required response spectrum for control panel assemblies.
By this, do"you mean that the curve shown on that diagram 23 envelopes all of the possible accelerations located anywhere 24 in the plant.
25 MR. SCHECHTER: Yes. This particular one is applicable GRUMLEY REPORTERS Phoenix, Arizona
C for both the horizontal and vertical directions in all buildings, all elevations. It does envelope the in-structure response spectra.
MR. STERLING: Then all the control panels used in Palo Verde are qualified to be used in any building?
MR. SCHECHTER: For seismic, that is correct.
7 MR. ALL'EN; Ed Van Brunt, you'e got a question.'R.
VAN BRUNT: Could you go back to Figure 14? As I understand it, this is kind of the flow chart of how the 10 field investigations are converted into data that is used in developing hardware and this information I guess at the point 12 of in-structure seismic data is factored into the specs.
13 Now, seismic data and things like that are a very specialized
'ield and we buy from a lot of vendors who are specialized 15 in areas, but they are not specialized in this area. What 16 kind of things do you do to ensure yourselves either at the 17 bid evaluation stage or later on that, say, a pump manufactur r, 18 who probably knows a lot about pumps but I would question 19 whether he knows very much about seismic calculations or that 20 kind of thing. How do you assure that he has properly 21 interpreted your specification requirements and properly 22 turned those into the loads which then get put into the 23 equipment and then get on into some later testing to assure 24 that whatever the testing is that he specifies does in. fact 25 reflect the requirements for the equipment?
t GRUMLEY REPORTERS Phoenix, Arizona
MR. BINGHAM: If I understand the question, Ed, it was, first of all, how do we assure ourselves that the manufacture can properly design to the seismic data that we would need?
MR. VAN BRUNT: I am really interested, Bill, in the assurance of the interface that what the specs require are reflected in the equipment, in the design of the equipment if first, and then certainly the design is proper that the testing has some assurance of being acceptable.
MR. BINGHAM: Let's separate it into two problems or 10 two parts, the first part being assuring that a bidder is qualified and the second part, once we have selected a suppli 12 that the interfaces are proper. Let me take the second part 13 first. The supplier in the specification is given the proper 14 seismic data and they will prepare a report that is sent to" 15 us on how they are analyzing or what program they are going 16 to use for testing.
17 MR. VAN BRUNT: Excuse me, Bill; you give him data, 18 but that data, as I understand it, is in the form of response 19 spectr'a curves and this kind, of thing.
20 MR. BXNGHAM: That's right.
21 MR. VAN BRUNT: What I am looking at is that equipment 22 manufacturers historically are used to dealing with loads, 23 not acceleration curves and things like that, and how do you assure yourself that he has properly interpreted those curves 25 and converted them into the loads? I am taking the tacit GRUMLEY REPORTERS Phoenix, Arizona
221 assumption that he knows how to take in the loads and convert them into equipment.
MR. BINGHAM: We require that they provide us their seismic calculations for review.
MR. VAN BRUNT: What does Bechtel then do with those calcula tions 7 MR. BINGHAM: Bechtel reviews the calculations, checks I
that the calculations reflect the data that we gave them and that the loads seem reasonable.
10 MR. VAN BRUNT: Have you ever rejected any'iR.
BINGHAM: Yes.
12 MR. VAN BRUNT: Does that interface get audited7 13 MR. BINGHAM: I am sure it does.
14 MR. VAN BRUNT: Through the QA programs 15 MR. BINGHAM: Through the QA program, yes.
16 MR. ALLEN: Vince, do you have a questionf 17 MR. VAN BRUNT: Excuse me, he hasn't finished the seco 18 part of my question.
19, MR. BINGHAM: I haven't finished the first part,'hich 20 was how do we assure ourselves that the selected suppliers are 21 qualified to do this sort of work. Generally, in this phase 22 of the work, that is done prior to even submitting a specifica 23 tion for request for proposal. We qualify the vendors prior 24 to our submitting a request for proposal. This's based on 25 Bechtel's experience not only ron Palo Verde, but all the jobs GRUMLEY REPORTERS Phoenix, Arizona
that we have, and generally once a year we will conduct audit on various aspects and assure ourselves that the vendors are qualified. As far as seismic, I think through the industry we all have a pretty good idea who the manufacturers are that can supply this safety equipment.
MR. VAN BRUNT: Do you have any manufacturers that are
,7 using consultants to do this for you2 MR. BINGHAM: Yes.
MR. VAN BRUNT: Would you say that is,predominant2 10 MR. BINGHAM: Many of them do. For seismic, yes, I think so.
12 MR. VAN BRUNT: One other question and I will relinquis 13 the floor to Vince. You indicated that Bechtel checks the 14 calculations and this kind of thing. What level of personnel 15 in Bechtel is doing that2 Is it a draftsman or is it an engineer; is it a guy that is experienced in this area?
17 MR. BINGHAM: It is certainly a person that is 18 experienced in the area. The individual that is responsible 19 for those reviews, at least the ultimate responsibility,.is 20 Bruce Linderman,,who is sitting behind you, and he has a team 21 of people that support all the projects. We try to train our 22 responsible engineers to do as much of the work as they are 23 capable and then we supplement the reviews.
24 MR, VAN BRUNT: Do they ever do independent calculatio MR. BINGHAM: Yes, we have done independent calculatio GRUMLEY REPORTERS Phoenix, Arizona
223 MR. VAN BRUNT: My last question. I presume -that this whole review process and the interchange between you and the 3 vendor is a documented situation which, as you have indicated, 4 can be audited by the QA people or whoever.
MR. BINGHAM: That's correct.
MR. NOONAN: I would like to back up to your question on your qualification of valves. Say you have motor operator valve supported by the pipe sitting on the middle of the pipe that maybe has a few snubbers on it, and so forth. Can you 10 kind of walk me through your procedure on how you come up with your loads and then how you tell your vendor to quality that valve.'3 MR. BINGHAM: Yes, I think we can. I presume you want to focus on the tehnical part of how this is, not the process part.
16 MR. NOONAN: No, I would like to hear the technical part.
18 MR. BINGHAM: Bruce Linderman will give you a back-19 ground on that.
20 MR. LINDERMAN: In preparing the specifications, we work closely with the stress group that is supporting the piping system, because the piping system is going to feed in the vi-23 bratory loads to the valve itsel f, and in there we have the 24 required input motion (RIM's) or response spectra that depict 25 the level that we ~t. This is given to the valve supplier. Then h GRUMLEY REPORTERS Phoenix, Arizona.
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qualifies his valve to these levels. He may actually do a test or he may do a test on the actuator and then analyze the valv top works, and this is all taken into account. If he does any analysis on the valve, then to prove operability of the total valve assembly, the actuator and the valve itself, he willalso do a static pull test so that he can prove that, number one, the actuator will operate, number two, that the actuator Y
7 mounted on the valve when displaced to the maximum that it auld be during a seismic event or greater will still operate the valve.
10 MR. NOONAN: I think I heard you say that you supply these valve manufacturers with response spectra. That indi-12'3 cates to me that. the only way that valve can be seismic qualified is by test, because you can'0 analyze using respons spectra without having more data. You need to know the 15 boundary conditions of the pipe. You need to know the modal 16 characteristics of the valve.
17 MR. LINDERMAN: These characteristics are given to 18 the supplier. He does not analyze the total piping system.
19 He analyzes the valve 'only. If you will notice, the ZPA 20 was very high. This is taking into account .any vibratory 21 motions, that he will get into the system.
22 MR. NOONAN: I don't want to belabor the point, but if the valve is sitting out and if you can see the pipe sitting out in the ZPA area, then I can see what you are doing, but if it is not, then I don't understand.
GRUMLEY REPORTERS Phoenix, Arizona.
e MR. LINDERMAN: Mell, then he's got the amplified portion of the curve to account for it.
MR. NOONAN: But then he needs your numbers for the modal characteristics of your piping for him to run his analysis.
MR. LINDERMAN: Right. Most of the valves on this-pro)ect are not mounted inside the middle of the line; they are mounted closer to the supports.
MR. NOONAN: So you are saying that most of your valve would be out in the ZPA area?
MR. LINDERMAN: Right.
12 MR. NOONAN: You treat them as individual bodies?
13 MR. LINDERMAN: Right. This was a decision made early 14 in the pro)ect to keep the valves out.of the. middle of the-piping 15 system', other projects that Bechtel has it is a different story and we do work more on an RIM.
17 MR. NOONAN: So when you do your piping analysis, you strictly do it that the valve becomes nothing more than a lump mass on that piping run.
20 MR. LINDERMAN: It is at least 'a two lump mass system 21 for the valve.
22 MR. NOONAN: And you determine what,,frequencies are 23 at that point plus any loads you might be putting into the 24 nozzles?
25 MR. LINDERMAN: Yes .
GRUMLEY REPORTERS Phoenix, Arizona
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MR. BINGHAM: Any other questions2 MR. VAN BRUNT: I would like to go back to Table 9 for a minute. I )ust want to clarify something. I see two columns of seismic levels indicated here. You'e got a safe shutdowa earthquake and you'e got .2g, which was selected based on the site investigation and then another used in the design of the stxuctures and equipment. One of those is the construction permit license design level, if you like, for the plant.
MR. BINGHAM: This column with the .2g.
10 MR. VAN BRUNT: Secondly, you i.ndicate that for margin purposes that you have beea usi,ng .25g. Have there been aay cases where you have eaten into that margin with either the 13 equipment or the facility designs7 I
14 MR. BINGHAM: 'At least to the best of our kaowledge, 15 we doa't have that case. However, the reason the .25 was put 16 here, Ed, is that" that is what is i.a our design criteria aad 17 we wanted to make suxe that that was clear to the boaxd.
18 MR. VAN BRUNT: I just wanted to claxify what the 19 li.cense level was versus what you are actually using for desi.ga.
'R.
21 ALLEN: John Roedel has a question.
22 MR. ROEDEL: I have two questions. One, the .20g is 23 our license value. That also has some conservatism in it, 24 does it not7 25 MR. BINGHAM: Yes, it does.
GRUMLEY REPORTERS Phoenix, Arizona
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227 MR. ROEDEL: Do you know based on the site investiga-tion what that number I
is? Isn't it .18?
3 MR. BINGHAM: Well, I would like to xesearch that.
I can give you the actual value for the board. Is it impor-tant for the board for this? There is margin. I don'
-remember the exact numbers.
MR. ROEDEL: That is satisfactory to me. The other
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R question I want to ask, I understand that you have been doing an extensive evaluation of all our seismic calculations, 10 that we can verify that all of the input from the vendors and our design are in fact correct. Are you doing that and 12 what have been the basic results of that?
=-MR. BINGHAM: Are we talking as far as safety-related 13 14 equipment?
15 MR. ROEDEL: Just safety-related equipment.
16 MR. BINGHAM: Most of our work, John, has been 17 focusing on structures and there have been a couple of 18 cases where we have looked at some supports, and at the 19 present time, we believe that we will be satisfactorily 20 resolving all of those within our established criteria.
21, MR. ALLEN: Roger, you have a question.
'22 MR. CLARK: I have seen seismic requirements in both 23 horizontal and vertical components. Is this a resultant 24 force or is it In previous jobs I have worked on 25 GRUMLEY REPORTERS Phoenix, Arizona
I 228 MR. SCHECHTER: These values are the zero period acceleratian for both the horizontal and vertica1 directions.
As I mentioned before, on using Reg. Guide 1.60, there is a separate figure, a separate curve, for the vertical direction.
The turning points are a little bit different. 'This one (indicating) is for the horizontal direction. There is a similar figure in the reg. guide for the vertical direction and, again, the vertica1 design response spectra is in conformance with the reg. guide. It has different turning points in it.
MR. BINGHAM: Are there other questions from the board 12 MR. ALLEN: Carter had a. question.
13 MR. ROGERS: On Exhibit IIIC-1 and 2, I think the 14 board wi11 recall that yesterday we had quite a discussion on what "in compliance" meant under PVNGS position and I think we decided that as far as environmental qualification, we are going to go back and take a look at whether "in compliance" is proper in each place or whether it should be "will comply" or )ust what is correct.
20 MR. BINGHAM: That's correct.
21 MR. ROGERS: Here I am wondering can we say "in compliance" or does this have to be reworded, also'R.
23 BINGHAM: This is in compliance.
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'R. ROGERS: This is in compliance in this case and on IIIC-27 GRUMLEY REPORTERS Phoenix, Arizona
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MR. BINGHAM: Yes.
MR. ALLEN: Ed Sterling', do you have a question?
3 MR. STERLING: On the response spectra that you are supplying the vendor, in I the case of say, an instrument that
,5 is on a support, does that response spectra include the support? Is that what the instrument itself will see or is that the floor, not particularly with control panels, but say a rack-mounted instrument or such.
MR. BINGHAM: The issue that we have at hand is 10 exactly what we give them. We believe that we give them an overall level so they know what the instrument will see, whic 12 is quite conservative coalpared to the actual site values. We 13 will reconfirm that. You might want that as an open item.
14 MR. ALLEN: Terry, would you mark that down?
15 Carter Rogers.
MR. ROGERS: On Table 10, that gives damping values 17 for Regulatory Guide 1.61. I did not find, and maybe I 18 missed it someplace, a PVNGS position for that regulatory 19 guide. Do we endorse those damping values?
20 MR. BINGHAM: Yes.
21 MR. ROGERS: So we could say that we are in compliance 22 with Regulatory Guide 1.61?
23 MR. BINGHAM: We are, Carter. The reason that we don' 24 have all the other regulatory guides on today is because we 25 are focusing on the seismic qualification portion.
GRUMLEY REPORTERS Phoenix, Arizona
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230 MR. ROGERS: But we are using these damping values 2 as far as the accelerations, and so forth, for the equipment?.
MR. BINGHAM: That's correct.
MR. ALLEN: Vince, you had a question.
MR. NOONAN: Yes. Under a previous question that was 6 asked about how you supplied response spectra, I think I am 7 hearing something different than when I asked the question 8 about the valve.
MR. BINGHAM: Yes, because he asked a question about 10 instrumentation.
MR. NOONAN: But if you are doing the )ob right, you 12 do your seismic analysis -- Whether it is on a piece of 13 equipment or whether it is on a piping system or what, you 14 develop response spectra at the'ocation of where that piece 15 of equipment or valve is. If it is a piece of equipment 16 that is tied to a floor that is mounted on supports and you'v'7 got a component that you want to qualify "that is at the top 18 of a cabinet, for example, I don't know how the work might 19 be, but if that is the case, the response spectra would be 20 the dynamics up to that location, the mounting location of 21 that component, and that would not vary. It would not, be 22 any di,ffexent for a valve or a piece of electrical gear or 23 -
anything else.
MR. BINGHAM: Let me see if I could put this in 25 perspective a little bit and we will reconfirm, because we GRUMLEY REPORTERS Phoenix, Arizona
p are not too clear on some of the details that actually-were given to the manufacturers. We handle the balance of plant equipment a little bit differently. For example, if there is a cabinet, we will give the response spectra at the base, at the floor or at the wall, wherever it, is mounted. We'l say it is at, the floor. The manufacturer then must determine 1
what acceleration happens to some component located in the cabinet. On instrumentation, we generally give conservative information to the vendors so that 'this equipment could be 10 used anywhere within the plant. In other. words, you qualify't for a substantially higher value than it might have in a 12 particular location so that you tend to envelope all of the 13 locations in the plant. On the valves, we tend to have the 14 same way of doing things, because in the early phases of the 15 project when you have to order this equipment, you don't know 16 exactly where a particular valve will be as far as in the 17 physical location of the plant. Now, as Bruce indicated, on 18 this plant, we tri.ed to locate valves near supports to 19 minimize the uncertainties of having some valve that had 20 high amplification and some particular problems with supporti 21 it'. I will supply the information on the instrumentation 22 later on.
23 MR. ALLEN: Ed.
MR. VAN BRUNT: Your response to Vince's question, 25 Bill, brought something to mind. I am thinking mostly now GRUMLEY REPORTERS Phoenix, Arizona
l' 232 of panels that might be wall mounted or something as the best 2 example. You may have located some panel in the third floor of 'the control building, let's say, and specified that to the vendor, and through some reason as the design evolved, the location of that panel let's say moved to the top floor of the control building. What kind of procedures and control do you have to go back and assure that the specifications for that panel are adequate or the panel supplied is adequate 9 for this relocations What is your control on that kind of 10 change't 11 MR. BINGHAM: Generally, that is in our overall design 12 change control program, Ed. Whether it was that or any 13 other issue in the plant, it would be the responsibility of 14 the responsible engineer with the system to show from review 15 of the drawings that the location has changed.
l6 MR. VAN BRUNT: I am not really so concerned with what Bechtel does in their change 'control, because I am very 18 familiar with that and we have discussed that ad nauseum. I 19 am more interested in what you do with the vendor. Here 20 you'e got a guy and you have specified something to him for 21 the third floor with some curve and whatever and now you have 22 moved it to the fifth floor and it's got a different curve.
23 Ruat do you tell 'the vendor, or do you make that )udgment yourself based on the data that he gave you7 25 MR. BINGHAM: Ed, what we do is we look at the curve GRUMLEY REPORTERS Phoenix, Arizona
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that we have given or we have from the supplier and check that with the new location. If it still is satisfactory,
,because, remember, we said we get, envelope curves, then we will accept it. If it is'ot, we go back to the vendor and modify the input data.
6 MR. UAN BRUNT: And the testing requirements would then also be modified?
MR. BINGHAM: That's right.
MR. ALLEN: Norm Hoefert.
10 MR. HOEFERT: Are your horizontal accelerations and loads considered in one direction or two?
12 >JR. SCHECHTER: Two directions.
13 MR. ALLEN: Pete Newcomb.
14 MR. NEWCOMB: You indicate in this Table 10 much of 15 the mechanical. structures of the plant. Mhat values or 16 percent of critical damping do you use for electronic 17 instrumentation, this type of thing?
18 MR. LINDERMAN: On your electronic equipment, if you 19 are doing an analysis, you will follow the table. If you 20 are doing testing, you will compare the Tps 'he, test 21 res'~onse spectra, to the required response spectra either in 22 the 2 or 3% curve or the 5% c'urve. Generally, we are trying 23 to compare on the 5% curve, which is written into IEEE 344.
24 'Some of the comparison, however, has been done on the 2 and 25 the 3% curves for the OBE and the SSE.
GRUMLEY REPORTERS Phoenix, Arizona
C 234 MR. NEWCQMB: So as long as you are consistent with the percent of critical damping, do you see any major variati n between using a 2% curve and a 5% curve?
MR. LINDERMAN: There is a large discussion as to which is the anre conservative. I don't think anyone has really come to the conclusion that one is more conservative than the other, because one can postulate either as nost conservative.
personally, X like to have a cceiparison on the 2% and, let's say, a 2% and 5%, both of them. Then I know a little bit more about the 10 type of motion that was fed into the test, and what have you, but right now there is only the one.
12 MR. ALLEN: John Barrow.
13 MR. BARRY: Going on with this question a little bit 14 more, on most of the electrical equipment, it seems the 15 vendors have been using 2%.. Has Bechtel been giving them 16 direction as to what value to use? They have been pretty 17 consistently using 2%.
18 MR. LINDERMAN: I believe in the specifications, it 19 shows 2%, but some data comes back that is qualified for 20 other plants which were 5%. Other specifications require 5s.
21 MR. ALLEN: Bill, I have a question kind of related 22 to two or three other questions. Assume we are out in the 23 field with a valve, large actuator, specified to be put in in a vertical position. However, when they start to put it in, they find they don't have the ceiling clearance. They had to GRUMLEY REPORTERS Phoenix, Arizona
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235 drop it down to a 30-degree angle. How can we assure ourselves we catch that and then analyze it.
MR. BINGHAM: Again, that gets back to the change control program, John. The constructor is not allowed to change the configuration without having approval of the engineer. Part of that approval then would include whatever 4
analysis is required.to assure that the valve can be rotated.
MR. ALLEN: How do we assure we catch this? I mean the welder is out there and he says it's not going to fit, so 10 he puts it in at 30 degrees.
MR. BINGHAM: There is an organization in the field, 12 the quality engineer. That is our first line of defense.
13 Me should hope that the superintendent would report it, and 14 usually that is what has happened. At least, my experience 15 has been that when there is an interference, I am usually the first to find out.
17 MR. ALLEN: Are there further questions from the board 18 on this before we move along?
19 DR. ROSKTOCZY; One..rof your slides addressed the 20 question of what equipment needs to be seismically qualified 21 and it referred back to an FSAR list. Yesterday we discussed h
22 the same sub'feet relative to the environmental qualification.
23 The first question is, is there any difference between the two 24 . lists, or whatever the list is for the environmental, can I 25 assume that the very same 'list applies to the seismic?
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MR. BINGHAM: You should be able to. Dennis will respond.
MR. KEITH: The two lists are in a different format, but everything that is Seismic Category I will go through the environmental qualification program.
DR. ROSZTOCZY: Then based on the discussion we had yesterday, the new list that you are going to provide is 8 going to have on it all the safety equipment as well as 9 systems related to safety; that new list is going to be the 10 list to be used for both environmental and seismic qualifica-11 tions, and if that new list has something on it that the FSAR 12 it list did not have, we are going to see to that that equip-13 ment also gets the appropriate seismic qualification included 14 in that list7 15 MR. BINGHAM: That is our intent, yes.
16 MR. ALLEN: John Barrow.
17 MR. BARROW: Dennis, I want to try to clarify what you 18 )ust said. Shouldn't it really be stated that anything that r 19 is Class IE is also seismically qualifiedf I can name you 20 some things that are seismically qualified, but aren' 21 environmentally qualified such as cable trays, cable tray 22 supports.
23 MR. KEITH: Mell, John, that falls under the,discussio 24 which Bob Carson went through yesterday on IEEE 627 and mechanical equipment in general. If you pick something like GRUMLEY REPORTERS Phoenix, Arizona
I 237 cable trays, there is not much you have to do in terms of.
environmental qualification, agreed, but, in general, every-thing that we call Seismic Category I must meet environmental qualification requirements.
MR. BARROW: If they are. applicable.
MR. KEITH: If they are applicable, yes.
MR. ALLEN: Are there any further questions?
MR. ROEDEL: Is your presentation going to cover what is sometimes called the two-over-one or what I think we call 10 Category IX seismic criteria or what is better described as an item that does not need to function during the design 12 basis earthquake that may be located over an article that mus 13 function during the design basis earthquake?
14 MR. B INGHAM: No.
15 MR. ALLEN: Are there any further questions from the 16 board before Bill proceeds?
17 MR. BINGHAM: We will:.now proceed with Section C.2, 18 Standard Review Plans.
19 MR. SCHECHTER: The next figure, Figure 17, shows the 20 documents that provide the requirements for the seismic 21 qualification program. Three Standard Review Plans are 22 listed, 3.9.2, 3.9.3, and 3.10. In addition, there are 23 several General Design Criteria listed and Regulatory guides.
24 These General Design Criteria and Regulatory Guides are referenced in the 'Standard Review Plans. I will be covering GRUMLEY REPORTERS Phoenix, Arizona
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all of these documents.
Exhibit IIIC-5 represents the first document, Standard Review Plan 3.9.2 entitled Dynamic Testing and Analysis of Systems, Components, and Equipment. Before I go on, we'sed the ~ords "in compliance." Ve are going to have to clarify that, but what it means here was that we are aware of the requirements, we agree with the requirements, and that the requirements are imposed on the vendor, on the supplier, and that we would be verifying that the supplier indeed did use those requirements. It gives acceptance criteria to confirm the ability of equipment to function 12 during and after a seismic event. It gives criteria for deciding when testing or analysis may be used. Analysis 14 . without testing can only be used when structural integrity alone will assure the ability of the equipment to function in its designed role.
17 'xhibit IIIC-6 goes on to state that the equipment 18 should be tested in its operational condition.<. The project 19 is in compliance. It gives the characteristics that the 20 seismic input motion must meet. Again, the project is in 21 compliance.
22 Exhibit IIIC-7. It states that the input motion 23 should be equal to or greater than the required response 24 spectrum. Again, the project is in compliance. It states 25 that the input rmtion should be a multi-frequency input and GRUMLEY REPORTERS Phoenix, Arizona
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it should be multi-directional. If not, it gives criteria fo when single directional analysis can be used. The project is in compliance, and I 'might add that for multi-frequency input, we generally use 1 to 33 hertz. Some of the later equipment is qualified using 1 to 40 hertz for the'ualification program, Exhibit IIIC-8 says that dynamic coupling between the equipment and related systems must be considered. The project is in compliance. The equipment should be attached 9 to the shaking table in a manner similar to the actual field 10 conditions. Again, the project is in compliance. It gives criteria for testing equipment in place by attachment of 12 devices that will vibrate the equipment. Again, the project 13 is in compliance 14 Exhibit IIIC-9 gives criteria for allowing the test 15 pxogram to be based on a selective representative sample of 16 the equipment and then it covers the supports, that the 17 supports of mechanical equipment should be capable of with-18 standing the effects of the seismic event, and it states that.
19 the combined stresses of the support structures must be withi 20 the limits of Subsection NF of the ASNE code. The project is 21 in compliance.
22 Finally, Exhibit IIIC-10 says that the supports 23 should be tested with the equipment in place or you use a 24 pseudo weight or mass that represents the equipment, and the 25 proj ec t is in compliance.
