ML17296B133
| ML17296B133 | |
| 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 8012170530 | |
| Download: ML17296B133 (395) | |
Text
SYSTEM REVIEW of the PALO VERDE NUCLEAR GENERATING STATION EQUIPMENT QUALIFICATION Before the EQUIPMENT QUALIFICATION REVIEW BOARD 10 12 13 14 15 VOLUME I OF III Pages 1 213 17 18 19 20 21 22 Y
23 Phoenix, Arizona 24 September 25 6 26, 1980 25 GRUMLEY REPORTERS Phoenix, Arizona gol8.~1 o S lo
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VOLUME I September 25, 1980 I N D E X Participants
,Introduction 14'7
Background
. Design Criteria Overview 67 10 Environmental Qualification Criteria Standard Review Plan 3.11 and General Design Criteria 1, 2, 4, 23 87 12'3 IEEE Standards 106 Reg. Guides 143 14 NUREG -0588, Commission Order CI I 80-21, 15 IE Bulletin 79-01B, 10CFR50 Appendix B 150 16 PVNGS Environmental Classifications 174 17 Recapitulation of Open Items 206 18 20 21 22 23 24 25 GRUMLEY REPORTERS Phoenix, Arizona
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VOLUME I
- -:September 25, .1980 3 BOARD MEMBERS 4 EDWIN E. VAN BRUNT, Jr.
APS vice President Nuclear Projects Management ANPP Project Director JOHN M. ALLEN Nuclear Engineering Manager Arizona Public Service Comp'any 8
A. CARTER ROGERS Nuclear Engineering Manager Arizona Public Service Company 10 JOHN T. BARROW Supervising Electrical Engineer Arizona Public Service Company A
12'3 WILLIAM F. QUINN Supervising Licensing Engineer Arizona Public Service Company 14 EDWARD C. STERLING III 15 Supervising Instrumentation and Controls Engineer Arizona,Public'Service Company 17 NORMAN,L. HOEFERT PVNGS Operations Engineering Supervisor 18 Arizona Public Service Company 19 ROGER W. CLARK Supervisor of Electrical Design 20 Generation Engineering Department Arizona Public Service Company 21 JOHN A. ROEDEL 22 Manag'er., Quality Assurance Arizona Public Service Company 23 KARL KREUTZIGER 24 Chief Electrical Engineer Bechtel Power Corporation 25 GRUMLEY REPORTERS Phoenix, Arizona
DR. SHELDON FREID Nuclear Staff Group Leader Bechtel Power Corporation PETER C. NEWCOMB Supervisor of Equipment, Qualification Instrumentation and Control Engineering Department Combustion Engineering, Inc.
PAUL WOLFE PVNGS Assistant Project, Manager 7 Combustion Engineering, Inc,.
DR. GEORGE SLITER Coordinator of EPRI/Utility Equipment Qualification Owners Group Electric Power Research Institute 10 VINCENT S. NOONAN Assistant Director for Materia'ls and Qualification Engineering 12 Division of Engineering Nuclear Regulatory Commission 13 f DR. ZOLTAN R. ROSZTOCZY 14 Chief, Environmental Qualification Branch Nuclear Regulatory Commission 15 16 ARTICIPANTS 17 WILLIAM G. BINGHAM 18 PVNGS.Project Engineering Manager Bechtel Power Corporation 19 DENNIS KEITH 20 PVNGS Assistant Project Engineer Bechtel Power Corporation 21 GERALD KOPCHINSKI 22 PVNGS Nuclear Group Supervisor Bechtel Power Corporation 23 ROBERT CARSON 24 Electrical Staff Engineer Bechtel Power Corporation
'RUMLEY REPORTERS Phoenix, Arizona
BRUCE LINDERIPN Bechtel Civil/Structural Staff Seismic Qualification Working Group Leader Bechtel Power Corporation KENNETH SCHECHTER Deputy Group Supervisor PVNGS Civil/Structural Group Bechtel Power Corporation ROBERT STIENS PVNGS Assistant Project Engineer Bechtel Power Corporation TERRY F. QUAN 9= Licensing; Engineer Arizona Public Service Company 10 J. PATRICK SHREWSBERRY Licensing Engineer Arizona Public Service Company 12 EDWARD J.'-'. GOUVIER 13 Electrical".Engineer Arizona Public Service Company 14 MARTIN L. RAINES l.5 Electrical Engineer Arizona Public Service Company MARK L. HYPSE 17 Electrical Engineer Arizona Public Service Company 18 LEONARD A. YORK 19 PVNGS Operations-Technical Engineer Arizona Public Service Company 20 SARJAPUR M. JAXADEV 21 PVNGS Operations Electrical Engineer Arizona Public Service Company 22 JANE A. BRAND 23 Manager of Community Relations Arizona Public Ser'vice Company 24 DR. HAROLD R. DENTON 25 Director, Office of Nuclear Reactor Regulation Nuclear .Regulatory Commission GRUMLEY REPORTERS Phoenix, Arizona
RICHARD A. VOLLMER Director, Division of Engineering Nuclear Regulatory Commission JANIS D. KERRIGAN PVNGS Project Manager Licensing Branch I3 Division of Licensing Nuclear Regulatory Commission JOHN BERGGREN CESSAR Project Manager Standardization and Special Projects Branch Division of Licensing Nuclear Regulatory Commission HERMAN E. LaGOW 10 Systems Consultant Nuclear Regulatory Commission ARTHUR C. GEHR 12'3 Attorney at Law 6 Wilmer 'nell CHARLES A. BISCHOFF Attorney at Law Snell & Wilmer 15 16 OBSERVERS 17 KENNETH COOK 18 Washington Public Power Supply System 19 W. C. MOODY 20 Southern California Edison Company 21 THOMAS C. GROZAN Florida Power and Light Company 22 J. K. MARTIN 23 Public Service Company of Oklahoma 24 S. A. BERNSEN Bechtel Power Corporation 25 WILLIAM H. WILSON B chtel Power Corporation GRUMLEY REPORTERS Phoenix, Arizona
v NORA MEADOR Arizona Public Service Company LAURIE MOORE Arizona Public Service Company DON LAWSON Arizona Public Service Company ROD CHAPIN Arizona Public Service Company REX KRAMER Arizona Public Service Company LEON ICARD Arizona Public Service Company 10 MARTHA McKINLEY Arizona Public Service Company L. E. VORDERBRUEGGEN 12'3 Nuclear Regulatory Commission ED REIS Nuclear Regulatory Commission 14 STAN NOURIKI 15 Nuclear Regulatory Commission 16 DENNIS J. CHIN Florida Power and Light Company 17 PAUL GROS Sl Q.N 18 Ebasco Services, Inc.
19 JEFF COHEN 20 JILL LEGG 21 LEE HOURIHAN 22 23 24 GRUMLEY REPORTERS Phoenix, Arizona
The'quipment Qualification Review Board of the Palo Verde Nuclear Generating Station convened in Pizarro Room C, 3 Del Webb's Townehouse Hotel, Phoenix, Arizona, on the 25th 4 day of September, 1980, Mr. Edwin E. Van Brunt, Jr., Vice-5 President, Nuclear Projects Management, Arizona Public 6 Service Company, Presiding.
MR. VAN BRUNT: My name is Ed Van Brunt. I am Vice-
,9 President, Nuclear Projects Management for Arizona Public 10 Service Company, and I am the officer responsible on a full-time basis for the engineering design, construction, and 12 quality assurance for the Palo Verde Nuclear Generating 13 Station.
14 The purpose of today's meeting is to perform a.
15 system review of the Palo Verde Nuclear Generating Station 16 Equipment Qualification Program. The concept of performing 17 system reviews was developed in a number of meetings which we 18 had with Dr. Denton. With this concept, the design of a 19 specific plant system 'or the structure of a specific program 20 is thoroughly reviewed for adequacy of design and compliance 21 with regulations by Bechtel project personnel in the technical 22 disciplines that are encompassed by the particular system or 23 program in question. Bechtel Power Corporation, as I am sure 24 most of you are aware, is the architect, engineer.', and 25 construction manager for the Palo Verde Plant. The system GRUMLEY REPORTERS Phoenix, Arizona
1 review is then formally presented by the Bechtel project staff to a review board of technical experts for concurrence.
3 Participation by Nuclear Regulatory Commission personnel in 4 this presentation is encouraged and should aid their under-standing of the system design bases or criteria, detailed design, construction,'rogram philosophy, review procedures, I
and system operation, thereby minimizing, if not eliminating, the review manhours required for that particular system or a
program.
10 As a result of the discussions that I have had with 11 Dr. Denton on this subject, APS to date has performed several 12 system reviews. They include the DC and AC Class IE Power 13 Systems and the Auxiliary Feedwater System. The first system 14 review of the DC Power System was performed here in Phoenix.
15 The second review of the AC Power System was done in the Nuclear Regulatory Commission offices in Bethesda, Maryland, 17 to provide an opportunity for greater participation and 18 observation by NRC management and staff. The latest review 19 was of the Auxiliary Feedwater System and was held here in 20 Phoenix late last month. Figure l provides the current 21 status of ongoing activities for these past system reviews 22 and also indicates the reviews that we have planned at least 23 through January or February. of next year. You can see at the 24 top that the DC Power System review is just about complete 25 and we are in the process of getting ready to submit the final GRUMLEY REPORTERS Phoenix, Arizona
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information to the NRC staff. The AC Power System review has been completed, the transcript has been sent to NRC, and we are in the process right now of resolving outstanding items, which will then be ultimately sent to the staff. The
, Aux Feedwater .System, which was done a couple of weeks ago, is at the stage of review of the transcript to correct errors, and as soon as that is completed, we will be sending that to the staff and then proceeding with the rest of the 9 activities. The Equipment Qualification, of course, will be 10 started here today, and we have scheduled in the month of October balance of plant instrumentation and control systems.
12 Then we have in early December fire protection, and then 13 after the first of the year, we are looking at the control 14 room design. Depending on the outcome of further discussions 15 with the staff, we may have some additional rev'iews to cover other systems or other parts of our application. That is 17 kind of the status.
18 We did a little research. We went back and looked 19 at how long it took us to do the DC Power System review 20 a't construction permit time using 'what I would call the 21 20-questions type of approach. Surprisingly enough, it took 22 us about, eight months, and if you look here from start to 23 finish, on this, assuming that there won't be any further 24 questions, it has only taken about six months, so there is a 25 saving in time involved in proceeding this way which I thought GRUMLEY REPORTERS Phoenix, Arizona
1 was, of some interest.
As I indicated, today we will be performing a revie 3 of the Equipment Qualification Program for the safety-related 4 balance of plant equipment, particularly as it relates to 5 compliance with NUREG-0588 for electrical equipment and applicable IEEE Standards. To explain what I mean by balance 7 of plant, I would like to mention that Palo Verde is-a 8 standardized plant with a separate Final Safety Analysis Report for the Nuclear Steam .Supply System portion of plant.
10 The Combustion Engineering Standard Safety Analysis Report 11 Final is referred to extensively in the Palo Verde Final
-12 Safety Analysis Report whenever information concerning the 13 Nuclear Steam Supply System is needed. The balance of plant for this, project is the equipment not within the Combustion 15 Engineering scope of supply. The CE scope of supply includes 16 the standard Nuclear Steam Supply'lant plus various other 17 options that APS has purchased from Combustion Engineering,... he 18 responsibility for the adequacy of the qualification of 19 equipment supplied by Combustion Engineering is clearly the 20 ultimate responsibility of the applicant referencing the 21 Combustion Engineering .Safety Analysis Report; in this paxti-22 cular case, Arizona Public Service'Company. However, the 23 details of this information is addressed using topical reports 24 CENPD-255 and CENPD-182 for Instrumentation and Control 25 Equipment and by CESSAR for other equipment in Combustion GRUMLEY REPORTERS Phoenix, Arizona
Engineering's scope.
We had planned to review this information as a part of the review of CESSAR and have not prepared any specific presentations today for that part of the equipment qualifica-tion; However, in some discussions we had here earlier, we have been requested to at least indicate'! how we plan to handle the equipment qualification for CESSAR. We will do that today and we will try and provide some other information and respond to any questions anybody has to the best of our 10 ability. We do not really have the appropriate people from Combustion Engineering here today to make a detailed presenta-12 tion.
13 The Bechtel project staff has prepared the Balance 14 of Plant Equipment Qualification Review, and it will cover 15 the following general areas:, Qualification Criteria, review procedures, specific examples, and difficult qualification 17 areas.
18 Bechtel will prepare formal responses to any open 19 issues defined by the Review Board during this review. These 20 responses will be reviewed by the Review Board for concurrence 21 Final resolution'of these items will be provided to the 22 Nuclear Regulatory Commission.
23 For today's review, we have assembled a review board 24 with a varied background due to the complexity of the program 25 being reviewed. Since the responsibility for an adequate GRUMLEY REPORTERS Phoenix, Arizona
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review lies with the applicant, that is, Arizona Public Service Company, the board's basic formation starts with selected APS technical personnel complemented with personnel 4 from other groups who have expertise and experience not necessarily available within the Arizona Public Service 6 Company organization. Prior to this meeting, board members were provided with appropriate sections of several documents to familiarize them with the Palo Verde Equipment Qualificatio 9 Program. These included sections from the Palo Verde Final 10 Safety Analysis Report, various IEEE Standards, related 11 NUREG documents including NUREG-0588, the Palo Verde Nuclear 12 Services Project Procedures Manual, and the Standard Review 13 Plan. At this time, I would like to introduce the members of 14 the board and say a few things about their responsibilities 15 in their various organizations.
16 John Roedel is the APS Nuclear Quality Assurance 17 Manager and reports directly to me. John is responsible for 18 development and compliance with the Corporate Quality 19 Assurance Program for Arizona Public Service Company. John 20 Allen, sitting, here to my left, is one'of two APS Nuclear 21 Engineering Managers who report directly to me. John is 22 responsible for the areas of electrical engineering, instru-23 mentation and control, licensing, and health physics and has 24 the primary responsibility for equipment qualification at 25 Arizona Public Service Company. He is also responsible for GRUMLEY REPORTERS Phoenix, Arizona
our records management section, which will be the ultimate resting place for all of these records. Carter Rogers'is the 3 other APS Nuclear Engineering Manager who reports directly to 4 me. Carter has responsibilities for mechanical engineering, 5 chemical engineering, civil engineering, nuclear fuel, and other nuclear-related items. Bill Quinn is the Supervising 7 Licensing Engineer. Bill reports to John Allen and has 8 responsibility for all licensing matters and coordinating the day-to-day interface with the Nuclear Regulatory Commission 10 assigned project manager in such matters. John Barrow is a Supervising Electrical Engineer who reports to John Allen.
12 He is responsible for the review of the Palo Verde electrical 13 systems for APS and the day-to-day interface with Bechtel r
and Combustion Engineering personnel in these areas. He also 15 has the responsibility of coordinating the APS effort for 16 Equipment Qualification. Ed Sterling is a Supervising U
17 Instrumentation and Control Engineer who also reports to 18 John Allen. He is responsible for the review of the Palo 19 Verde instrumentation and control systems and the day-to-day 20 interface with Bechtel and Combustion Engineering on these 21, systems..- Norm Hoefert is the Operations Engineering 22 Supervisor at the Palo Verde Plant and is responsible to the 23 Engineering and Technical Services Superintendent for mech-24 anical and electrical engineering support, including 25 monitoring station performance and the in-service inspection GRUMLEY REPORTERS Phoenix, Arizona
1 program.
We have also asked Roger Clark, Supervisor of 3 Electrical Design with the Arizona Public Service Company's 4 Generation Engineering Department, to participate as an
-5 independent member from APS on-this board. Roger is not 6 directly involved in the Palo Verde Project, although from 7 time to time, he has been utilized as a consultant in various 8 areas.'oger has been with APS for nine years and has been t involved in electrical system design for APS'ossil power 10 plants. Prior to APS, he was with Stone and Webster for, ten years as an electrical'engineer and for four of those 12 .years worked on nuclear projects, namely Surry l and 2 and 13 North Anna 1.
14 Two review board members, are from the Bechtel 15 Engineering staff. These representatives are Karl Kreutziger, 16 Chief Electrical Engineer, and Dr. Sheldon Freid, Nuclear 17 Staff Group Leader. They are not directly involved 'in the 18 design of the Palo Verde Project; however, they may be used 19 as consultants to the Bechtel .Palo Verde Project Group as 20 required.
21 . Representing Combustion Engfneering on the review 22 board are Paul Wolfe, Palo 'Verde Assistant Project Manager, 23 and Pete Newcomb, Supervisor of Equipment Qualification, 24 Instrumentation and Controls Engineering. Paul reports 25 directly to the CE Project Manager and is responsible for the GRUMLEY REPORTERS Phoenix, Arizona
CE interface with APS, specifically the Palo Verde Project Nuclear Steam Supply System equipment qualification and the generic equipment qualification for all the System 80
,4 projects. He is also responsible for providing licensing support, technical support, and liaison with the CE plant engineering staff. Pete works in the Instrumentation and Controls Engineering group and'does not report to the CE Palo Verde Project Manager.'; However, he is responsible for all CE Nuclear Steam Supply System Instrumentation.-and 10 Controls equipment qualification. Combustion Engineering, the Palo Verde Nuclear Steam Supplier, is involved in this 12 review only to deal'ith the BOP-Nuclear Steam Supply Syst'm 13 interface requirements and,'s I indicated previously, it 14 had been our plan to discuss in a.separate meeting the 15 equipment qualification for the CE equipment for Palo Verde 16 and to clearly define at that time the utility's supervision 4
17 and responsibilities"in that program. We will try and deal'ith 18 some of that here today as we can.
19 To piovide added expertise on the board in the 20 relatively new area of equipment qualification, APS has 21 asked Dr. George Sliter, of the -Electric Power Research 22 Institute, to participate on this board. George is the 23 coordinator of the EPRI(Utility Equipment Qualification 24 Owner's Group. He is also the EPRI Project Manager for the 1
25 Equipment Qualification Data Bank.
GRUMLEY REPORTERS Phoenix, Arizona
i lo The NRC has sent a number of representatives, as Janis Kerrigan has inwcduced, to participaw in tnis system revie and we welcome .their full participation.
We will provide a transcript of this review to the Nuclear Regulatory Commission as soon as we have received and proofed it from the court reporter. For the benefit of the couxt reporter, I would ask'hat the review board members or anyone else, for that matter, please identify themselves before making any statements, and I would appreciate if you 10 would not make any statements or anything else until you are recognized by the Chair so we can at least have a little orde 12 out of chaos. We encourage the NRC representatives present 13 to participate in this review as well, As, indicated by Janis, we will not entertain questions from the public during the 15 review. However, members of my staff and members of the 16 Commission will be available following the meeting to answer 17 any questions that members of the general public might have 18 relative to this interchange of information. that is going to 19 go on here today. At the completion of the review, any open 20 items which have been identified will be reviewed and, when 21 agreement on their scope has been reached, Bechtel or other 22 responsible organizations assigned for xesponse will be 23 designated to prepare appropriate responses, which will be sen 24 to the members of the board for theix review, comments, and 25 ultimate concurrence.'pon complete board concurrence with GRUMLEY REPORTERS Phoenix, Arizona '
1 the responses, these will then be formally sent to the 2 Nuclear Regulatory Commission for their review. In this 3 connection, I would ask Terry Quan, from my staff, and Gerry 4 Kopchinski, of Bechtel's project staff, to keep independent 5 notes of open items and then we will kind of back through them and backcheck when the meeting is completed.
Bill Bingham, who leads the Bechtel group, will indicate how they are going to make their presentation, and I would request in that context, Bill, that, at the appropria e 10 points in your presentation, the board be given opportunity 1
to ask ques tions .
12 Incidentally, as a side issue, I will be leaving 13 the::meeting at about 11:30 to accompany Dr. Denton on a tour 14 of the Palo Verde construction site, and at that time I 15 will turn coordination of the meeting over to John Allen and 16 he will complete the activities for the day.
17 Mith that, if there are no questions from the board 18 members or anyone -in-the audience, Bill, I would like to turn 19 it over to you and ask you to introduce your representatives 20 that are here and then we'l go from there.
21 MR. NOONAN: Before we start into discussion with the 22 balance.'.:"6f~'plant, could you give me some indication as to 23 the percentages of the scope of review for the CE scope of 24 review versus the balance of plant scope of review.
25 MR. VAN BRUNT: I am not sure I understand what you GRUMLEY REPORTERS Phoenix, Arizona
l2 1 mean by percentages.
MR. NOONAN: Well, amount of equipment. In other 3 words, is 50% of the equipment under the CE scope of review and 50% under balance of plant, or is it 60-40? Can you just
. give me rough numbers?
MR. VAN BRUNT: I 'would guess it is about a 50-50 7 proposition. ,It is kind of hard to measure. If you are 8 looking at physical size, certainly the largest pieces 9 equipment coming from Combustion Engineering are the steam-10 generators and reactor vest. If you are lookina at numbers of ll pieces of equipment, electrical equipment,. I think 50-50 migh 12 be that order. It certainly wouldn't be any more than that 13 in my view.
14 MR. NOONAN: Would most of the equipment inside the 15 containment be related to Combustion Engineering or would 16 they be'split pretty evenly?
17 MR. VAN:BRUNT: The majority of it wo'uld be, yes, sir.
18 Not all, but the majority.
19 . MR. NOONAN: The majority would be Combustion?
20 I MR VAN BRUNT: That's correct.
21 MR. NOONAN: 'You indicated right now 'that we made a 22 request earlier that we have some Combustion people here to 23 -
talk about their scope of review. Can I get your views on 24 that right now?
25 MR. VAN BRUNT: Well, we have talked to the CE GRUMLEY REPORTERS Phoenix, Arizona
representatives here and we'l see what we can do. We will try and deal as much as we can with that. We will certainly tell you what -our participation with CE will be and we will try and do as much as we can with the CE program in the limited time. As I indicated in my opening remarks, we had really not intended to deal with that particular area today.
We understand our responsibilities relative to that equipment and plan to carry them out to the full extent,,but we had intended to deal with that particular aspect of the balance 10 of plant in a separate meeting.
MR." NOONAN: I guess, speaking for the NRC people 12 here, that we can make ourselves available to accommodate the 13 Combustion people whenever they can get here.
I 14 MR. VAN BRUNT: We'l see what we can do. We have 15 talked to the CE people here and we'l see what arrangements we can make.
17 MR. NOONAN: Thank you.
18 5R, ROSZTOCZY: Did I understand this correctly that 19 you completed your part of the presentation and you're 20 planning to hand it over now to Bechtel2 Is there any other 21 presentation from Arizona Public Servicef 22 MR. VAN BBIJNT: Not a formal presentation by APS.
23 Mr. Bingham will be making a px'esentation and many of the 24 things that are incorporated in his presentation are relative to things that Arizona Public Service Company does in this GRUMLEY REPORTERS Phoenix, Arizona
particular program. We will be pursuing the program that has been developed jointly by APS and Bechtel. They are implementing the program, if you like. We are working with them, and I think it will become clear from Mr. Bingham's presentation what. our. role is in that particular program.
P My remarks were basically intended to set 'the stage for the meeting, to have everyone understand who is here, what the players are, and how the meeting will be performed, 9 DR. ROSZTOCZY: . I have a few questions which relate 10 to Arizona Public Service's role in the equipment qualifica-tion. Is this the appropriate time to ask those or should I 12 wait for some time 'later?
13 MR. VAN BRUNT: I would suggest that you wait until 14 Mr. Bingham pre'sents at least the. first part of his presenta-15 tion. I have not seen his presentation, so I am just 16 speculating on what he is going to 'present. After he makes 17 at least the first part of his presentation, then if you 18 have questions that relate"to APS'articipation, ask those 19 at that time and I am sure that we can answer those questions 20 for you.
21 bK. ROSZTOCZY Thank you.
22 MR. VAN-BRUNT: Are there any other.questionsf 23 Okay, Bill, I would like to turn it over to you.
24 MR. BINGHAM: Thank you.
25 My name is Bill Bingham. I'am the Project Engineer'RUMLEY REPORTERS Phoenix, Arizona
0 15 1 Manager for Bechtel. As Ed indicated, we are here today to 2 present equipment qualification at the fourth formal meeting 3 of the PVNGS Systems Review Board. I have with me today from the project Dennis Keith and Bob Sapiens, who are Assistant Project Engineers, also Gerry Kopchinski, the 6 Engineering Group Supervisor for the nuclear discipline, and 7 Ken Schechter, Deputy Civil/Structural Group Supervi.sor. I 8 also have with me Bob Carson, Bechtel Electrical staff, who is responsible for environmental qualification for our 10 Los Angeles Power Division, and Bruce Linderman, Bechtel 11 Civil/Structural staff, who i.s responsible for seismic quali-12 fication for the Lo's Angeles Power Division.
13 As Ed indicated, our agenda today will include the 14 background of the PVNGS qualification program and a review of 15 our intended compliance with the various design critiera.
16 The design criteria will consist of an overview, environmental 17 qualification criteria, and seismic qualification criteria.
18 I think it is important to mention for the board that during 19 the presentation today, you may have the impression that all 20 of this work, from the manner in which it is presented,'s in 21 order. I want to indicate to.:the board that; while we are 22 very sure of what we have to do, not all is going well wi.th 23 the various suppliers that we are working with, and we will 24 try the best we can to point this out during the meeting.
25 By the way, if you cannot hear, please put your GRUMLEY REPORTERS Phoenix, Arizona
If hand up in the back so we can be sure to speak a little bit louder, and I also might indicate that, Ed, there are some spaces on the side for those people way in the back. If they would like to move their'hairs up, this might be an appropriate time to do that.
(Thereupon a brief off-the-record discussion ensued, after which proceedings were resumed as follows: )
MR. BINGHAM: After the background, that I will go 9 through in just a few minutes, we have set up the presentatio 10 to look at an overview of the design criteria, a review of environmental qualification criteria, and then we will have 12 the seismic qualification criteria separately. There are 13 several subheadings, as you have seen, and, based upon the 14 length of the presentation, I will entertain questions at the 15 end of the various subheadings.
TrIe will talk 'about the equipment qualification 17 process. I think this is important for the board to under-18 stand and it will.give you an overview of how Aps has set:
19 up their. review team and, how .Bechtel supports them. Me will 20 also talk.a littler-bit about the reviews of the group, and, 21 finally, will get into the 'qualification plans,,t: he checklists, 22 the auditing procedures, and how APS and Bechtel assure that 23 what is done in the work is correct and meets the established 24 criteria. Finally, we will go through documentation, and 25 then we have some examples that we would like to present for GRUMLEY REPORTERS Phoenix, Arizona
the board's information. We do understand that some back-ground material is necessary and we will spend a little time on that. Then, finally, for the board's information, we will present some of the major problem areas that we are having "today with the various equipment suppliers.
Ed, I would also like to request that, as we have at the past meetings, all questions be directed to me and I
. will assure that the appropriate person answers the question.
MR. VAN BRUNT: Okay, fine.
10 MR. BINGHAM: With that, I would like to get on to the presentation.
12 MR. VAN BRUNT: Excuse me, Bill.
13 Dr. Rosztoczy, I think that the time for your question is when we are, talking about how the whole program 15 works. Then you can pursue the issue of how Arizona Public 16 Service Company i.s involved. I think it will become more 17 obvi.ous then and you may get your questions answered or it 18 would be a better time to ask those particular questions.
19 =Does anybody on the board have any other questions N
20 at this pointf A 21 If not, Bill,.go ahead and proceed with your 22 presentation.
23 MR. BINGHAM: Thanks, Ed.
24 Figure 2 shows the PVNGS design development. That 25 is a slide that we have put up before for the board. Ho~ever, GRUMLEY REPORTERS Phoenix, Arizona
18 as Ed mentioned, the membership of the board has changed.
2 There are other utilities arid observers here and I will spend a few minutes going through the design development on Palo Verde.-
As you see on Figure 2, the hub of the work is 6' called the Design Criteria. This is the basic document that is used, reviewed, and sets the criteria for the project.
It consist of three volumes, which I have shown here, that list all the criteria for all of the systems as well as 10 the environmental work, qualifications, seismic criteria in the book. It is a very dynamic document. It is kept up-to-12 date and is revised as appropriate during the life of the 13 plant.
14 From this document, we then go to the development 15 of our design. From the design, we develop our procurement 16 specifications, system descriptions, schedules, construction 17 specifications, test specifications, and station manual.
18 At the same time, we set up the plant arrangement and from 19 that feed back'.to the development of our design. As I have 20 indicated befoxe, this is one of the projects that has a very 21 large-scale design model, Our model is three-quarters inch 22 to the foot, and on that we show in detail.all of the piping, 23 equipment, electrical conduit, and trays in order to assure 24 that the design does not have inconsistencies in it and we can review it for system applications or in many cases for our GRUMLEY REPORTERS Phoenix, Arizona
separation reviews and assurance that the design does meet the established criteria. From that, we develop our detailed construction drawings and our planning photographs. ~
As input to the design criteria come our standard criteria, our basic PAID's, and information from the NSSS vendor, in this-. case Combustion Engineering.
Figure 3 indicates how the design criteria for equipment qualification are implemented. I think it is I
important for the board to understand that equipment qualific 10 , tion is not a system, but it is a necessary part of the overall program to have qualified equipment for use in safety 12 systems, so we are organized a little bit in this area. Ther 13 are other areas in this control room design and in our overal 14 environmental concerns where we handle specific issues a 15 little bit different than the review process, which many of 16 the members on the board have heard before. I would like to 17 indicate that when we talk about environmental qualification 18 for a piece of equipment, we are talking about a substantial 19 amount'of paper. This (indicating) happens to be for one I
20 piece of equi'pment and represents the documentation .just for 21 environmental .qualification. As the board knows, there are 22 other qualifications that certification documentation is 23 required that make up a substantial package to assure that. the 24 equipment does meet the established criteria. APS has set 25 up an environmental qualification team. This team is headed GRUMLEY REPORTERS Phoenix, Arizona
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20 by John Barrow, who Ed mentioned earlier, and Bechtel support this team for all of the work that is involved with the environmental qualifications. The design criteria is input to the specifications. These go to 'the supplier. The suppli then prepares the qualification plans and, the reports. There is a qualifications summary that goes into the FSAR and it also -indicates that records will be availble for all the equipment. Zt has become necessary to'stablish this independent APS/Bechtel sponsored qualifications program for 10 what we call our recalcitrant vendors and suppliers to assure that we do have compliance with our criteria. You will be 12 hearing more in detail later on about the problem areas that 13 we are having and specifically how .they relate to meeting 14 the intended criteria that we have established.
15 Figure 4 indicates the scope of the PVNGS qualifica-16 tion program.
17 DR. DENTON: Ed--
18 MR. VAN BRUNT: Yes, ~Harold.
19 DR. DENTON: Could I go back to the previous slide a 20 moment'?
21 MR. BINGHAM: Certainly.
22 DR., DENTON: Could you tell me a bit about .the basis 23 of the review team and the resources that you have actually 24 put there? Is it a one-man office or a 100-man office or 25 something in between?
GRUMLEY REPORTERS Phoenix, Arizona
MR. BINGHAM: Overall size, there are about, I would guess, four or five people from APS that are involved. In the Bechtel organization, we have four'r five people that focus particularly on equipment qualification. They are .
5 supported by individuals in the various disciplines on the proj ect. The way we are set up, Dr. Denton', is that on our team of some 300 engineers and designers, we have responsible engineers that look after various purchase orders or various pieces of equipment with the vendors and their responsibility 10 is essentially to follow that piece of equipment from the specification through the evaluation to receiving the vendor 12 information and its application into the total system. We 13 have in the neighborhood of 50 responsible engineers on this 14 project and the team then would be the five or so APS indivi-15 duals monitoring, reviewirig our work, and on the Bechtel side, 16 there would be five people coordinating the efforts, assuring 17 that the information comes at a proper time and that the 18 reviews are conducted properly, and then some 50 people below 19 that, that look at the individual equipment. We also have 20 people that assist and review not only balance of plant 21 suppliers, but, as Ed probably mentioned, we do assist',him 22 in the review of the NSSS suppliers as well.
23 MR. NOONAN: I would like to ask a question back on 24 Figure 2 a little bit, if you could go back to that one. It 25 showed the utility as giving you specific requirements and GRUMLEY REPORTERS Phoenix, Arizona
II 22 1 there is a design criteria then evidently established, and th design criteria is established by Bechtel, is that correct?
MR. BINGHAM: Well, the design criteria is drafted by Bechtel based upon inputs from the utility. The utility then
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reviews and approves the design criteria for application for this particular project.
MR. NOONAN: The utility then does actually approve 8 the design criteria?
MR. BINGHAM: This is the document that they approve, 10 that's correct.
MR. NOONAN: How is the interface then carried on with 12 your NSSS vendor as far as this design criteria being 13 compatible with their part of it where your interfaces come 14 together? How is that handled?
MR. BINGHAM: I will touch on that a little bit later, 16 Vince, but let me just give an overview. The way that we 17 operate with Combustion Engineering is through a formal 18 system of sending the information, for example, the design 19 criteria, to them for review to assure from their viewpoint 20 that the criteria really reflect the interface requirements 21 that they have. There are subsequent things that 'go on.
22 That information is documented. It is fed'into the licensing 23 documents. The licensing documents then are again reviewed 24 in what we call our four-party review where all of the 25 participants are together. The review is documented and signe GRUMLEY REPORTERS Phoenix, Arizona
23 off by all the parties involved, APS, Bechtel, Combustion Engineering, and perhaps some other consultant that may be there at the time 'or a particular section. Then during the couxse of the work, all of the criteria that are given to Bechtel.either. through what Combustion calls their IR 6 documents, which indicate criteria that we must meet, or 7 through letters and correspondence, we then incorporate that 8 information into drawings and specs and into our design criteria.