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Exhibit IIIC-11 is the Standard Review Plan 3.9.3 entitled ASME Code Class 1, 2, and 3 Components, Component 3 Supports, and Core Support Structures. For the Palo Verde Pro)ect, we are in compliance with IEEE 344-1975 and Regulatory Guide 1.100 for the qualification testing of our equipment. Pump and valve support stress limits should be within the requirements of Subsection NP of the ASME code.
We are in compliance with the first part of this. The second part, component support stxess limits shall meet the criteria of Reg. Guides 1.124 and 1.130,we are in compliance with Reg. Guide 1.124. Reg. Guide 1.130, does not.apply,'since 12 there",are no Class I plate-and-shell supports for the balance 13 of plant components.
Exhibit IIIC-12 deals with the requirements of Reg. Guide 1.67. 'This Reg. Guide deals with the design oZ the pressure relief valves and as such is not related to the 17 seismic qualification of equipment.
18 Exhibit IIIC-13. The last Standard Review Plan that I want to discuss is 3.10 entitled Seismic Qualification of Category I Instrumentation and Electrical Equipment. The 21 requirements are very similar to Standard Review Plan 3.9.2 22 for mechanical equipment. Again," it gives criteria for 23 determining the acceptance or the ability of equipment to 24 function during and after a seismic event. It gives criteria 25 for deciding when to use testing or analysis to qualify the GRUMLEY REPORTERS Phoenix, Arizona
equipment. Analysis without testing can only be used when the structural integrity alone will assure the ability of the eguignent function during and after a seismic event. The project is in compliance.
Exhibit IIIC-14 gives the characteristics that the seismic input motion must meet. The project is-in compliance.
It states that the equipment shall be tested in its operation condition and operability should be verified during and after the test. The project is in compliance.
Exhibit IIIC-15 states that the input motion should 10 be equal to or greater than the required response spectra.
The project is in compliance. zt provides the characteris-12 ties of the input motion, that random vibration input motion 13 should be used and should have multi-frequency. If not, it gives criteria that must be used for single frequency 15 input motion.
16 Exhibit IlrIC-16 states that the input motion should 17 be multi-directional. It does give criteria that state when 18 you can use single directional input motion. In other words=,
19 you have to justify its use. The project is in compliance.
20 Xt states that the equipment shall be attached to the shaking 21 table in a similar manner to actual field conditions. The 22 project is in compliance.
23 Exhibit IIIC-17 allows for testing equipment in 24 place by means of attaching devices that will vibrate the 25 equipment, and the project is in compliance. I. allows a GRUMLEY REPORTERS Phoenix, Arizona
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242 test program setup based on a representative sample of the equipment. The pro)ect is in compliance.
Exhibit IZIC-18 pertains to the seismic design adequacy of supports. It states that the analysis or test shall be performed on all supports of Seismic Category I electrical equipment and instrumentation to assure their 7 ability to withstand the seismic event. Again, the analytica results should include the required input motion that is equal to or greater than the required response: spectra, and 10 the combined stresses of the support structures should be ll within the limits set forth in subsection NF of the ASME code.
12 The project is in compliance.
13 Exhibit IIIC-19 states that the supports should be 14 tested with the equipment installed or that a pseudo or dummy 15 mass be applied that represents the weight of the equipment.
16 The pro)ect is in compliance.
17 Finally, IIIC-20.states that documentation required 18 to demonstrate equipment seismic qualification shall be 19 retained for the life of the plant, and the project's in 20 compliance. 'E 21 MR. BINGHAM: Are there any questions7 22 MR. ALLEN: John.
MR. BARRY: On Slides IIIC-7 and IIIC-15 both, Item 24 D on both of them, it says that every TRS should be character-25 ized in the same manner as the RRS and conser'vatism in GRUMLEY REPORTERS Phoenix, Arizona
ampli.tude and frequency content should be demonstrated. If I am not mistaken, we have seen some qualification plans and reports especially in electrical where the RRS has been a previous RRS on' previous pro)ect or job that the manufactur has, done.and then he has proposed to do an analysis to show that it is suffi'ciently similar to their previous test response spectra -- it is;.not exactly what ours is, but they propose to do an analysis to show that it's sufficiently close to it to be good fox qualification. Are you accepting 10 such analyses?
MR. BINGHAM: We are not sure we understand the 12 question.
13 MR. ALLEN: John, repeat the question.
14 MR. BARROW: I believe we have seen occasionally test 15 response spectra submitted by vendors on qualification of equipment where the equipment had been qualified on another 17 pro)ect to that test response spectra and it didn't entirely 18 enve3.ope, our required response spectra and the vendor 19 proposed an analysis, or I think in one case the vendor qualific didn'ropose 20 an analysis, and the question we made on the 21 tion plan was is an analysis going to be provided to show 22 that it is sufficient7 23 MR. BINGHAM: And the question is would it be acceptab for them to'ave an analysis in this case'7 25 MR. BARROW: Are you accepting analysis to show that. a GRUh'ILEY REPORTERS Phoenix, Arizona
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non-enveloping test response spectrum is sufficient to qualify the equipment?
. 3 MR. BINGHAM: We might accept it. If you would like, w can spend a few minutes and indicate those cases where we would. There will be one example that will come up later on where this case occurs. Perhaps we could wait until that example, .and then have a dissertation on why that might be acceptable.
MR. ALLEN: You mean on one of the problem vendors?
10 MR. BINGHAM: No, on one of the examples that we are-well, yes, John.
12 MR. ALLEN: Why don't we wait until that time.
13 Ed Van Brunt, did you have a question?
14 MR. VAN BRUNT: Yes. This may duplicate a question 15 that Carter asked before, but I am not sure. In looking through here, and we are looking now at acceptance criteria, 17 I am not sure in the context of acceptance criteria what you 18 mean when you say "in compliance." What'oes that mean to 19 me?
20 MR. BINGHAM: It means we are in agreement.
21 MR. VAN BRUNT: So you are in agreement with the 22 acceptance criteria. What does that result in? Does that 23 then get fed into the spectra? Is that what you are telling 24 me? Does that get fed into the design; or exactly what do 25 you mean?
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MR. BINGHAM: What we mean'is if you compare the SRP's that we are looking at right nav with what we are doing that you would find no disagreement between what a reviewer using that checklist, the SRP, would have when he audits or looks at what is being done on the plant.
MR. VAN BRUNT: But are you comparing these criteria against our criteria or are you comparing these criteria against the implementation of our criteria2 MR. BINGHAM: Well, yes. Both.
10 MR. VAN BRUNT: Twice or once'7 MR. BINGHAM: Well, hopefully once. We not only have 12 to look at the criteria, but ultimate implementation criteria.
13 MR. VAN BRUNT: Then secondly, go to Exhibit IIIC-11.
14 You have gone through here and we are in compliance and then suddenly here under Item 2, you say Regulatory Guide 1.124 is accepted and then you go on to say'that 1.130 is not applicable. What does "Regulatory Guide 1.124 is accepted" mean7 Does that mean you are in compliance with it or that 19 you are interpreting it, or what does it mean7 20 MR. BINGHAM: Generally, and we will cover this when 21 we get to regulatory guides, but generally what we are doing is portraying the commitments in the licensing documents, the PSAR, the FSAR, when we say it is accepted.
24 I believe those are the words, Dennis, that we use 25 in the documents.
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MR. VAN BRUNT: I guess all I am asking, Bill, is why doesn't it say "in compliance?"
MR. BINGHAM: We could change this and say in compli-ance.
MR. VAN BRUNT: So there is no intention. there to not be in compliance or indicate that there is some minor 'deviati n from the requirements or something?
MR. BINGHAM: That's correct.
MR. VAN BRUNT: Just to follow up on that, on Exhibit 10 IIIC-12, we are into the same situation now where you have a requirement, and instead of saying "in compliance," there 12 is a dissertation. Again, does that indicate to me or should 13 that say "in compliance" and then this would )ust be some 14 explanatory words, or what?
15 MR. BINGHAM: Yes. This is indicating that there are only certain portions of the guide that are applicable to this 17 particular issue.
18 MR. VAN BRUNT: Then, in conclusion, at least going 19 through this Standard Review Plan, I could say that as far as 20 all of the criteria that are listed here that it is correct 21 to say that "in compliance" would apply to every one of them?
22 MR. BINGHAM: Yes.
23 MR. ALLEN: Any further questions from the board?
Pete.
25 MR. NEWCOMB: On Exhibit IIIC-S, under G, you talk GRUMLEY REPORTERS Phoenix, Arizona
about dynamic coupling between the equipment and related systems. I have a question regarding field installation and how the interface exists between what is tested and how it is installed. Perhaps an example is the easiest way. Many cabinets, for example, have different entry points where maybe flexible conduit is used, fixed conduit is used,"
cable hangs, whatever. How do you ensure that the installati n 8 in the field is verified by the seismic testing performed?
MR. BINGHAM: I am not sure I understand your question.
10 MR. NEWCOMB: For example, a fixed conduit input to a cabinet will have one very definite seismic response and 12 seismic effect at that interface whereas a'flexible conduit 13 will have an entirely different response or effect. How do 14 you ensure that what you tested is what you installed?
15 MR. BINGHAM: Let's leave that as an open item, John.
16 MR. ALLEN: Okay. Terry, would you- mark that down.
17 MR. NEWCOMB: I have one more question. Exhibit IIIC-18 14, please. Here the requirement discusses that operability 19 should be verified during and after the testing. In the 20 context of seismic testing, how do you define operability?
21 For example, do you mean continuous output or do you mean 22 accuracies, response times, linearities? Are there two 23 definitions between environmental qualification operability 24 and seismic qualification operability?
25 MR. BINGHAM: Are you focusing on electronic equipment GRUMLEY REPORTERS Phoenix, Arizona
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in your question?
,2 MR. NEWCOMB: Response time of a valve, for example.
You can take it anywhere you want. Do you verify all the normal operability characteristics you would do when you had the time say during an environmental test?
MR. LINDERMAN: Operability is checked by different ways for different pieces of equipment depending upon how it is qualified. On many of the pieces of equipment, if we'e got relays in there, we will actually check for chatter, 10 whether there is chatter or not. Ve wi11 have the devices change state. Many of the relays then are checked to see .
12 if they change within the millisecond change time. They 13 check to make sure that there is no chatter while 14 you are at the change state. I believe that some of the 15 battery chargers, and I don't know whether it is this project 16 or another one, we have tested to show output instead of each 17 individual component not working, but checking that the 18 battery charger was producing the voltage and current that 19 was required. Valves, here again you are checking the 20 devices so that there is no chatter. You are checking the actuator during the test to make sure that it will change 22 state within the rated time. Then you are checking that the overall valve will operate within the time limits. So 24 different equipment has different criteria.
MR. NEWCOMB: This testing is performed during the GRUMLEY REPORTERS Phoenix, Arizona
actual seismic event. testing.
MR. LINDERMAN: Again, depending upon what it is. If we are doing a static pull test on a valve, the valve is test during the static pull test. The actuator is also qualified by a dynamic test during its qualification test:
MR. BINGHAM: Other questions7 Ed Sterling has a question.
. MR. STERLING: On Exhibit IIIC-19, I think we found the answer to that by an open item a whi.le ago, you say in 10 comp1iance,
'I and down in this last sentence, you say in such a case, equipment should be tested separately for operability 12 and the actual input motion to the equi.pment in the test 13 should be more conservative than the support provides. That 14 would tell me that you are supplying the equipment vendor 15 with the actual curves.
16 MR. BINGHAM: That's correct, but the open part was 17 how thorough have we been in doi,ng it, and that is what I was 18 going to respond to.
19 MR. STERLING: Okay, we will leave it an open item, 20 then. The other part of that, the same section there, are yo 21 designing the supports to dampen out 'vibrating motion to the 22 equipment or are you trying to lower the'amount of seismic inputs to an instrument supports i 24 MR. SCHECHTER: Ve try to. make the supports rigid if 25 at all possible, which would reduce the ampli.tude to the GRUMLEY REPORTERS Arizona 'hoenix,
C 250 1 equipment.
MR. ALLEN; Any further questions? Vince.
MR. NOOHAN; On this particular section, I guess I 4 'have a lot of questions. I will try to highlight the ones 5 that I would have. I really 'don't know how to do this withou 6 taking too much of the board's time. This particular section 7 is one we would have a lot of questions on, we in NRC would.
8 Again, I will try to highlight the areas and if we can get 9 some answers, that will be fine. If not, I will maybe ask 10 that it be an open item.
For example, on IIIC-5, you say you are in complian e 12 with Statement A. Statement A would almost say that any 13 electrical piece of equipment or valve would be tested.
14 MR. LINDERMAN: To s'how operability of devices, the test would be done. This is true.
16 MR. NOONAN: Can all your valves be tested physically?
Is it possible?
18 MR. LINDERMAN: Well, here again we will test the 19 actuator. We may actually analyze the total valve system.
20 MR. NOONAN: Some valves are pretty large and you would have a hard time getting the proper amount of steam 22 flow.
23 MR. LINDERMAN: Well, here again, if you recall, I 24 said we will test the actuator, we will analyze the system, we will do a 'static pull test to show that the total thing GRUMLEY REPORTERS Phoenix, Arizona
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251 can operate.
MR, SCHECHTER: We would use the test .method or a combination of the test and analysis.
MR. LINDERMAN: It is a combination of test and analysis. Any of the devices would be tested.
MR. NOONAN.'. On the next page, on IIIC-6, large valves that had very high flow rates, high steam flow rates, for example, big valves, there is no way to test those.
MR. LINDERMAN: That's correct.
10 MR. NOONAN: So to be in compliance, we would have to say really you are in compliance from the standpoint that you are trying to use "analysis to verify that type valve wi.ll operate properly in the seismic condition.
MR. LINDEBMAN: Right. Ve are using a combination of 15 analysis and testing.
16 MR. NOONAN: '-'. On III-7, it says the test input motio shall be characterized in the same manner as the seismic input-motion. Given that you have a".test response spectrum, should you use the single frequency to 'try and envelope the test
,'response spectrums 21 MR. LINDERMAN: No.
22 MR. NOONAN: You would not.
23 MR. LINDERMAN: No.
MR. NOONAN: In no casep 25 MR. LINDERMAN: Here again, I am )ust thinking.
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252 Generally the random motion will envelope it, and here again it I cannot remember whether is this project or another project that I think there have been a few pieces that Wyle 4 has had to put some sine beats on top of random to envelope the low frequency end down to l, 2,. 3 hertz.
MR. NOONAN: Yes, I understand that part. That is not what really bothers me. The part I would be concerned about is where you use a single frequency sine wave to try and envelope the whole spectra.
10 MR. LINDERMAN: No.
MR. NOONAN: You don't happen to have the CPS mass storage unit. That is not one of your items, is it7 13 MR. BINGHAM: A what7 14 MR. NOONAN: CPS mass storage unit. I understand it 15 is in Palo Verde.
MR. VAN BRUNT: Vince, would you clarify that question?
I am not sure any of us understand what you are asking.
18 MR. NOONAN: The equipment is labeled CPS mass storage unit. It is utility equipment used to facilitate periodic 20 testing and maintenance of the system, rack mounted chassis.
21 MR. ALLEN: A core protection system'7 22 MR. NOONAN: Could be. I don't know whether this is Bechtel or this is CE.
24 MR. WOLFE: If it is CPC, it is CE.
25 MR. BINGHAM: Is that what it is, core" protection calculator.
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MR. NOONAN: Core protection calculat'-or.
2 I will ask a question that has been raised by 3 Dr. Okrent, of the ACRS7 I will 'expect I will have to answer 4 it. When you do a multi-frequency, multi-input test, we'e 5 gotten to the point now where we make very corap3.ex test 6 equipment, when you are trying to shape your response spectru 7 and you are using multi-frequency type of inputs and you'e 8 got three different directions going on, or at least two directions with maybe the thing turned, it takes time to 10 establish that spectrum. Do you have any feel for how long 11 in a normal test it would take you to just shape that spectru 12 ge't to where you feel like you have the proper spectrum 13 envelope'7 14 MR. LINDERMAN: Can I go ahead and answer that?
15 MR. BINGHAM: Sure.
MR. LINDERMAN: On this project, we have not been 17 looking at how long it takes to shape the curve to get the response spectrum. However, on another project, we have been yg looking into this and we have been looking into some of the 20 standard Wyle Laboratory test methodology to get it and we are finding that within about 10 seconds or so, we are getting about 90% of the response spectrum.
23, MR. NOONAN: I have witnessed some tests personally 24 where it took them maybe on the order of two or three days to get a piece of equipment shaped because of the fact that GRUMLEY REPORTERS Phoenix, Arizona
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254 they had so much feedback coming in out of the equipment it was giving them a lot of difficulty. The question Dr. Okrent is raising, given that it takes you some time to shape your spectrum, you are putting it under a vibration input, you then take it to your level and you run it, now you take SEE it and put it out in your plant and you see it is going to operate under your SSE level, does that give you any concern?
r MR. LINDERMAN: I misunderstood your first question when I answered it. What you are talking about is when we are y0 trying to get the table to actually shake with the equipment on it. Generally with the testing laboratories that we have been involved with and the tests that I have experienced
]3 mysel f, they have shaped the curve without the equipment on the table. Then they mount the equipment on the table and they start going through their OBE,testing, they will double-check their shaping of their curves so that when they get to the SSE testing, then they are only essentially doing one SSE curve.
19 MR. NOONAN: But you do five OBE's.
20 MR. LINDERMAN: The specification requires a minimum 21 of two OBE's for this project. They are doing at least that 22 number. They may do a couple extras because of'problems. On 23 one of the pieces of equipment that we wil1 have on here you will notice that they actually went through 13 OBE's total when they were looking at the total two direction because of GRUMLEY REPORTERS Phoenix, Arizona
0' some fallacy in the equipment and there was a little bit more 2 testing. The question that I answered about the 10 seconds was how long and how well your input motion shaped the response spectrum.
MR. NOOHAN: The concern Dr. Okrent has is, given that we put all this time on the equipment and shaping the spectru say like, for example, the one where you said you had 13 it up OBE'hen you'put to the SSE level for 10 or 15 seconds, now you install this" equipment in the plant, does that give you 10 any concern as to the confidence that this thing will take another SSE?
12 MR. LINDERMAN: The equipment is supposed to be 13 refurbished by the supplier and most of the devices will be 14 changed out and it doesn't give me great concern, because 15 generally the equipment will take it. It is whether it 16 malfunctions or not, whether the relay has some chatter in it.
17 So structurally, yes, it is going to take it. It is going to 18 take another and it is going to take another and it is going 19 to take quite a few of them. The devices will generally take 20 it', too, whether it chattered or not, and it is not really 21 overstressing the equipment.
22 MR. ALLEN: Vince, before you go on, I want to talk to 23 Ed a little bit and Ed is going to have to leave here in a fe 24 minutes, so why don't we take about a 15-minute break.
25 (Thereupon a brief recess was taken, a fter which GRUMLEY REPORTERS Phoenix, Arizona
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1 proceedings were resumed as follows: )
MR. ALLEN: I think, Vince, you have a few more questions.
4 MR, NOONAN: Yes, )ust a few more. I won't take too 5 much longer.
On IIIC-8, when you talk about fixture design under Paragraph H, are there any cases where you do the testing for your vendors?
MR. BINGHAM: No.
10 MR. NOONAN: It is a11 done by them? So, in other words, your fixture design for different equipment is for your equipment only.
13 On IIIC-11, you said you had no plate and shell 14 supports for BOP.
15 MR. BINGHAM: That is correct.
16 MR. NOONAN: None at a11?
17 MR. SCHECHTER: Supports, that's correct.
18 MR. NOONAN; On IIIC<<l2, safety-related overpressure 19 protection devices, relief va1ves, and so forth, there is an 20 EPRI program going on right now testing safety valves ~ Are you in any way keeping track of that program and what is occurring.
23 MR. ROGERS: The answer is yes, we are. I am the APS EPRX technical contact and Bill Quinn is the APS 25 licensing contact. Ne followed that program through 26 the Combustion. Engineering Three Nile Island GRUMLEY REPORTERS Phoenix, Arizona
I 2 7 owners group that studied various Three Mile Island things.
We have input our actual pipe runs, and we have reviewed the programs that, have recently been published by EPRI. We are very much involved with that study.
MR. NOONAN: The only other question I wanted to get back to is on IIIC-15, Paragraph E, random vibration input motion. Can you go into a little more technical detail as to how you would shape your spectrum and what you'r frequency P
spacing would bef 10 MR. LINDERMAN: The different laboratories have their different methodologies to'hape their curve.
12 MR. NOONAN: Well, let me get to the point. Does the 13 lab use a random noise generator or do they shape by using sine beats'5 I'ifferent
.MR. LINDERMAN: Wyle Lab has been doing most of the testing. They use a random noise and they shape. it through 17 'hird octave filters. Each filter has a third octave band 18 with the filter on it.
19 MR. NOONAN: If you went Co some lab where they did 20 not have that piece of equipment and they had to use sine 21 waves to develop it, would you put on a requirement that they 22 also use third actave spacingf MR. LINDERMAN: I would want a little bit closer than 24 third octave spacing, if they are using sine beats. I know 25 Westinghouse has a methodology. I am aware of theirs. The GRUMLEY REPORTERS Phoenix, Arizona
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258 only lab that I am aware of that uses that is Acton Lab and I am trying to go back and remember what series of curves they did use when I reviewed one document that Acton had done where they had used sine beats, and I think they had more than third octave filter.
MR. NOONAN: Closer than third octave?
MR. LINDERMAN: Closer than third octave. This is right.
MR. NOONAN: But in any case, then it would be third 10 octave or less?
MR. LINDERMAN: Third octave or less would be the 12 spacing.
13 MR. NOONAN: I guess the last thing I want to bring up was you make a statement on IIIC-16 where you say that unless 15 it can be demonstrated that the equipment response in the vertical direction is not sensitive to the vibration motion, 17 and so forth. Do you have equipment that has been tested to 18 single sine wave type testing or single sine beat testing 19 that you plan to use? I was wondering how you were going to 20 make a determination.
21 MR. LINDERMAN: I am thinking back through and remembe 22 ing all of the packages that we have checked, that we have 23 reviewed, from the suppliers supplying it, and I don't think 24 I recall of any of them using single frequency.
25 MR. NOONAN: I am not trying to give the impression we GRUMLEY REPORTERS Phoenix, Arizona
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1 are against single frequency, because I am not. I am just 2 saying that if you had a piece of equipment that had been 3 tested to si ngle frequency and tha t tes t had been done-properly, then, fine. I am just wondering how you make the determination and say for your location i.n the plant that 6 that i.s adequate.
MR. LINDERMAN: If someone should come in with a 8 single frequency test, we would first look at the response 9 spectrum of the actual location where the equipment is 10 'ocated. Then we would start looking at what is the malfunc-11 tioning mode of the equipment being qualified, what different 12 frequencies it could be exposed to, the number of modes that 13 we would expect in that, and this type of methodology is what 14 we would have to look at.
15 MR. NOONAN: Well, the only concern I would raise, and it is just a comment, is that given that you had a piece of 17 equipment that was done using, say, a single frequency type 18 envelope and you knew that equipment had resonances at a g9 higher frequency area, then I would seriously question the 20 validity of that test.
21 MR. LINDERMAN: That's ri.ght. I would, too. The only time I would really want to look at single frequency would 23 be'n a single device. Then you know about what is happening 24 MR. NOONAN: Thank you.
25 MR. ALLEN: Vince, do you have any further questions':
GRUMLEY REPOATERS Phoenix, Arizona
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260 MR. NOONAN: No.
MR. ALLEN: Are there any additional questions from anyone on the board before we move along? Zoltan.
DR. ROSZTOCZY: Are all the seismic tests that you are performing, for this program being done on full-size equipment MR. BINGHAM; I don't think so. If you would like further information, John, you could have that as an item.
MR. ALLEN: Why don'0 we put that down on the list to verify that.
10 MR. BINGHAM: I think there are some exceptions.
DR. ROSZTOCZY: I would be interested to know when you 12 have exceptions, and then in the cases where you are working 13 with scaled equipment, are you specifying additional instru-14 mentation for the purpose of verifying the calculation or 15 method that will be used to,extrapolate the data to full-seal 16 size.
17 MR. ALLEN: Any further questions?
18 DR. ROSZTOCZY: One more question. You mentioned 19 documentation at the end, and I think the words were that yes 20 you are maintaining the documentation on this. I am not sure 21 if this is the appropriate time, but sometime today I would 22 like to hear a description of how APS is planning to maintain 23 equipment qualification and seismic qualification documentati n.
24 How do you plan to set it up? How do you plan to maintain it-25 for the life of the plant?
GRUMLEY REPORTERS Phoenix, Arizona
MR. BINGHAM: Do you want to hear that today or would you like that as an open item for response?
DR. ROSZTOCZY: If possible, I would like to hear it today to the extent that you can do it.
MR. ALLEN: Okay, we will do that before- the end.
DR. ROSZTOCZY: Xt is the type of question that I would like to know if it is going to be one file, are you going to have a file which is called, let's say, equipment qualification file and then all the information that we 10 discussed like specifications, calculations done, test result everything is going to be in this file, or, as an alternate, 12 are these going to be in different files, how many files are 13 involved, who is going to keep them, what location are they 14 going to be kept, and so forth.