9 We have a procedure that we use to send back this document 10 to Combustion.. Combusti.on reviews it, and then they respond in writing either it is satisfactory or you didn't interpret 12 it properly, please correct this. Ties is the flow of how we handle 13 the interfaces to assure ourselves that Combustion Engineerin 14 in this case has made a review of our interpietation of thei 15 requirements to assure that we have interpreted and applied 16 it properly.
17 MR. NOONAN: Then does APS act in a role as an overall 18 coordinator between the NSSS and the balance of plant to make 19 sure that these. requirements are all meshed together properly?
20 MR. B INGHAM: Ed, 21 MR. VAN BRUNT: The way we are set up, Arizona Public 22 Service Company has contracted with Combustion Engineering 23 to provide the Huclear Steam Supply System, and that contract 24 is directly with Arizona Public Service Company, as are our 25 contracts for all of our equipment. We have also contracted GRUMLEY REPORTERS Phoenix, Arizona
24 with Bechtel to be our engineer/constructor. As I indicated in my opening remarks, Bechtel has been delegated the responsibility to administer, at least as far as the technical aspects are concerned, the Combustion contract.
Basically, the information that Bill has been talking about goes back and forth between Combustion and Bechtel. However, copies of all of that information are sent to us and, in parallel with the review that Bechtel is doing of those documents, we are reviewing them as well. This is a matter 10 of expediency, so it doesn't go from one person to another'nd back, it is a parallel review, and we concur in parallel 12 with the activities" that are going on with Combustion or 13 Bechtel. If we have a problem, we raise the issue. So we 14 in house, through our own procedures setup; within my 15 organization review the same documents and look at the things 16 that Bechtel's people are doing and things that Combustion 17 are doing.
18 Might I say for .convenience of getting the meeting 19 done more expeditiously Bill is going to leave points after 20 vaxious segments of his presentation for questions and I 21 think the presentation would go along a little faster if we 22 would hold our questions until that point in time unless 23 you'e got some clarification or something that you need from k
24 something he has said. Then we will let all the questions 25 be asked at one time. Otherwise, it kind of gets disjointed, GRUMLEY REPORTERS Phoenix, Arizona
h 25 and I think with some of the flow of the presentation, we
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get lost. So if I could ask that everybody would hold their 3 questions until the end of each segment of the presentation, I would appreciate it. Each segment is normally broken down 5 into pieces that are not so large that you lose your train of 6 thought.
MR. BINGHAM: Thank you, Ed. I believe we are on 8 Figure 4, which indicates the scope of the Palo Verde 9'ualification program. As we have discussed, it is broken up 10 between the Combustion Engineering equipment and the Bechtel ll equipment. Under Combustion, there is instrumentation and 12 control equipment and non-NSSS instrumentation and control 13 equipment, so we have essentially split the two, and, of 14 course, we have the same under the Bechtel scope.
15 Looking further at the figure, for the information 16 of the board, I have tried to indicate where this information 17, is covered. Of course, for the Bechtel information, this is 18 in the PVNGS FSAR. The instrumentation and control equipment 19 is covered by Combustion Engineering under their two topicals, 20 CENPD 255 and CENPD 182. The balance of the equipment 21 supplied by Combustion Engineering is covered in CESSAR-F in 22 Sections 3.10 and 3.11.
23 Further, we have depicted some examples for the 24 board's information. Under Combustion Engineering, you will 25 find the plant protective system, in-containment sensors and GRUMLEY AEPORTERS Phoenix, Arizona
0' transmitters, and supplementary protection system. Under the non-instrumentation control, you will see the LPSI pump, the high pressure safety inj'ection pump, and valves. These are examples. It is not an inclusive list. '
For Bechtel, you will see the balance of plant ESFAS, the battery charger, and BOP instrumentation; under 7 non-electrical equipment, diesel generator, auxiliary feed-8 water system, and essential spray pond pumps.
Figure 5 shows the relationship of the PVNGS 10 project milestones to the various qualification requirements.
y(
We put this together to give the board an idea of the time 12 frame, because, as you know, this project started back in 1
13 1973 and I think the keys that we want to focus in on are the 14 construction permit in May of 1976, the applicable qualifica-15 tion standards committed to at that time, the IEEE 323-1974, 16 IEEE 344-1975, and Reg Guide 1.89. 'You can see from Figure 17 5 long lead items occurred from 1975 through early '77. This 18 includes the safety injection pumps, pressurizer valves, solenoid valves, charging pumps, equipment of that nature.
The major BOP purchase orders started about the beginning of 21 1976 and are essentially complete at the end of 1978 except 22 ,
for some small items, The FSAR then was docketed in 1980.
23 The bulletins and guides that we will be talking about, 24 NUREG 0588, IE Bulletin 79-01B, IEEE Standard 627, and Commission Order CLI 80-21, have fallen substantially after .
GRUMLEY REPORTERS Phoenix, Arizona
27 we have completed the procurement of the equipment. I indicated earlier to the board that we are attempting to 3 assure that our criteria, which you will hear about in a 4 little while, is reflected in our purchase orders that were placed some two to three, in some cases four, years ago.
Figure 6 shows our qualification program developmen and we have separated for understanding by the board the qualification of IE components, ~t zs', electrical components, and qualification of other safety-related components. We 10 have split the presentation into two parts for ease of understanding. We will look at the environmental conditions, 12 that is, temperatur'e, pressure, radiation, chemical, and then 13 we will look at" the seismic issues separately today. The 14 ma)or qualifications for the IE equipment fall under NUREG 0588, and you will heax more about that a little later, IEEE 323-1974 and,IEEE 344-1975. For our non-IE components, our other safety-related components, we will be looking at IEEE 627-1980 and IEEE 344-1975.
19 ~
Table 1 is 'a brief summary of the equipment qualification methods from our design criteria. Basically, what it depicts for various safety-.related categories are the qualification methods and it gives some examples of the type of equipment;;that fall within those categories. We are looki 24 at four categories, A, B, C, and D, on Table 1, in-containment equipment, outside containment possible harsh environment, GRUMLEY REPORTERS Phoenix, Arizona
0 28 outside containment - non-harsh environment, outside contain-ment - no age-sensitive components, but physical integrity 3 required.
We have listed five methods of qualification.
5 Method 1 is type testing, Method 2 documented analysis, 6 Method 3 documented operating experience, Method 4 ongoing qualification program~ then we 'have a last method, which is allowable by the codes, which is a combination of the other methods. As you can see under qualification methods, we have 10 all the methods and we have, noted that type, testing is our preferred method. Items that fall in this category for 12 balance of plant ar'e wire and cable and valves. In Category 13 B, outside containment - possible harsh environment, again we treat this in the same manner, In.,this, particular case, 15 we are looking at motor control centers and valves and valve 16 operators. For outside containment - non-harsh 'environment, 17 which is Category C, again we do prefer to have type testing.
18 Some of the examples are the diesel generator and the control 19 panels for the balance of plant. Our final category, Category 20 D,.we are looking.- at Methods 2,. 3, and 4, or a combination.
21 Examples there are things like Q cooling coils and the control r
22 -
room='eiling.
. Figure 7 is a simplified indication of the qualifica 24 tion process. It shows the interfaces between APS/Bechtel 25 'ualification team and the equipment suppliers. I did discuss GRUMLEY REPORTERS Phoenix, Arizona
0 0'
a little bit earlier on the question. from Vince Noonan some of these principles, but I would like to spend just a moment and go through this slide for the board. Figure 7 is essentially split in two, the'APS/Bechtel side over here (indicating), Equipment Suppliers on this side (indicating),
and I am focusing now on the balance of plant equipment suppliers. We started with the design criteria. Of course, that goes into the specifications. The specifications indicate inspection, hold, and witness points for the equip-10 ment. That goes to the supplier, who performs the design, manufactures the equipment, developes qualification plans-and 12 procedures as we ar'e depicting focusing on the equipment 13 qualification issue. This information flows to the qualifica 14 tion team for review, again is reviewed in APS, goes to 15 Bechtel for review, down to the 50 responsible engineers that 16 we discussed earlier. Input is given to the equipment 17 supplier, comments are made, and we follow up to assure that 18 the qualification plans and procedures of the equipment 19 supplier reflect our criteria. From that point, the supplier 20 then goes through the qualification program. It may be testi 21 analysis, or combinations. We'have an audit of testing 22 programs. I would indicate to the board at this point that 23 we have not yet conducted an audit of the testing program.
24 Our first one will be coming up with some of our electrical 25 equipment toward the end of this year. From this then is a GRUMLEY REPORTERS Phoenix, Arizona
30 supplier qualification report, the reports I showed you earlier, which is the document like this (indicating) . That goes to the qualification team for review, input back and I
forth to assure that everything is acceptable and complete.
Data..then is summarized and,,at the appropriate time, submitt in summary form in the FSAR. The qualification report and other'ualification documentation is sent to Palo Verde for retention.
Figure 8 is the PVNGS schedule for equipment 10 qualification. From the slide, you note that we have the balance of plant equipment on the bottom part of the slide 12 and the CE equipment on the top. I will just spend a minute, 13 since there is interest Sn the schedule. CENPD 182, which is the seS.smic qualification for the equipment, as I explained 15 before, was submitted in Nay, 1977. CENPD 255 environmental qualification was submitted in July of 1980. Let me make a 17 note,'his shows in May, but we will correct thS.s for the 18 record, Ed.. It should be July. They are presently in the 19 process of revS.ew. There will be documentation prepared and I
20 information submitted on the same schedule as the balance of 21 plant information.
22 .Looking at the balance of plant, .we have about 23 44,different suppliers for thS.s equS.pment. We have been 24 holding qualification review meetings with all of them, 25 meetings to assure that the programs are going to meet the GRUMLEY REPORTERS Phoenix, Arizona
established criteria, and have been reviewing and validating in some cases our review of the qualification plans and information that has been submitted to us for review. This, of course, has'll been in preparation for submittal of the final information for our operating license.
I do show here, the milestone,. Gquipment Qualificatio Review Board.. That is us today. Me intend to have two submittals, the first submittal in November of 1981, which will encompass about 70% of the information. Summaries will 10 be submitted to the licensing documents and the records will hi be available with APS.'he final submittal is scheduled for 12 April of '82. Again, information for the licensing documents, 13 and the xecords then will become available. Finally, at that 14 time, presently, scheduled, is the SER Supplement, and the 15 Unit 1 fuel load date on that schedule shows November, 1982.
l Figure 9 is a summary of the BQB equipment 17 qualification status. Of the 59 purchase orders requiring qualif'ication, you can see how they are split amongst disciplines. Our purchase ordex's with qualifications the'axious 19 20 completed prior to NUREG 0588 come out with 15. Ve have 21 re-reviewed these and find that we have one that is now 22 complete in accordance with that document. Qe are going to be 23 discussing the details later on in the presentation of this 24 particular area and the comparison, so I won't spend more time than that on that at this time, Ed.
GRUMLEY REPORTERS Phoenix, Arizona
32 1 With that, I would like to ask if there are 2 questions from the board.
MR. VAN BRUNT: I have a couple myself, but I will let 4 the board go first. Anyone want to raise any particular 5 point7 Carter.
MR. 'ROGERS: Bill, I would like to go back to Figure 7 2, if I could. I would like to continue along..the line of 8 Vince Noonan's, questioning and try to further understand Figure 2. Figure 2 shows, at the top of the figure Utility
'I 10 Applicant Specific Requirements inputting into the design criteria 'and you mentioned, Bill, that the design criteria 12 is a rather dynamic'ocument. It does vary from time to time; 13 it is kept up to date. Can you tell me how APS ensures that its criteria requirements are met throughout the plant design 15 -
looking at all of the other peripheral parts of the design 16 criteriag What procedures does -the utility or does APS use 17 to ensure that its requirements which are found in the 18 design criteria are met7 19 MR. BINGHAM: I think, Ed, that that is really a 20 question the utility should answer.
21 MR. VAN,BRUNT:: I think, if I can rephrase his 22 question for him, he would like to understand the interfaces 23 and where the utility interacts with Bechtel..
24 MR. ROGERS: That 's right.
25 MR. VAN BRUNT: I agree with you that that is probably GRUMLEY REPORTERS Phoenix, Arizona
33 1 a question that either Carter or I should answer.
MR. BINGHAM: Me do have several meetings with APS over the course of the design. Generally, we meet and have met since the beginning of the project about once a month.
I At those meetings, we review the status of the project from 6 the design, and I think it is that review that is documented, 7 that is followed up, that APS, uses for part of the assurance that goes on. I will discuss the process. I guess that is what Carter is asking 'for. I did discuss it a little bit 10 when we were dealing with Vince Noonan's question, but, in addition-to that, of course, there is information that comes 12 out of those meetings. As far as interfaces, Bechtel will 13 make statements about what the'y are doing, and that has 14 follow-on audits by APS and our own house. Maybe one example I
15 I could mention"came from our review last month on the auxiliary feedwater system where there was a concern about 17 whether Bechtel had indeed been diligent in assuring that 18 Combustion Engineering's interface requirements were 19 incorporated in the design and was it documented. APS held 20 an audit. just recently to assure themselves that things were 21 in order. So there are checks and balances that 'go on. The 22 process basically is one of assuring that we work together 23 with the utility. Me have documented procedures that we use on the project to assure that we have made sure that interface 25 are put into the design properly, and from my experience at GRUMLEY REPORTERS Phoenix, Arizona
least on this project, we have had a tremendous, amount of encouragement from APS to focus on this particular issue, because later on it becomes very difficult to backfit criteri in the particular plant. So the process is something like this: A,piece of, information will come in,,it is reviewed by Bechtel at the proper levels, the information also goes.: to APS, we incorporate it in the design, we get .together and review the design, particular problem areas, set between us the course of action that we wish, make any modifications as 10 appropriate to the design criteria, then we incorporate it in the drawings. The dxawings then come back to APS for 12 review. APS as well as the other suppliers, in the case we Engineering, will send back it 13 were talking earlier CombusCion their comments. We incorporate the comments, and many times 15 we have to have special meetings to resolve particular issues.
16 Once those are incorporated, the final review is done and 17 the drawings are released for construction. That is generally 18 the overall program.
19 MR. ROGERS: Let me make it 'a little easier. On 20 Figure 2, we see Chat the utilf.ty applicant specific require-21 ments go to'design criteria.. An arrow comes out of there 22 over to development of standard design and then down on the 23 right.-hand side of Figure 2 to procurement specifications, 24 system descriptions, engineering schedule, construction 25 specifications, and so on, I don't see an arrow going back GRUMLEY REPORTERS Phoenix, Arizona
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to the utility. Is there indeed such an arrow going back?
Does the utility receive copies of procurement specifications What happens there so that the utility might review those, for instance7 MR. BINGHAM: Yes, they do,.'Carter. All the key documents are reviewed and approved by the utility and all the documents go to the utility for comments. It doesn' l
show on this particular slide, 'because I was trying to portray the overall process and;:not all of the detailed flow 10 of information on, the project.
MR. ROGERS: Now let me see if I can word this second 12 one so you can answer it. How does Bechtel interface with 13 APS with regard to the CE interface specificallyf 14 MR. BINGHAM: As Ed mentioned earlier, Carter, 15 Bechtel has been asked to administer technically, at least, 16 the contract with Combustion Engineering, so we support the 17 review of the contract as well as all of, the interface 18 information. We have people that are assigned to devote thei 19 time fully to looking at the Combustion Engineering interfaces 20 and information that comes to us to assure that it is provide 21 . in the proper xtime frame for the project.* Ve have design 22 review meetings with Combustion at which APS is a participant periodically. During the formative stages of- this project, 24 we were meeting every two months or so back at Combustion 25 in Windsor. We now have meetings on the order of every three GRUMLEY REPORTERS PhoenixArizona
36 to four months, because most of the design information is available. We have focused our attention then on meeting with Combustion in the field looking at the interfaces and the requirements that come up in the field as they pertain to the engineer and the requirements the engineer has. Those I
6" are held about every six weeks.
7 MR. VAN'.BRUNT: Carter, excuse me, let's go to Shelly.
,MR. FREID: On Figure 7, I have two questions. As you go through the information flow, you get down to the point 10 where qualification is done by testing or analysis, and my question is who makes that decision on how a particular piece 12 of equipment is in fact qualified, whether it is done by 13 testing or analysis, because on Table 1, there 'are several 14 options given. One is preferable, but who does in fact make 15 the decision? Does the vendor'or the equipment qualification 16 team people's 17 MR. BXNGHAM: Well, the vendor would make the decision 18 based on the particular piece of equipment.. The review team 19 may not agree with that decision, and from there you would 20 develop into a final acceptable way of testing your particular 21 equipment. For example, if it'was )ust impractical to run a 22 test, you would accept some other acceptable method.
23 MR. FREID: So it .is basically the vendor who has 24 the initial cut'?
25 MR. BINGHAM: The fixst shot at it, yes.
GRUMLEY REPORTERS Phoenix, Arizona
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I
MR. FREID: The second 'part of that question, if you 2 take the arrow going to the left, you order the testing, 3 which is relatively simple, it is a go or no-go.::decision, I presume, do you also audit the analysis if it was done by analysis rather than testing or if it is done by, a combinatio/
of methods.
MR. BINGHAM: I suppose you could call it a form of 8 audi. ting. Actually, we review the calculations. For example, in seismic areas, Bruce. Linderman will do a detailed review 10 of the work that comes in to us."
MR. FREID: So then auditing is done on both testing 12 and analysis 7 13 MR. BINGHAM: In that context; yes.
MR. VAN BRUNT:,,I would like .to follow up on Shelly's 15 question, Bill. You indicate that the vendor makes the 16 choice. Specifically, what do~:the specifications .say to the 17 vendors Does it give him three or four "options,'ell him 18 that he has to comply with 'IEEE 323 or whatever it is, and 19 then he takes his best shot at what he thinks he can dot 20 Is that the way it works, or do you indicate in the specs 21 that you prefer type testing2 22 'MR. BINGHAM: Ed, as I indicated before, the speci.fica-23 tions were written long, long ago.:
MR. VAN BRUNT: I understand.
25 MR. BINGHAM: What we are doing today is somewhat GRUMLEY REPORTERS Phoenix, Arizona
~ i different than what we did before. We did rely on IEEE 323-7 which has a statement in it that type testing is preferred, so the specifications in the early days didn 't give the 4 kind of guidance that we might give in a set of specification today if we were to go out to a particular vendor.
6 MR. VAN BRUNT: Harold, you would like to ask a question?
DR. DENTON: I have a follow-up question to the one the panel just raised. When you mentioned you audit the supplier, could you describe the nature and depth of that audit? I am interested in how complete do you audit. Do you 1
II 12 look at their results of tests on every piece of equipment 13 or every tenth piece, or how do'ou decide the scope of your 14 audit of that' 15 MR. BINGHAM: Let me 'focus on the auditing for equip-16 ment qualification, because we doaudit for compliance to the specifications in other areas. The point .that we are trying 18 to focus on is when a testing lab says, "Here's your report,"
19 signs it off, gives it to you'. the equipment is qualified.
2o 'ow do you really know that that is the case? Did they run 21 the test at the proper cycles? Did they have the proper 22 measurement of temperature or pressure or whatever parameter I
k 23 we are looking at? Did they record the information properly 24 and analyze it properly? Now, there really aren't too many testing labs, I think as we all know, and some of them are GRUMLEY REPORTERS Phoenix, Arizona
39 getting very busy right now, so I think it is even more important for us to audit to the extent that we feel necessar First, is the testing group applying the principles that they 4 should properly, are they using the right equipment, has it been calibrated so that the result:s that we get are proper, and has .the information been interpreted properlyf We will probably- not do every one, but, as I indicated in the presen-tation, we are focusing now on that particular issue, and if it so comes out when we review a particular supplier that things are not like we had hoped, then we will review more until we are satisfied that the reports that we get do reflect 12 what we are told.
13 DR. DENTON: I guess I would phrase that one a bit finer 14 if I might. Does this mean that you audit each, supplier at 15 least once on each piece of equipment as opposed to auditing 16 the same piece of equipment several times? I guess I am 17 interested are there laboratories testing equipment for you that you don't audit at a11? 'I am trying to get you to define 19 in more detail the nature and scope of the audits that you do 20 so I can get a feel for what competence should be placed in 21 the word "audit."
22 MR. BINGHAM: I indicated that for equipment qualifica-23 tion, we have yet to conduct one of our audits and that our first audit would be toward the end of this year. We will 25 probably be looking in great detail at everything that goes GRUMLEY REPORTERS Phoenix, Arizona
on. I might indicate for the board's benefit that that testing will be on a piece of electrical equipment and it
'3 will be conducted at Wyle's Morco Laboratory. We will
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be looking in great detail at all the various aspects, because we really haven't to date taken a look at, for example, what has been done at Huntsville, except I might mention that the engineers do. witness from time to time particular seismic tests to make sure that things are reflected. That is about all we have done to date. We are 10 going to focus more diligently on the programs, and one of the things that worries us is that when testing labs become 12 overloaded, as they might, that there might be a tendency to 13 not focus attention on the particular issues necessary, so 14 we probably will have a little more diligence on that equipme t.
I 15 You asked a question about would we look at each 16 piece of equipment or would we look 'at s'elected equipment.
17 As the board knows, we have three identical units and some 18 of the equipment has already been shipped in order to maintai 19 our construction schedule and we have deemed i.t appropriate 20 to qualify equipment for Unit 2 or Unit 3 and to have that 21 qualification complete prior to the operating license or 22 prior to submitting the information for review by NRC. I 23 would guess when it comes'o valves and valve operators, for example, the Limitorque operators that we have, that that 25 would cover a broad spectrum. There has been a substantial GRUMLEY REPORTERS Phoenix, Arizona
amount of work in the industry to assure that that particular qualification is satisfactory, and I would expect that we wouldn't spend as. much time on that as perhaps we
'would, on qualification of some of the diesel generators where there really haven't been extensive testing programs or 6 extensive work on some of the components such as the governor 7 and control systems, and it would be my expectation that we would focus our attention on those particular areas during the next several months.
if I can I
10 MR. VAN BRUNT: Bill, interrupt.
Harold, just to follow up on Bill's comments, as 12 the applicant I
is th'e person that is ultimately responsible 13 for the adequacy of all thi.s equipment, we are going to be 14 looking very carefully at the testing laboratories to assure 15 ourselves that they are in fact doing the things we want them to do, and, through our own quality assurance activities, 17 we will be auditing these facilities either with our own 18 forces or through the Bechtel'QA organization, which we 19 utilize to do audits, and we will be 'setting up these programs 20 to audit the same as we do any'other vendors to assure 21 outselves that theiw programs are adequate. So independent 22 of how much auditing Bechtel'may think is appropriate,
'I 23 we will be doing that which we believe is necessary to assure that the equipment is appropriate.
25 John.
GRUMLEY REPORTERS Phoenix, Arizona
42 MR. ROEDEL: Bill, you spoke of equipment qualificatio 2 I would like to focus on commodity qualification to get a 3 little clarification and more explanation of what the word 4 "audit" means. For instance, what has been the involvement in Bechtel, .Bechtel Engineering, or Bechtel supplier quality 6 representatives in the qualification of Rockbestos cable?
7 Were they not,present,, were they not witnessing some of the 8 tests in the qualification of that material?
MR. BXNGHAM: The answer to your question is yes, we 10 did, John. The area that I was trying to focus on was equip-11 ment qualification and indicate to the members here that we 12 are just getting into the swing of our audits on that particu 13 lar type of equipment, that particular area, and I am sure we 14 will use all the elements that we use in our other audits of 15 equipment. I also tried to indicate to Dr. Denton that we 16 believe there is even more emphasis in this particular area 17 that must be put on certain aspects of our review. I did not 18 indicate earlier that the engineers responsible for the 19 inspection plans, and our inspection plans are being updated 20 to include these elements. We set the criteria from an 21 engineering viewpoint and then we have individuals in our 22 auditing department," procurement department, Chat go out and 23 actually look and assure that our requirements are met. Then 24 we as an engineer might be there, also, as a follow-on, if yo 25 will, the second layer.
GRUMLEY REPORTERS Phoenix, Arizona
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MR. ROEDEL: That is why I brought up the difference betwee'n the equipment qualification versus material qualifica tion, which we are now engaged in, and have been for some 4 time, so that we .could qualify the material for installation in--
containment. I just asked that question because I wanted to make that clear.
VAN BRUNT: Ed Sterling.
STERLING: I want to 'follow up on Dr. Denton's question. In your plan for audit, would you say that the 10 plan would be to take a look at procedures that a lab might users For example, if they make certain assumptions when running an analysis', then that particular assumption or analysis would be applicable to more 'than one piece of 14 equipment if they used it over and over again, are you satis-fied through an audit that it was a satisfactory way to 16 proceeds The same thing with the type of .test 'procedures 17 that they might use.
18 MR. BINGHAM: That's correct.
19 MR. VAN BRUNT: Are-'there other questions in this 20 particular arear'orm.
21 MR. HOEFERT: On Figure 7, I have a question. The 22 end of Figure 7 is qualification documentation, which then 23 goes to the PVNGS site records. There is going to be a large 24 quantity of qualification documentation, many reports, and 25 so forth. How are all the various tasks which have to be ORUMLEY REPORTERS Phoenix, Arizona
44 performed throughout the life of the plant to maintain qualification being identified and tabulated so that all these tasks can be performed or will be performed in the future.
MR. BINGHAM: Are you talking about, once the equipment becomes under the jurisdiction of APS operations? Is that what you are focusing on?
MR. ALLEN: No. I think I can expand on his question a little bit, Bill. Norm is talking about a requirement 'whic 10 comes out of a qualification program that operations has to check a breaker every 1,000 cycles. How is that information 12 going to be compile'd and sent to operations so they can put 13 it in their maintenance procedures. Right, Norm?
14 MR. HOEFERT: That's right, that type of thing, and I 15 am particularly concerned is this going to be picked up in the FSAR or tech spec or sepaxate document. Just how will 17 this all get together?
18 MR. BINGHAM: Yes, it will probably be in several 19 different places. All the'information will.be compiled and 20 be given to APS engineering by us 'and that will be implemente 21 into the various procedures or t'ech specs, if that is the cas 22 or test specifications or maintenance documents.
23 MR. HOEFERT: Has it really been decided yet where 24 this information is going to go?
25 MR. BINGHAM: Again, I believe that I would have to GAUMLEY AEPORTERS Phoenix, Arizona
if
'I
1 ask Ed for information from APS, but it is my understanding 2 that the principles are established, but perhaps the details 3 aren't yet totally worked out.
MR. ALLEN: That's correct. As far as specific 5 maintenance procedures, that will be taken out of the tech 6 manuals'both by Bechtel and APS nuclear engineering and identified to operations. As far as tech spec requirements, 8 we haven't gotten into the tech spec requirements on this 9 yet. We don't know exactly which portion of it will be tech 10 spec requirements and which won'.
11 MR. VAN BRUNT: Other questions? Dr. Rosztoczy.
12 DR. ROSZTOCZY: I have a few questions which 13 relate to some of the presentation.and some of the answers 14 to questions, and then I would like to come back to some of 15 the basi.cs. For details of the record, let me ask them one 16 by one and I would like to get 'them answered.
17 MR. VAN BRUNT: Sure, go right ahead.
18 DR. ROSZTOCZY: First, from one of your answers to 19 one of the questions, I understood that the environmental 20 specifications are being prepared by the contractors, Bechtel 21 or Combustion Engineering, then they are submitted to APS for 22 approval and APS approves them,'o if we are going to'audit, 23 let 's say, a year or two years from now your files, then we 24 would find in each file environmental specifications that the 25 contractor prepared on a piece of paper that shows that APS GRUMLEY REPORTERS Phoenix, Arizona
46 reviewed these and'approved them, is this correct?
MR. BINGHAM: That is correct.
DR. ROSZTOCZY: The second question relates as a follow-up on an earlier question. The question was asked who makes the decision on what type of qualification is going to be performed, whether it H is going to be testing or something else instead. Did I understand it correctly that the vendor or supplier of the equipment makes a recommendatio of how he is planning to test this equipment and then this 10 recommendation is reviewed'y the equipment qualification team and it is approved by the equipment qualification team, 12 so again the files would have a piece of paper indicating tha 13 the team reviewed this and made the decision that it, is appro-E priate to go'with analysis, for example, instead of testing'?
15 MR. BINGHAM: There will be approval of the test plan, that 's correct.
17 DR. ROSZTOCZY: There is an approval for the test plan 18 for each piece'f each type of equipment?
19 MR. BINGHAN: For each piece. Excuse me, the qualific 20 tion plan. The qualification plan may be test, analysis, 21 combination, whatever is appropriate for the particular 22 piece of equipment.
23 DR." ROSZTOCZY: Yes, and there will be an approval 24 for the selected approach, which might be a combination of 25 these.
GRUMLEY REPORTERS Phoenix, Arizona 4
., MR. BINGHAM: Yes .
2, DR. ROSZTOCZY: The third one is maybe a follow-up on Dr. Denton's question. You indicated that you are going to audit this. I didn't get, the clear answer whether you are going to audit every type of equipment qualification or, instead, you are going to audit only selected ones. For example, if the vendor is going to go for qualification for 25 different types of equipment that are going into this plant, then is it your intent:to audit each of those or are 10 you going to pick only some selected ones? If you are going with the selected equipment approach, then do you have a plan 12 how you make your selection? Have you already made those?
13 Do you know which one you are going to follow?
14 MR. BINGHAM: It has been pointed out to me there may 15 be a bit of confusion. We do review every report in detail 16 to make sure that it meets the established criteria, every 17 plan, every report that comes in from all of the vendors.
18 We probably will be selective in the audit. That is, we 19 will pick the equipment that we would expect a testing lab 20 to have difficulty with or we have heard from the industry or 21 NRC in some cases that there has been difficulty in qualifying.
22 When I responded to Dr. Denton, I was trying to portray that we are in the early stages of really what should be considered 24 for a large nuclear project that is in our time frame, and if that turns out to be that one needs to audit all of the GRUMLEY REPORTERS Phoenix, Arizona
F' 48 equipment, then we will audit all of the equipment. We suspect from our review and our discussions with APS that probably will not be necessary, and I cited one example that I believe was a Limitorque motor operator, where we felt that perhaps everything might be in order on that particular one. I am sure that, as Ed indicated, APS will assure themselves by asking appropriate questions of us that we have done our job and that if we don 't audit all of them, there will be well documented reasons for not doing that.
10 DR. ROSZTOCZY: So the answer to my.question is that you don't have at this time a plan which will tell you 12 exactly which ones 'you are going to audit, you are developing this as you go along, and you will assure that appropriate 14 amounts will be audited.
15 MR. BINGHAM: That's correct.
DR. ROSZTOCZY: Let me go now to another set of 17 questions, which axe kind of basic and I think they kind of 18 relate to the beginning of your presentation. Could we have 19 Figure 2 up for a second2 Figure 2 is a very general portrayal for design criteria and it is not specific to V
20 equipment qualification. It shows one line which indicates that certain information is flowing into the design criteria .
from the utility. Now let's go to Figure 3. When we go to 24 Figure 3, then the equivalent of this is not shown. I don 't 25 see a clear block which would te'll me that certain information GRUMLEY REPORTERS Phoenix, Arizona
had been given to the environmental qualification team. My questions relate to certain information which I think this I
team should have, whether it has already been given to them and in what form has it been given to them. The first question is: Before y'ou can start to go ahead with a program qualifying the equipment, you have to know what equipment needs to be qualified, so has. APS prepared a list of safety- .
related systems which need to be environmentally qualified and has that list been supplied to all the appropriate people 10 like Bechtel, Combustion, and the team mentioned there7 MR. BINGHAM: Ed, maybe I should make a comment here.
12 First, the answer t'o your question is yes.
I The rest of the 13 presentation is structured to present the details of the working of the organization, particularly Section IV, and I 15 wonder if maybe you might want Dr. Rosztoczy to indicate 16 his questions at this time and then as we go through the 17 presentation, those that remain unanswered we can deal with 18 when we go into Section IV.
19 MR. VAN BRUNT: Dr. Rosztoczy, this isn't the first 20 one of these that we have done and we have learned a little 21 bit as to the most expeditious way of getting from here to the 22 end. What I would suggest is that as you ask your questions 23 such as this one that if Bill knows that somewhere along later in his presentation he is going to deal specifically 25 with that subject, he will identify that to you, and when he GRUMLEY REPORTERS Phoenix, Arizona
1 comes to it, he will try and note it or certainly you will 2 note that you either got your answer satisfactorily or that 3 you did not rather than try and take it out of context. It 4 is the same reason I tried to hold the questions until the end of a particular area. If that is agreeable to you, I would= like to proceed that way. We have found that that is 7 probably the most expeditious way of getting from one point t 8 another and it makes a little more orderly presentation.
DR. ROSZTOCZY: Yes, I think that would be fine.
10 So you say that yes, such a list has been prepared.
The next question is are we going to get a copy of that list 12 today?
13 MR. BINGHAM: I had not.planned to give you a copy of 14 that list today, but I am sure that Ed and his people can 15 make it available.
16 MR. VAN BRUNT: We will send you a copy of the list.
17 DR. ROSZTOCZY: It is my observation from some of the 18 reviews that we are conducting for other plants that the 19 lists the different utilities are using are not uniform.
20 Certain systems are included on one utility's list and other 21 it utilities are not including them. I think villi..be for the 22 benefit of you as well as everybody else, including us, if 23 there would be an early agreement on that list that that list 24 is complete and nothing has been left off from it.
25 MR. BINGHAM: I think I can respond to that part of the GRUMLEY REPORTERS Phoenix, Arizona
question. All of the equipment that we are talking about is equipment that is flagged in the FSAR as safety-related and the list of equipment is noted in Appendix 3E of the FSAR, so that equipment has been listed and it ties back to our basic qualification table. There is a meshing of the two it 1
to make sure that we have covered all.