15 MR. BINGHAM: Any other questions, John?
16 MR. ALLEN: Any further questions?
17 MR. BXNGHAM: Let's go on with the presentation, then.
18 What we are going to cover is Item 3, the General Design 19 Criteria, and Item 4, the IEEE Standard 344, and then we will 20 ask for questions at that time.
21 MR. SCHECHTER: Exhibit IIIC-21 covers the General 22 Design Criteria that are referenced in the Standard Review 23 Plans. These are from 10 CFR 50, Appendix A. The first one 24 has to do with the quality standards and records. It says.
25 that the structures, systems, and components important to GRUMLEY REPORTERS Phoenix, Arizona
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26 safety should be designed and tested to quality standards commensurate with the safety function to be performed and tha the records should be maintained throughout the life of the 4 plant. The project meets the requirements of Appendix B, 10 CFR 50.
Exhibit IIIC-22, General Design Criterion No. 2,
'design bases for protection against natural phenomena. The I
structures and the equipment important to safety are designed to Seismic Category I requirements. The project is in 10 compliance.
h Exhibit IIXC-23, General Design Criteria No. 4, 12 pertains to environmental and missile design bases. This 13 criterion is not applicable to seismic qualification of 14 equipment.
15 Exhibit IXIC-24, General Design Criteria No. 14, 16 reactor coolant pressure boundary. Again, this criterion is 17 not applicable to seismic qualification of balance of plant 18 components.
19 Exhibit IIIC-25, General Design Criteria No. 15.
20 The reactor coolant system and protection systems shall be 21 designed with sufficient margin to assure that the design 22 conditions are not exceeded during any condition of the plant 23 normal operation, including anticipated operational occurrenc s.
24 The project is in compliance.
25 The next document that I would like to discuss, GRUMLEY REPORTERS Phoenix, Arizona
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263 shown in Exhibit IIIC-26; is IEEE 344-1975. It is entitled IEEE Recommended Practices for Seismic Qualification of Class IE Equipment. The requirements in here are very similar to requirements that have already been mentioned in the Standard Review Plans, but I will go over them briefly. The first one has to do with assurance that the equipment can perform. Ne need to verify the performance of the equipment during and after an.SSE preceded by a number of OBE's.
Exhibit IIIC-27. For qualification by analysis, 10 five OBE's should be used preceding the SSE, and for qualifi-cation by test, one or more OBE tests that produce the equiva 12'3 leht effec't of five,OBE's for a site specific value]. The value that the project is using is two OBE's based on the spe 14 cific value for the site. The project is in compliance with 15 the requirements.
16 B, qualification should be done by analysis, test, or 17 a combination of these two methods. We agree with this requirenent II 18 C, the margins specified in IEEE 323-1974 shall be employed. The project is in agreement with this.
20 Exhibit IIIC-28. This section has to do with 21 analysis. For analysis, there are two general approaches.
22 For static analysis, the response of the equipment is assumed 23 to be the peak value from the required response spectra and 24 then this response is multiplied by a factor of 1.5. For 25 dynamic analysis, a mathematical model is prepared of the
'RUMLEY REPORTERS Phoenix, Arizona
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264 equipment that represents its mass and stiffness characteris-tics and then a modal extraction is performed to obtain the frequencies and mode shapes. If the lowest frequency is greater than 33 cycles per second, then the equipment is con-sidered rigid and you can use a static factor applied to the equips .
On Exhibit IIIC-29, if the frequencies are lower than 33 cycles per second, then you can either use a response spectru analysis or a time history analysis to obtain the responses o the equipment. For combining the responses, you can go ahead 10 and use a square root sum of the squares method if you do not have closely spaced modes. If you do have closely spaced 12'3 modes, then you have to use an absolute sum of the responses on the closely spaced modes. The project agrees with this criterion.
14 Exhibit, IIIC-30 deals with testing. Again, it states that the input motion shall conservatively simulate that post 16 lated, therefore the response spectra developed from the moti n 17 on the test table should be equal to or greater than the re-18 quired response spectra. The project agrees with iC. The equipment should be attached to the shaker table in a manner 20 that simulates the actual field attachments. The project 21 agrees with that.
Exhibit IIIC-31. C requires that sufficient monitoring equipment be used to monitor the performance of the equipment before, during, and after the test. The projec is in compliance. D states that exploratory vibration tests GRUMLEY REPORTERS Phoenix, Arizona
l 265 can be used to aid in the determination of the test: method that would best qualify the equipment. The project agrees with this requirement. E states that. seismic qualification 4 tests shall be performed with the equipment subjected to normal operating conditions. The project is in agreement with that.
Exhibit IIIC-32 provides criteria for deciding between single and multi-frequency testing. The project is in compliance. It states when multi-frequency or single-10 frequency input"motion should be used,'nd the 'project is i.n agreement.
12 Exhibit IIIC-33 sets criteria for the use of 13 single directional tests, and if that cri,terion is not met, 14 then it requires multi-directional tests to be performed.
15 The project preference is biaxial testing. The project is 16 in agreement.
17 Exhibit IIIC-34 allows for large or complex equip-18 ment'the use of both testing and analysis methods. The 19, project agrees with this.
20 MR. BINGHAM: Are there any questions'R.
21 ALLEN: George.
22 MR. SLITER: Mould you please elaborate on Exhibit 23 IIIC-27, Item C, margins specified in IEEE 323-1974 shall be 24 employed where applicable; Is this the aging part of the 25 test programs GRUMLEY REPORTERS Phoenix, Arizona
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266 MR. LINDERMAN: This has to do with the seismic. It is essentially the 10%. We are talking about the, seismic II right now, and I think the margin that we were talking there is the 10% over.
MR. SLITER: And I assume, also, margins in the aging before seismic?
MR. LINDERMAN: Yes.
MR. ALLEN: Further questions? Vince, go ahead.
MR. NOONAN: I guess the philosophy, going back to the 10 same type of question on margins,* you always intend to 12'nvelope every part of this response spectra. Can you give me some of your thoughts on that?
13 MR. LINDERMAN: Generally, we envelop the total curve; 14 however, at the low end, that is at one, two, possibly at thre 15 ,hertz, some gf the tests do not envelope it. At that time, 16 we do check to make sure what resonances there are at the low 17 frequency end. If there are no resonances in the low fre-18 quency end, then we will accept not enveloping the complete RR 19 MR. NOONAN: As a comment, n'ormally we say you have to 20 envelope it, and so forth, but sometimes that is not really 21 practical. I will give you a person'al comment that if you 22 could stay within plus or minus one and one-half dB of the 23 envelope, I think that would be sufficient.
MR. BINGHAM: One and one-half?
25 MR. NOONAN: One and one-half dB's based on voltage and GRUMLEY REPORTERS Phoenix, Arizona
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1 the power.
BINGHAM: Are there other questions7 3 DR. ROSZTOCZY: You were talking about General Design 4 Criteria 2 and 4. No.' refers to natural phenomena and 4 5 refers to environmental conditions associated with normal 6 operation, maintenance, postulated accidents, and so on.
7 The general design criterion is not specific on any load 8 combinations, what load has to be combined with what other load. How do you handle seismic loads and accident loads, 10 including the type of loads that we discussed yesterday like vibration, expected vibration caused as a result of the 12 accidentf Do you combine those with the seismic load and do
$3 you test the equipment for the combined load?
MR. BINGHAM; First of all, loading combinations are l5 covered in the design criteria. As we indicated yesterday,-
16 there are some combinations that we were discussing and had l7 as open items'o review that have not been considered, or at 18 least have not been tested. One of these is the new issue 19 of,IQCA motion and its impact as we].1 as-sana internal flutteri g 20 from two-phase 'flow I believe is.rwhat was discussed yesterday.
21 I think, John, what we would like to do in order 22 to assure that we give the proper response is leave this as 23 an open item, please.
24 DR. ROSZTOCZY: As a comment on that, in one case wher 25 this received a great attention and it was brought ta a resolution GRUMLEY REPORTERS Phoenix, Arizona
26 was the BWR containment question of combination of accident loads and seismic loads. The requirement was that they had to be combined. So long as you combine the loads, we know it is acceptable. I think that ought to be looked at in the very near future.
MR. BINGHAM: I appreciate the comment. We do under-stand the concern.
MR. ALLEN: Further questions7 DR. ROSZTOCZY: Yes, I have one more question. Thi's R 10 is General Design Criterion No. 14. It is Exhibit, IIIC-24.
Your statement on the right-hand side is that 4
it is not 12 applicable to seismic qualification of balance of plant 13 components. I am not sure exactly where is the dividing 14 line between balance of plant components, but one item which 15 we will be concerned with is pump seals.
MR. BINGHAM: This is reactor coolant pressure boundar 17 we are referring to.
18 DR. ROSZTOCZY: Yes. Do you provide any pumps which a 19 part of the reactor coolant pressure system 1ine7 20 MR. BINGHAM: Not that I know of.
21 MR. KEITH: No. The only pumps which are part of the 22 reactor coolant pressure boundary are the reactor coolant 23 pumps ~
24 DR. ROSZTOCZY: So then it is on the balance of plant 25 components.
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MR. KEITH: Right.
MR. ALLEN: Further questions? If not, then let '
move along.
MR. BINGHAM: That brings us to the final section, which is C.5, Reg. Guides..
6 MR. SCHECHTER: These Reg. Guides are the ones that were mentioned in the Standard Review Plans. Exhibit IIXC-35 Reg. Guide 1.20, entitled comprehensive vibration assessment program for reactor internals during preoperational and 10 initial startup testing. This Reg. Guide is not applicable to seismic qualification of balance of plant components.
12 Exhibit IIIC-36, Regulatory Guide 1.48 entitled 13 Design Limits and Loading Combinations for Seismic Category I 14 Fluid System..Components. The guide sets for the design limit 15 and loading combinations for various ASME components. Loadin 16 combinations for the project are presented in the FSAR 17 Chapter 3.9. The design limits are in accordance with ASME 18 Section III.
19 Exhibit IIIC-37, Regulatory Guide 1.67. We had 20 already mentioned this Reg. Guide earlier. It deals with 21 the design of pressure relief valves and, as such, it is not 22 applicable to seismic qualification of equipment.
23 Exhibit IIIC-38, Reg. Guide 1.68 entitled Initial 24 Test Programs for Mater-Cooled Nuclear Power Plants. Again 25 this Reg. Guide is not applicable for seismic qualification GRUMLEY REPORTERS Phoenix, Arizona
of equipment.
Exhibit IIIC-39, Regulatory Guide 1.92, which deals wit'a combinino modal responses. The airs't criterion is combination of modal responses and it states that when you do not have closely spaced modes, you can use the method of the square root of the sum of the squares for combining the responses.
When you do have closely spaced modes, you have to use one of the three methods mentioned in the Reg. Guide for combinin 9 the closely spaced modes. The project is in agreement with 10 this portion of the Reg. Guide.
Exhibits IIIC-40 and 41 give the requirements for a 12 combination of effects due to three spatial components of an 13 earthquake. In A, it describes a response spectra method 14 where you go ahead and coahine the responses in each of the 15 three directions by a square root sum of the squares method.
16 The project is in agreement. In a time history analysis wher 17 you go ahead and you compute the responses in each of the 18 three directions separately, you can go ahead and use the 19 square root of the sum of the squares method for combining 20 the responses. The project is in agreement with that method.
21 Finally, C, in a time-history analysis where you 22 calculate the responses from all three directions at one'ime, 23 the response you get is the combined response.
24 Exhibit IIIC-42. This is Regulatory Guide 1.100, 25 Seismic Qualification of Electric Equipment. This Reg. Guide GRUMLEY REPORTERS Phoenix, Arizona
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271 1 modifies the criteria set forth in IEEE 344-1975. The first item is that you'an only use the 1.5 static coefficient when I you have frame type equipment. Otherwise you have to go 4 ahead and provide justification for that'actor. The project 5 agrees with that criterion.
Exhibit'IIIC<<43. No. 2 tells you that the test response spectra must closely envelope the required response spectra to verify the adequacy of test input motion. Ne are in agreement with this. I might note that again in the low 10 frequency range, sometimes it does not envelope and we look at that on a case-by-base basis; Item 3 there says that a sine sweep test or single frequency test is unacceptable g3 unless the justification is provided, and we agree with that 14 requirement.
f 15 Exhibit IIIC-44, Regulatory Guide 1.124 entitled 16 Service Limits and Loading, Combinations for Classinear-17 Type Component Supports. The project is in agreement with 18 this Reg. Guide.
19 The last one,'Exhibit IIIC-45, Reg. Guide 1.130, 20 sets the service limits and loading combinations for Class. 1 21 plate-and-shell type support components. It is not applicable 22 since there are no Class 1 plate-and-shell supports for 23, balance o f plant components ~
24 MR. BINGHAM: Any questions? Pete.
25 MR. NEWCOMB: I have a quick one. In previous discussi GRUMLEY REPORTERS Phoenix, Arizona
you had Table 10 showing critica1 damping factors from Reg.
Guide 1.61. You haven't discussed 1".61 any further here.'s there more applicability of that to your efforts?
MR. SCHECHTER: I think that when I covered Reg. Guide 1.61, I mentioned that equipment suppliers also make use of Reg. Guide 1.61 to obtain their damping values that they should use.
MR. NEWCOMB: Do you make use of Reg. Guide 1.61?
MR. SCHECHTER: For the design of structures, we do.
10 For the design of piping, we also make use of that Reg. Guide.
MR. ALLEN: Any further questions'? Vince.
12 MR. NOONAN: I have one question on IIIC-40. I am sur 13 you are all aware of the five plant shutdown problem we went 14 into a year or so ago. I expect now all your computer 15 programs when they do the intramodal type calculation do not use the algebraic method.
17 MR. BINGHAM: That's correct.
18 DR. ROSZTOCZY: Exhibit IIIC-38. The requirement 19 relates to testing conducted during the-initial test program 20 and your position is that this is not applicable to seismic 21 qualification of equipment. I was under the impression that 22 some testing is usually done in the initial testing phase; 23 namely, to apply some loads at some part of the- as-built system and then measure responses at other locations physicall 25 to verify your calculations that you have done for the system.
GRUMLEY REPORTERS Phoenix, Arizona
273 Nouldn't that fall under this requirement2 MR, KEITH: Yes. Our start-up program will include a program like you are talking about where we have the system running and shut valves and stop and start pumps and things like that and measure the vibration at various points. Our 6 interpretation had been )ust that that didn't specifically tie in with seismic qualification, but we will be doing that.
DR. ROSZTOCZY: Does that program include also maybe
'pplying some loads to the system and measuring responses for 10 the purpose of checking some of.your seismic calculations?
MR. KEITH: Simulating a seismic load, is that what 12 you'e--
13 MR. ROSZTOCZY: You simulate some load. It doesn' 14 have to be seismic load, but you simulate some load at one 15 point and you measure. the response to that load and then you 16 check this against the method that you used for seismic.
17 MR. NOONAN: He is talking about doing a modal type 18 of frequency test system like the aircraft test usually does.
19 MR. BINGHAM: Presently, no.
20 MR. ALLEN: Anyone on the board have additional ques tions 2 22 MR. BINGHAM: May I ask to have a clarification7 Is 23 there some suggestion that that is a requirement'r might 24 be a requirement7 25 DR. ROSZTOCZY: I do not know. I will have to check on GRUMLEY REPORTERS Phoenix, Arizona
274 MR. ALLEN: No further question? Then let's proceed, Bi11.
MR. BINQHAM: This brings us to Section IV, Equipment Qualification Process, and we will also cover Section V, Documentation, at the same time. I would like to make one comment for the board that many of the things that you will hear now have been discussed during the presentation that we had yes'terday, so I wi11 be a little brief in the description What I am basically trying to portray are the details of the 10 process and the elements of some of the check plans that we have so that you will understand them a little bit before we 12 get into the actual examples, which have the check forms 13 filled out.
14 You recall Figure 7 showed the equipment qualifica-15 tion process and I went through that in detail in yesterday 16 morning's session.
17 Exhibit IV-1. The purpose, of course, is complianc 18 with the design criteria, that we are in compliance with the 19 regulations, codes, and standards, and with the specifications.
20 Exhibit IV-2. The specifications are to implement 21 the design criteria, establish hold and test points. We have 22 in addition to that review by the responsible enginee'rs and specialists as required, and we develop inspection plans so 24 that we can assure that there is an on-hand, if you will, 25 in the supplier's or the testing laboratory's facilities r a GRUMLEY REPORTERS Phoenix, Arizona
~ 1 275 review of the actual tests of actual equipment.
Exhibit IV-3. You have heard description of the qualification methods, the testing, analysis, operating experience, ongoing qualification, combination of methods, and also a description of the qualification procedures.
k I Figure 18 is an overview of the process. Me talke yesterday about the supplier submittal essentially to the qualification team that consists of APS and Bechtel. On the APS side, their nuclear services group has a review. They 10 also have a checklist that I will indicate the elements of.
In Bechtel, we have seismic reviewers headed by Mr. Linderman 12 and we have environmental reviewers headed by Mr. Carson as 13 well as stress reviewers as required for the particular 14 piece of equipment. All of this information is fed to the 15 responsible engineer for that piece of equipment. Comments 16 are coordinated. Those comments then are sent to the vendor.
17 If the resolutions are not acceptable, of course, we keep 18 working with the supplier until they become acceptable. Once 19 they are acceptable, then the records go to Records-Retention.
20 Exhibit IV-4. In the procedures or plans, @PS has 21 their own checklist, Bechtel has an environmental checklist, 22 there is a seismic checklist, and these are combined or will be combined into one package as part of the total documentatio There will also be specialist reviews, maybe attached to the 25 program, and there will be a rereview of already accepted GRUMLEY REPORTERS Phoenix, Arizona
1 6
documentation to assure it is in compliance with the elements of NUREG 0588.
Qualification reports. As I indicated, there is an APS review, there is a responsible engineer and specialist from Bechtel who review, there is a review of all documenta-tion, there may be an amendment to the FSAR to include the summary data, and, of course, we have to assure that we have demonstrated auditable compliance with NUREG 0588.
Exhibit IV<<5. These are the elements of the APS 10 check-off list. This list is not part of and does not have to be part of the documentation package. It is in their 12 records to demonstrate that they have diligently reviewed the 13 environmental and seismic. reports that come to them and have 14 resolved all comments that they might have successfully with 15 Bechtel and the supplier. Of course, they will look at all the.key elements, the description of the equipment and the 17 environmental service conditions, and then they will look at the methods of 323 and flag any exceptions. They wi11 look 19 at any special maintenance procedures. They will look at the 20 program and plan, is it in the requirements, are the performa e 21 limits correct, how do the failure definitions stack up with 22 the requirements, and then they will look at the operating-23 experience program and plan.
24 Exhibit IV-5A. Finally, they will review for analysis assumptions, how the mathematical models are derived GRUMLEY REPORTERS Phoenix, Arizona
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and )ustified, and any ongoing programs.
Exhibit IV-6. The environmental qualification checklist will cover the description and location of the components. It will look at operability requirements, the designator, time, operation, function, the designated environment, the qualified environment from the 'supplier, the 7 margin, the equipment mounting and orientation, .(Exhibit IV-7 8 the qualification method, type, sequence, specimen, instrumen tation, aging method, humidity aging, performance characteris 10 tic monitoring, the instrumentation calibration, and the component interfaces. There will be an evaluation, and from 12 that a list of deficiencies. These deficiencies are flagged 13 on a work order that is followed and tracked with a separate 14 system to assure compliance.'his 15 is Exhibit IV-'8 and is a chart similar to what 16 you saw yesterday that has the environmental service conditio s 17 as supplied and the qualification margin. That is part of 18 the checklis t.
19 On Exhibit IV-9, we are now looking at the seismic 20 qualification checklist and that will have / again a component 21 description and location, equipment qualification method, 22 vibration inputs of loads, response spectra, required 23 acceleration, the qualification test data looking at frequenc axis, number of tests, frequency range, TRS, lab mounting, 25 verification of functional operability, and test results.
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There will be a section on the analysis of the test data looking at the model type, looking at the computer codes used the 'combination of dynamic responses, the damping, support i
considerations, and the critical structural elements. Finall there will be a list of deficiencies and those will be,put on a work order and will be followed to assure completion.
On Figure 7, we talked about the qual'ification testing, and now if we can go to Exhibit IV-10, the testing will be "actual equipment or prototype, the lab procedures, 10 sequence will be covered, there will be an analysis of the method as submitted by the manufacturer, and we require that 12 they provide a description of their other methods if they 13 use them.
'his is Exhibit IV-11. It is an explanation of 15 the audit of testing. We did discuss this yesterday. I 16 would like only to highlight the issues that we talked about, 17 that it would be conducted by what we call a supplier quality 18 representative as part of our procurement department that 19 goes out in the field, maybe supplemented with the engineer.
20 We will review the test procedures,, plans, and reports. We 21 review the report data at the manufacturer's facility or at 22 the testing laboratory. We review the procedures for. perform-23 ing, the tests, collec ting and reducing the data. We will 24 verify the capability of test equipment and instrumentation t 25 perform tests. We will verify instrument calibration and make sure it is traceable to the National Bureau of Standards.
GRUMLEY REPORTERS Phoenix, Arizona
27 We will verify tests performed in accordance with procedures and any deviations that may be .noted. We will verify the results and conclusions to assure that they reflect the test data. We will examine internal review processes," sign off procedures, and quality assurance procedures. We will verify the existence of an aging library or extensive literature data bank i,f referenced in the. reports.
I,
,,This is Exhibit V-1. I will briefly summarize what we discussed yesterday, that all documentation will have its own log number; There will be a report number, and a sub)ect title, and any proprietary information will be noted 12 by subject and where it is located.
13 'xhibit V-2. We indicated that the records would 14 'e made complete before they are given to APS and any
'references to proprietary information would be part of them.
Yesterday we indicat'ed that there would be a data D summary update on the FSAR. The elements are shown in 18 Exhibit V-3. We will describe t
the type of equipment, the 19 component, the equipment location, building, elevation, the 20 manufacturer, the model number, the Palo Verde Nuclear 21 Generating Station specification number. The environmental 22 ,designator, the qualification methods, qualification 23 environment, the time base, the seismic qualification 24 including the method, the excitation method, and the frequenc 25 range. We will also discuss operability, time when required, GRUMLEY REPORTERS Phoenix, Arizona
280 demons tra ted.
Conti.nuing on Exhibit V-4, the accuracy which was requi.red, what was demonstrated. We will report on the 4 environmental qualification. We will indicate the report number and any pertinent revision number, and we will indicat the qualification life i.n years.
Are there any questions7 MR. ALLEN: John Barrow.
BARROW: Goi.ng back to Exhibit IV-4, I wanted to 10 clarify something. On the plans and procedure review and 13'R.
12 qualification reports review, discussing the APS checklist, you show the APS checklist for plans and procedures. On the qualification portion, you show APS review. In actuality, 14 the APS checklist wi11 be used both in the review of plans 15 and procedures and in the review of reports. I wanted to 16 clarify that fact, that our revi.ew on the reports is'bei.ng done with the same checklist.
18 Then on the next page, I think, Bill, you made the 19 statement that our checklist wouldn't be in the final report, 20 and we had hoped that the final checklist that we do on the 21 final report after it is signed off will eventually be put 22 with the report: in a final document.
23 MR. BINGHAM: That's fine if you so desire.
24 MR. BARROW: That was the intent. Also, on Exhibit 25 IV-5, I think 344-1971 under Item III should be 344-1975.
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281 MR. BINGHAM: That's correct.
MR. ALLEN: That would be an open item then to correct 3 our slide. Do you have it?
MR. QUAN: I 'e already got it.
MR. NEWCOMB: I might. add that also includes 323-75.
It should be '74.
MR. BARROW:
I The last question I have is in Exhibit
.IV-ll, I can see where most of the items on here fall, the 9 supplier representative would be knowledgeable to be able to check, for instance; examine internal review process, sign off procedures, verify existence of an aging library, 12 but going up to the second and third and fourth bullets, are 13 the SQR's also knowledgeable enough to review test procedures 14 plans, and reports for compliance, to review test data, and especially to review the actual procedures for performing the tests?
17 MR. BINGHAM: No, they are not.
MR. BARROW: In the case that they are not, does 41 18 19 Bechtel have a> way to supplement their expertise?
20 MR. BINGHAM: We generally will send an engineer with 21 them into the shop.
22 MR. ALLEN: Further questions? Norm.
23 MR. HOEFERT: My question concerns the performance of 24 tests which have to be done after the plant is operational 25 replacement of life-limiting components, certain maintenance GRUMLEY REPORTERS Phoenix, Arizona
282 items, and so forth. Has this been looked at to determine if. these test;s can indeed be performed during plant operation or are we going to be faced with situations where we may have to shut certain systems down or maybe the whole plant to t
perform tests required to keep equipment qualified', Who is looking at that and how7 MR. BINGHAM: The reason I am a little confused is
)ust what test you might think you would be rerunning.
MR. HOEFERT: Qe11, specifically replacement of life-10 limiting components.
MR. BINGHAM: I understand the question is on the ite 12 that would have 'to be maintained and replaced, and we are 13 looking at that a'nd we are making sure that that information 14 will be put into the maintenance procedures, and we are also 15 making sure that the equipment is available to make those 16 changes without having to shut down systems or shut down the 17 plant because of access reasons. H MR. HOEFERT: Is this somehow tabulated or documented 19 in your checkli.stf.'R.