~
DR. ROSZTOCZY: These lists have undergone certain developments of Three Mile Island, and so on, so I would like to have a clear 'understanding today of what it is 10 exactly that you are working with so we can take a look at that list, and if we have any comments, we would feed it 12 back to you in a relatively short turn'round so we could 13 have an early agreement on that list.
14 MR. VAN BRUNT: Bill, let me ask Terry'nd Gerry both 15 to put on the list --' am aware of the list you are speaking 16 of and we will submit that list to you, but prior to 17 submitting it to you, we will review and be sure that it 18 complies with the present-day requirements or any new require I
19 ments that have come up,since we submitted it the first time.
20 DR. ROSZTOCZY: I think what I am asking for is not 21 that this list be necessarily submitted to NRC, but to presen 22 it to this board so the members of this board can see it and 23 kind of pass a judgment, including NRC representatives.
MR. VAN BRUNT: Let me deal with that part of the 25 question. Dr. Rosztoczy, the mechanics of what happens is r GRUMLEY REPORTERS Phoenix, Arizona
9 52 that this will be an open item for the board and that will be a question that will be dealt with, and as a part of the responses to that will be this particular list and that will become a part of the over'all documentation of this particular meeting. So, in essence, in kind of a round about way, the same thing .that you have been asking will be accomplished.
DR. ROSZTOCZY: Thank you. That will be fine.
The second question is again along these lines and the question is has APS prepared a list of environmental 10 parameters, various things like temperature, pressure, that has to be considered in the qualification of the various 12 equipment7 In some'ases, of course, some are riot applicable, 13 but they have to be considered, and are we going to receive 14 a copy of that list today'R.
15 BINGHAM: The answer is yes. That is Item B.9. of 16 your agenda.
17 DR. ROSZTOCZY: Under Item B.9., we will see a copy?
18 MR. BINGHAM: We will see a copy of that.
19 DR. ROSZTOCZY: .The third question is has APS identifi 20 environmental zones for the plant'P Have you divided the 21 plant into environmental zones and then established the 22 numberical -values or time functions of these environmental 23 parameters for each of those time zonesf Have you provided 24 this information to the contractors who are writing the 25 specifications for the various equipment?
GRUMLEY REPORTERS Phoenix, Arizona
Oi I, lf h
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MR. BINGHAM: Again let me respond. The answer is yes, we have established them. You will hear them today under Section B.9. One point that I tried to make earlier was that we are in the process in some cases of backfitting the requirements to have a complete understanding with some of the very early suppliers where we might have had general or envelope criteria. You are going to hear all about that today when we get into the environmental qualification criteria.
10 MR. VAN BRUNT: Dr. Rosztoczy, I would like to interrupt for just a second just to clarify something. You 12 are directing your questions to APS, and that is perfectly 13 fine and I or my staff could answer these questions just as 14 well as Mr. Bingham could. However, we work so closely 15 together in our organizations the way that we have structured 16 these proceedings', at least as far as the interface workings 17 between our two organizations, Bill is prepared to answer 18 those questions. If you wish to ask APS a question about 19 how we process something within our organization, we will 20 directly answer that. In these areas where things are going 21 between us and Bechtel, Bill we have just designated as a 22 matter of convenience, since he is up here;, to answer those kinds of questions'. I didn't want you to feel that we could not answer these questions if we so desired.
25 DR. ROSZTOCZY: My main concern is whether these things GRUMLEY REPORTERS Phoenix, Arizona
have been established and have been provided to all parties involved, for example, Combustion Engineering or a third party or fourth party involved, and have they received this information.
MR.. VAN BRUNT: All things that go through the interface Bill is perfectly capable of answering, as we are, but as a convenience, he will be answering. If you want to get into the specifics that occur within the Arizona Public Service Company organization itself, then one of my staff or 10 myself will be very happy to answer those questions.
MR. BINGHAM: In your handout, as you get back to 12 them, you will see 'the qualifications and the zones and 13 everything, so the material is your handout. We will get 14 into that.
15 DR. ROSZTOCZY: Let me then see those in the presenta-16 tion. If I have anything more, I will ask it at that time.
17 MR. VAN BRUNT: Do you have any more questions?
18 DR. ROSZTOCZY: No. Thank; you.
19 MR. NOONAN: I would like to go back to your earlier 20 statement of the purchase orders and I would like to ask 21 Bechtel as to given a particular piece of equipment that 22 will interface. with your NSSS vendor, how are his requirements 23 integrated into your purchase order and what procedure is followed.
MR. BINGHAM: If it is an interface, the criteria are GRUMLEY REPORTERS Phoenix, Arizona
55 1 put in the purchase order. A draft is sent to Combustion 2 Engineering for review. They comment and send us back a 3 formal letter indicating their comments and acceptance or 4 request that we make some modifications and finally will accept that we have interpreted the information and included them properly. So there is a formal system that we have in our house that not only covers the original requirements, but 8 any revisions that may happen thereto during the course of the design.
10 MR. NOONAN: In this interchange of information, is APS then kept informed of what is being done between Bechtel 12 and the NSSS vendor?
13 MR. BINGHAM: Yes, they are part of the process.
14 MR. NOONAN: They are part of the process. Okay. If 15 I could go to Figure 6, this is a question on the service 16 conditions. I notice you list temperature, pressure, radiatio 17 and chemical. I don't see aging. ,Is that to be discussed?
18 MR. BINGHAM: Yes, it will. This was just to present 19 an overview for the board's information of generally how the 20 program works. When we get into the detailed discussions, we 21 will be covering in particular the aging requirements.
22 MR. NOONAN: All right. I have a few more questions.
23 On Table l, I look at the various safety-related equipment 24 categories, A, B, C, D, and particularly the one I am most 25 concerned about is the in-containment - possible harsh GRUMLEY REPORTERS Phoenix, Arizona
1 environment. You indicated 'that you would allow Method 3 to be used to qualify equipment. Can you tell me where you 3 -
have documented operating experience for equipment exposed 4 to harsh environments.
MR. BINGHAM: We haven't done that yet, but we are 6 prepared to discuss that in detail later on, so if you could 7 hold that question until that time, I think we will cover it 8 properly.
MR. NOONAN: If I can go to Figure 7, I have two 10 questions. The first question is in this qualification team 11 review, I suspect that that team is to look at -- maybe it is 12 in the next block where you do the audit of testing, I am not 13 sure where,,but, anyway, given that you have some anomalies 14 that occur during a test, how are those anomalies resolved 15 and, if they impact the NSSS supplier, how are they resolved 16 with himp7 MR. BINGHAM: First of all, we will cover the process 18 in detail under Section IV later on. We resolve them in the 19 same manner as we resolve all of our problems with APS, very 20 carefully. Your question about Combustion Engineering, in 21 other areas, of course, we have extensive meetings and reviews 22 to resolve the particular issues.
23 I think, Ed, that you may want to respond on the 24 plans for Combustion Engineering in this particular case.
25 MR. ALLEN: Regarding how we handle Combustion GRUMLEY REPORTERS Phoenix, Arizona
e Engineeringf MR. BINGHAM: If there is an anomaly in what Combustio is doing for testing as far as it relates to equipment qualification, as I understand.
MR. ALLEN: So far as Combu'stion Engineering, we work with Combustion Engineering very closely, as we do with Bechtel. For example, we have seen some of their qualifica-tion programs, we have commented on them, we have received 9 Bechtel's comments on some of their qualification programs 10 and some of our concerns, and then we transmit these to Combustion Engineering and we periodically have meetings with 12 Combustion Engineering trying to resolve our differences, ver 13 similar to how we handle them with Bechtel.
14 MR. NOONAN: So APS takes that function to make sure 15 that any anomalies that occur on either side in the testing 16 of equipment, that those anomalies are not detrimental to 17 safe shutdown of the plant2 18 MR. VAN BRUNT: Right. Mr. Noonan, there is no question that we are ultimately responsible and we are going 20 to take what action is necessary, be it with Bechtel or be 21 it with Combustion. or be it with any sub-vendor, to assure 22 ourselves that any anomalies are resolved to our satisfaction.
23 As far as Combustion is concerned, we work very closely with Bechtel in reviewing those matters and thep, of course, with 25 the Bechtel sub-suppliers, we are working very closely with GRUMLEY REPORTERS Phoenix, Arizona
1 Bechtel to resolve those matters.
MR. NOONAN: I guess one of the things I am thinking about is particularly on some, of your seismic testing where you might be testing a piece of equipment and you get some spurious signals out of that equipment. Those signals might be very minor and be very short-time based and a judgment made on Bechtel's part that these would not cause any detri-mental effects as far as that equipment is concerned, but these types of signals could be fed into an NSSS piece of 10 equipment that could cause detrimental effects, and that is what I am looking for, given you get these types of anomalies, 12 to make sure that this is integrated into the NSSS side to 13 assure that you are not going to have some malfunction occur 14 with some other piece of safety-related equipment.
15 MR. VAN BRUNT: Bill, let John make a comment.
16 MR. ALLEN: I would like to respond to that a little 17 bit about'differences of opinion between us and Bechtel and 18 Combustion. Many times we have had and we have requested 19 that an outside consultant be brought in, an independent 20 consultant, to help us resolve problems. So if we have 21 gotten to where we couldn't come to an agreement, we request 22 an outside consultant come in for a third opinion.
23 VAN BRUNT: This is exactly what we have done recently. You heard before Mr. Roedel mention a specific 25 problem we have had with Rockbestos. We bought some GRUMLEY REPORTERS Phoenix, Arizona
e 59 10 CFR 50-55(e) type material and what we did was bring in an outside consultant, an expert in that axea, to review the whole matter and make recommendations to us as to what we should do about these particular problems. So in our functio as the applicant and having the ultimate responsibility for this plant, we will be assuring ourselves, be it through Combustion or our own forces or through the Bechtel staff, that anomalies such as you speak of or any other matters that may be a problem with equipment qualification or any other 10 darn thing in the plant will in fact be resolved satisfactori MR. ALLEN: In addition, I might say that in this 12 case with the Rockbestos, within APS, not necessarily inside the nuclear engineering organization, we have Roger Clark's 14 people in generation engineering we want to help us out 15 on this problem. In addition to that, we have a cable expert 16 that we went to. So we have quite a large resource in that 17 area to help us resolve our problems.
18 MR. VAN BRUNT: I don't think there is any particular cookbook method that I can outline to you as to how we could V
20 take care of an anomaly. Each anomaly will have to be dealt 21 with as a particular problem and handled as appropriate for E
22 that particular si.tuation.
23 MR. NOONAN: I just wanted to be sure that it is 24 handled properly.
25 MR. VAN BRUNT: I assure you that it is.
GRUMLEY REPORTERS Phoenix, Arizona
MR. NOONAN: I have one last question, or I want to comment. On Figure 7, I find it very difficult where you leave the decision to test or do analysis up to your supplier or your vendors. In some cases, I guess the supplier maybe has the capability of making that type of determination, but there are probably some small type suppliers that really woul not have engineering capabilities of making these determina-tions whether this equipment should be tested or should be analyzed, and I don't understand'that process at all. It 10 seems to me that Bechtel should have that responsibility of determining whether the equipment should be tested or analyze 12 MR. BINGHAM We share your concern, Mr. Noonan. I 13 think that probably the best thing to do is to listen to the 14 rest of the presentation, and at that time, let's have a 15 discussion on this particular issue so that we can portray exactly how we are handling this and how the team is assuring 17 that the proper decision is made, because it is something 18 that we don't treat lightly.
19 MR. NOONAN: Then later on in your presentation, you 20 are going to talk about pieces of equipment. One thing I 21 would like you to address -is how you handle the testing of 22 relays, since relays have been a problem not only in this 23 industry, but many other industries, and they are a constant 24 source of trouble, particularly under vibratory dynamic loads.
25 I would like to see later on a discussion on that.
GRUMLEY AEPORTEAS Phoenix, Arizona
61 MR. BINGHAM: We will do that. We will be pleased to 2 do that.
MR. VAN BRUNT: Do you have any other questions, 4 Mr. Noonan?
.Any other board members have any questions at this time?
DR..ROSZTOCZY: Mr. Chairman, going back to my previou statement, I do have one question.'R.
VAN BRUNT: We'l let you get away with it.
10 DR. ROSZTOCZY: In the presentation, you have indicate 11 that for certain types of equipment, you have a preferred 12 mode of qualification. The preferred mode for many of them 13 was testing. Do you have a list of those cases where you have 14 decided not to follow the preferred mode of qualification and-15 are those cases and their reasons going to be discussed here 16 today?
17 MR. BINGHAM: Yes. In general, most of our in-contain nt 18 and perhaps all of our in-containment has type testing'n 19 some form, and even equipment in Category B, which is outside-20 possible harsh environment. Our biggest problem is that the 21 vendors are coming to us and saying that, for various 22 reasons, it can't be done, or it is not practical, or somethin 23 else of that nature. You will be hearing latex'hen we get 24 into the problem areas the process that we, have amongst us 25 wrestling with this particular problem. To date, we have GRUMLEY REPORTERS Phoenix, Arizona
Oi 0
62 not backed down. If you could at the time that we get through the presentation ask the. questions what about this what about that supplier, we would be more than I'quipment, 4 pleased to bring the board up to date on where we stand and tell you how we are. talking and what we hope the outcome will be.
DR. ROSZTOCZY: What I am asking for, are you keeping a list of those items where you are not following the preferred one2 10 MR. BINGHAM: Yes.
DR. ROSZTOCZY: In other words, this is exceptional 12 items. This is supposed to be the short list rather than the 13 one where you follow it, and are you going to discuss the 14 reasons why did you decide not to perform testing for those 15 cases.
MR. BINGHAM: We don't believe that we are in the 17 position yet where we have had to accept other than what we 18 wanted, and that is the area that we will discuss with our 19 problem vendors. I think it isSection VIII of our agenda.
20 I guess what I am'aying is the bottom line to you, 21 Dr. Rosztoczy, is that we don't give up easy, and we will 22 give the board a perspective'of where. we stand. I'm sorry, I 23 am corrected. It is in Section VII, Qualification Problem 24 Areas. We do not and we don't intend to give in on a type testing unless it is demonstrated to be impractical.
GRUMLEY REPORTERS Phoenix, Arizona
63 DR. ROSZTOCZY: Then the answer is that up to date, you have not given in on any of theme MR. BINGHAM: To my knowledge, we have not. When we get into the details; if there is one in there, we will I
make sure that we flag it this afternoon.
DR. ROSZTOCZY: So it is a nice short list.
MR. VAN BRUNT: How many more questions have we got?
Karl, you'e got one. Bill, you'e got one. Carter's got one. Why don't we take about a 15-minute break at this 10 point. We will get back here at about 25 after.
(Thereupon a brief recess was taken, after which 12 proceedings were resumed as follows: )
13 MR. VAN BRUNT: Bill, let me say a word before you 14 proceed.
15 As I indicated earlier in my opening remarks, I have to leave and go out to Palo Verde, so I am going to turn 17 the, Chair over to Mr. Allen. He will be handling the meeting 18 from now until the completion. So, John, if you would pick 19 up 20 MR. ALLEN: Bill, I think some other people have some 21 questions. Bill Quinn.
22 MR. QUINN: On Figure 3, you indicated a box which shows independent qualification programs that you are doing 24 for your recalcitrant suppliers. I am sure you are going to touch on that later.
GRUMLEY REPORTERS Phoenix, Arizona
64 MR. BINGHAM: That 's correct.
MR. QUINN: Can you just tell me, have all those.
3 recalcitrant suppliers been identified to date?
MR. BINGHAM: Not completely.
MR. QUINN: Have the ones identified to date been 6 factored into your schedule on Figure 87 7 MR. BINGHAM: We are including that in our schedule.
I 'think, John, before we go on with more questions, 9 there were a couple of clarifications I wanted to make. One 10 of these figures, Figure 7, says "Qualification Test Review."
11 That should be "Qualification Team Review." We will correct 12 that.
13 MR. ALLEN: Then that will become part of the record.
14 MR. BINGHAM: Yes. The second is, that it has come 15 to my attention that there may be some misunderstanding on 16 exactly what we are doing with regard to type testing, and we 17 will make sure that we clarify that during the presentation 18 so you know exactly what is done with the various pieces of 19 equipment.
20 Are there any other questions from the boards 21 MR. ALLEN: Go ahead, Karl.
22 MR. KREUTZIGER: I have three questions which we might 23 cover later, so I will just state the questions. The first 24 question on Table 1 is the definition of harsh or possible 25 harsh environment. I would like to have a little explanation GRUMLEY REPORTERS Phoenix, Arizona
(
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either now or later, because I see a piece of electrical equipment, a motor control center, listed in the examples and I was wondering whether or not a possible harsh environ-ment was limited to such events as high energy line breaks or whether the harsh environment included other parameters.
MR. BINGHAM: Fine. We will answer that later on.
7 MR. KREUTZIGER: The second question I have refers to Figure 6. In Figure 6, there is a qualification of IE components on the left and qualification of other safety-10 related components on the right. On a previous slide on Figure 4, the examples of non-electrical equipment, the word 12 there is "non-electrical equipment." Where do such items as 1
13 valves fall with respect to qualifications of items like 1a limit switches or other items that might be considered 15 electrical in nature and, therefore, require to be qualified to 3237 Specifically, to clarify my question, as I see that 17 on the right-hand column on Figure 6, the only document that 18 'you have for environmental qualification is IEEE 627-1980.
19 Was there or has there been any qualification of equipment, 20 since you indicated that most all of the equipment has been 21 purchased as to environmental qualification criteria for 22 non-class IE equipment.
23 MR. BINGHAM: We will be responding to that.
MR. KREUTZIGER: The last question I have is the role 25 of the qualification review team. My undexstanding is that GAUMLEY REPORTERS Phoenix, Arizopa
66 the number of people is comprised of five APS people approximately and five Bechtel people'doing coordination.
What is the definition and role of the individuals and how does this team function with respect to their review?
MR. BINGHAM: We will cover that, under Section IV.
MR. ALLEN: Are there any more questions? George.
MR. SLITER: With regard to Figure 5, your Qualifica-tion Requirements Time Line, is it your intention to revise the FSAR to eventually reflect the degree of compliance- to r
10 NUREG 05882 MR. BINGHAM: I think I would have to refer that one 12 to APS.
13 MR. ALLEN: What was the question again?
14 MR. SLITER: Would you eventually revise your FSAR, 15 that's why I asked the'uestion of Bechtel, to reflect the degree of compliance with 05882 17 MR. ALLEN: That's correct.
18 Any further questions on thi.s before Bill moves on 19 to the next subject? Ed.
20 MR. STERLING: On Figure 8 at the bottom line, you 21 have these qualification review meetings with the 44 PO 22 vendors. Are you going to cover the scope, of what you 23 accomplish with that later on?
24 MR. BINGHAM: Yes.
25 MR. STERLING: I will defer my questions, then.
GRUMLEY REPOATERS Phoenix, Arizona
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67 MR. ALLEN: Go ahead, Bill, to the next subject.
MR. BINGHAM: With that lengthy introduction and 3 background, I would like to ask Bob Carson to continue the presentation.'here is a considerable amount of detail that 5 we will cover in the presentation. Generally what we will do is break for questions at the end of III. A., Overview of Design Criteria, and then when he gets into Section B.,
Environmental Qualification Criteria, we will break at the g, end of each of those subheadings.
10 MR. ALLEN: Bill, if I may say something, lunch ~
scheduled for 12:30. How is that going to fit into that 12 presentationf We have to eat right at 12:30.
13 MR. BINGHAM: Well, why don't we stop at 5 or 10 minutes prior to that time for our presentation. You can ask 15 questions until that time, break for lunch, and then continue.
MR. ALLEN: Okay, fine.
17 MR. CARSON: Exhibit IIIA-1 is an overview of the 18 design criteria having to do with environmental qualification.
1g First of all, a .few definitions. Safety-related equipment 20 as it applies to the nuclear station is any item of equipment which is, necessary to mitigate the consequences of a design basis accident and to allow the station to be brought to a safe shutdown condition. This equipment is, identified by 24 system and by item of equipment in the plant and the appropriat 25 qualifications are applied. Qualification is a demonstration GRUMLEY REPORTERS Phoenix, Arizona
t>>
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68 that the safety-related equipment items will perform properly at the times when they'are called upon to perform and mitigate consequences of the accident and to allow the plant to be brought to a safe shutdown. It is also a demonstration that this performance can be accomplished at the times necessary and under the conditions which prevail at the time of the and that would be normal operation, abnormal C'peration, conditions, design basis accident conditions, post-design basis accident conditions, and in-service tests. Any time 10 the equipment is called upon to operate, that is demonstrated by some qualification method. In answer to one of 12 Dr. Rosztoczy's questions, service conditions are determined 13 for each piece of equipment at its location in the plant.
14 Environmental zones are set down in this project by building, 15 and the environmental conditions which accrue at those locatio s are determined by reference to information supplied by 17 engineering; for;instance, by calculations 'made by the 18 project staff having .to do with pressure and.temperature and 19 radiation releases" due to the design basis accidents.
20 Safety-related operational requirements have to do 21 with when the equipment is called upon to operate, what it has 22 to do, and methods for showing that this is. proper. Various 23 criteria are involved having to do with the operational requirements. Some are NRC requirements as listed in General 25 Design Criteria 1, 2, 4, and 23 of Appendix A, and Sections GRUMLEY REPORTERS Phoenix, Arizona
69 III and XI of Appendix B to 10 CFR Part 50. IEEE Standard 2 323-1974 is the basi.c document having to do with acceptable 3 methods and criteria and procedures to follow for qualifying primarily electrical or Class IE safety-related equipment, 5 but, as will be shown later, the principles and criteria of 6 that particular document are general enough and generic 7 enough that their application applies to all sorts of safety-related equipment. A rather recent document, IEEE 627-1980, 9 which has been in preparation for several years, really
]0 ,involves the principles of quali.fication for all types of safety-related equipment and will be acting as an umbrella document for qualification with reference to IEEE 323-74 as j3 the specific document for safety-related electrical equipment.
The principles and criteria contained in 627 are very, very 15 similar to 323, but their application is across the: board for 16 safety-related equipment. Other requirements for qualificatio 17 appear in the several NRC regulatory guides, which are interpretations and possibly modified requirements having to 19 do with IEEE documents having to do with qualification. The 20 indicated word. here, "daughter" documents, is. against 323.. Th re are a whole series of IEEE standards which have been and are being developed which apply to specific items of electrical 23 equipment, and we wi11 talk about thos e a 1 itt 1 e bit later, 24 but they cover particular items and the methods in the individ 25 IEEE standards all are aimed at providing successful qualificat 'r.
GRUMLEY REPORTERS Phoenix, Arizona
70 in accordance with the basic 323 document.
This is Exhibit IlEA-2. The purpose of establish-ing a qualified life for a safety-related piece of equipment.
Qualified life, first of all, is a time period based in years or portions of years during which the equipment can perform its safety-related function. Qualified life is that time period after which it has experienced the rigors of all the environmental parameters and is still able to do its job when called upon when subjected to a design basis 10 accident. Xt may not be able to continue for a longer period of time under normal operation, but it is demonstrate 12 - that it will do its job for that length of time and still be able to perform its function under a design basis 14 accident or'ny other condition accruing from a design basis 15 accident at that time. To establish an assumed end-of-life condition by artificially or naturally aging the piece of 17 equipment is a part of the qualification- process,. There are 18 accepted aging mechanisms and methods which are used for 19 equipment to put it in an assumed end-of-life condition.
20 The qualified life that is always looked for hopefully is
'21 the life of 'the plant, which is based on a 40-year life. We 22 would always like to have equipment of a 40-year qualified life. Sometimes that is not possible. We age the equipment artificially or naturally to that qualified life period, then 1
25 subject it to seismic events and design basis accident events GRUMLEY REPORTERS Phoenix, Arizona
71 to show that it will still do its job.
Information required for each safety-related 3 equipment item. Again in answer to one of Dr. Rosztoczy's questions, identification of the equipment and its safety-related function, all safety-related systems and all items within the system are identified and pieces of equipment are indicated in the FSAR. The safety-xelated functions are determined for each piece of equipment under the 'conditions of the design basis events during which it must operate to 10 mitigate various consequences, of those events. The operabili requirements are determined: When does it have to operate, 12 for how long does it have to operate, under what conditions 13 does it have to operate, and what does it do when it operates.
The range of service conditions during normal, abnormal, 15 design basis event, post-design basis accident, and test 16 conditions, all these service conditions are evaluated and 17 determined for that particular piece of equipment in its 18 location. Only a few were indicated on one of the previous 19 slides having to do with temperature, pressure, radiation.
20 The whole gamut of operating requirements has to be deter-21 mined for that location. If an item, for instance, is subjec d 22 to flooding or submergence ox'f it has a dust problem 23 involved in it during any one of its operating modes, that 24 I
is determined, it is indicated in the specification'or the 25 equipment, and those things are taken account of during the GRUMLEY REPORTERS Phoenix, Arizona
~ '
qualification process. The identification of components and/or modules of equipment which must be subjected to aging deterioration. Not everything in every piece of equipment ages. at the same rate and not every item of the equipment in fact ages. You could have equipment, for instance, such as metallic items which don't age on a time basis or through temperature or through exposure to some of the conditions in the plant. Metals, of course, rust if exposed to some conditions. Allowances are made for this in the design of 10 the metallic items. Those items which age primarily due to temperature or radiation would be organic materials such as 12 electrical insulation or plastics or other materials which 13 are used as portions of equipment. Those materials are 14 determined and, as a part of qualification, certain require-15 ments will be attached to them. Certain methods will be used to artificially age them as a portion of the qualification 17 process.
18 Exhibit IIIA-3. Documentation as to the methods 19 'sed for qualification must be, provided and it must be 20 pxovided in an auditable form. Mr. Bingham indicated that 21 documents similar to this (indicating) and in many cases 22 considerably fatter items of documentation"are,involved in 23 a qualification program. Those documents include information 24 of what types o f qualification methods are used, - as agreed 25 upon ~ the. vendor and Bechtel and APS, the procedures on how GRUMLEY REPORTERS Phoenix, Arizona
~,
73 the qualification is to be accomplished, reports of the qualification process, the data that is taken, the use of the data,,anQ the reduction of the data into usable reports. This information is all in auditable form; that is, it can be 5 looked at at any time by NRC personnel or others who have the 6 need to know, and it is kept by APS at various locations.
7 .Documentation by vendors which is used to supplement the 8 qualification effort or which may be proprietary to that 9 vendor which he feels it is not in his best interest to allow 10 in public records is also available at the vendor's location ll and in many cases at 'APS'ocation if that can be arranged.
12 The material in terms of the documentation has to be availabl 13 for the life of the plant. If the vendor chooses to say 14 something is proprietary and it will not be made available as 15 a portion of the program, it must be specifically identified, 16 its location has to be identified, and assurance given that 17 that documentation will be available for audit for the life 18 of the plant, the assumed 40-year period.
19 As mentioned, XEEE 323-1974 is the basic document 20 having to do with qualification of electrical safety-related 21 equipment, the so-called .Class IE equipment. Other safety-22 related equipment is covered under the general principles and 23 methods and criteria contained in that document as indicated 24 in NRC's Standard Review Plan Section 3.11, Revision 1. The 25 application of the 627 document, which is a very new one, and
'RUMLEY REPORTERS Phoenix, Arizona
fact is not even available at this point for official distribution but is available to the industry, has to do with V
all types of safety-related equipment. It contains in=
general the same principles, the same criteria for qualifica tion of safety-related equipment -- identification of the equipment, identification of the modes of operation, documen-tation, and such as that, as are in IEEE-323.
Exhibit IIIA-4 has to do with standardized environmental and seismic qualification specification 10 appendices. The information to the vendor having to do with qualification indicating what needs to be qualified a'na how 12 is to be qualified 's presented in regard to the several 13 specifications by these standard appendices which are 14 attached. You will notice there is quite a variety of these 15 covering various types of equipment.
16 Exhibit IIIA-5"is additional appendices having to 17 do with particular pieces of equipment. Down to Appendix 4U 18 cover various seismic qualifications. Appendices 4V and 4Y 19 have specifically to do with the Class IE electrical equipment 20 and the safety-related control and instrumentation devices.
21 In, these, reference is made to the IEEE Standard 323 as to th 22 basic general requirements for qualification, and if there are 23 ,any 'other special requirements or a;particular method which 24 is mandatory for that piece of equipment, this would be 25 specified in the appendix or in the specification for the GRUMLEY REPORTERS Phoenix, Arizona
, individual item of equipment.
MR. BINGHAM: Are there any questions?
MR. ALLEN: George.
MR. SLITER: On your No. 3) on Item III.A-2 is the expression "Establish an assumed end-of-life condition."
Could you please elaborate on what you mean by the word 7 "assumed" here in this context?
MR. CARSON: Well, the end-of'-.life condition is 9 determined by the aging. The methods of aging we will discus 10 a little bit later, but, for instance, in terms of organic ll materials or electrical insulation, the Arrhenius method is 12 used extensively to'etermine by accelerated methods a life 13 that can be expected at an operating temperature. By using 14 the Arrhenius method, we could, for instance, say tnat an 15 electrical insu>><ion. system, when operated at a 90-degree C 16 ambient, will last for 50 years or more, or 40 years, or 17 20 years, depending upon the components and constituents 18 used in that system. The vendor when agin'g will use the 19 appropriate method to provide the aging and he will, of cours try to get the longest age or the longest life that he can.
.)
20 21 Some materials under the conditions existing in the plant 22 won't indicate a 40-year life,. but the aging mechanisms 23 have to be determined, the aging methods used, to give what is the assumed end of life, because we can't determine the 25 actual end of life. We are trying to demonstrate that this GRUMLEY REPORTERS Phoenix, Arizona
equipment, based on its. components, its constituents, under 2 the conditions when it has to operate would operate for that 3 period determined by the accelerated aging methods.
MR. ALLEN: Since we are on that slide, Bob, that last bullet down there, Identification of Components and/or 6 Modules of the Equipment Which Are Subject to Aging Deteriora 7 tion, what is the basis of determining whether they are 8 subject to aging deterioration or not7 What is your criterio 9 for that?
10 MR. CARSON: The criterion for that is primarily based ll on, first of all, determining whether the component, the 12 module, or the individual item is in fact safety related, 13 does that particular thing have to operate in order to mitiga n the consequences of the accident or have to operate to allow 15 the entire piece of equipment to function properly. Once, you determine that a piece of equipment, a module within it, 17 or an individual item within it has to operate, you then have 18 t'o determine whether that item has some aging mechanism. I 19 mentioned metals. Metals, for instance, don't age signifi-20 cantly. They don't age at all, really, in regard to tempera-21 ture or in terms of radiation for most of the magnetic 22 materials that are used, so you would say that metallic items 23 can be disregarded in terms of age deterioration mechanisms for the parameters that we are worried about. But if you 25 look at organic material, plastics, electric" cable insulation, GRUMLEY REPORTERS Phoenix, Arizona
things like that, those are known to deteriorate due to the effects of temperature, due to the e'ffects of radiation, possibly moisture in the humidity situation, and you need to determine the materials-, the components that age, and once you determine what ages, you have to figure out the mechanisms by which they age, determine the characteristics of that material that you are looking for, and make a test, r
make an analysis, or an analysis backed up by some testing in order to determine what the aging is under the conditions 10 in which you are operating. That is the whole point of the accelerated aging.
12 MR. BINGHAM Any other questions?'R.
13 STERLING: Just'to respond a second on what John 14 had indicated,, who sets that criteria? Do you ask the 15 vendor to qualify his equipment and then he comes back with a list of what he thinks ages or doesn't age with an analysis, 17 or do you or do APS and Bechtel set the criteria about what 18 they must test to or not?
19 MR. BINGHAM: John, again, some of these questions 20 would be more appropriate to answer at a later"time, because e 21 will be hitting these issues during the next part of the 22 review, and I think I would ask to jet us present some of our 23 material in this area and then we will, I am sure, answer 24 those particular questions.'R.
25 STERLING: I have another question, if I may, on GRUMLEY REPORTERS Phoenix, Arizona
Exhibit IIIA-3. If you are going to hit this later, let me know. You are calling for the supplier to maintain some 3 documentation. How do you plan to handle the supplier who 4 is going out of business or a loss of that documentation 5 because it =is not in the utilityf MR. CARSON: We cover that in a later portion of the 7 presentation.
MR. STERLING: Gn the next page, IIIA-4., could you, p
clarify the difference between active and nonactive equipment 10 that are in the various appendices, the tit:lesf MR. CARSON: I would like to have Ken Schechter 12 answer that particular question, since those are involved 13 with seismic definitions.
14 MR. SCHECHTER: I will cover that later on in my 15 presentation.
MR. BINGHAM: We are covering that later on, also.
17 MR. ALLEN: Shelly, did you have a questionf 18 MR. FREID: Yes. This rather extensive list of 19 appendices cover most of the principles brought forth, but 20 several times we refer to IEEE 62Q, which covers nonelectrica 21 equipment, and I don't see an appendix that- covers the 22 environmental qualification of nonelectrical equipment. Are 23 you in the process of developing an appendix to cover those 24 areasf 25 MR. CARSON: Not specifically. As indicated, the GRUMLEY REPORTERS Phoenix, Arizona
document is very new, 1980, but the principles of 62/ read I
=
very, very similarly to 323. It is an umbrella document 3 having to do with qualification. As well, I will indicate z 4 a little bit later when we discuss the Standard Review Plan, the principles of 323 have been asked for'nd have been made I'equirements for the several vendors of nonelectrical 7 equipment specifically. We are asking them to use the 8 principals of. 323 and apply them to those pieces of equipment 9 which are not specifically electrical.
10 MR. FREID: My question is how do you in your specific tions make that clear. In all of these others, it is obvious 12 you 'append an appendix that defines exactly what they are to 13 do in these areas. In the case of nonelectrical equipment,
]4 how do you let the supplier know what you intend him to do?