20 BINGHAFi.'t is not in the checklist;. but it is 21 supposed to be covered as part of the maintenance reviews 22 that are conducted on the plant.
23 MR. ALLEN: Ed Sterling, do you have a question7 24 MR. STERLING: My question gets back to, it started 25 yesterday, who decides what is aged, -and so forth. I suppose GRUMLEY REPORTERS Phoenix, Arizona
this might be an appropriate place to ask it. You had on your schedule way back in the presentation, equipment qualification meetings that were held with all the vendors to bring them up to speed on the requirements of the project, what they had to qualify to. Maybe you could go over the scope of those type of meetings. Were we trying to encourage them to do type testing? Were we trying to direct them in some way to perform the most preferred tests rather than just what they felt was the way to go themselvesf 10 MR. BINGHAM: We will talk about, that a little bit in problem areas, Ed. We had the meetings, as you know, with 12 many of the vendors in order to assure ourselves that they 13 are very serious about their commitments to meet the require<<
14 ments of IEEE 323-1974, whatever they might be for the 15 particular piece of equipment. What those meetings have come out with have been not very satisfactory results, in some 17 cases because of technical impracti'cability, in some cases 18 lf of commercial issues. In some cases, we are finding 'ecause 19 that techniques of doing the work are not clear and that the 20 vendors are just not willing to perform any tests or to spend 21 money to conduct the tests, and then we are finding that 22 vendors are going out of business. We have.a little bit of 23 all of those, which we will talk about later. Our program is 24 ongoing. We do have detailed schedules, follow-up, in order 25 to assure that we do meet the overall schedule. We have not GRUMLEY REPORTERS Phoenix, Arizona
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284 presented those to the board, because that is kind of the detailed working of the syst: em, but they do exist.
MR. STERLING: Just to expand a little further, since the field is just starting to develop aging criteria and also finding out what types of materials have aging and which ones can, be neglected, is there a check between the vendors where one vendor might tend to neglect one type of material, they 8 claim it does not have an aging mechanism so they would not age that one, whereas another vendor may with the same type 10 of material have successfully found a way.to age it and would 11 have done something? Is there a correlation between vendors 12 as far as who is aging what and what criteria they use?
13 MR. BINGHAM: Well, there are a lot of programs to 14 compile what is going on by the various vendors for various 15 pieces of equipment. We are aware of the. problem that 16 because of uncertainties, we need to bridge that gap, and at 17 least for Palo Verde, we are doing two things. One, we are 18 rereviewing the vendors and their programs to determine wheth r 19 if
'here is consistency, or one vendor can learn from another, 20 so to speak, where we can inform them "Don't tell us you can'o 21 it, because we know Vendor A is doing it," and we will 22 help them in that manner. Second, we are looking at other 23 projects to see where we are having difficulty in not being 24 able to accept or having to accept a method that may not be the best for us for our particular application to see if other GRUMLEY REPORTERS Phoenix, Arizona
i f 285 projects within Bechtel -- there are many of them that are going through qualification, not only plants that are in the
.3 construction permit stage, but plants that are also in the 4 operation stage. So we have those two programs that supplement and try to bridge the gap between these type suppliers.
MR. ALLEN: Further questionsf DR. ROSZTOCZY: The procedures as you describe them g are,,oriented toward showing compliance with certain require-y0 ments. Your real goal is to assure that this equipment is going to function under appropriate accident conditions. The are some differences between these two. Regulations are not
]3 perf ec t . They might address lif certain aspects of qua ication
~4 and they might be somewhat short in some other areas.'f you sometimes have knowledge that might not be in the requla>>
tions, what requirements do you have that 'the vendors have knowledge in terms of making 'a judgment whether the equipment will function according to their knowledge and their under-yg standing and, if they are asked to make such a judgment, then 20 is this documented in any form.
21 MR. BINGHAM: Yes, this judgment would stem from the 22 work orders that I 'discussed. The reviewer first would go 23 through and define any deficiencies, which I think would be 24 it fairly obvious. Either meets the criteria or doesn'. it Let's take your case of judging whether that would be accepta le GRUMLEY REPORTERS Phoenix, Arizona
4 286 or not and taking the case that we discussed in'seismic where you might not envelope the lower frequencies. There would be a work order written. That work order would be reviewed by our technical experts and APS as well and it would say we looked at the response spectra', that we looked at the 6 frequencies of the equipment, and it is acceptable for this 7 application for that not to envelope the lower frequencies.
8 That then will be signed off and become part of the documenta 9 tion package.
10 DR. ROSKTOCZY: Are your reviewers ever asked a 11 question like, "Are you aware of something which might preven 12 this equipment from functioning under accident conditions?"
13 MR. BINGHAM: Yes, we do from time to time, but I don'4 know of any formal documentation that we have asked that 15 specific question. Shat we try to do with our responsible 16 engineers is to have them in a training or updating session 17 in order to inform them of what is going on, the important 18 'items to be concerned about. I think we conduc'ted our most 19 recent one in the environmental section. Mr. Carson conducte I*
20 that maybe some two months ago or so where he had all the responsible engineers in the room, went through all the procedures, all the new things that they need to think about, 23 and we have documented those type of sessions ~
24 MR. SLITER: Mr. Bingham mentioned that it would be desirable to have consistency among the qualification programs GRUMLEY REPORTERS Phoenix, Arizona
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287 of vendors. This goal is one of the hoped benefits of the EPRI sponsored equipment qualification data bank that is now being established under contract to NUS Corporation and I 4 would ask that both Bechtel and APS encourage vendors to contribute data to the data bank. Solicitations for data will be sent out in the next couple of weeks to utilities and equipment vendors.
MR. BINGHAM: Any other questions?
MR. LaGOW:. On Exhibit XV-'l for audit of testing, you don't have a bullet here that says you verify that the equipment was in the proper operating mode at the time it was 12 exposed to the environment that you are checking. Maybe it is implicit in your specification, but I think this is a 14 very important point, -that it should be in the proper operati 15 mode so that you'can see if the relays are chattering if 16 they are being vibrated, so you can see that it is being radiated, if you are getting spurious signals in logic circuits, and when you are changing pressure to see that no membranes are .moving around and opening or shorting equipment.
20 MR. BINGHAM: We can modify the slide, John. These 21 were the highlights, but that should have been highlighted.
22 MR. ALLEN: Okay, why don't we modify the slide to 23 show that.
24 Are there any further questions?
25 Okay, Bill, go to the next subject.
GRUMLEY REPORTERS Phoenix, Arizona
288 MR. BINGHAM: I am reminded that on our checkoff sheet although I didn't show it on the highlight slide, I will add 3 it, John, that we do indicate the replacement schedule for 4 any piece of equipment or component that has to be replaced 5 shorter than the 'specified life. I think Mr. Hoefert asked 6 that question. That is where the information first occurs, 7 and then that information would be transferred to the main-tenance requirements.
MR. HOEFERT: Could you repeat that? I didn't catch 10 that.
MR. BINGHAM: Sure. On the checkoff sheet, we do 12 indicate the specified time for components that have to be 13 replaced in less than the qualified life of the plant, and 14 it I indicated that was not shown on Exhibits IV-6 and 7 and 15 we will add that point to it.
MR. ALLEN: Let's go to the next section.
17 HR. BINGHAM: Our next section isSection VI, Example 18 Qualifications. If 'you will look at the agenda, Enclosure 19 iii, we have split that into Environmental and Seismic and we 20 have indicated that we have examples for the balance of plant 2l ESFAS, which is the actuation system, the balance of plant 22 instrumentation, diesel generator, battery charger, and then cables under environmental only to discuss what is being done 24 there. It is our intent to present the BOP ESFAS environment 25 then seismic, as the example, and we will go through those in GRUMLEY REPORTERS Phoenix, Arizona
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detail. We were not intending to spend a detailed discussion of the other items, but they are in your handout. So if it is permissible, John, what we would suggest is that we go through the environmental qualification checklist, we entertain questions on it, we go through the balance of plant ESFAS seismic checklist and entertain questions on that, and then if the board would care to review other of the checklist we would be pleased to put them on and go through those in detail.=
10 MR. ALLEN: Fine.
MR. BINGHAM: I will ask Bob Carson if he would start 12 with the balance of plant ESFAS environmental checkoff sheet 13 MR. CARSON: This is Exhibit VI-1 covering the 14 Engineered Safety Features Actuation System supplied by Genera Atomic Corporation. As was indicated yesterday by Mr.Bingham 16 the life of this program, the life of this design phase on 17 the plant, has been going on for several years and, as 18 indicated, much o f the balance of plant equipment was purchas 19 in the time period 1975, '76, '77, '78. This particular item 20 of equipment, the purchase order was issued in 1976, the 21 testing program was conducted in late 1978, so we are working 22 here with interpretations by Bechtel, the engineers, by the 23 vendors in that time frame. They were working to IEEE 323-24 1974 and the interpretations that were in place at that time 25 as understood by the vendors and by us in the program.
GRUMLEY REPORTERS Phoenix, Arizona
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This particular equipment is located in the control building at elevation 140, which is the control room elevatio It is Environmental Designator No. IV, which would be Table 5 in your handout which we had pictured yesterday afternoon.
The applicable design basis accidents for which this equipmen must function would be the LOCA or the main steam line break and, as was indicated on the environmental sheet, th'ere is very little change in the environment in the control 'room'nder either of those design basis 'events. The equipment is 10 'o operate during the first 30 minutes of the design basis event and it 'must'perate continuously during that time perio 12 The function of the equipment is to provide actuation and 13 sequencing for the emergency. safety features indicated> and 14 control when these equipments operate to mitigate the conse-15 quences of the specific accidents. The environment is 16 I
indicated in the designator sheet, so that indicated environ-17 ment would be attached to the information. That would be 18 the information as indicated in Table 5 for the control 19 building and this would be the control room. The temperature 20 is very well controlled, atmospheric pressure, relative 21 humidity in the order of 20 to 90% in this particular area--
22 I'm sorry, attention is called that this is the control room 23 area. Humidity is 30 to 50%, very, very well controlled.
24 Radiation, no difference between the normal environmental 25 conditions and the accident environmental conditions, because this is a v ry highly controlled area with special air GRUMLEY REPORTERS Phoenix, Arizona
4 S 0'
conditioning equipment. No chemical environment at all.
Exhibit VX-2. Xn this particular section, we are comp'aring the designated service conditions and does the 4 suppliers qualifed'service meet or exceed the FSAR require-5 ments. The radiation effects were not considered due to the 6 fact that they were indicated as being very low at that time.
7 We are now rereviewing>>j- of this equipment on the basis of 8 the indicated radiation of 10 to the third rads, but we do not expect to find that there is any problem with any items 10 in this equipment. Marg$.ns were not specifically indicated 4
in terms of radiation,and all the other effects of margins ar 12 as is indicated in Exhibit VI-7, which is the end sheet of 13 this particular checklist. As,you will notice l here, this 14 is the environmental conditions as, qualified by the supplier.
15 This particular equipment was tested- in the temperature range 16 40 to 104 degrees, atmospheric pressure, note the humidity 17 20 to 95%, no radiation was considered, no chemicals were 18 considered during these tests. The design basis accident 19 as indicated at the time of the purchase order was this set 20 of parameters here (indicating). On this 'part of the sheet 21 (indicating), these are qualification margins, and now we 22 are looking at qualification margins as applied to the 23 environmental designator parameters, and you will notice here 24 we are saying that the margin in temperature was 30 degrees on the low end and 24 degrees on the high end because Table V GRUMLEY REPORTERS Phoenix, Arizona
4 292 indicates that the maintained temperature in the control room 2 is 75 plus or minus 5 degrees. Pressure was not applicable.
Relative humidity is 30 to 50%, they tested 20 to 95%, so 4 there is wide margin on the humidity factor. No radiation 5 and no chemicals. This particular equipment is made up of 6 typical modules as manufactured by the vendor, General Atomic and after ambient temperature verification was made of the C
successful performance, all of this equipment was burned in for 160 hours0.00185 days <br />0.0444 hours <br />2.645503e-4 weeks <br />6.088e-5 months <br /> at a temperature of 120 degrees. After the 10 burn in, there was a,verification made of, the successful operation, of operational logic, and that was done at ambient I
12 temperature and also at a high temperature of 124 degrees 13 with standing water in the bottom of the cabinets to simulate 14, a high humidity condition. Xt was also tested at a low 15 temperature of 40 degrees plus or minus 5 degrees F with a 16 relative humidity of 20%. All of these informations are 17 contained in the test reports. This equipment is arranged for horizontal mounting, floor mounting, and it will be welded to ig embedded channels in the floor. The test situation was that 20 it was tested while horizontal. The qualification method was 21 in accordance with 323-74 by type testing.
22 On Exhibit VI-,4, the tests were not specifically 23 conducted in accordance with the indicated sequence of 323 24 and the differences were that the temperature margins were not applied in Steps 6 and 7; that is, there were no GRUMLEY REPORTERS Phoenix, Arizona
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temperature margins applied in the DBA and the post-DBA operational point. As you will notice in Paragraph D.4) of thi's exhibit, to conduct a heat aging, there was no specific Arrhenius plot determined for this equipment, because it is not a single component. It is not a single material equipmen It is made up of a variety of items of various materials and it was tested and aged on the basis of temperature cycling, since this is in the area of very well controlled atmosphere, 75 plus or minus 5 degrees maintained by safety-related air 10 conditioning equipment, redundant equipment, so those limits will not be deviated from. The assumption was made that ther 12 would be two air conditioning failures. Even though we have 13 redundant equipment, the assumption was made that there would 14 be two complete failures of the air conditioning system per 15 'year during the design life of the plant, 40 years, and then 16 there was a 40% margin attached to that paxticular assumption, 17 so we were looking, at possible failures of air conditioning 18 of 124 times in the life of the plant. That was then simu-19 lated by this single covering two-hour period, at which time 20 the equipment was operated at 40 degrees F, assumed air 21 conditioning failure in which the temperature rose over a 22 five-minute period to 120 degrees F for 20 minutes and then 23 back down over a 90-minute period to a 40-degree F level.
24 That cycle was repeated 124 times and this was considered in 25 this program to be equivalent to aging of 40 years for this GRUMLEY REPORTERS Phoenix, Arizona
( 4 I type of equipment.
In the period of this testing covering 248 hours0.00287 days <br />0.0689 hours <br />4.100529e-4 weeks <br />9.4364e-5 months <br />, every 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> equipment was operated in the auto test mode.
After the aging conducted here, the equipment was operated in the normal environment at high temperature again and the equipment was then operated on a whole system basis, the
- entire system comprising the BOP. The ESFAS cabinet was hooked up and was operated in the auto test mode for some 120 hours0.00139 days <br />0.0333 hours <br />1.984127e-4 weeks <br />4.566e-5 months <br />, which would be under full power and logic operatio 10 sequential operations, in the equipment. This equipment was also seismically tested, and that will be explained by 12 Mr. Schechter.
13 Exhibit VI-5 indicates that there was no specific 14 humidity aging done, but the effects of humidity were taken 15 into account at the various temperatures over the range of 16 20 to 95% ~hereas the indicated humidity in this area is 17 maintained in the order of 30 to 50%. Dry heat was applied 18 for the cyclic operation, which'simulated aging. The 19 performance characteristics that were required was that the 20 'logic operations were to be proper under any conditions to 21 which the equipment was subjected, and the performance 22 characteristics monitored were the operation of the logic and 23 all the operations weie successful.
24 The performance characteristics were monitored continuously. They were also monitored during the seismic GRUMLEY REPORTERS Phoenix, Arizona
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testing. The test report indicates that the test instruments were in current calibration, and that would be indicated in the test reports from the laboratory, the 'numbers of which appeared on an earlier exhibit.
Exhibit VI-6; interfaces. The interfaces of this equipment include cables attached to the equipment and enter-ing through the proper places. This equipment is fed from below through openings in the floor and there were simulatS.on of cable going into the equipment durS.ng the testing procedur The judgments made on the testing program, the cyclic operation simulating aging, the successful burn-in, the 12 testing cycle for more than 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br />, the 'judgment is that 13 this equipment is qualified for 40 years, and the test report are indicated here. There are no specific indicated replace-15 ment parts needed to be put into thS.s equipment on a periodic 16 basis.
17 This then is the checklist for the independent 18 review of the program.. As T indicated earlier, this program 19 was conducted in the time period 1976 through '78. This 20 equipment has been delivered to the field and is currently 21 installed.
22 MR. BINGHAM: guestions2 23 MR. ALLEN: I have one to start off with, I guess. I 24 thought you had S.ndicated a while ago that this checklist 25 had this life limiting component'.information on it plus speci GRUMLEY REPORTERS Phoenix, Arizona
296 requirements such as sweeping out cabinets every so often.
I didn't see that on here.
MR. CARSON: That would be here under the evaluation.
Qualified life time is 40 years. If the qualified life time had been less than 40 years, which would indicate some life limiting components, that, would have been specified here by specifying the time and the replacement schedule and the replaceable items, and that information would appear here.
MR. HOEFERT: I can see where that would apply to a 10 it life limiting component, but doesn't really seem to cover periodic maintenance, operational checks that may have to be 12 done.
13 MR. CARSON: This particular equipment is self-testing 14 Self-testing features are built in, so there are no specific 15 tests that you have to go through. Operational main'tenance, if by that you mean every so often you are supposed to go in 17 and dust it off or polish the glass, that sort of thing is 18 included in the vendor's instruction manuals that come with 19 the equipment and are provided to APS and would be maintained 20 in their maintenance file. These indications here are only 21 replacement items which are necessary to maintain the 22 qualification of the equipment.
23 MR. HOEFERT: Certain vendors have identified certain 24 of these preventive maintenance tasks in their qua lification 25 reports and those are the ones I am talking about.
GRUMLEY REPORTERS Phoenix, Arizona
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MR. CARSON: There are certain reports in which state-ments are made like the q'ualified life is contingent upon application of periodic maintenance indicated in the instruc-4 tion manual number so-and-so, and if that is the condition 5 under which the vendor says that it must be operated, we ask 6 specific questions about that and ask them if that is in fact 7 correct, and if they insist that these maintenance procedure 8 must be indicated, we will so indicate that and again point you to their instruction manual where they say you have to 10 check the gasket material every,timeyou open the bearing housing or you must replace the gasket every time you open 12 the bearing housing, something of that sort.
13 MR. HOEFERT: Are you requiring the vendors to identif 14 the difference between preventive maintenance which is 15 required to maintain the equipment qualified and preventive maintenance which is not for that purposely 17 MR. CARSON: Yes, because we require and are requiring on a basis -- We are investigating this with all of our
]g vendors. At present, we are requiring them to identify any 20 item, any component, any material item that is subjected to age deterioration and we are requiring them to tell us what 22 the lives of those materials or components are and tell us I
23 the replacement schedule that is necessary to maintain the life. We are saying the qualified life of the 'ualified 25 equipment is 40 years based on the fact that every four years, GRUMLEY REPORTERS Phoenix, Arizona
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you replace this, and we are asking them to define what those items are that need to be replaced and the will be replacement'chedule.
That information supplied to APS for inclusion in their operating procedures.
MR. HOEFERT: Again, you went back to replacement, and those I can see would be included on your checklist. Shat about tasks which are not replacement tasks'P Are those going to be included under Section A7 MR. CARSON'. Not specifically, because those are not 10 items that have specifically to do with the qualification and maintenance of the qualification of the equipment. If he is 12 saying, as I indicated before, every so often you have to 13 polish the glass on the meters or sweep the dust out of the 14 bottom of the cabinet, that is a routine preventive mainten-1 15 ance type of thing which would. be included in the instruction 16 manuals that the vendor provides to you.
17 MR. HOEPERT: I )ust have a concern that it is going 18 to be very hard to differentiate those tasks which are 19 required to maintain it qualified and those which are not, 20 because I have seen some reports where the vendor has put 21 down that a certain maintenance: task had to be performed to 22 maintain it qualified. II 23 MR. BINGKAM: How should we handle this particular 24 issue, John?
25 MR. ALLEN: John wants to clarify something.
GRUMLEY REPORTERS Phoenix, Arizona
1 I 299 MR. BARROW: Specifically, the one that Norm is talkin about I believe is one that we saw -- I can't remember if it was load centers or switch gear where we saw a requirement the vendor was going to push on us to vacuum the transformer windings every three months or six months, or something like
.that, vacuum all the dust off the transformer windings in order to maintain qualification. As I recall, back then our response was that that seemed hardly necessary, that the equipment should be designed so that it could sit in the 10 ambient conditions that we specified it to be in without having to have that kind of detailed maintenance to keep it 12 qualified. But if, like Bob said, you had a requirement that 13 you would go back to the vendor and negotiate with him, if 14 he turns out to be very adamant about that, you don't seem to 15 have a place on your form to indicate such requirement. All 16 you have a place for is indicated life limiting components, 17 but not specific actions that are required to keep qualifica-18 tion over and above normal periodic maintenance. They don' 19 discuss normal periodic maintenance in their qualification 20 report, )ust maintenance required for qualification. I think 21 that is what he is getting at.
22 MR. HOEFERT: That is exactly what I am getting at.
23 MR. BINGHAM: I understand the point. What I had 24 asked the Chairman was how we should proceed with the issue.
25 MR. ALLEN: Well, I thought you said a while ago that GRUMLEY REPORTERS Phoenix, Arizona
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300 you intended to use that spot there for that purpose.
MR. BINGHAM: If it is required to maintain the qualified life, it will be on that sheet. What: I hear 4 suggested is there may be some gray areas that we need to 5 pay attention to and shouldn't they also be included on the 6 sheet., I suspect that either we take the course of eliminati 7 the gray..areas or determine that we should include some 8 information. on this particular sheet so that it has special instructions, and that gets into the maintenance procedure.
10 ,~. MR. ALLEN: It sounds to me like you need to do both, 11 eliminate tiie gray areas and then ensure that type of informa-12 tion will be identified on that sheet somewhere.
13 MR. BINGHAM: Fine.
14 MR. ALLEN: Further questions? George.
15 MR. SLITER: On Exhibit VI-4 on Item 4, you have a
- 16. box called Arrhenius Methods to check whether heat aging 17 was conducted. Does a check in this box imply that the way 18 that the Arrhenius me'shod was applied was reviewed and'hat,
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19 is acceptable:and do you have some 'method on your form for 20 explaining yes, Arrhenius was used, but there may be some 21 issues in the way it was appliedf 22 MR. CARSON: This specific-indication is to indicate 23 whether or not the vendor used an Arrhenius method for aging, 24 and if he used the Arrhenius method, we would require and he would have to give us in the tes t reports the basis for GRUMLEY REPORTERS Phoenix, Arizona
'I determining the Arrhenius'urve and show us how he used it.
If there were any questions about his application of the Arrhenius method or his determination of the Arrhenius method those questions would be asked and cleared up prior to the acceptance of the report so there would not be any question on this when it finally got resolved. He would use the Arrhenius method and, if used, i.t would have been previously determined tha t the application o f tha t method was reasonable MR. SLITER: Are there any final checklists near the 10 end of that cycle?
MR. CARSON: Yes.
12 MR. BINGHAM: Let me make a clarification. We are 13 working with this form to make sure that it is a good check-14 of f list, and looking at Section 4, we believe we, should;.have 15 a box that says is the method acceptable, and we will add tha MR. SLITER: Are there any organic materials in this 16 17 piece of equipment?
18 MR. CARSON: There
/I are organic materials, yes, because 19 this is made up of standard modules, as I indicated, that 20 are built by General Atomic. Those modules have relays in 21 them. They have various other equipment. They have circuit 22 boards. They have other types of equipment that do include 23 organics. It was this particular thing that really prevented 24 the use of an Arrhenius method because of the fact that they 25 have numerous types of material in there..and it would be GRUMLEY REPORTERS Phoenix, Arizona
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302 essentially impossible to put together an Arrhenius method for this equipment. That is why the aging cycling was chosen as being a reasonable method at tha't time to indicate the effects of aging in the assumed worst. condition that would apply in this area; that is, the complete failure of the redundant Category I air conditioning systems.
MR. SLITER: I have two questions about the temperatur cycling. Is it true that this was not meant to be any kind of an accelerated testing completed, this cyclic type I.
10 approach?
MR. CARSON: Well, by the cyclic type of testing, that 12
/
simulated an accelerated aging. The fact that it was 13 operated and burned in early. would be, really the same sort 14 of thing that you would do if you were. using techniques from 15 IEEE 650. You are burning in for infant. mortality type of failures. It was then cyclically operated under the extreme 17 temperatures that we felt might accrue in that area. The 18 whole equipment was then operated, as I indicated, for some 19 160:: hours after these cyclic operations to again look for 20 any failures of materials or components or individual items 21 within the equipment. So the whole sequence of events was 22 looked at as an accelerated aging method.
23 MR. SLITER: Is the duration of these cycles, 24 approximately two hours, is that assumed to be the approximat 25 time that if an air conditioning failure took place, that GRUMLEY REPORTERS Phoenix, Arizona
303 would be the cycle?
MR. CARSON: Yes. It was anticipated that any air coaditioaiag failure would be corrected and the temperature would be gotten down to the original level within a two-hour period.
MR. SLITER: In its normal operating mode, would this equipment be continuously activated such that there may be self-heating effects?
MR. CARSON: This equipment is continually energized 10 and it is also in continuous test mode, self-test mode, so there is some internal heating, but with the types of-12 components in here a'nd the mode of operation, internal heat 13 generation is extremely low. The iaternal heat rise i,s in the order o'f 3'*to 5 degrees over the ambient.