]5 MR. CARSON: Previous to recently, within the past
]6 year, vendors were not specifically advised that other than 17 electrical equipment was to be addressed in more detail than 18 to address the seismic problems. During the past year, we
]9 have been in contact with all of our vendors and have 20 requested them and are requiring them to address their pieces of equipment, no matter what they are, in regard to the principles and criteria of the 323 document. Bill Bingham 23 mentioned earlier that we are having meetings with these 24 44 different vendors that we have involving these 59 different purchase orders that are involved. We are meeting GRUMLEY REPORTERS Phoenix, Arizona
1 with each of these vendors. We are asking them to look at 2 their programs, identify those pieces of nonelectrical 3 equipment that have aging mechanisms that are safety related, 4 and give us information about the qualification status of 5 those items, give us aging mechanisms, deterioration modes, 6 look at these things so that -we will have this information, 7 which is now being called for in the 627 document, but we 8 have looked at it and are looking at it in relation to the 9 principles of the 323 document.
10 MR. BINGHAM: Further questions, Johnf MR. NOONAN: On Exhibit IIIA-2 under Paragraph 4),
12 you have a bullet there called Determination of Operability 13 Requirements. I mentioned this earlier, but it was brought 14 out during the break that maybe I was not being speci.fic 15 enough to get my concern across. When Bechtel makes this 16 determination of operability requirements and looks back at 17 their test results to see whether or not they have passed 18 these test results, I was talking about anomalies and how 19 these anomalies are fed back to the utili.ty or to the NSSS 20 supplier. I would like to give a specific example to show 21 my concern. Recently there was a test by another NSSS 22 vendor regarding a piece of electrical equipment. That 23 electrical equipment was monitored for output. Its output wa 24 monitored to see whether or not it met the requirements of what it was supposed to do under seismic environment. In p
25 GRUMLEY REPORTERS Phoenix, Arizona
81
'oing so, they found small type spurious signals coming out 2 of the piece of equipment that were not supposed to be there.
3 These were signals that were in duration about one millisecon 4 but you would get a number of these occurring say within a 5 period of about a 100 millisecond duration. After 6 investigation, it was found out that, while this was not 7 particulaxly detrimental to the piece of equipment that the 8 NSSS supplier was providing, these signals did perform an 9 adverse function on a piece of balance of plant equipment.
10 That is what I am trying to get across. When you look at the determination of operability requirements, do you consider 12 those requirements as to how they relate back to the NSSS 13 people?
14 MR. CARSON: In the specification for the particular 15 equipment item, we will indicate the acceptance criteria for 16 that particular piece of equipment, what does it have to do 17 under what conditions, and we hope that we have determined 18 everything involved in the operability that might cause a 19 problem. If during the testing some anomaly such as you
)
20 mention does come up and is identified, we would go back to 21 the responsible engineer and identify those anomalies. We 22 would go back into an analysis of the system in which this 23 piece of equipment operates to see whether it can be determin 24 whether such an anomaly would cause a problem. If it is 25 analyzed and determination is made that such a thing is GRUMLEY REPORTERS Phoenix, Arizona
1 indicated as not causing a problem, then that would be 2 accepted. If it is determined that 'that would cause a 3 problem, we then will go back to the vendor and try to 4 eliminate that or possibly have a redesign of the equipment 5 to eliminate such anomaly that would cause detrimental effect MR. NOONAN: That procedure is in place between you and the utility and the NSSS vendor? That's what I am 8 looking for, to make sure that procedure is in place.
MR. BINGHAM: Vince, that's true for everything that 10 we do. We use the same procedure. We have to do that in ll order to assure that there is feedback in design. I think 12 what Mr. Carson sai'd is once it is flagged, we don'0 neglect 13 it, we follow thxough, and we can cite other examples in the 14 balance of plant design.
15 MR. NOONAN: I would like to ask one other additional question, or two additional questions, really. I am not 17 sure what paragraph this would fit under, but I think it 18 would fit under Paragraph 4) on the same slide. As you all 19 know, we have an IE Bttlletin Statement 79-14, which for the 20 public is referred to as the as-built conditions. I see 21 nothing in hexe that shows me that when the plant is being 22 built and modifications are made out in the field, whether 23 those modifications are a change in mounting or change in 24 location, how that is fed back into the qualification of that 25 equipment and how are records kept of that so that those GRUMLEY REPORTERS Phoenix, Arizona
0 0
l v
83 things are noted, if they affect the quali.fication of the equipment, it is so noted and something can be done about MR. BINGHAM: We can respond to that. What I would 5 like to do is to respond a little later, if I could, John.
MR. ALLEN: Okay. Gerry, do you want to make a note 7 of that2 8 MR. BINGHAM: Make a note of that.
P 9 MR. ALLEN: You want to make a phone call over lunchy 10 MR. BINGHAM: Yes.
MR. NOONAN: The final question would be on the next 12 page, IIIA-3 slide, on No. 5) where you talk about documen-13 tation. Recently, there has been a Commission interim order 14 to staff on equipment qualification dated May 23. In that 15 Commission order, it directs the staff to make sure that 16 adequate documentation is being maintained at a central 17 location. The supplier in my estimation does not conform to 18 that requirement of keeping documentation in a central loca-19 tion, and I guess I would like Dr. Rosztoczy to address that 20 in detail as to what we at NRC expect on that particular issu 21 MR. BINGHAM: We would like to hear.
22 QR. ROSZTOCZY: The required documentation is that it 23 has to be maintained at a central location and it is the 24 responsibility of the licensee. Those are the two important 25 parts, the central location and the licensee. There are also GRUMLEY REPORTERS Phoenix, Arizona
A 84 some clearly defined words which I believe permit, for example, maintenance possibly at two places. One may be at the utility's location for most of the plant'ocumentation and then the nuclear part at the Nuclear Steam "Supply System vendor location. Nevertheless, even in that case, the responsibility for the maintenance of both of these files rests with the licensee.
r MR. BINGHAM: I t:hink that is very helpful, John.
MR. NOONAN: One other point on the same thing. We 10 would like to discuss maybe very brie'fly here the subject of replacement parts. Replacement parts documentation also has 12 to get into this package. I think you ought to address how 13 you are going to handle replacement parts, how you are going 14 to maintain documentation to assure us that if you go out and 15 replace a part with a different part that: it has met all of the qualification requirements of the previous part.
17 MR., BINGHAM: John, I think 'that probably falls more within the APS area, the, replacement parts.
19 MR. ALLEN: That's correct. Presently Bgqce Kapgan, o 20 John Roedel's department, is coming. up with a corporate QA 21 manual which. this type of issue is covered in, so maybe I 22 could ask John Roedel to comment a little bit about that and 23 then possibly No'rm Hoefert, from operations.
24 MR. ROEDEL: To answer your question, we are developing 25 a system of purchasing that is based on the safety-related aspect of that item and what is necessary to inform us to GRUMLEY REPORTERS Phoenix, Arizona
85 assure that that item meets Chose requirements, so the procurement activity will be directly associated with what is necessary to assure us that the technical requirements are met. If we can buy that as an off-shelf item and still verify that the technical requirements are met, we will do it.
I am sure that if it is qualified electrical equipment, most of it won't be bought that way, but some of it could be as N
long as we can still verify its technical requirements and th previous requirements as expressed in the purchase order for 10 its original purchase.
'MR. NOONAN: And the documentation of the qualificatio 12 of that replacement'art will be kept where'R.
13 ROEDEL: Well, that will be available at the plant I
14 'site. We are documenting all our documents on a microfilm 15 system so that it will be available at different readouts in 16 the various parts of the plant or wherever the procurement 17 activity begins.
18 MR. ALLEN: I might clarify that, Vince, a little bit.
19 We intend to film every piece of documentation that we get 20 especially related to safety-related components and there 21 will be records kept both in the central engineering office 22 and the power plant, so it will,be in two different locations, 23 identical records.
24 MR. NOONAN: So when your IE inspector comes out to the 25 site, he would have a set of records to look at?
GRUMLEY REPORTERS Phoenix, Arizona
86 MR. ALLEN: Right, or if he happens to be at the engineering office, he will have the same records there.
Norm, would you like to respond on your procure-ment of parts at allf MR. HOEFERT: What specific area?
MR. ALLEN: On the procedures you have developed on how you handle spare parts, or do you think John Roedel covered it satisfactorily' MR. HOEFERT: I think generally John covered it as far 10 as we will have documentation at the site of any quality assurance requirements that are needed for each particular 12 part that is purchased.
13 MR. ALLEN: Any further questions7 14 DR. ROSZTOCZY: I have one question. In your presenta-15 tion, you gave a verbal definition of safety-related equipmen 16 and you tied it to the design basis accident. I hope that was 17 an oversight and what you really mean is all transients and 18 accidents, that the plant might be exposed to.
19 MR. CARSON: Yes. As I indicated, the equipment must 20 operate whenever it is called upon to operate .during any 21 Period normal abnormal, design basis event, Post-design 22 basis event,. test, whatever. Any time period during the operation of the plant during its life,under any conditions 24 that accrue at its location, for any operational mode of the 25 plant, that equipment must operate and has to be demonstrated GRUMLEY REPORTERS Phoenix, Arizona
during the qualification phase that it will operate.
DR. ROSZTOCZY: Thank you.
MR. ALLEN: Any further questions? Carter.
MR. ROGERS: I would like to take Vince Noonan's first question and turn it around just 'a little bit. Let's say that-we have a relay, for instance, that we are purchasing through'he balance of plant and that relay is 'tied to Combustion Engineering's qualified equipment. The relay is tested and it comes up with an anomaly. Are <here procedures'n 10 place which would ensure that Combustion Engineering is notified of that anomaly and has a chance to review it for K
12 acceptability or not7 13 MR. BINGHAM: Yes," there are.
14 MR. ALLEN: Any further questionsf If not, Bill, why 15 don ' you proceed.
16 MR. BINGHAM: Because of the time, I think probably we 17 would only be able to go through the first part of the next 18 section, which, is -III. B. Environmental Qualification Criteri
'I 19 Item 1, Standard Review Plan, and if we have time after that, 20 John, we will try to do the Design Criteria. Section 3.'is 21 a very lengthy presentation, so I think that would be best 22 to hold unti;1 after lunch.
23 MR. CARSON: Figure 11 indicates the environmental 24 qualification criteria having to do with safety-related 25 equipment which would be applicable in the environmental GRUMLEY REPORTERS Phoenix, Arizona
qualification program for the project. As we have indicated earlier, we define Class IE or electrical safety-related equipment and we identify other safety-related components or nonelectrical equipment and indicate the principal sources of qualification requirements for those types of equipment. The box area her'e (indicating) represents the HRC's Standard Review Plan for Qualification. of Safety-Related Equipment Section 3'l, Revision .l. All of these items within the box are specifically referenced in the Standard Review Plan as 10 being applicable to qualification of equipment.
Exhibit IIIB-1, Section 3.1l of the Standard Review Pl 12 For the following p'resentations where we talk about these 13 several items, we have only. extracted certain portions of 14 these, those items that bear specifically on qualifica-15 tion. I have not 'reproduced the entire document. The Standard Review Plan indicates the same- sorts of things that 17 we have talked about earlier. Safety-related equipment has 18 to be identified, its operational requirements dhtermined.
19 Environmental design related mechanical and electiical 20 equipment has to be shown to meet all of its weguiRetnents.
21 Exhibit IIXB-2. The Standard Rsv'ice alan calls for 22 the applicability of 323-1974.and it indicates that, even 23 though 323 was specifically designed and put together for 24 electrical safety-related equipment., the criteria, the 25 methods, the sequential testing, the aging in that document GRUMLEY REPORTERS Phoenix, Arizona
have to do generically with all types of safety-related equipment.
On Exhibit IIIB-3 are various requirements having to do with the application of 323 in regard to specific types of electrical equipment called out in the daughter documents to- that standard having to do with electrical penetrations IEEE 317, 334 for motors, 382 for valve opexators, 383 for wire and cable. As indicated, there are a number of other specific IEEE documents either in place 10 or being prepared now covering other items of electrical equipment.
12 Exhibit IIIB-4. In regard to the environment, one 13 of the parameters is chemical spray primarily involved with 14 in-containment chemicals. during a design basis event. The 15 equipment has to be qualified fox operation in that chemical 16 environment, and then the chemical requirement has to be that which will accrue in the specific plant.
18 Radiation is also "involved with the design basis 19 events. The equipment must be shown to be operable in 'the 20 radiation environment under any circumstances that will accru 21 at its location.
22 Exhibit IIIB-5. Another one of the specific items 23 called out in the Standard Review Plan is General Design 24 Criterion'No. 1 of 10 CFR 50, Appendix A, quality standards 25 having to do with structures, systems and components related GRUMLEY REPORTERS Phoenix, Arizona
to safety or safety-related items. The project maintains 2 quality assurance requirements in accordance with Appendix B of the 10 CPR 50 document.
IIB-6, General Design Criterion No. 2,
'xhibit 5 design bases for protection against natural phenomena. All 6 safety-related equipment is designed and qualified to withst 7 the effects of natural phenomena if such accrue at its 8 location.
Exhibit IIIB-7, General Design Criterion No.
10 environmental and missile design bases. Again, safety-ll related structures, systems and components must be designed 12 so that any., environmental or missile conditions that accrue a 13 the location are taken care of. In addition, physical 14 independence and redundant equipment is provided throughout 15 the plant so that a single item of safety-related equipment 16 if it is somehow disabled will not prevent the safety functio 17 from being performed.
18 Exhibit IIIB-8, General Design Criterion No. 23, 19 protection system failure modes. Safety-related equipment 20 has to be designed and qualified so that it will fail in a 21 safe manner. In the single- failure criterion, one piece of 22 equipment failing will not prevent the safety function from 23 bei.ng performed through the multiplicity of equipment provide 24 MR. BINGHAM: I think, John, let 's entertain questions 25 at this time for Sections 1 and 2.
GRUMLEY REPORTERS Phoenix, Arizona
91 MR. ALLEN: Any questions from the boards DR. ROSZTOCZY: The last few slides that you presented 3 had a separate column for the Palo Verde position and there 4 were certain words indicated there.- Maybe we can have the first one up, which was IIIB-l. In the right-hand column, there are words saying that that is in compliance. At the 7 present stage of your work, most of them have not yet been 8 tested, so you are obviously in no position to make any 9 conclusion that, it is in compliance. You hope .that by what 10 you are going to do in the next few months or the next year that by the end of that work, you will arrive at this conclusion. I think the slide in its present form is grossly misleading and those words should be modified or eliminated 14 from them.
15 MR. BINGHAM: You are absolutely right. In my opening 16 remarks, I indicated that you might get that impression from t
17 what we were presenting that we were'n compl'iance with 18 the principles of the documents, and I', had hoped that that 19 clarification would help. But that is true.
20 DR. ROSZTOCZY: Probably you should use words like you intend to comply with this rule, something like that.
22 MR. CARSON: What we are really indicating is that we 23 are in agreement with the positions stated in the documents and we are applying them to our, qualification programs. We 25 are asking our vendors to provide qualification programs which GRUMLEY REPORTERS Phoenix, Arizona
92 meet these criteria, and when we get all done with the total programs, our qualifications will be in compliance with all of the documents that we are discussing.
DR. ROSZTOCZY: Those words would be much better on th slide, also.
MR. BINGHAM: John, we have followed the format of the last two or three boards of review by using this presentation.
It apparently is confusing, and we can either qualify it for the record that that is the case, as we have done, or if the 10 board would desire, we can modify the slides for the record to make that statement.
12 MR. ALLEN: I think, like the slide indicates, it is 13 our intent to comply and we are not where we can say we compl 14 100%. I think as long as that is in the record, that should 15 be satisfactory.
MR. BARROW: I think, though, that it ought to be 17 explained, because, as his question suggests, quite a bit of,"
'18 our testing might be. still yet to come, or the vast majority 19 of our testing. It might be pointed out the percentage of 20 our equipment that has already undergone some or all of its 21 testing by the vendors. Could Bechtel indicate that7 22 MR. CARSON: Are you indicating environmental or 23 seismic, or both?
24 MR. BARROW: Environmental and/or seismic.
25 MR. CARSON: As I indicated, a great amount of the GRUMLEY REPORTERS Phoenix, Arizona
93 I
equipment has had some qualification testing, analysis, or 2 combination programs performed on it. The earlier table 3 indicated that 15 programs had been considered complete prior to the issuance of the 0588 document and only one now is considered complete. Those programs that had been considered complete are being reevaluated on the basis of the more recent requirements. Those programs which are in process, the new requirements are being applied to them. So they 9 will all eventually comply with all of these requirements 10 that we are talking about today. But, yes,, a great number of items have had some testing, analysis, or some qualification 12 'pplied to them.
13 MR. BARROW: In addition, isn't it true that the 14 balance, the other ones besides the 15, probably the majority 15 of them have had some testing done?
16 MR. CARSON: Yes, they are in process. As Bill 17 indicated, only a few items have not at this date been 18 purchased and these programs have been'n operation and in 19 the testing and qualification process over'he past years.