15 MR. SLITER: So thea in 1978, you did accept this as an acceptable method.
MR. CARSON: As I indicated, under the interpretation 18 of 323-74 that were prevalent in the industry at that time, 19 this was considered to be a reasonable method for this type 20 of equipment in this very highly controlled atmosphere..
21 MR. SLITER: Would your )udgment change now in 1980?
22 MR. CARSON: In 1980, for thi,s type of equipmeat, we 23 would be looking at methods incorporating the IEEE 650 24 approach in which the items of equipment in the cabinets 25 would be analyzed, significaat aging if exhibited on the components would be identified, and the whole analytical GRUMLEY REPORTERS Phoenix, Arizona
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and type testing sequences shown in the table in IEEE 650, we would look at that and also recognize the fact that certai components are indicated as being not significantly age sensitive during a 40-year period.
MR. BINGHAM; I would like to make one clarification on. the environment to make sure that you do understand that we are assuming not single failure, but double failure of safety equipment and have put that equipment through that sort of an environment.
10 MR. SLITER: I was wondering whether we were in a position yet as far as your knowledge of aging technology is 12 concerned to now go back and take this cyclically-applied 13 environment and make some estimate as to, for example, if we 14 had instead of a 1.4 margin, only a margin of, say, 1 in 15 terms of cycling,'ut then take the additional margin and get 16 an equivalent accelerated aged life or some such thing. Do 17 you think this would be possible at this time or do you think 18 it is still beyond the technology2 19 MR. CARSON: I really don't understand what you are 20 saying.
21 MR. SLITER: If you cycle the temperature to this 22 extent, suppose we now assume that there are no failures of 23 redundant air conditioning, you now have this cyclic tempera-ture profile applied, you could interpret that cyclically applied profile as an accelerated Arrhenius type approach GRUMLEY REPORTERS Phoenix, Arizona
r 1 and use the Arrhenius theory to back out what an equivalent life would be in terms of, say, its baseline temperature, 75 degrees plus 5 degrees Fahrenheit margin.
MR. CARSON: This could be done. This could be done on the basis that you would investigate the equipment and the materials within this total equipment and determine what is the life-limiting material, and that material could then be looked at on an Arrhenius plot or that material could be
- studied and the excursions of temperature and time could 10 be applied to that to say that for this material, since this is the worst one in there, and the temperature equivalent is 12 so many years and we did it 124 times, that is the equivalent 13 of so many years. Such an analysis or reanalysis of this 14 equipment has not been contemplated.
15 MR. BINGHAM: Other questions, John7 MR. BARRotI: A coupl'e of little questions on the form.
17 On Exhibit VI-4 under Item C, the yes/no box under the test sequence being equal to a more severe or not, it's got to be 18 19 one or the other. 't either is equal to or more severe or 20 it wasn', so is the form incomplete without that marking on 21 it7 Is that )ust an oversight is the question.
22 MR. CARSON: In this context, yes. We would indicate 23 that this was equal to or more severe in our estimation than 24 the required sequence.
25 MR. BARROW: The other question was there doesn' GRUMLEY REPORTERS Phoenix, Arizona
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306 seem to be any date on this form. If this is a Xerox of an actual form used for qualification review, I take it it is not necessarily complete at this time, since it is not dated.
MR. BINGHAM: John, as we discussed the other day, we are coming to grips with putting the whole package together with a coversheet and- a check-of f that all the elements are there and all the: signatures and that sort of thing. What we are putting up here is something to depict the elements so that the board can understand what's going on. We are not 10 presenting today the complete QA documentation package which will have to have all the good stuff on it.
12 MR". ALLEN: But it wi11 be dated.
13 MR. BINGHAM: Oh, yes. Everything will be dated.
14 MR. ALLEN: Additional questionsV Ed Sterling.
15 MR. STERLING: On VI-4 again, on Item 4,'he other box 16 has an explain and justify in the title there and yet as I 17 read what is underneath that box, it is )ust an explanation.
18 There is no justification. Do you intend on your final 19 documentation to be justifying considering the fact that ther 20 are some methods that may be used in good use and some that 21 are not) 22 MR. CARSON: Could you rephrase that question, pleasef 23 MR. STERLING: Yes. The justified portion of that box 24 has not been written down. You have an explanation of what you have done, but you haven't justified it, GAUMLEY REPORTEAS Phoenix, Arizona
I 307 MR. CARSON: The parentheses at the bottom provide the factor of 1.4 margin for projected air conditioning failures.
HR. STERLING: That is just an explanation.
MR. CARSON: That is an explanation, but for this particula'r equipment, we look at that as the justification for using such a cycle on the basis that this is, 'is Bill pointed out, in an area that is served by redundant safety-related aii, conditioning systems and, therefore, what we are looking at is not a single failure'f the system, we are looking at the failure of two independent systems, and we axe saying that that just can't happen and, therefore, we are usi 12 that as a justification for using this method.
13 MR. STERLING: You have explained your margin, but this Item 4 is aging. It should have a justification as to 15 the technique of aging you are using. If you are not using the Arrhenius method and you are going to modify that, but 17 you are using another method, you should justify the use of 18 that method. So whatever method you pick, whether it is a 19 straight-line method or whatever, you should justify the use 20 of that method on those materials that you intend to age.
21 MR. BINGHAM: I think, John, that the point that you 22 are getting to is the degree of completeness of, the justifica 23 tion, and I suspect that'as we go through and re-review all 24 of this information with APS that the final product will have 25 the required justification and explanation in it. I think GRUMLEY REPORTERS Phoenix, Arizona
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308 that our intent is to cover that.
MR. STERLING: Let me just elaborate on what I am saying. It is up to the licensee to assure himself that what is being done is adequate. A lot of these reports that the vendors put out are rather complicated, and to adequately show to myself if I were reviewing whatever I put down, by explaining a justification in my own words like they are doing there, I have assured myself that I understand what they are doing and that it is satisfactory to my way of think 10 ing.
I had one other point. Since this was done before, 12 on Exhibit UI-1, you have your time requirement at zero minus 13 30.
14 MR. CARSON: No, that is zero to 30.
15 MR. STERLING: Zero 'to 30, I'm sorry. In the next 16 exhibit, you said that your radiation'was under review. Your 17 time required is also under review I take it now as far as 18 margins. You have to add that hour margin in there.
19 MR. CARSON: This is'ne of the problems that we had i
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20 with that specific requirement in 0588 where they mentioned 21 equipment to be operational for an hour, and that requirement 22 is specific for equipment inside the containment first of all 23 in 0588. One of our questions is how far into the DBA do we 24 look. It says seconds or minutes, and how many minutes is 25 minutes. Is that 1, 5, 10, or 250? Then do you add an hour GRUMLEY REPORTERS Phoenix, Arizona
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on top of that? So we do have some problem with that particular requirement.
r MR. STERLING: Is that the case? Is that. one hour only for inside the containment? Does somebody know?
MR. CARSON: Do we have a copy of 0588? I'm sorry, that is under the section called margins in Category I of 0588 on Page 15, and it says some
'k equipment may be required by the design to only perform its safety function within a short time period into the event, 'that is, within seconds or t,
10 minutes, and once its function is complete, subsequent failures are shown not to be detrimental to plant safety.
12 It says equipment in these categories is required to remain 13 functional in the accident environment for a period of at 14 least one hour in excess of the time assumed in the 15 accident analysis. So it is not applicable only to the in-containment equipment. This 'sequencer and safety actuatio 17 system actually operates and performs its required function 18 in the range of 30 to 50, seconds because it sequences the 19 equipments that are added to th'e diesel to perform whatever 20 functions are necessary to mitigate the consequences of the 21 accident. So a 30>minute period in terms of margin as 22 applied in 323-74 where they ask for 10% on time margin is 23 several hundred percent, but in terms of 0588, if you add an 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to that period, you would be talking of 60 minutes plus 30 or 40 seconds. We would see no problem in having this GRUMLEY REPORTERS Phoenix, Arizona
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10 equipment operate under those conditions, since it is in continuous operation through the life of the plant.
MR. STERLING: Do you intend to upgrade that block to show an hour and 50 seconds?
MR. CARSON: We would not anticipate that we would go back and make additional tes ting, but we will ) us tify the fact that it could operate for an additional period of one hour, since, as I mentioned,. i,t operates continuously in any case and is in this highly controlled area where none of the 10 effects of the accident really come into play with this particular equipment.
12 MR. BARROW It looks. like John Allen is going to 13 make me ask the question. I will just make a statement.. A lot of argument has been made about this where we have had 15 discussions about this one hour thing and there is a lot of 16 leeway. You could argue it never would have to operate after 17 the first five seconds or 20 seconds or whatever, but this 18 one is kind of unique in that if you had a LOCA and you were 19 operating sequenced aTid a half-hour later or an hour later, 20 if you got a loss of power, the sequencer would have to 21 operate 'again.
22 MR. CARSON: That's correct.
23 MR. BARROW: So this may be one of the cases where 24 that could conceivably be important.
25 MR. CARSON: In that regard, for the hour's operation, GRUMLEY REPORTERS Phoenix, Arizona
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we would also point out that in 0588, the principal discussion there is in regard to equipment in harsh environ-4 ments to make sure that that equipment could oaera<e in 4 the DBA environment, and there is no ha'rsh environment here.
The equipment operates energized continuously. It has been 6 shown in the testing in the qualification that it will operat 7 numerous times during the period, and we therefore feel that there is no specific requirement to again show that't might operate at times zero and then again at time 30 minutes and 10 again at time 60 minutes.
MR. BINGHAM: I think, John, getting back to the basic 12 question at hand, that we said yesterday we would be 13 re-reviewing the documentation, and in this particular case, 14 it may be of advantage to clarify the form to indicate that 15 that issue had been dealt with and was deemed acceptable and 16 appropriate for this piece of equipment, since it is..not in 17 a harsh environment, or any other piece of equipment that we
,18 are looking at. I think our statement yesterday was that we 19 were not aware of equipment we were responsible for that was 20 in a harsh environment that we would have difficulty with 21 the one-hour requirement, but that we would have that under 22 review.
23 MR. ALLEN: Any further questions2 MR. NOONAN: Just orie: small one. Earlier, you used 25 the term "burn in" test. Do you require all your suppliers GRUMLEY REPORTERS Phoenix, Ar)zona
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to do a burn in on your equipment?
For equipment which contains this type
'R.
CARSON:
of components, electronic type components, the vendors will normally do a burn in test and we would look at their procedures and their test programs to see that they have in fact operated the equipment for some long period of time prio to the point, where they would do their baseline testing. Me don't specifically require them in our specifications to do that.
10 1lR. BINGHAM: Just a minute. In some specifications, we do require that. On some specifications, we do, and, John 12 without looking at the details, I don't think we have the 13 people here that could tell us whether this particular one h
14 required burn in. Generally, that is important to us.
15 MR. ALLEN: In any case, you get burn in by default
)ust by acceptance testing.
17 MR. BINGHAM: Yes.
18 MR. CARSON: But it would certainly be looked at in 19 the procedures.
20 MR. NOONAN: I guess the point I was trying to make 21 was that you do your burn in tests, and particularly if you 22 do a thermal cycle burn in test, it is a good method to find 23 manufacturing defects.
MR. BINGHAM: Yes.
25 MR. NOONAN: It increases, reliability of the equipment GRUMLEY REPORTERS Phoenix, Arizona
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313 in the field.
MR. ALLEN: Vince, would you like that to be an open item to determine our policy on burn ins?
I think I would, like for it to be I
MR. NOONAN: Yes, an open item. In fact, I encourage it to be an open item.
MR. ALLEN: Okay, we'l get that down as an open item then.
John Barrow.
MR. BARROW: I can clarify it a little bit. On our 10 specifications when vendors are using IEEE 650 to qualify the equipment and 650 calls for burn in" like battery chargers, 12 generator inverters', and radiation monitors, we have had burn in done in those qualifications.
14 MR. CARSON: But, again, that is coming from the 15 suggested procedure for the qualification, that burn in.
MR. ALLEN: Additional questions?
17 DR. ROSZTOCZY: The piece of equipment that you 18'9 describe here is not a system in itself and, therefore, it.
doesn't have a complete function. It was only a component of 20 a system. In order to accomplish the function, there are 21 other portions of the same system that must function. Other-22 wise, you can't perform. The other parts include sensors, 23 cables, actuators, and so on. There has been 25'mplifiers, 24 nothing on this sheet which would indicate what other pieces have to perform their function and nothing that would pull GRUMLEY REPORTERS Phoenix, Arizona
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these pieces together and, indicate that the overa11 system is going to function. Is there a second level beyond these 3 sheets that you fillout for systems as opposed to components 4 and then is there a certification, some signatures on that 5 other sheet indicating that somebody reviewed this system and 6 checked that each component sheet has been filled out like 7 this one and that'-.the overall system is going to function.
MR. BINGHAM: No, there is not.
DR. ROSZTOCZY: How do you know then that the system 10 is going to function? Let me phrase the question to APS.
11 How will you know it, this )ust being an example? How will 12 you assure that this system is going to function' 13 MR. BINGHAM: I think the way that we would cover this 14 particular issue is through the way that we start the program 15 with a list that says these are all the items that have to be 16 qualified, and then in our specifications we assure that all 17 the inputs are handled and are tested. Me talked yesterday 18 about any abnormalities that are noted in the tests would be 1g put back into the analysis of the particular component and 20 . individuals would be. notified to assure that those issues were handled. Therefore, we have determined that the 22 interfaces are met. That means this component that we took 23 out of this system now does everything it is supposed to do 24 based upon "our overall analysis of what it was supposed to do in the complete system. So we believe that the way it has GRUMLEY REPORTERS Phoenix, Arizona
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1 been covered is that we started from the cradle to the grave, 2 so to speak, and we separated out pieces of equipment to test 3 because of certainly the impracticability of putting the 4 whole plant in a chamber of some kind and testing it, and we believe that is how we take care of this particular issue.
6 My response to you that there wasn't a final check-off sheet that says yes, indeed, we looked at this and again confirmed 8 that everything was in order was true. Qe do not have that 9 sheet. But we believe that we have safely covered the 10 application of qualifications.
DR. ROSZTOCZY: The approach as you are describing it appears "to me rather weak. The final requirement is that
$3 the licensee or applicant has to certify that all the systems, all this equipment, is going to perform the intended function and they have to certify this under oath. As you submitted it it to us, seems to me that there is no direct way to establish that conclusion. You are saying that you started a system or a program and you assumed that that system or yg program worked correctly, and even if you do it that way, 20 no clear boundary is drawn here. I don't know where does this system end and where does the next one start. There must be some connection to this, and it is not clear where the 23 boundaries are, either. So I think it would be extremely 24 important that at the end you pull all of this together and somebody takes a look at what has been done in terms of the GRUMLEY REPORTERS Phoenix, Arizona
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components, and when you add those together, does this establish the qualification of the entire system. Xn this case, I don't know how many components there are, but there could be easily a dozen or more components, and if something was left out, gust one piece was left out some~here, you wasted your time.
MR. BINGHAM: That's true. I don't'think we disagree with that and, Ed, I am sure you want to make a comment, but let me gust add a few thoughts. What we are assuming in our 10 presentation today is that the board understands all of the systems. I am sure that is not the way we should be going, 12 but the reviewer or responsible person that knows that system 13 knows the components, would have the list of the components 14 tha t have to be checked, would know the interface, and, by 15 review, could using their professional )udgment assure 16 themselves that all of the interfaces were properly addressed.
17 Now, I guess John or Ed could--
18 MR. VAN BRUNT: Let John comment first and then I woul 19 like to comment on it, too.
20 MR. ALLEN: A couple of things. The ultimate test of 21 the system, of course, is during preoperational testing where 22 you actually make sure that the motors::start, or whatever, 23 that the control room isolates. That gives you a total test 24 from cradle to grave, I might say, and whether the system is 25 going to work. The way we qualify it is with each individual GRUMLEY REPORTERS Phoenix, Arizona
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system, we qualify this system and then, for example, we'e 2 got a radiation monitoring system that feeds into this sy-.tern it is qualified, and then we'e got the actuation devices
,on the other end, for example, maybe some switch gear, and it is qualified all to each individual environmental qualific tion, because some of it might be in different -locations in the plant. So what I guess you are saying is who goes and looks at each one of these systems to make sure they qualify.
DR. ROSZTOCKY: Yes. I am not sure what is the case 10 here, but this might even be a good example that part of this might be coming from a different vendor. Is there any 12 Combustion scope in this system?
13 MR. ALLEN: Input.
14 MR.'CARSON: Just inputs, contact closures from remote 15 operators.
16 DR. ROSZTOCZY: How about the sensors? Containment 17 pressure has to be measured for this system.
18 MR. CARSON: That is a contact closure.
19 DR. ROSZTOCZY: Who is responsible for the instrument 20 that measures containment pressure2 21 MR. BINGHAM: That is balance of plant.
22 DR. ROSZTOCZY: The reactor coolant system pressure.
23 Here is a system which has components part of which is 24 balance of plant, part of which is in the CE scope, and there 25 isn't a sir@le person who has looked at the entire system and GRUMLEY REPORTERS Phoenix Arizona
r 4 said that those components, some of them coming from one 2 source, some coming from another source, some might even be 3 coming from a third source, that all of those added together 4 establish the qualification of the system. That thing that 5 someone mentioned doesn't do this job. You can do-all the 6 testing you wish and startup, that is not going to establish 7 qualification for an accident condition..
MR. ALLEN: No, it doesn't establish qualification.
DR. ROSZTOCZY: A large number of the. components in 10 this system are, in the harsh environment, one which was on ll the board is not in the harsh environment, but a large number 12 of components of this system are in the harsh environment 13 and they have.to be qualified for the harsh environment. I 14 think it would be important that at the end, somebody pulls 15 all. of this together and I think it would be wise if he would 16 have to put his signature that he has done this, looked at 17 all these pieces, is certain nothing was left out, and 18 establishes the qualification of the overall system, the
]9 overall function.
20 MR. VAN BRUNT: I understand what you are saying, 21 Doctor, because from my perspective, the whole is the sum of the parts. Qe can start with the whole system with an overall 23 requirement for the system and then we specify all the parts 24 and we are going to verify that all the parts are right and they go in to make up the whole. That would include CE stuff GRUMLEY REPORTERS Phoenix, Arizona
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as well. So I have a little bit of difficulty in understandi g if I go in and specify a whole system and specify all the 3 environmental requirements and that adequately gets put into 4 the equipment and the equipment is adequately tested and 5 demonstrated, each of the individual components, why it is then necessary as long as we'e got all the components in to just all those up and be sure that we did the I'o back and add 8 all, because if we did our job right going in, we should have 9 them. However, I will commit that we will go back and take 10 a look at this and verify whether we believe there are any ll loopholes in the program we have which would permit something 12 to slip by.
13 MR. ALLEN: Did you get that, Terry?
14 MR. QUAN: Yes.
15 DR. ROSZTOCZY: Now let me see Exhibit VI-1. Under 16 Design Basis Accident, this indicates loss of coolant 17 accident and main steam line break. What is the significance 18 of that? Is it an indication that this equipment has to 19 function only after those two incidents and there are no 20 other cases when this system has to function?
21 MR. CARSON:, That's right. First of all, let me 22 clarify. In this system, the component is called the BOP 23 @spy,S ~<~eered Safety Features Actuation System. This 24 particular item purchased under this purchase order JM-104 is not the entire Safety Features Actuation System. It is GRUMLEY REPORTERS Phoenix, Arizona
only that portion of it which is located in the control room which receives input from outlying s ensors and sends actuation signals to outlying equipment. It is, primarily a relay cabinet. That is the component, the black box, that we are looking at here, and that relay system is a grouping 6 of relays which takes a contact closure from a loss of voltag indication or from a high pressure or reactor coolant system 8 malfunction, takes that relay closure and converts it into 9 some intelligence and sends it to a motor and tells it to 10 operate. That has to operate when either of these accidents occurs and that is its only function. It does not normally 12 do a'nyth'ing during normal operation of the plant except be 13 ready to perform its function in an accident.
MR. ALLEN: Bob, there is an additional design basis 15 accident, so I think that is what Zoltan is getting at, from 16 the loss of power.
17 MR. BINGHAM: It has come to our attention that this 18 form as it was filled out may be misleading, particularly 19 with the discussion that we have had, and probably for this 20 particular piece of equipment, since there is"no harsh 21 environment, there probably should have been an N/A in this 22 column and this particular column should reflect the condition 23 for which it has to operate. In this particular case, it 24 doesn't see any harsh environment. Dennis, what might be put in that column?
GRUMLEY REPORTERS Phoenix, Arizona
MR. KEITH: I think on that one, you would put an N/A also for equipment that is in a nonharsh environment, because that is for a qualification concern.
MR. BINGHAM: Ve will be reviewing that, John, and this can continue as an open item to make sure that with our re-review, we do pick up all these issues.
DR. ROSZTOCZY: I think there are two obvious problems one of them that was mentioned here that the identification o the component is incorrect on this sheet because it doesn' 10 clearly and uniquely identify the component that we are talki of. Instead, it has the name.
12 MR.'INGHAM: Mell, this does right here (indicating},
you see. The tag number identifies the piece of equipment.
14 I realize for the board that it is difficult for you to 15 understand what J-SAB-C02B is', but. to somebody that means 16 something.
17 DR. ROSZTOCZY: Let me make a suggestion then. I thin 18 it probably would be helpful for your work to specify the component by its name, whatever name you give to it. For:
example, if this is one ESFAS actuation relay or something, 21 then write that in. It would be beneficial to your work to 22 also identify the system. By doing so, it would be easy to 23 pull together all of those components that form one system, 24 and then whoever is doing the overall review could check if 25 everything has been properly qualified. So probably it would GRUMLEY REPORTERS Phoenix, Arizona
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22 1 be appropriate to have both a system identification and a 2 component item identification on this sheet..
3 Going back to the design basis accident, one would 4 expect there to see every accident for which it has to function and would possibly establish some conditions for I
this, and I would expect to see exactly the same for every 7 component of this system there, because the system has a 8 function and, in order to perform the function, all component 9 have to work, so each of them should have the same there.
lp When I go to the next component of this system, which happens to be in the harsh environment, those components become very 12 important, and by omitting something from there like loss of l3 powB *0 steam genex'Btox'ube rupture could result in inappro-priate qualification of some of the components.
l5 MR. BINGHAM: I think what we need is to have some explanation of the shorthand that we use, because we are l7 very diligent in following systems throughout all of the l8 operations in design of the plant through these type numbers, lg what safety train, what channel, what system they are in, 20 and they are followed all the way through all of the plant.
I think we understand your concern and perhaps when one is aware of the nomenclature, they then can take this particular, 23 tag number or identifier and can relate easily to the piece of 24 equipment.
25 DR. ROSZTOCZY: Is there any code number or letter in GRUMLEY REPORTERS Phoenix, Arizona
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1 the number which would uniquely tie this component to a given 2 systems (Thereupon a brief off-the-record discussion ensued, after which proceedings were resumed as follows: )
MR. ALLEN: Okay, Bill.
MR. BINGHAM: I think the way we would like to leave 7 this with the board is that we will review the concerns that 8 Dr. Rosztoczy has brought up, and I would just like to 9 indicate that my previous statement that we are very diligent 10 in being able to understand where this equipment is throughou ll all of the plant by the designator does hold and there are 12 means to take that number and find out where that system is.
13 So let's leave it at that point.
14 MR. VAN BRUNT: Just as a follow-up on that, I wanted 15 to indicate to Dr.Rosztoczy that, speaking for the applicant, 16 we are very concerned about the same thing you are. Me want 17 to be able to track back to ground zero, if you like, and I 18 would second what Bill said, that we have worked very hard 19 since the beginning of this job to "assure that when given any 20 particular component or any tag number that we can go back through. I think if you were a little more familiar with the 22 systems that we use that you probably could go from those 23 numbers right back through. I don't use them every day. I can't either. But I know that the fellows that work with the stuff every day can track it right back to the system and GRUMLEY REPORTERS Phoenix. Arizona
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everything else. I think what you are looking for is there, but we will ensure ourselves that it is. =
DR. ROSKTOCZY: If I look at the other column, the 4 time column what has been discussed earlier, then the answer is that this certain component is in the control room and that*'art, is not important or not applicable, but you do have 7 another piece, for example, the pressure sensors in the 8 containment, in your scope for which you have already filled 9 out a sheet like this or are in the process o f filling out a 10 sheet like this. It is likely that your e'ngineer has the ll same number that that column has, which is 30 minutes. That 12 will result in inappropriate testing and it certainly would 13 be unacceptable, so maybe you should go back and see for thos 14 parts of the equipment which are exposed to the harsh environ 15 ment what time periods did you 'use and let's discuss the 16 time a little bit more. The extra hour has been discussed, 17 the one-hour environment. There have been also statements 18 made that it performs its function in a very short time like j9 30 seconds or so. That is not so. This equipment will have 20 to perform a function and you don't know when that function 21 will come after the beginning of the accident. For example, 22 if you look at the spectrum of small breaks, then you will find that, depending on the break size, actuation might 24 happen shortly after the accident or it might happen quite a bit later. There are even break sizes in the small break GRUMLEY REPORTERS Phoenix. Arizona
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325 spectrum which won't even depressurize to this leve1 where 2 this would be actuated. They are, however, actuated on high containment pressure, but with a small break, it could take very long to reach that value. So I don't know where the 30 minutes came from. It certainly is not the time that should be on the appropriate sheets for that part of the system that is exposed to harsh environment. That should be looked at very carefully. There are all spectrums of breaks and they don't proceed with the same speed.
10 The other point I think has been very we11 stated, that even after it performs its. LOCA-related first function, 12 this piece of equipment might be asked to perform at a later 13 time again, and that should not be forgotten. Those also 14 should be qualified for a rather long time.
15 MR. ALLEN: Did you have a comment, Carter?
16 MR. ROGERS: Bill, I wonder if you might explain the 17 shorthand of the tag number. Do we have someone here that 18 can do that7 19 MR. KEITH: Me have Ed Sterling.
20 MR. STERLING: The J portion is instrumentation.
21 Anybody who can do it better correct me if I am wrong. The 22 S portion of 'that tag number is the system number, system 23 designator, and A and B are the channel. The C02 A and B on 24 those two is the cabinet number.
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25 MR. CARSON: That is a specific relay cabinet located GRUMLEY REPORTERS Phoenix, Arizona
in Channel A and located in Channel B. There are two items, so there are two of these in each unit in the control room; and it takes inputs from various points and it sends out 4 signals to various points.
DR. ROSKTOCZY: Could we have Exhibit UI-6, please?
On this exhibit, we see the signatures of two individuals who have reviewed this and signed it. It is not clear what are they signing for. What does the signature indicate here?
There is no statement on there of what they are signing, so 10 it leaves that a little bit vague. Is it the purpose of the signature to say that these individuals are certifying that 12 this component has been properly qualified?
13 MR. BINGHAM: Let me give you a little background, 14 Dr. Rosztoczy. First, we have many documents that we review and sign off that we have reviewed them and they meet our 16 criteria from the vendors. We have a form that is stamped 17 on or attached to all the various documents. That also has a signature and has all the legal words on exactly what we 19 have done as far as our review and does release the manufactu 20 to proceed with the work. In other words, it is our release 21 that really constitutes the docunent review like a test 22 report, a vendor drawing, whatever other document it is that 23 we have asked to approve before manufacturing proceeds. Thes 24 sheets are supplemental sheets to assure that we have flagged for the responsible engineer all those items that are GRUMLEY REPORTERS Phoenix, Arizona
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327 1 important that they specifically review. It is like a 2 checklist that the pilot uses before he takes the airplane 3 off to make sure all the switches are thrown, and so forth.
4 It is our way when we have a very large number of people 5 doing work'of assuring, one, consistency amongst the groups, 6 two, th'at individuals do not forget to ch'eck a very important 7 point, and, three, it enhances our training of these 8 individuals as some leave the company and others come on the 9 project. So it really is a supplemental form and the 1p signature here is required so that we can have traceability 11 to the reviewer that they have looked at those checkpoints.
12 They are essentially saying I have looked at them, I have 13 assured myself in my evaluation that what I have put down 14 there repxesents good professional practice, and that what 15 the vendor has done meets the established criteria. Further, 16 as I indicated to you, it gives us a way to assure ourselves 17 that we flag deficiencies and that we have a manner in which 18 to track those deficiencies and assure ourselves that they 19 are reviewed by the proper people. So when you see the 2p signatures here, they are saying yes, I have reviewed it, it 21 is satisfactory, or here are the deficiencies. Second, from 22 'he pro)ect management standpoint, we can go to those 23 individuals if we find through our audit of these forms that 24 they have not interpreted something in the propex manner and correct their misunderstanding as to how this form works.
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28 DR. ROSZTOCZY:= I am not sure that I understand the 2 answer to the question. Are you saying that these individual 3 here are certifying that this piece of equipment has been 4 qualified to the appropriate requirement7 MR.'BINGHAM:. No. The vendor certifies that the equipment has been qualified. We are in a reviewing position to assure that the vendor has done what they are supposed to I
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DR. ROSZTOCZY: '
understand that. With that under-10 standing that the licensee in a sense has responsibility to 11 review all of the equipment what he receives from the vendors
],2 and is certain that he has done it in that process, .what I
$3 could call the licensing process, these individuals are 14 certifying that they have checked on this and the qualifica-tion that has been performed is appropriate.
l6 MR. BINGHAM: It meets the established criteria.
17 DR. ROSZTOCZY: It meets the requirements How do ~
you know from here whether they found it acceptable or they 19 found it deficient7 You said in either case, they would sign.
20 How do you know if these individuals, the two shown there, if they signed because they thought it was acceptable or the signatures indicate that they are deficient7 23 MR. BINGHAM: If there were deficiencies, the procedure 24 that goes with this check-off form indicates that they are to fill it out. I may not have made that point clear, but there GRUMLEY REPORTERS Phoenix, Anzona
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is a procedure that tells the individual how to use the check-off form, and in there it says, "If there are deficienc es, 3 fill this out."
DR. ROSZTOCZY: But that is a different form. That is 5 not this form. It is some other form attached to it.
MR. BINGHAM: Indicate the deficiencies. Indicate 7 them right here on whatever it is, No. VIIX -- I'm sorry, 8 we'e got to be careful, because we have come to grips with 9 this particular issue. If you look at Exhibit VI<<1.1, VIII, 10 Qualification Deficiencies, it'ays, "The following is a list 11 of qualification deficiencies requiring work orders." Those 12 would be listed.
13 DR, ROSZTOCZY: 'This appears on this form which was 14 used apparently for one sample, but it does not appear on the 15 other form, the one which was your example.
16 MR. BINGHAM: It doesn't appear on the old form.
17 If we go thnough some of the other exhibits -- For example, 18 that is Exhibit C of* the. Procedure, which is an updated form.
19 Me will add that form to the record, John.
20 DR. ROSZTOCZY: I think it would useful to have a 21 statement above the signature which would indicate what are 22 they signing for.
23 Now let..me go back to Exhibit VI<<4. If you go to Item 3) there, which is "Test temperatures were measured by,"
25 then they checked under "Other" and they said "Under Review,"
GRUMLEY REPORTERS Phoenix, Arizona
v, h 4 ~
t M
, so obviously they haven't completed their work. They don' know yet whether this has been properly done, but they signed at the end of the sheet. What does that mean7 MR. BINGHAM: You are absolutely right. I was trying to indicate that we are trying to have a better control to complete this review and explain what it is, and consequently the new form that I showed you attempts to do that. I did indicate in earlier discussion that the document that goes back to the vendor has the signature on it of the 10 individual and will indicate that there are comments that must be resolved or that we have reviewed and find the 12 document acceptable and manufacturing or testing or whatever 13 may proceed. So there are-two documents and let me try again 14 to explain. The basic document-that comes in would be a- test plan or a test report. Let's take the test report. The test 16 report comes in, it is logged in through our document control 17 system, it goes to all of the involved parties, including the 18 customer. They all use their check-off sheet to go through 19 the various elements and compile comments. Those 'comments 20 come back to the reviewer -- I think there-.4s a form in there-21 go through the reviewer and then will be statused and sent to 22 the vendor. Let's assume that there is a lot of comments.
23 Those comments go to the vendor and say, "Please resolve these 24 comments before work proceeds," or "Pork may proceed, you can 25 resolve these comments later." The vendor then takes this, GRUMLEY REPORTERS Phoenix, Arizona
and let's assume he has to resolve the comments before work proceeds. He resolves them and resubmits the document back to Bechtel. Bechtel then takes the new version of the 4 document, sends it out to all individuals involved, and let' assume that the first round is enough, reviews and determines that all the comments are resolved. The responsible engineer will then sign off on that document that work may proceed, 8 but we have not relieved the manufacturer of any of the 9 requirements to assure that he has "qualified and justified 10 the qualification of that equipment. That is the major ll document side and that is where the signature really means 12 something. On this form, it is an internal control form as 13 well as a way to provide information that is readily accessib 14 for .this particular concern and we want the sign off so that 15 we can have traceability.
16 DR. ROSZTOCZY: If you rely on the second form in 17 addition to this for the documentation that this component 18 has been properly qualified, then I think you should have 19 presented here both forms and you certainly should include 20 both forms in your file.
21 MR. BINGHAM: Mell, I indicated earlier that we wouM 22 include both forms in the file. If this form disappeared 23 forever, there wouldn't be anything more than just an inconve 24 ience as far as the documentation of the qualification in our 25 opinion.
GRUMLEY REPORTERS Phoenix, Arizona
r A.
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DR. ROS2'.TOCZY: Then maybe there was no need to present this one. You should have presented the one that you depend on.
MR. ALLEN: Bill, Art has a comment he would like to make.
MR. GEHR: I think the point has been well taken.
Right above the signature, you have a phrase "Evaluation Approval:" And that is too broad for what you intend that signature to mean. It's just plain and simple that way.,
10 it B.ll. You will find in the records and will look like it those two people approved the evaluation when in fact the 12 form itself as filled out shows they have not. The suggestio 13 is if you are going to have this as a permanent record that 14 you put in a statement that "The material shown on this form 15 is true and correct to the best of my knowledge." Then that 16 would be a meaningful signature. But when you put on that 17 form "Evaluation Approval," sign it, that indicates that those 18 people're signing more than they intended and you ought to 19 get rid of that and put in a proper designation for'hatever 20 anyone signs.
21 MR. BINGHAM: Well, let's take that under advisement, 22 John.
23 MR. ALLEN: We will keep that as an open item.
24 I think the time is telling us that we should break 25 for lunch.
GRUMLEY REPORTERS phoenix, Arizona
I 333 DR. ROSZTOCZY: One final question. Xt is a short one Xn this case, the aging test on this specific equipment was an actual agi.ng test for the type of perfonnance that you expect from the equipment. By putting a piece of equipment through this test, you establi.sh that i,t is qualified for the type of performance. What assurance do you have that the piece that was tested has been discarded or somehow eliminate and'ill not be placed in any plant?
NR. BINGHAN: We require in the specification that 10 we have the equipment either refurbished ox replaced and the vendor must document that that has been acconiplished. We do 12 audit and perhaps would look at that particular issue on a 13 case>>by-case basis.
DR. ROSZTOCZY: What would refurbish mean in a case 15 like this?
H 16 MR. BXNGHAN: We11, the heat might damage the paint 17 or the surface of the component, or maybe they might get 18 some of the wiri.ng dirty in the tests, or if they are shaking 19 it, there may be some minor structural local anomalies that 20 you would want to fix up to make it look like a new product, 21 those kinds of things.
22 DR. ROSZTOCZY: But that would be grossly inappropriate 23 This has been aged now to a point beyond which its operability 24 i.s not guaranteed at all, so this piece of equipment under no 25 circumstances should be placed in that plant, and to refurbish GRUMLEY REPORTERS Phoenix, Arizona
it .like repaint it a little bit and put it into the plant would be a gross mistake.
MR. BINGHAM; X understand your point. X think we have a response, John,, but why don't we leave this open for now
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and X wi,ll come back.
1K. QUAN: Could X have that question stated again?
DR. ROSZTOCZY: The equipment that actually was tested 8 has been aged to the limit required for the performance.
9 There is no guarantee that it wi.ll perform beyond this limit, 10 so this would have to be discarded and should never be placed ll in the plant, What assurance has been made that that step 12 was donee 13 MR. ALLEN: Really, can you say it is aged to the 14 limit' 15 DR. ROSZTOCZY: The limit that you qualified it for, 16 so it's performance beyond its limit is uncertain and, 17 therefore, it should be discarded.
18 MR. ALLEN: Let's break for lunch. Mhy don't we try 19 for 'as fast as you can eat and get back.
N 20 (Thereupon the meeting was at recess.)
21 22 23 24 25 GRUMLEY REPORTERS Phoenix, Arizona 6
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335 September 26, 1980 1:45 p.m.
MR..BINGHAM I would like to ask Ken Schechter to go through the seismic equipment qual%,fication for the same piece of equipment.
MR. SCHECHTER: Thank you. I would like to discuss the qualification checklist for the same piece .of equipment that Mr. Carson discussed earlier, the Balance of Plant 8ngineered Safety Features Wtuation System, Exhibit VI<<8.
10 It is in the scope of balance of plant. The supplier is General Atomic Company, Electronics Systems Division. It is a control board assembly that houses various devices, 90 inch s 13 high, 64 inches wide, 36 inches deep, weighing 3,400 pounds.
14 It is located in the control building at Elevation 140. Xt i mounted in the field by welding, total weld length of 52 inch s.
Natural frequencies in each direction were not measured. It was qualified by testing. The functional description is aalance of Plant ESFAS. The equipment is required for both hot standby and cold shutdown.
20 Exhibit VI-9. The equipment is available for inspection in the plant, and it was qualified by means of testing by Hyle Laboratories, and the report number was 58343.
23 The only load that was considered during this test was seismic .
The required response spectra was attached.
25 Let me )ust switch for a second and I will show the GRUMLEY REPORTERS Phoenix, Arizona
required response spectrum for SSE. This is Exhibit VX-12.
Let me just point out the zero period acceleration of 1.6g.
Let's go back to the other one,'lease. (Exhibit VI-9) The required zero period acceleration in each directio for the SSE for all three directions is 1.6g-as specified on the required response spectra. For the OBE, it is 1.0g.
Section VI deals with if the equipment was qualifie by test. In this case, it was, so it is filled 'out. The inpu was multi>>'.frequency random input motion. It was a multi-10 directional test. The total number of qualification tests were 13 for OBE and 7 for the SSE, the frequency range from 12 1.25 hertz to 33 hertz, and the test response spectra did 13 envelope the required response spectra.
14 Exhibit VI-10. The input zero period acceleration 15 levels were 2.0g for the OBE for all three directions and 16 3.4g for the SSE, which is quite a bit higher than the requir 17 zero period, accelerations. The laboratory mounting was by 18 means of welding, total length 52 inches. The functional 19 operability of the equipment was verified and there were no 20 modifications needed as a result of the test.
21 Section VII is not filled out, since the piece of 22 equipment was qualified by testing. If it was qualified by 23 analysis'or a combination, it would have been filled out.
24 MR. LaGCN: Nas the equipment operated during test?
25 MR. SCHECHTER: Yes, it was.
GRUMLEY REPORTERS Phoenix. Arizona
f Exhibit VI-ll. Again, this is part of the section and if it was qualified hy analysis, we complete this.
Section VIII talks about deficiencies in the qualification of the equipment, and in this particular case, there were none.
Then this form was signed off.
MR. BINGHAM: Are there any questions?
DR. ROSZTOCZY: No question, just a comment. Many of the same things which we critiqued on the other sheet need 10 to be corrected on this such as the signature and it should be reviewed for misleading type of statements. Can you do 12 that as an open item?
13 MR. BINGHAM: Ne agree.
14 MR. NOONAN: I guess I have a couple comments. On the 15 sheet, one addit'ional comment was operation. There is no 16 place on the sheet that would show that this thing was 17 functional.
18 MR. CARSON: Yes, that was indicated.
19 MR. NOONAN: You say it was functionally checked, but 20 does that mean before or after or during the operation? I 21 think you should be specific in whether you check during the 22 operation.
23 MR. BINGHAM: Let's make a note of that.
24 MR; NOONAN: It should say it is tested before or 'after 25 or during. The status function during the test should be so GRUMLEY REPORTERS Phoenix, Arizona
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stated. I don't see that on here.
The other thing is you showed the required response spectra, but you didn't show the test response spectra. You wouldn't have a copy of that, would you, by any chance?
5 MR. LINDERMAN: We have a copy here, but it is in the document.
MR. NOONAN: Would that be normally attached to t'his?
LINDERMAN: It would. normally be attached, yes.
'R.
MR. NOONAN: Is it something I could just take a quick 10 glance at?
(Thereupon a brief off-the>>record discussion ensued, 12 after which proceedings were resumed as follows; )
13 MR. NOONAN: The only other comment I would tpake is 14 in the process of trying to establish a curve, it looks like 15 you pretty much enveloped the whole area. As a result of 16 trying to do'so, you tend to bring up the zero period 17 acceleration quite a bit.
18 MR. LINDEBMAN; That's right.
19 MR. NOONAN; That's why I think -- well, I know 344 20 doesn't have any tolerances given to the spectra. It seems 21 reasonable that there should be some tolerances, and that' 22 why I made the statement before there ought to be at least 23 10% or 127. in some cases ~here you might boost it up high to 24 try to get it above the required level, which you are also 25 bringing up your zero period acceleration. I would,. see ".no GRUMLEY REPORTERS Phoenix, Arizona
e V problem if you could show a spectrum that had a few dips below. the required spectrum of, say, 10 to 12%. I am not saying the whole thing should be 10 or 12% below, but I am saying a few points. I would see no problem in doing that if that creates a problem in your testing where you are 6 starting to bring up the rigid body part of the specs.
MR. LINDERMAN: I know in the past it has always been 8 they want them completely enveloped and never have had any 9 allowance for slight dips.
10 MR. NOONAN: But the people that wrote the document I 11 don't think had much experience on the actual testing areas 12 and I think it is realistic to rea1ize that you can't all the 13 tim envelope that spectrum fully. I would have no pxoblem 14 if certifications had small deviations, as I say, of 10% or 15 so. I always used 1.5 dB, which was my criterion based on 16 acceleration, and 3 dB on power.
17 MR. BINGHAM: Other questions, Johnf 18 MR. BARRCN: I just have a suggestion. Ve found this 19 real helpful;.when we fill out the NS 15 form and send a copy 20 to Bechtel for them to incorporate our comments. They 21 suggested this, so I am going to return the favor and suggest 22 it. When you fi11 out your form, it would be helpful if 23 anywhere that it was not applicable or there was no coaxnent, 24 fill in "None" or ".N/A" on the section. That way, if somebody goes back later, they will just know by looking at it that GRUMLEY REPORTERS Phoenix, Arizona
the person didn't forget to fillout that part of it.
MR. BINGHAN: We'l do that.
MR. ALLEN: Any further comments?
Shall we proceed to the next section, then?
MR. LaGOW: I did have one other comment. On the previous form that you had up before we went to lunch, the qualification form, I think that you ought to expand that to show how the equipment was operated and, if it has inputs and outputs such as this equipment did, to show that you 10 monitored the sensitivity of the input and the current capacity of the output and things like that.
12 MR. BINGHAM: I beU.eve that is part of our open item, 13 is it not, to review those issues?
14 That gets us to our last section,Section VII, 15 Qualification Problem Areas, and we will cover both environ<<,
16 mental and seismic. We will take environmental first", and 17 Bob Carson will present that.
18 MR. CARSON:. Exhibit VII-1 is a listing of the 19 major problems that we are having at the present time, by no 20 means a complete listing of all of the problems that we are 21 having, in the area of qualification, and you can see that we 22 are talking here about battery chargers, the supplier Power 23 Conversion Products of San Diego, and a very short summary 24 of the problem that we are having, safety-related design 25 problems with the battery chargers. In this case, this vendor GRUMLEY REPORTERS Phoenix, Arizona
4 is having problems with quali.ficatioa of circuit breakers and some other porti.oas of the equipmeat that go into this battery charger and that is preventing him from shippiag this equipment, so it is holding up installation. We have been in contact with him aad are working with him for these particula areas.
JM-108, one of the control system specifications having to do with the Safety ~quipment Status System made by Beta, %heir test plan was considered deficient when it was 10 submitted. We have made numerous comments on their plaa.
It has been the subject of considerable di,scussioa aad meeti,n 12 and phoae. calls with them and we were anticipating them to 13 have resubmitted that by August." It has not yet been receive 14 The supplier is not responsive to our requests for addi.tional 15 information and for rework oa his plan and we are having to 16 try to expedite him, and if we doa't get resolution soon, we 17 will have to take some further action up to and including 18 possibly initiating some program of qualification ourselves 19 rather than relying on the vendor to do that.
20 Here is another control system eqoipnent order having to d 21 with valves by Control Components, of Xrvine, California.
22 They are having great problems in getting their testing progra 23 under way. Their original program having to do with- valves 24 for the Palo Verde project was goi.ng to be one of qualifying 25 by similarity and relying on testing aad analysis and testi.ng GRUMLEY REPORTERS Phoenix, Arizona
for valves that were going to be produced for another client.
That nuclear plant has since been delayed. They never build the valves upon which they were going to base their qualifica tion for Palo Verde valves, so they are now having to construct some'additional- equipment and there have been some commercial problems involved in addition I to the lack of getti g the plan put together. Their qualification plan has also had some deficiencies in it and we are working with them on that.
Another valve problem. We are talking about Exhibi 10 VXI-2 here. Fischer Controls. In terms of valves, they are having problems with the valve actuators and Fischer them-12 selves are not too anxious to .talk to us about getting those.
13 problems resolved. One item that is not listed here, because 14 this is only a representative sample of some of the problems, 15 js a vendor Harlo 'which is providing us with some electrical 16 relay cabinets, who has completely abandoned the qualificatio 17 program, has said that they area!t going to be involved with 18 it, they will not qualify the equipment, and in this regard, 19 the qualification program has been taken over by APS with 20 Bechtel acting as the agent and we are working with the test-21 ing laboratories, Wyle, to provide the qualification for that 22 equipment.
23 The diesel generator sets being provided by Cooper Energy, this is a very, very complicated and large-scale 25 program. It involves the engine, the generator, the control GRUMLEY REPORTERS Phoernx. Arizona
1 cabinets, all of the items that were shown in the dotted 2 block when we talked about IEEE 387 for the diesel generator 3 equipment. We have asked them some time ago to look at thei.r 4 total scope of supply in relati.on to IEEE 627; that is, to 5 talk to the problem of safety-related equipment, safety-6 related components in the entire scope of supply, and not onl 7 look at the strictly electrical items. This i.s generating an 8 extremely large program which they are having great 9 difficulty putting together. We have been i.n contact with 10 them continuously and are hopeful that within the next couple of months, we will have some information. Ne are following 12 those on a'day-to-day basis.
13 Bingham-Willamette, who is providing the auxiliary 14 feedwater pumps, has also been contacted to look at their total scope of supply in regard to IEEE 627, to look at all 16 of the safety-related i.tems, all safety-related components, 17 and there are commercial implications in that program.
18 Another valve probem from Dresser with Rotork 19 actuators. The aging tests on the Rotork actuators were due 20 to start in August of this year. They have been delayed.
21 A test plan for the entire valve equipment has not yet been 22 formally submitted. We are expediting that. In this regard, 23 we have received communications from Dresser that they are 24 leavi.ng the nuclear servi.ce valve i.ndustry, they will accept no further orders for valves for nuclear power stations, and GRUMLEY REPORTERS Phoenix, Arizona
are not at all anxious to continue 'with programs that they have in house. They have indicated that, in answer to our requests to provide information on materials which form gaskets and.packing and such, they will ask their sub-vendors for such information and they will pass on whatever they get for us in regard to those requests. They will take no action to perform any other qualification testing on the equipment.
This is a severe problem and may very well be a program which will hive to be taken over by APS with Bechtel acting as thei 10 agent.
This is just an indication of some of the problems 12 that we are having, major ones. In addition, we are in 13 contact with all of our vendors, as I indicated yesterday, to 14 clear up any minor problems which are involved, some 15 deficiencies in documentation, some clarification on items 16 that were in either programs or procedures or reports. Those 17 are being handled by TWX, by mail, by telephone calls, by 18 meetings with the individual vendors in an attempt to get all 19 of this documentation in our files.
20 MR. BINGHAM: Are there any quests.ons2 21 MR. ALLEN: Ed Sterling.
22 MR. STERLING: On Exhibit VII-1, if we can start there 23 you have indicated you have problems with test plans, and so 24 forth, but you haven't really indicated what type of problems.
25 Are they problems in how they are determining what they are GRUMLEY REPORTERS Phoenix, Arizona
45 going to age or not age or how they intend to age things, or what type of problems'R.
CARSON: The problems range the entire gamut.
A11 of the things that you mentioned are problems that we have seen on test plans -- how to age something, ~here can they get information about aging, what laboratories they migh use, things of that sort, how should testing for operability be accomplished. Essentially anything that has to do with a testing plan has at one time or another been a problem or 10 has called for comment back to the vendors. Some are respon-sive in getting the answers back to us and modifying the 12 programs,'f necessary. Some have been very, very unresponsiv 13 in getting back to us and it has caused considerable delays in many of these programs.
15 MR. STERLING: For example,, a vendor might be stumblin 16 over a particular type of material in that he can't find a 17 way of aging and yet you know of another way. Have you been 18 passing along this type of information7 19 MR. CARSON: We have passed along as much information 20 as we can. We have pointed them in directions where they can 21 obtain information. We have made suggestions to them as to 22 modifications for their programs. We have,not undertaken to 23 dictate to them specific things except if they suggest that they are going to say "We have been building this sort of 25 equipment for 25 years and it works just great and, therefore, GRUMLEY REPORTERS Prloenix. Arizona
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that's fine and that is what we are telling you and that what we will sign to." We. tell them that that is not acceptable, they have to give us a definite program, a 4 definite plan, they have to provide satisfactory documenta-tion for a qualification effort.
MR. STERLING: Have you found any of the mechanisms 7 that they have been using for aging or whatever to be 8 proprietary to one type of vendor and he won't release that 9 type of information that you can use to age that same materia 10 on another vendor?
lS.. CARSON: No, we have not found that they have any 12 proprietary aging mechanisms. We have found -that a vendor 13 has said, "We have paid to have this particular program 14 implemented," or "We have paid to have this material aged and, 15 therefore, that information is proprietary and we won't give 16 it to,you. Ve wi11 provide you with the end result, but we 17 won't give you the information. You can come and look at it.'8 We have gone and audited material, and in those cases, as 19 indicated yesterday, we here required that such information 20 be specifically identified and its location be specifically identified so that anyone who needs to audit that information wi11 know what to look for and where to go to see it. We are 23 now also instituting. requests to make sure that all such 24 information that is retained by the vendors will be available 25 for the life of the plant either in the vendor's facility or GRUMLEY REPORTERS Phoenix, Arizona
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in some storage facility or that APS would have the opportuni to obtain such information for maintenance and storage for the life of the" plant.
MR. BINGHAM: Are there questions, John?
MR.,ALLEN: Any questions?
MR. CLARK: I have one. Harlo Company" is one of the bigger board manufacturers in the country and didn't they manufacture the board or control panels or relay panels?
MR." CARSON: Harlo is the manufacturer of the relay 10 panels, yes.
MR. cLARK: They are one of the bigger vendors in 12 the country I would assume. Are they droppi.ng out of the 13 nuclear business now or is i.t gust for,th5.'s particular panel?
14 MR. CARSON: They have not specifically indicated that 15 they are dropping out of the industry, but they are saying, 16 in effect, "We will build a panel. If you wi.sh to use this panel in your nuclear plant, you may do so. If you don' 17 18 wi.sh to use this panel in your plant, use something else."
i 19 MR. LaGOW: Would you clari,fy which, problem you are 20 talki.'ng about there? That is not one that is speci.fi.cally 21 listed on this tabulation.
22 MR. CARSON: That attitude we are finding i.s becoming 23 more prevalent, that people are saying, "The nuclear industry 24 is too much of a headache for, the amount of material that we are buildi.ng and we really don't want to talk to you."
GRUMLEY REPORTERS Phoenix. Arizona
MR. BINGHAM: Other questions, John?,
MR. ALLEN: I think Vince had a question.
MR. NOONAN: Maybe you already answered it. I guess the bottom line is that they don't see any commercial gain in doing the qualification tests.
MR. CARSON: That's right.
MR. NOONAN: They will provide the product and it is up to you to take on the qualification of the item, is that corrects 10 MR. CARSON: That is what is happening, yes, sir.
MR. NOONAN: I suspect it is probably the bottom line 12 on all these negative responses you have been getting.
13 MR. CARSON: Right, and we are working with them to 14 hopefully change their attitudes, and if we can change those 15 attitudes, we are working with them to get the required 16 documentation and do the required qualification programs.
17 MR. NOONAN: On the relay panel board, was it Harlo, 18 is there sufficient competition in that field that you can go 19 to other competitors to get it or are you pretty much limited.
20 MR. CARSON: At this point in time, there is no time 21 to go out and do a complete new procurement, so we have under 22 taken to qualify the equipment ourselves and that is in 23 process right now.
24 MR. NOONAN: Given, say, for future plants, are there 25 other options7 GRUMLEY REPORTERS Phoenix, Arizona
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MR. CARSON: There are not too many other options.
There are people who will build equipment like that, but they are becoming few and far between.
MR. ALLEN: Herman, did you have a question?
MR. LaQN: Is it primarily aging or is it the seismic 6 testing, or which is the problem?
MR. CARSON: The entire operation of providing qualification. It is a great effort on the part of a vendor, 9 particularly a reasonably small vendor or a small vendor, to 10 undertake such a program. It ties up great amounts of his time and effort which he feels can be more profitably used 12 building things for the commercial market.
13 MR. ALLEN: John.
14 MR. BARROW: I have just one thing to add. To give yo 15 an example, when Solid State Controls was talking about 16 dropping out of the nuclear industry, one of their vice-17 presidents told me their documentation on nuclear orders 18 constituted 80% of their paper work, but the nuclear orders 19 were only 20% of their business, so that was the main reason 20 they";"were thinking about getting out.
21 MR. ALLEN: Any further questions?
22 DR. ROSZTOCZY: The examples which have been shown on 23 this slide are basically schedule type of problems, in some 24 cases maybe contractual problems to make a contractor do the L
25 job with one exception, the very first one. The very first GRUMLEY REPORTERS Phoenix. Arizona
one refers to safety-related design problems. Have there been some actual tests done on that equipment and was the result negative; in other words, some components in that I
system didn't pass the test7 MR. CARSON: There have been extensive tests done on 6 the battery chargers and, in fact, they perform very 7 satisfactorily. The problem is in getting the proper docu-8 mentation for the circuit breakers, one of two circuit 9 breakers in that equipment which are being obtained from 10 General Electric Company and from Westinghouse. Our vendor, Power Conversion Products, is having difficulty getting qualification information on breakers that he is buying from
$3 a subsupplier.
DR. ROSZTOCZY: You are saying then that that first problem is not really a safety problem, it is more of a 16 documentation problems 17 MR. CARSON: That's right, yes. We don't allow any 18 qualification programs that indicate safety problems. We are 19 working to get the programs successfully completed and we wor 20 to get the proper documentation, and an awful lot of our problem is getting the proper documentation.
22 DR. ROSZTOCZY: I understand that. I am going in the 23 direction that are you aware of any equipment that actually 24 failed under the testing that it was tested for so some desig changes were needed to correct this, for example, that could GRUMLEY REPORTERS Phoenix, Arizona
'I put you back on your schedule or could cause you some if difficulties a given component undergoes the specified test but it doesn't pass the test, you have to go back, you have to make changes.
MR. CARSON: There have been areas.
DR. ROSZTOCZY: Could you give me examples or could
'7 you give me the cases when the actual test wasn't passed and some design change was needed'R.
BINGHAM: There have been areas, I think CQHSXP.
10 was one of them, where tests were made by the particular vendor, they filed a Part 21, of course, because they had 12 already shipped some of the equipment, and in our normal 13 course of work, we also file our 50;55(e) rs and these are all on record. there is probably a handful or so that I 15 know of where that has occurred.
16 DR. ROSKTOCZY: The ones in operating plants would go 17 on record. How about the ones which are )ust for a CP.
18 MR. BINGHAM: The same.
19 DR. ROSZTOCZY: The same thing2 You file the same way 20 for a CP control systems 21 MR. BINGHAM: The vendor will file a Part 21 if it is a 22 generic problem and they have shipped equipment to be installe 23 In oth'er words, it has gone through their program as being 24 acceptable and now they find out it II is not'and theY w>>t 25 a test, and we have a few occasions on this plant where that GRUMLEY REPORTERS Phoenix. Arizona
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has been the case, -yes.
DR. ROSZTOCZY: But this first case is a'case when they already shipped something out, so they shipped )ust like 4 it would have been all right and they found out later there was a problem. How about cases when you )ust gave them a 6 specification, they take your specification, they develop a test program, and they take their equipment and it doesn' pass? I assume that one would not be reportable, because they haven't shipped it yet.
10 MR. BINGHAM: If they have not shipped it, it is still in the formative stages of design. I would guess that they 12 would make modifications to provide the proper piece of 13 equipment for the intended service.
14 DR. ROSZTOCZY: The question was, I believe, have ther 15 been any cases on Palo Verde.
16 MR. CARSON: Those sorts of cases get corrected before 17 they leave the vendor's factory.
18 MR. BINGHAM: That isn't the question. His question 19 is have there been any that we know of.
20 MR. CARSON: We had some problem with Rockbestos cables 21 that had been shipped.
22 MR. BINGHAM: There have been some.
23 MR. VAN BRUNT: Some had and some had not.
24 MR. BINGHAM: Some had not been shipped.
25 MR. VAN BRUNT: In the case of Rockbestos, we filed a GRUMLEY REPORTERS Phoenix. Arizona
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353 50.55(e) on that particular situation.
DR. ROSZTOCZY: Some of these cases when they do perform the tests and they don't pass are still valuable.
information. The valuable information is sent and they tell
- us how close'e are to some failure threshold.. When you hav
)ust passed that test, you don't know if you barely made it or if you were very far removed, but when you do fail some
,8 test and you start to get some ideas as to which equipment or what component in given equipment is the limiting one that is 10 closest to the threshold--
MR. BINGHAM: I can think of one example, and that is 12 in-containment transmitters that both Westinghouse and Barton 13 have been having difficulty qualifying as well as Foxboro, 14 and I am sure that the Commission is aware of those.
15 MR. NOONAN:, To follow the same line, if there have 16 been failures during a test program which you would normally 17 maybe expect to happen, it would not be uncommon to happen, 18 in your final test report, do they document the progressive 19 nature of these failures, what they were, and then final 20 resolutions of the failuresf 21 MR. CARSON: All anomalies are indicated and the 22 resolution of the anomalies is indicated, either something 23 that is of no consequence or something that requires redesign 24 or some other'corrective action, but, as I indicated, the 25 end result is before a plan is approved and certainly before GRUMLEY REPORTERS Phoenix, Arizona
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the report is approved, the equipment must be put in such shape that it,is qualified and it does do its job.
MR. NOONAN: I understand that. I just wondered if there was a trail that could be tracked to look at.
MR. CARSON: Oh, yes. The reports indicate anomalies and anomalies are analyzed and, if they require corrective action, that is done and the test or the analysis and test is restarted at that .point and continued to a successful completion.
10 MR. ALLEN: Further questionsf Does that conclude your presentation, Bill?
12 MR. BINGHAM: No, we have one other subject. Ne have 13 seismic on the agenda. Really, we don't have any particular 14 . problems with'pecific vendors as we indicated in environmenta l5 Of course, we do have the open issues we discussed earlier upon our re-review that may come up and present us some 17 problems. I think we should leave it at that point for the 18 board.
19 That would conclude our presentation, John.
20 MR. NOONAN: I wonder if I could )ust bring up briefly 21 about the relay problems, type testing of relays. Do you 22 have such a program in place? I am talking about type testing 23 of relays. Do you have such a program in place where you 24 would take, say, a sample of relays, put them on a table, 25 shake them, look for contact chatter problems or even maybe GRUMLEY REPORTERS Phoenix, Arizona
~ I E relay failures?
MR. CARSON: Bechtel as such does not have a program to test relays or any other specific component. There are e
programs by General Electric, by Westinghouse, by Gould-Brown Boveri and other people who manufacture relays. We know of programs that are going on with these manufacturers who are doing these things and we are certainly anxious and we consta ask them for information about what the status is of relay testing programs. We do take account in any of our programs 10 of relay chatter as Bruce Linderman indicated earlier. If during a seismic'examination, for instance, we notice chatter, 12 that is measured, and if it is less than 2 milliseconds, we 13 assume that it is no problem unless an analysis of the circui 14 indicates that the 2 millisecond bounce would be a problem.
15 We are guided there by IEEE Standard 501, which allows a 16 2 millisecond bounce.
17 MR. NOONAN: I guess you have nothing in that system 18 that would integrate those bounces and give you a false 19 signal?
20 MR. CARSON: That's right. We have those circuits 21 re-examined to see if that would cause a problem, 22 MR. NOONAN: One of the NSSS vendors that you mentioned 23 we went through a lot of their equipment, particularly in the control room. We did type testing or required them to do 25 type testing and we found a lot of prob1ems in relays.
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MR. CARSON: Yes, we know of problems in relays.
MR. NOONAN: They produce a tremendous amount of relays.
MR. CARSON: We know GE, for instance, has discontinue 5 use of certain relays which just a few years ago were 6 indicated as being successful, and they are replacing them 7 with their new Century series on one of our projects.
8 The'ogtle project is in a hassle right now with'them about 9 changing relays.
10 MR. NOONAN: That's fine.
MR. ALLEN:: The next item l had that. you had asked 12 for some indication on what we are going to do is the documen-13 tation as far as equipment qualification. I touched on it 14 briefly yesterday, but our intent right now is that APS will have full documentation for both the BOP qualification progra and the NSSS program. These will be filed by purchase order or by equipment type like relay panels, ESFAS cabinet, 5 KV cable, and it will include all documentation in one single 19 package. For example, the spec will be there, the PO and the 20 qualification plan, the test result, all the information and all the sheets like we have been seeing here. Once those are assembled, they will be kept both in a hard file and they 23 wil1 be microfilmed" and kept on a computer based system at.
24 both Palo Verde and our engineering offi,ces in Phoenix. So we will have them in both places for audit and use by GRUMLEY REPORTERS Phoenix. Arizona
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357 Engineering and Operations.
DR. ROSZTOCZY: For example, if somebody would corn out here and want to follow the qualification of a given system, then what he would have to know, he would have to know the component. list for that system.
MR. ALLEN: Not necessarily the component list. He would have to know the system. For example, he would want to know switch gear so we could go to EMO, whatever it is, some number, and look that up through the spec number, purchase 10 order number, and then that total package would be ready for E his audit.
12 DR. ROSZTOCZY: Once again it was mentioned here 13 earlier as an example the safety injection actuation system.
14 Xf I look at the whole system, it has a number of components.
15 Would those components be filed one following the other or 16 do you have to find the identification number for each of 17 . those components and then go to the appropriate component?
18 Then I have to have somewhere a component list for the system.
19 Once I am in possession of that, then I could go and look at 20 the list. Then you are saying once I went to the file of a 21 given component, then everything would be together in that 22 one file.
23 MR. ALLEN:. Right. In some cases like instrumentation, 24 you would have to go to the:.instiumentation index, which 25 would reflect the purchase order number. Then you would take GRUMLEY REPORTERS Phoenix, Arizona
the purchase order number and that is where everything woold be filed. You would have to go to electrical elementaries.
You would see what switch gear, motor control centers, or whatever was involved. You would determine its purchase orde Then you would go to that and that file would be there with the corresponding qualification information.
DR. ROSZTOCZY: And it would include the qualification information independent of who generated it, whether it was generated by Bechtel or whether it was generated by a 10 manufacturer who had, in turn, turned it over to Bechtel and you got it through theme 12 MR. ALLEN: Right.
13 DR. ROSZTOCZY: What is your time schedule for establi h-14 ing this filef From our viewpoint, especially I am intereste 15 in a date when you say this is all complete so one can come out here and look at it.
17 MR. VAN BRUNT: For one component or for all components.
18 DR. ROSZTOCZY: Mell, not specifically which component.
19 MR. VAN BRUNT: Seriously.
20 DR. ROSZTOCZY: I think I am looking for all components, 21 or maybe almost all. For example, you were talking yesterday 22 in terms of preparing a submission at the time when you are 23 something like 70 or 75% complete. The question would be the 24 when is the file complete for all of those items which are in your submission7 GRUMLEY REPORTERS Phoenix. Arizona
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Y MR. ALLEN: At the present tim, we'e got a great 2 deal of that information filed, already compiled into the 3 purchase .order filing system. Cable, for example, I believe 4 that would be probably complete.
MR. BARR04l: That would be complete.
MR. ALLEN: Bill, what was our date for submission of the first--
MR. BINGHAM: November, '1.
MR. ALLEN: November, '81, that would be 70%, and 10 then six months later the rest of it.
DR. ROSZTOCZY: Does this mean that at this time when 12 you submit to us the summary type of information, at that 13 same time the file is complete for all of that equipment?
14 MR. ALLEN: I don't think you could say it would be 15 100% complete, because, as Bill indicated, we'e got some 16 problem vendors, and that is-not going to be 100% complete.
17 Probably, what would you say, Bill, 10%?
18 MR. BINGHAM: I don't know. The intent would be to 19 have the information available that was prepared for the 20 summary sheets, so you might have 100% of the 70% in form 21 that could be auditable. I don'0 know whether you could have 22 it all in your records management system.
23 MR. ALLEN: No, it will be in hard copy.
24 MR. BINGHAM: There could be hard copy available to 25 review.
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MR. ALLEN: So as far as an audit team coming in and looking at it, we would have a hard copy available.
DR. ROSZTOCZY: So any time you get it to a submission then following the date, we could audit components which are in the submission?
MR. ALLEN: Yes. The microfilmed stuff wou1dn't be going on until later. You would probably rather audit the hard copy anyway.
DR. ROSZTOCZY: That's right.
10 MR. SLITER: If I understand from the previous conver<<
sation, there is a target date for submittal of 0588 summa'ata 12 ~
13 MR. BINGHAM: Yes. If you look at that schedule, 14 Figure 2, I believe it is, in the handout.--
15 MR. ROGERS: Figure 8. ~
16 MR. BINGHAM: I'm sorry, Figure 8, you will see the 17 November date. Look under Bechtel Power Corporation. It says summary submittal documentation of licensing and then 19 the site records available as well.
20 MR. SLITER: Thank you.
21 MR. ALLEN: Norm, do you have a comment?
22 MR. HOEFERT; I just wanted to add at this time, the 23 file you were talking about is being completed at Deer Valley 24 and the plant files are not completed. They are not in 25 condition I don', t believe to be audited at this time.
GRUMLEY REPORTERS Phoenix, Arizona
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MR. VAN BRUNT: I think that it would be fair to say that at that point in time, there would be one. complete file.
'Whether we would have the mu1tiplicity of files established and the multiplicity of microfilm established would be another matter, but there would be a complete file which would be auditable, and most likely that would be the hard copy file in the engineering offices.
MR. ALLEN: Are there any more comments on that item?
DR. ROSZTOCZY: Since we brought up this schedule, 10 maybe this is an appropriate time to bring up some comments in connection with the schedule. The schedule also shows som 12 NRC actions which are not correct. I don't expect to act on 13 this schedule that is on here.
14 MR. VAN BRUNT: You are going to do it faster; right?
15 That's what Harold told me.
16 DR. ROSZTOCZY: This one shows the issuance of the NRC 17 SER at.',:the same time as you are submitting to us, and we 18 normally require 10 months to do that work and not zero time.
19 MR. VAN BRUNT: Let me say that I discussed that with 20 Harold this:.morning somewhat and there are some difficulties 21 with that, I understand.
22 DR. ROSZTOCZY: This shows there are two submittal 23 dates and one of them is November, so that comes the end,of
'81', and then it says the final equipment qualification 25 summary submittal is the end of March, and exactly the same GRUMLEY REPORTERS Phoenix, Arizona
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time it shows an SER from NRC. That is just not possible.
MR. VAN BRUNT; Mell, as I indicated to you, I spoke with Harold Denton this morning some about that and had some conversations about it and I guess the question is partly a 5 legal question as to whether the Commission could issue an.
6 SER.
DR. ROSZTOCZY: It includes lots of practical question ,
8 too, and one of them is whether we would. even start to audit 9 it without having it be completed. It depends on the 10 availability of people, and it is a great inconvenience to 11 come out here for two audits as opposed to one audit and we 12 might nat do the actual audit until it is completed. Me woul 13 study the first submittal, we would select from there certain 14 things we wanted to audit, then we would wait for the comple-15 tion of the submittal study, select some more for audit, and 16 then come out and have one audit which covers both the first 17 and the second submittal. So I think that a realistic date 18 looking at this would be the end of '82.
19 MR. VAN BRUNT: Mell, my comment to that would be that 20 that is'unacceptable to us and we are certainly going to have 21 some conversations with the Commission about the schedule for
,22 the project. This is one issue in that whole situation.
23 So we are going to be looking at what we can do and I believe 24 that the staff will be looking at some things that they can do 25 so we can get to some common ground that will meet at least GRUMLEY REPORTERS Phoenix. Arizona
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our objectives if we hold up our end of the bargain for fuel load in '82.
DR. ROSZTOCZY: Right. I think it just points out the need to correct that scheduled time of submittals.
MR. VAN BRUNT: You have to understand that we can' speak for the staff. We can only write down what we would like to pursue.
DR. ROSZTOCZY: Right. Somewhat interrelated with this, also, the form what you are submitting here, I was 10 under the impression from the presentation that these dates here were -- I have to be careful here -- .the submittal that 12 is shown here, the November date and the March date, do those 13 represent all equipment qualification independently whether balance of plant or the CE plant system.
15 MR. VAN BRUNT: Bill, can you answer the intent on tha 16 I am not sure.
17 MR. BINGHAM:, Yes, that is the intent.
18 DR. ROSZTOCZY: So when the final part comes in, that 19 would mean it is complete for the entire plant.
20 MR. VAN BRUNT: Yes, I agree. That was the intent.
21 MR. KEITH: The CE schedule is shown on there.
22 DR. ROSZTOCZY: Yes, I think it is shown.
23 MR. VAN BRUNT: That is assuming that we don't have 24 some insoluable problems with, as Bill calls them, .recalcitran 25 vendors, which is the real world, I may say.
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NR. ALLEN: Any further questions' NR. NOONAN: I would just like to make one comment on the basic concept of this meeting. I think the meeting has been worthwhile. It has shown us what you have been doing and I think you have seen some of the NRC requirements.
A couple things I would like to repeat from yester-day. I said that the Commission is now on its hydrogen burn, problem. They are looking at it. While it doesn't affect your plant as much, it might affect other plants. I think 10 you ought to follow what -is going on there to see what is coming out of that, because they have asked us to look at 12 equipment under a hydrogen burn 'type of environment. It is 13 not a requirement 'yet, but clearly they are thinking that way, or at least they are asking us to look at it.
15 The purpose of this meeting is when you come in 16 with your submittal to have the best submittal that you can 17 possibly have so it cuts down on the staff review. Hopefully, 18 we could eliminate any questions and completely cut that 19 period out so we don't have this question and answer going 20 back and forth. We get the submittal, we look at it, and 21 then it is in good shape, we select out those items we want to 22 audit, we come out and audit them, and then we come out and
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23 render the SER.
NR. VAN BRUNT: I think from my opening remarks, that 25 is our intention as well.
GRUMLEY REPORTERS Phoenix, Arizona
~ I MR. NOONAN: Clearly, there are some schedule problems that we have to work on. I think we ought to do that as soon F
as possible to know what your requirements are so we can take a look at our manpower and work out a schedule that is compatible to both people, and you know from discussions with Harold that he wants to shorten down this whole proceeding and not lengthen it by any means.
MR. VAN BRUNT: While I wasn't here the full meeting, just based on the conversations that I have had with people 10 and the part of the meeting I have been here, I think that from our perspective, the meeting is being very helpful to us, 12 because, as we discussed this morning, while there are variou 13 standards and things that cover this area, there is a vast 14 interpretive area that is not written down, and I think we 15 have gone a long way in the interchange of information here 16 to understand the interpretations that you folks are putting this and it will certainly help us in at least where we
'n 17 18 can be as responsive as we can. So I think it has been helpf 19 to us.
20 MR. NOONAN: I think the, basic concept is to gain 21 confidence that the utility itself has a handle on all the 22 problems and is really involved in all the work and has not 23 just left its contractors dictate action and say we can work it out with the NRC. We would like to eliminate that part of 25 We would like to "see it more basically between the GRUMLEY REPORTERS Phoenix, Arizona
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licensee and the NRC.
MR. VAN BRUNT: The licensee is the responsible party.
MR. NOONAN: That's right. That is one of our main 4 concerns and that was one of the things we addressed yesterda 5 about the NSSS vendors. I understand there are some problems 6 there. But in this particular field, he feels that the NSSS 7 should also come under the same kind of a type o'f action, 8 and you probably have talked to him about that. 'So that is 9 that problem.
10 I think in general the meeting is worthwhile. It ll gives us an idea of what you are doing and how we11 you are 12 doing it. I guess I don't have any further comments.
13 Do you have anything further?
14 DR. ROSKTOCZY: I have some coranents, but I still have 15 questions in two areas. One of them is the failure of the 16 nonsafety equipment. It has been brought up yesterday and 17 there was some discussion on it. My understanding was that is you have a design criterion that nonsafety equipment indepen-19 dently how does it fail, "in which mode does it fail,'annot 20 degrad'e the operation of safety-related equipment. This is a rather strong criterion to have such a design cri'terion, and if you are executing it across the board everywhere for 23 your system, I think that is a positive item. I am not sure 24 how easy it is to accomplish this. Is this design criterion clearly spelled out in your FSAR?
GRUMLEY REPORTERS Phoenix, Arizona
MR. KEITH: I don'0 believe it is in the FSAR. Let 2 me describe for you just briefly what we do do. We do a 3 hazards review, a separation review throughout the plant, and there we look at all kinds of failures in each area. We go compartment by compartment throughout the plant, so we look 6 at failures in each area. Specifically in the seismic area, 7 we look at all the non-Category I equipment which is located 8 near Category I equipment to determine whether there is a 9 potential for this failing during a seismic event and damagin 10 Seismic Category I equipment. If we determine that there is ll that possibility, then we classify it as Seismic Category IX, 12 which means that it is supported to Seismic Category I 13 requirements. It doesn't have to function for anything 14 following the SSE, but we then support it to assure that it 15 will not fault and damage any Seismic Category I equipment.
MR. VAN BRUNT: That is specifically stated.
18 DR. ROSZTOCZY: But is that a more general criterion 19 in the FSAR across the board, not only for seismic,but for 20 other possible mode of failure areas?
21 MR. KEITH: Could you give me some examples of the 22 modes of failure you are thinking about? Maybe I can be more 23 specific ~
24 DR. ROSZTOCZY: This is a very difficult problem in 25 that it is a negative statement, not a positive statement.
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For example, if you inanufacture a truck, then it is relativel easy to test whether it does the purpose what it is manufactu ed for, but it is very difficult to test whether it has any othe kind of side effects, and our biggest concern is that there are only certain equipment that qualify for the environment.
There are many other equipment there which is not qualified.'he reason for not being qualified is that you don't depend on it. You are not planning to call on this piece of equip-ment, but do~you know the failure of those is not going to 10 cause some problem for you or for the operators of the plant who are seeing some of those other instruments also which are 12 not qualified.
13 1'E. BINGHAM: I think probably, Dennis, it would be best to review the question and then we can respond back to 15 the particular issue.
16 MR. VAN BRUNT': Bill, I think I agree with you. It is 17 a broad question and I think we would have to think about it.
18 The seismic area is one that we can deal with because it is 19 the specific one that we have considered. I think we would 20 have to think about the other one as to whet:her it falls in 21 the same category or not.
22 DR. ROSZTOCZY: I think it is very broad and, because 23 of that, it is very difficult, so I, would like you to take a 24 look at this and t:ell us what are you doing to assure yourself that you won't be surprised later.
I GRUMLEY REPORTERS Phoenix, Arizona
r q 0 MR. VAN BRUNT: We have made a note of that.
MR. KEITH: I would just like to ask if you are talkin 3 about the Crystal River, I know we addressed that in our last system review, where there was some non-IE instrumentation 5 which gave some problems.
DR. ROSZTOCZY: I don't have anything specific in, mind 7 but I think if you go back to some of the actual cases when 8 something happened, yes, you can bring out examples like the 9 Crystal River problem and any others. Every time when there 10 has been an accident, that kind of cascaded. Almost always ll I find some nonsafety grade equipment in the chain that had 12 some role in one way or another that contributed to the 13 accident. It is very difficult to address that. I am asking 14 you to try to do the best you can.
15 The second area where I would like to hear a little 16 bit more, and this I think is addressed to APS, is the 17 quality assurance of the equipment qualification review.
18 Your final submittal is going to have the statement that you 19 have reviewed all of the safety<<related equipment and you 20 found that they would function under their predicted environ-21 mental conditions. >lhat quality assurance programs do-you 22 have now that are going to help you to this final conclusion?
I 23 First, if we look at the work that is being done within your 24 own organi.zation, within APS'rganization, what quality 25 assurance procedures are being used there7 We were talking GRUMLEY REPORTERS Phoenix, Arizona
E yesterday about the equipment qualification team which has members on it from APS. Are they doing the work? What are they doing? Figuring out some of the sheets which we have seen? Are they doing calculations? Are they doing these under one of your quality assurance procedures? If yes, then which one? Have you had discussions with the other organizations like Bechtel and Combustion whether they are doing their work within their organizations under safety quality assurance procedures and which quality assurance 10 procedures are those? Then, finally, 'normally a quality
. assurance, department like your Quality Assurance Department 12 performs it work by auditing the process. They do go out and 13 they audit certain things within your organization and they 14 do go out and audit the other organizations, also. Have ther t
15 been any, audits on equipment qualification programs or 16 procedures either within your organization or within the 17 Bechtel organization or the Combustion organization or whoever 18 is involved for Palo Verde, and if there have been any, what 19 was the outcome of those audits?
20 ,MR. VAN BRUNT: I will be able to answer-"that partly.
21 Unfortunately, John Roedel, who is our quality assurance 22 manager, could deal more'pecifically with your question as 23 to what audits have been done and this kind of thing, had to 24 lea've and catch an airplane. Let me deal with it in a general 25 way and then we will deal with it specifically as an item afte GRUMLEY REPORTERS Phoenix, Arizona
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I go back to check the record.
Take the APS woxk first, which is the easiex. Ve have a procedure, NS 15, I believe that is the correct procedure, Revision 2, which is Class IE equipment qualifica-tion. This is a Nuclear Services Department internal procedure within APS. That is the procedure that is followed 7 by the engineers within our engineering organization in 8 doing the various and sundry reviews associated with equipmen qualification. That like all the other procedures that are 10 in the Nuclear Services Department procedures manual comes ll under the complete quality assurance program of APS and is 12 audited under that program. As to whether there have been Ie 13 audits made of that yet or not, John, can you answers MR. BARR(Ã: I might just add the last time it was 15 audited, I had to rewrite the, procedure, so it is right up 16 to date with what QA wants us to do.
17 MR. VAN BRUNT: I guess the answer directly as far as 18 APS'unction is concerned is yes to all those items.
19 Pith the Bechtel situation, I think I can also say 20 the same thing, that there is a procedure. I don't know the
- 2) number offhand. I presume first that the Bechtel quality 22 assurance ox'ganization, which has been delegated various 23 aspects of the overall Arizona Public Service Company quality 24 assurance program, has been auditing that and I would expect that our own quality assurance people have, audited that whole GRUMLEY REPORTERS Phoenix, Arizona
program as well or wi11 under our normal plan of events for the balance of this year or next year sometime. I don't know specifically whether they have or not. I would have to go back and check the records.
The CE program falls much in the same category.
CE has a quality assurance program. That program would encompass the equipment qualification program, and again within Combustion their quality assurance people would be l
auditing that program and we ourselves or in conjunction with 10 the Bechtel quality assurance organization will or have audited that program, too.
12 So I think across the board without getting into 13 the specifics of how many audits, when they were done and 14 what the results were, the answer to all three questions 15 is yes.
16 DR. ROSZTOCZY: In connection with your work, you 17 mentioned the procedure and you read the title of it. The 18 title had in it IE, which would indicate that it applies to 19 electrical equipment. Ve are talking here of equipment which 20 goes beyond the scope of electrical. Is there another 21 procedure that you use for the other areas or is this 22 procedure, even though it is called IE, being used in a 23 broader- terms 24 MR. VAN BRUNT: I will have to give you an answer on 25 that. I don't know.
GRUMLEY REPORTERS Phoenix, Arizona
MR. BARRCM: That procedure is being used.
MR. VAN BRUNT: Across the board?
MR. BARRCM: Across the board to review all equipment.
Although it specifically addresses 323 and 344, it can'be used to address any of the qualifications. It is all done 6 on that basis.
DR. ROSZTOCZY: Those were the two questions. Then I was asked if I wanted to make any comments. Yes, I would like to make some comments,.
10 MR. QUAN: Excuse me, before you do, on your last 11 question, there was some remark that Ed made that he could 12 answer generally. Has there more detail that you would like 13 in answering that question?
14 DR. ROSZTOCZY: Yes. it I think would be appropriate 15 if you would put it on the open item list and then we would 16 have a more specific answer which would include the processes 17 used within the three orgard.zations and some statement about 18 how the audits would have been performed and what was the 19 outcome of those audits.
20 MR. VAN BRUNT: And if 'we have not performed them, we will give you the schedule for those.
22 .DR. ROSZTOCZY: Just indicate that you haven't done it yet.
24 MR. VAN BRUNT: I can give it to you now that I intend 25 to. I know that for sure. I just can't tell you specifically GRUMLEY REPORTERS Phoenix, Arizona
N when.
DR. ROSZTOCZY: If some has already been done, I 3 would be interested to know what was the outcome of the audit Along the line of comments, I would like to 5 emphasize that this meeting has been the type of meeting 6 when we had Bechtel upon the stand presenting information to 7 us and we have been asking questions. Every time when this 8 type of a meeting proceeds, questions are being done in the 9 areas where some toughness for something missing is being 10 detected. Because of this, sometimes just listening to the 11 questions gave a negative picture of the overall process.
12 That is not necessarily the case. It should not be interpret 13 along those lines. I think we have seen during the past two 14 days that paramount work has been done, certain things have 15 been accomplished. At the same time, also, there is need for 16 additional work. In this area, in the equipment qualificatio 17 area, one might be able to cut it into three steps, the 18 overall process. One of them I would call really specifying 19 what needs to be done, the second one is to do the actual 20 testing, and then the third one is to look at the results of 21 those tests and arrive at some conclusions from them. Becaus 22 the testing process itself is rather lengthy and extensive in 23 many cases, especially with sequential testing, it is very 24 important to straighten out the first part, the front part, 25 as early as possible. Without that, the testing would go the wrong way or might go the wrong way.
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75 There have been a few items brought up here which are not fu11y resolved. I think you should pay special attention to those items and try to resolve those and to straighten those out so you won't be surprised later.
Mr. Noonan already mentioned the responsibility tha basica'lly rests with the licensee. In this .case, the utility hopefully will be the licensee.
llR. VAN BRUNT: One and the same.
DR. ROSZTOCZY: I don't have to elaborate on that, but 10 I would like to emphasize that this is a very 'important aspect of equipment qualification. In most areas when we are 12 reviewing the plant and the equipment qualification area, 13 we again in NRC do not review the equipment qualification of every piece or every type of equipment. It is just too 15 broad and there is too much work involved with it and we have 16 no intention to do that. Instead, we are only auditing it.
17 We are only auditing how good a job you have done, so we rely 18 on you even heavier in this area than we rely on you in other 19 areas. That is why we are very interested to know how are 20 you 'doing your work, because we depend on you very heavily.
21 We would like to certainly encourage you, you meaning APS, to 22 exercise an agressive leader role in this process. That is 23 where the main portion of the work is.
24 In terms of where do you stand today, we have not 25 received really a detailed account of this. We have seen some GRUMLEY REPORTERS Phoenix, Arizona
4V slides -and heard some remarks that provide some insight of where you stand, but we didn't see kind of an itemized accoun .
Typically, we'receive in the harsh environment area approxi>>
mately 90 to 100 types of equipment qualification summary sheets, which means more pieces of paper so many times. Even though 100 sounds like a lot, it is maybe not impossible to have some kind of a chart where you mark where you stand on each of, those and how close to accomplishment it is. Prom the slides which have been shown, it appears to me that right 10 now you have approximately nothing that has been fully completed yet. There was one item shown which was completed 12 at one time, but you are reviewing at least part of the proce s 13 again. It would be important to start to finish some of 14 them if you intend to finish all of them within a year.
15 The comments on the presentation in general, I personally felt that the presentations were maybe a little bit too general. Me spent a relatively large amount of time 18 on overall requirements probably both you and us are familiar 19 with and we spent only a limited amount of time on specific 20 Palo Verde items. If there is any future meeting or anything, 21 I for one would be interested to hear more of the specific 22 cases, just exactly how you do your work. Obviously, you 23 cannot do it for many pieces of equipment, but you can select 24 the one like we discussed some examples today and then discuss 25 the process for the event case. I have not seen, for example, GRUMLEY REPORTERS Phoenix, Arizona
a sample specification. It was not presented, so I don' know exactly what you do in writing the specification. How detailed are those? Are those kind of general or quite specific7 Me just didn't get to that. Me discussed only one part or maybe one-half of the scope. Obviously, one big open item is the other half of the scope. Also, there are still a fair number of unresolved issues even in the half that we have discussed. I am-not sure exactly what was the 9 goal of the board, what does the board want to accomplish by" 10 this meeting, and maybe we could talk a little bit about that but because we have seen only half and because there are outstanding items, I don't think we are at the final point 3
12 13 yet. Maybe it would be appropriate to have a second meeting.
If there is such a second meeting, then probably the focus 15 at that meeting should be on APS'ole in the overall qualifi cation, how the ~hole thing is being pulled together, and the 17 of course, on the second half, the part that we didn't have, 18 and the outstanding items which are not finished at this time 19 yet or weren't resolved.
20 One comment that has been made by someone, and I am 21 not sure who made it, during the meeting was a recommendation 22 for some kind of a 'verification program on the environmental 23 : parameters. The purpose of this would be that the environ-24 mental parameters are postulated in a'onservative manner and 25 the actual parameters like temperatures and equipment that is GRUMLEY REPORTERS Phoenix, Arizona
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exposed to aging or radiation levels and the accumulated dosage to radiation might be significantly different than it was assumed when the qualification was made. If it is 4 'significantly lower, for example, than this could extend the qualified life of the equipment. Maybe this is the right ti l'o give some thought to that and see if you want to undertake some kind of a program. It really would require only to have measurements taken at some locations and those be read at 9 certain intervals. Maybe that could be helpful for your staf 10 as well as for others who are having the same question.
Overall, I think the meeting has accomplished a lot 12 but there is still some more to be done in the future.
13 MR. VAN BRUNT.: Let'me respond to that. I think 14 really you only asked. me one question. There may be a 15 number of areas that we ought to take a look at, and we will 16 take a look':at it. The one question I heard directed to me 17 or to the board, and I will speak to that, is what did we 18 expect to accomplish. In the di.scussions that I have had wit 19 Harold Denton about this particular program, when I say 20 program I mean the concept of a systems review, the intent of 21 that was to, in essence, replace what I'all the 20 questions 22 phase that we used to use for getting through a construction 23 permit application or a licensing application wherein we 24 would submit an FSAR or a PSAR, as the case may be, the staff 25 then review that and send us a myriad t'ould of questions and GRUMLEY REPORTERS Phoenix, Arizona
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we woul'd send you a myriad of answers, and usually that ~ould beget more questions-and we would give you some more answers, and after while we would narrow it down so we only had a few open items and then we would sit down and talk. The purpase of this is that the board, in essence, was going to serve the function of that question and answer phase on both sides of the table..
Ne as the applicant are responsible. Me should kno as much about this plant if not more:than you do. Your 10 purpose here is certainly to observe what we have done and see whether we are knowledgeable about the plant and to 12 participate to the extent that'is appropriate. In this 13 particular instance with equipment qualifications, I think 14 your participation was very important, because, without being 15 critical at all of the staff, and,that is not my intention, it is an area that is very, dynamic; awhile there are 17 standards and other documents that supposedly describe the 18 area, there is an enormous amount of interpretation that goes 19 with them. So the question and answer exchange that has 20 gone on here is one that.I think has given you the opportunit 21 to understand what we were doing, where we were heading, what 22 our interpretations were, and it gave us an opportunity to 23 hear from you after you looked at what we were doing to see whether that matched what your interpretations were. I think 25 in many cases, it did, and in some areas, it didn', and GRUMLEY REPORTERS Phoenix, Arizona
in some areas we have given, you some food for 4'ossibly thought as to whether maybe you are going down the wrong line or not. That is what the purpose of the board was. The boar is meant to be a group that is knowledgeable in, this area.
Xt is a group that understand what Bechtel is doing from inside, what Bechtel is doing as we view it from outside, what APS is doing, and then some independent people who are not involved in the day-to-day fray, so to speak, who can look at all of us and tell us a little bit about what. we'e 10 doing or ask questions that we may not be able to see. So that is the purpose of it. The open items then that come out 12 of it are questions that I would see in the old way of doing 13 business that would be at the end of the two, or three 14 exchanges when you really get down to the nitty-gritty issues 15 that have to be solved. Those now will be extracted from the 16 transcript from the list that Terry and Gerry have kept and 17 dealt with letterwise and will form an addition to the 18 transcript. Then somebody.like yourself sitting down in the 19 evening quietly can read all that stuff and you should have a 20 complete picture of our program and what we are going to do.
21 From that, then you should be able to draw a conclusion as 22 to whether you think our program is adequate or not, whether 23 we aredoing the right thing, whether we satisfy all the 24 regulations, and then, certainly because there is information yet to be submitted, audit that information. Having done all GRUMLEY REPORTERS Phoenix. Arizona
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1 that, you ought to have a nice warm feeling that all the 2 equipment that goes in this plant is satisfactory.
I, think that is a lot of words to indicate what we see this whole thing is about. I have some question in my mind whether a programmatic ~ ,of .review such as this one 6 was lends itself as much to- this kind of an exchange as a 7 true systems review where you'e got a piece of hardware you 8 are looking at, because there is so much interpretation that 9 goes on, but I can say from our side of the table, so to spea 10 that it has been very, very helpful to us to have this interchange and get some information. I hope it has been the 12 same to you folks.
13 Anybody else on the board want to say anything7 MR..ALLEN: I think that summarizes it pretty well.
15 MR. NOONAN: Xf I could )ust make one more minor 16 comment. A lot of utilities seem to have a problem sometimes 17 coming to us and discussing problems in advance. They know 18 about it, but they don't feel like they can come to NRC and 1g open Pandora's box, so to speak. I would like to change 20 that attitude at least in the areas that I am responsib3.e for 21 and I would offer that any time you want to talk about any 22 matter, whether it is during business hours or even after 23 business hours, problem that you have or matters of interpre-24 tation, I would sure offer to do whatever I could to get you 25 that interpretation in as short a time as possible.
GRUMLEY REPORTERS Phoenix, Arizona
MR. VAN BRUNT: We appreciate that. I assure you we are not bashful.
MR. ALLEN: If there are no further comments, I think we should review the open items that we have identified today Why don't we take about a 15-minute break.
(Thereupon a brief recess was taken, after which proceedings were resumed as follows: )
MR. ALLEN: Terry Quan'ill read the open items that we have identified today.
10 MR. QUAN: Continued from yesterday's list, Open Item 23: How thoroughly does the qualification team ensure that 12 the required response spectrum supplied to the vendor for 13 instrumentation is not for the floor only, but includes inst rumenta tion support >
15 Open Item 24: How is it verified that the equip-16 ment installed in the field is the same type as the 'equipment 17 that was seismically qualified7 Different types of equipment 18 have different seismic effects; i.e., rigid versus flexible 19 conduit.
20 'Open Item"25: What are the exceptions to fu11<<size 21 equipment seismic tested'or these exceptions, is additiona 22 more accurate instrumentation required to provide data to 23 perform proper scale analysis'P 24 Open Item 26: How are seismic loads combined with 25 accident loads?
GRUMLEY REPORTERS Phoenix, Arizona
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Open It:em 27: On Exhibi.ts IV>>5 and IV-5A, vaxious 2 items should be corrected t:o show IEFE 344-1975 and IEEE 323-1974.
Open, Item 28: In Exhibit IV-11, the equipment '
qualification checklist is to be modified to show that the 6 equipment can perform in its operational mode during and 7 after the testing. Also include operational parameters that 8 were monitored during testing.
Open Item 29: How will preventive maintenance 10 necessary to maintain qualification be differentiated from other preventive maint:enance in the environmental qualifica<<
k 12 tion sectionsf 13 Open Item 30: In Exhibit VI-4, add to the 14 environmental qualification checklist a check-off box for 15 acceptance of the Arrhenius method used in Item 4) of that 16 exhibit.
17 Open Item 31: Define the qualification team's burn 18 in policy.
19 Open Item 32: How is it assured that complete 20 systems are qualified when system components are qualified individually, especially systems requiring a BOP/NSSS interface.
23 Open Item 33: In Exhibit VI-1, review the checklis 24 for applicability of the DBA and time when x'equired shown for nonharsh environments.
GRUMLEY REPORTERS Phoenix. Arizona
Oi Open Item 34: In Exhibit V -1, consider listing not only the systems, but also the components af that system on the equipoient qualification checklist.
Open Item 35: Insert "updated Exhibit VI-6 ~
Open Item 36: Change the sign off on the equipment qualification checklist from "Evaluation Approval" to more appropriate wording such as "True and correct to the best of my knowledge.
9 Open Item 37: For equipment that has been aged 10 to required qualification, its continued life is uncertain.
ll What assurance is there that this equipment can be install d 12 in the plant.
13 DR. ROSZTOCZY: I think that it should not be installe 14 i,n the plant.
15 ?K. QUAN: I think there was some question of whether 16 the equipment can be refurbished and then installed.
17 DR. ROSZTOCZY: It should not be. It should not be an 18 it should never be used in the plant, so you need assurance 19 that it will not be i.nstalled i.n the plant.
20 MR. QUAN: I thought there was some question that our 1
21 assurance could cover possibly refurbi.shing.
22 MR. ALLEN: Rebuildi.ng. Rebuilding or replacing aged 23 components and then put them back in'he plant.
DR. ROSZTOCZY: It is very questionable.
25 MR. ALLEN: . Mell, li.ke a piece of equipment that has a limited life. component," if it is qua ified overall for GRUMLEY REPORTERS Phoenix, Arizona
40 years arfd the capacitor for t n years, then you would 2 have to change the capacitor out in ten years, but the 3 equipment overall still remains qualif ied.
DR, ROSZTOCZY: The emphasis was that if you have aged a piece of equipment to the extent of the 40-year life of the plant, that piece of equipment should not be installed
.7 in the plant because it is starting its 41st year now and 1
it is not qualified to work in its 41st year.
MR. ALLEN: Because it is'ver 40 years. Okay, we 10 understand what you mean.
DR. ROSZTOCZY: You need assurance that the tested 12 piece will be discarded because it has already been aged.
13 MR. ALLEN:, Yes.
14 MR. QUAN: Let me rephrase that.
15 DR. ROSZTOCZY: When it is appropriate, I think refurbishment can be consummated, but it would have to be very carefully done to be sure that all those parts which are susceptible to aging or susceptible to radiation, that all of those parts have been fully replaced in the system.
20 MR. QUAN: Is it it all right as stands? ,I would think that would be part of the assurance program.
22 DR. ROSZTOCZY: Would you please read the question 23 again?
24 MR. QUAN: For equipment that has been aged the 25 required qualification, its continued life is uncertain.
GRUMLEY REPORTERS Phoenix, Arizona
r 86 What assurance is there that this equipment can be installed 2 in the plant by re furbishing?
DR. ROSZTOCZY: No, I think it should be rewoxded.
4 What assurance is there that it wi.ll not be i.nstalled in the plant unless it i.s appropriately refurbished?
MR. QUAN: I will restate the question. Open Item 37:
For equipment that has been aged the requi.red quali.ficati.on, i.ts conti.nued li.fe is uncertai.n. What assurance is there that this equipment i.s not installed in the plant unless it 10 is appropriately refurbished?
Open Item 38.
12 MR. ALLEN: Just a second. Ed, di.d you have a questio 13 lm. STERLING: For clari.fication's sake, instead of 14 referring to it in the second section as pieces of equipment 15 which have been qualified, menti.on test specimen, because we 16 are not talki.ng about a generic group of equipment, but rathe 17 that piece of equi.pment that was actually tested and aged.
18 MR. VAN BRUNT: John, I thi.nk you'e got enough 19 i.nformation i.n the record on, this so that we understand what 20 the question i.s. I don't think Terry needs to rephrase the 21 question again.
22 MR. QUAN: Open Item 38: For the seismic example, 23 Exhibits VI-8 through VI-11, i.ncorporate the open i.tems inclu ed 24 in the environmental example, Exhibits VI-1 through VI-6.
Open Item 39: What is bei.ng done to assure there GRUMLEY REPORTERS Phoenix. Arizona
isn't any possibility of the failure of nonsafety-related equipment affecting the op'eration of any safety-related equipment?
Open Item,40: Describe the Arizona Public Servtc e Company's quality assurance program in detail as it relates 6 to the equipment qualifications. -Also describe the audit of 7 APS'quipment qualification procedures, vendor qualifica-8 tion programs, and Bechtel equipment qualification programs, 9 including the outcome of those audits.
10 That's all. Does anybody have any additional open 11 items?
12 MR. ALLEN: Carter.
13 MR. ROGERS: I would like to add one from yesterday.
14 Yesterday during the proceedings, there was discussion 15 pertaining to qualification of equipment in safety-related 16 areas. Question was made as to whether there is redundant 17 cooling in all of the safety-related areas. The response 18 made at that time was yes, there is redundant cooling. I 19 talked to Bechtel after the meeting and, while I am sure that 20 there is some redundant equipment in some areas, I am not 21 certain that all areas have redundant equipment. Bechtel, 22 due to the time problem, was unable to confirm one way or 23 another this a fternoon, so I would like, to add as an open 24 item this particular subject, and I would like to further ask 25 Bechtel that if there are areas that contain safety-related GRUMLEY REPORTERS Phoenix, Arizona
'e 1 equipment where the cooling is not redundant.and the failure 2 of a cooling system could cause excursions into temperatures above normal to address how those are to be handled in the quali.fication program. That i.s a 'lot of words. I thi.nk that the question, Terry, we could phrase fairly easily by saying are all areas containing safety-related equipment served by 7 redundant HVAC and, if not, what is done to account for this 8 in the qualification program.
MR. QUAN: I am not quite sure that second question is 10 phrased correctly.
MR. ROGERS: If not, and if a failure of a nonredundan 12 system occurs, how is that failure handled in the qualificati 13 program?
V 14 MR. VAN BRUNT: Terry, why don't you give all,those 15 words in, the record a number.
16 MR. QUAN: Open Item 41: Is there redundant HVAC in 17 all areas where safety-related equipment i.s located? If not, 18 what i.s done 'to assure a failure of the nonredundant HVAC 19 will not affect the qualification parameters of the safety-20 related equipment?
21 MR. ALLEN: Any further questions or items that you 22 'ould li.ke added to the open item list? Are there any 23 additional items that anyone would like to discuss? Okay, 24 fine.
I would like to thank the board members for thei.r GRUMLEY REPORTERS Phoenix. Arizona
participation and the NRC for taking their time to come out a n
d participate in our system review. I would like to thank the 3 presentors from Bechtel and everyone that showed up to 4 observe the proceedings. I will declare the meeting closed.
10 I HEREBY CERTIFY that I was present at the meeting:
11 before the Palo Verde Generating, Station Equipment Qualifica-12 tion Review Board; that I made a shorthand record of all 13 proceedings and testimony had and adduced before said Review y4 Board at said meeting; that the foregoing 389 typewritten pages constitute a full, true 'and accurate transcript of said 16 record, all to the best of my skill and ability.
17 18 RK . GRU 19 urt Reporter 20 21 22 23 24 25 GRUMLEY REPORTERS Phoenix, Arizona