20 They are all at some state, but most of them are not 'fully 21 complete.
22 MR. BARROW: Thank you.
23 MR. ALLEN: John.
24 MR. ROEDEL: May I ask a question that maybe can clarify these various slide presentations to me? Is not the GRUMLEY REPORTERS PhoenixArizona
94 column on the left-hand'ide the acceptance/rejection criteri for the various activities that are neecteQ fox either a systeiTi or the testing of an article and the right-hand column is a statement that this project is going to meet that requirement, that was the acceptance or rejection criteria, and that the implementation of the acceptance criteria has not been 7 accomplished yet? Is not that what you are saying?
MR. BINGHAM: John, that's true. This is a format
- 9. that we have adopted for this particular board of review to 10 not only state what we are doing, but to compare it with the standard review plans and indicate where we stand as far as 12 the key elements in' hose standard review plans. An issue in 13 earlier boards of review that has come up is well, that 's 14 all very nice; now we know what you are doing. The board 15 has wanted to know how does that compare with the regulations 16 or the criteria. The intent here is a little bit more 17 difficult for the board, I am sure, to understand, because it 18 is not a system like the aux feedwater syst: em or the power 19 system that we have done. We have tried to take the same 20 format, because you are used to seeing it, and essentially 21 put the key elements on the left column and then indicate 22 more importantly those areas where we have exceptions or areas 23 that are just not practical as far as the regulations to 24 comply with on the right column.
25 MR. ALLEN: Do you have a better understanding of that GRUMLEY REPORTERS Phoenix, Arizona
95 now or do you still have a problem with it?
DR. ROSZTOCZY: I think I understand it and I under-stood it from the beginning, but I think the wording on the slides is not consistent with the present state. I just intended to bring attention to that.
MR. ALLEN: Carter, did you have a question?
MR. ROGERS: John Roedel p ret ty well i summar z e d what I was thinking. Actually, maybe this is a poor example, but it would be very difficult in my mind to say that there are thre 10 criteria that are there and all must be met, and when reading those criteria, I think that I would have difficulty finding 12 an acceptable exception to those whether it has been tested 13 or not, and I would think that equipment would meet this position even after they are tested or otherwise they are not 15 acceptable. Maybe we'e got a little time element question here, but our position as I read this, and in my mind, too, 17 sitting on the safety board, is that we should be in complian e 18 with those three elements that are listed on this slide.
MR. ALLEN: Pete.
20 MR. NEWCOMB: I have two questions related to Exhibit 21 IIIB-7. Under the'Palo Verde, position statement, you state 22 that systems and components outside containment important to 23 safety are provided with redundancy. First of all, would you 24 explain why outside was chosen and what is done for inside containment.
GRUMLEY REPORTERS Phoenix, Arizona
MR. CARSON: We are talking primarily here, as 2 Mr. Bingham indicated e'arlier, of the balance of plant equipment, which is primarily located outside of the contain-Certainly all equipment having to do with safety-F, ment.
5 xelated functions is provided where necessary in redundancy 6 both inside and outside. CE provides redundant equipment.
7 Balance of plant equipment is, provided in redundancy, What 8 we are addressing here primarily is the balance of plant 9 equipment. That is why the distinction was made outside the 10 containment.
MR. NEWCOMB: So the Palo Verde position is in fact 12 both inside and out'side?
13 MR. CARSON: Absolutely.
14 MR. NEWCOMB: Bechtel is primarily affected on the r
,15 outside containment.
rL 16 MR. CARSON: That's right.
17 MR. NEWCOMB: The second question I have is you were, 1
18 relating redundancy as a means evidently of meeting some of.
19 the requirements of environmental effects. Could you explain 20 the basis for that? In other words, I read Criterion No'. 4 21 to state that you must accommodate the effects of environment 22 conditions. Where does redundancy relate to that requirement?
23 MR. CARSON: Well, what we are indicating here is that redundant equipment is provided and if, due to some 1'he 25 environmental action, a piece of safety-related equipment is GAUMLEY REPORTERS Phoenix, Arizona
97 disabled, the arrangement is such that a single environmental occurrence would not, be involved with more than one piece of equipment, so the other equipments which are redundant and 4 perform the same function would not be affected by a single 5 environmental occurrence.
MR. NEWCOMB: What you are saying then is that the 7 redundancy is also combined with physical independence or 8 positional independence?
MR. CARSON: Yes, the physical independence of the 10 equipment. The walls around the rooms in which the equipment ll is located segregate one piece of equipment from another piec 12 of redundant equipment so that only one can be damaged 13 possibly in a given incident.
14 MR. BINGHAM: John, it is 12:30.
15 MR. ALLEN: I think we had better postpone any further k
questions until after lunch, because they did ask that we hav 17 lunch at exactly 12:30. Why don't we adjourn the meeting and 18 come back at 1:30.
19 (Thereupon the meeting was at recess.)
20 21 22 September 25, 1980 1:30 p.m.
23 24 MR. ALLEN: Bill, were you able to get any resolution 25 to any of those items?
GRUMLEY REPORTERS Phoenix, Arizona
1
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MR. BINGHAM: Yes, we have some resolution and, as I remember, before we broke, there was a question before the bo'ard on how they wished us to respond to the modification of the examples on the use of the words "in compliance."
MR. ALLEN: What I would like to find out from the board is would anybody be opposed to changing that to wording that would be more acceptable to Zoltan such as "intended compliance," or do you have some words you would like?
MR. ROSZTOCZY: A number of different wordings have 10 been mentioned here. I think any of those would be fine.
My only concern was that the present wording kind of expresse 12 a past tense type of thing, that it already has been establis ed 13 to be in compliance, and it is more like the future.
14 MR. ALLEN: "Future compliance," would that 15 MR. BARROW: John, I suggest "in the process of 16 compliance" or to show that we'are actually energetically 17 endeavoring to comply.
18 DR. ROSZTOCZY: I m not sure if it is necessary to 19 pick the words right here. I think you'e probably got the 20 message from the comments, and why don't we just leave it to 21 you to correct the words to whatever is appropriate.
22 MR. ALLEN: Bill Bingham, could I ask you then to go 23 back and correct those slides with some wording to show that 24 it is our intent to comply or some other words like that.
MR. BINGHAM: All right, we will correct them.
GRUMLEY REPORTERS Phoenix, Arizona
MR. KOPCHINSKI: All of them, I presume?
MR. BINGHAM: All of them.
MR. CLARK: Bill, I have a question concerning 4 equipment that meets the qualifications and then say ten year 5 down the road or five years or K years, is there anything 6 that states anywhere that you would require a requalification 7 and, if so, how is it documented or spelled out to Operations MR. BINGHAM: As I recall, John Allen touched on that earlier. If there is a qualified life less than 40 years, 10 let's say 20 years or 10 years, that will be so noted and, 11 as John mentioned, it will become part of the maintenance 12 procedures to replace it. Generally that is how it is 13 handled.
14 MR. CLARK: Maybe a restatement of that is if we do 15 have equipment that has been qualified for 40 years life and 16 say it has operated 10 years, how do we prove that it still 17 has 30 years life left on that piece of equipment? Mainly 18 rotating machinery.
19 MR. BINGHAM: Mell, I think the concept is that you 20 demonstrate prior to that that its qualified life is 40 years.
21 Of course, there will be periodic testing of all safety 22 equipment as required in the Tech Specs to assure'that it is 23 still performing its function monthly or some other period as 24 determined by the Technical Specifications.
25 MR. ALLEN: Any further questions? Shelly.
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100 MR. FREID: Could we go to Exhibit IIIB-8, please?
It doesn't seem that the PVNGS position addresses the Design 3 Criterion No . 23 for equipment qual ification. It address es 4 the position, but in particular for equipment qualification, 5 we qualify the system that it would not fail under adverse conditions, postulated adverse envir'onments, but more so don'0 we qualify that the component if it fails will fail as the design intends7 What I mean is a valve is designed to fqil either closed or fail open or to fail as is and the 10 qualification program assures that it fails in that mode.
MR. BINGHAM: Yes, that's correct.
12 MR. ALLEN:, Ed, did you have a question, or does Georg 13 MR. SLITER: I think that brings up a more general
'~
14 question about again your statement of position. You said earlier, Mr. Bingham, that this was meant to mean not so much in compliance, but in agreement, but this would be the location in which you may bring up any exceptions to the requirement. There may be an implication then that if the 19 words "in compliance" or "in agreement" are not here that 20 there may be an implied exception. I will assume in what I 21 have heard so far that in anything you have said, you have i
22 not come up with any exceptions, and can I,also assume that 23 if you had any exceptions, in future proceedings you would 24 be explicit about calling them exceptions7 25 MR. BINGHAM: That's correct, George. Our intent is to GRUNiLEY REPORTERS Phoenix, Arizona
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inform the board exactly where we stand and it is our intent 2 to delineate all exclusions, all exceptions.
MR. SLITER: And there are none.
MR. BINGHAM: Only as indicated, that's right, and 5 again I must indicate to you this is our intent. If we run up against a vendor that we have extreme difficulty with, there may have to be some compromises, and, of course, NRC 8 and APS and all parties would have to be a party".to that 9 particular compromise. But we really intended 'not to hide 10 anything or imply that anything. is hidden in our presentation 1], today.
12 MR. ALLEN: Any further questions? Yes, sir.
13 MR. VOLLMER: I have a question on safety-related 14 equipment. Your definition "would prevent or naitigate the consequences of an accident and provide fox a cold shutdown."
16 is that right?
17 MR. CARSON: To mitigate the consequences of an 18 accident and allow safe shutdown of the plant.
19 MR. VOLLMER: That is cold shutdown?
20 MR. BINGHAM: Yes.
21 MR. VOLLMER: Further, how do you intend to deal with two things: One, the changing requirements in the action 23 plan which are i,dentifying equipment that will be in the 24 future categorized as safety related and may not necessarily currently be in your QA as safety related, and, also, the GRUMLEY REPORTERS Phoenix, Arizona
l02 changing requirements such as use of different source materia on your balance of plant equipment, that is, higher radio-activity content of fluid than you probably now normally assume? I am wondering how the program deals with this and, also, if you are dealing with in any way what are categorized as systems and components that are not necessarily safety related by the true definition, but are important to safety in the context of the TMI lessons learned.,
MR. BINGHAM: We are considering all 'those points and 10 will be discussing some of them, for" example, the radiation, and there are other points that you didn't mention. We know 12 that there are changes that are coming, or at least potential, 13 that we must consider. We work very close with APS with 14 input 'from meetings like this and other discussions we have 15 with NRC or other utilities. When we go through the details, there will be appropriate places where we can respond'to how 17 we are tackling what I might call escalation of present 18 criteria, at least as we know them. So if we have missed a 19 point, maybe at that time I would suggest to the board that 20 that be brought- up so. that we are sure to clarify it. The 21 response to your question is yes, we are aware of 'verall 22 them 'and we have them as part of our program and they would 23 be handled in the proper manner; that is, if they come in as 24 a requirement, they will be reviewed with the utility, 25 become part of the criteria, and be implemented in the plan.
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103 MR. ALLEN: Any further questions before we move along?
Yes, sir.
DR. ROSZTOCZY: I am not sure if I get the gist as it relates to single failure. On the left-hand side of the slide, the question is what happens if it fails because of some environmental condition. This would be kind of a systematic failure. If you have four channels that have safety components in them and if one of those components in each of the channels fails because of environment, then the 10 indication is they do fail in the safe mode. On the right-hand side, your position doesn't address this question.
I e
12 MR. BINGHAM: Help me with the question again.
13 thought we did cover it.
14 DR. ROSZTOCZY: The requirement quoted on the left-15 hand side indicates that should there be a failure because of environmental conditions, then that should be in the safe 17 state, to be given in such a way so that it falls into the 18 safe state. The right-hand side kind of ignores this problem 19 and instead talks about single failure. Environmental failure 20 typically are not single failures, but they are multiple 21 failures.
22 MR. CARSON: Dr. Rosztoczy, I think you are asking 23 what if the piece of qualified equipment experiences a 24 failure due to an environmental parameter?
25 DR. ROSZTOCZY: Right.
GRUMLEY REPORTERS Phoenix, Arizona
l 104 MR. CARSON: What we are indicating is that we determine what environmental desiqnator it is in and what the 3 range of those environmental parameters are for those 4 locations and we test all j.tems or otherwise test the 5 equipment for that complete range of parameters, and we would 6 not anticipate that an item would fail. because of some environmental parameter, as you indicate, a common mode failure. We are taking account of the total~ range of paramet DR. ROSZTOCZY: That's correct, and that meets an 10 earlier requirement which is not shown on this slide. This requirement quoted on this slide goes a step further and it 12 says that, for example, you didn' predict the environment or 13 an unexpected environment somehow happens and should we fail, then it should be designed to fail in the safe mode.
15 MR. CARSON: This is correct.
DR. ROSZTOCZY: The right-hand side does not address 17 this question. The right-hand side should say yes, you are 18 going to see to that, that
~ if they fail because of high 19 temperature or because of something, that it falls into the 20 safe mode.
21 MR. CARSON: This is right, yes.
22 MR. BINGHAM: Yes, we meet that.
23 DR. ROSZTOCZY: Let me go back to the previous slide, 24 which is IIIB-7, Somebody asked some questions on this just before lunch. I am not sure if I followed all the answers GRUMLEY REPORTERS Phoenix, Arizona
1 El
105 to that. I might be somewhat repetitive, but let me try it anyway. Here again the left-hand side emphasizes that the equipment has to be designed to accommodate the environmental conditions, and on the right-hand side, there is no answer to that.
MR. CARSON: Again, as we have indicated, we design the equipment and qualify the equipment for all of these conditions. This is a further explanation. In addition to qualifying it for the range of environmental conditions, we 10 also take these precautions to further prevent any problems.
MR. BINGHAM: We agree with you this response is a 12 little confusing, and I think what I would offer is that we 13 clarify it in the record, John, 14 MR. ALLEN: Okay, if someone'would mark that down as 15 an open item then to be clarified, Exhibit IIIB-7.
16 DR. ROSZTOCZY: Is it your intention then to design 17 to meet the environmental conditions7 18 MR. BINGHAM: Yes.
19 MR. ALLEN: Any further questions on this'7 If not, 20 proceed with your presentation.
21 MR. BINGHAM: Before you start, I think there are two 22 things that we had left. The others we will discuss after the 23 break, John. First of all, with respect to Mr. Vollmer's question on the qualification of perhaps not safety-related 25 equipment, we are not now looking at that in our present GRUMLEY REPORTERS Phoenix, Arizona I
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106 plan, but we are aware of that potential,.
The second thing is I wanted to make sure that we had made the point that the positions on qualifications today represent a project qualification in our work not only in thi area, but in all areas. We have positions that we do present to our customers to start with and they may or may not follow that particular position. So I wanted to make clear that what you are seeing here today is a position that is for the Palo Verde Project and you might see some different positions 10 on other jobs wher'e Bechtel is involved.
With that, let's start into this next presentation, 12 John. This is a fairly long presentation. I just tell the 13 board that it will take somewhere in the neighborhood of a
.half'hour to 35 minutes, and, if you deem appropriate, we 15 can break in the middle, or if everybody is wide awake, we 16 can go on.
17 MR. ALLEN: I suggest that we hold the questions until 18 the end of the presentation to help us move along.
19 MR. CARSON: Exhibit IIIB-9 has to do with requirements 20 set forth in IEEE 279-1971, criteria for protection systems 21 having to do with test data and the range of transient 22 conditions which the equipment must operate under, and we are 23 in agreement with these positions in terms of the qualifying 24 program.
25 Exhibit IIIB-10, further on IEEE .279. Minimum GRUMLEY REPORTERS Phoenix, Arizona
0' 107 performance requirements to be documented. We are in agreement with that requirement.
Exhibit IIIB-11, having to do with IEEE Standard 308, which has to do with the Class IE power systems which are installed in the plant, the AC system, the DC system, and vital instrumentation and control power systems. The project provides such systems and those safety-related items in the systems are qualified for use in .the environments in which they must operate.
10 Exhibit IIB-12, having to do with IEEE 317-1976 covering electrical penetrations. The penetration assembly 12 is a device whereby'lectrical circuits are passed through 13 the containment and provide for the safe and continued 14 passage of electric circuits for Class IE circuitry and also 15 .serves as a pressure boundary for the container.
16 Exhibit IIIB-13. Design qualifications for the 17 penetrations have .to be verified by material testing and 18 other methods to show that they are compatible with their use.
19 For the project, our specification EM035A requires qualifica-20 tion of penetrations under all postulated operating conditions 21 Margins are to be applied as. indicated and as suggested by 22 the IEEE 323 document. The project is in agreement with the 23 use or margins in qualification programs.
24 Exhibit IIIB-14 continues indication of margins 25 'and the fact that conductors used in the penetrations must GRUMLEY REPORTERS Phoenix, Arizona
108 meet the requirements of,XEEE 383 having to do in part with flame tests. The project is in agreement with that requireme t.
Exhibit XIXB-15, having, to do with the basic qualification document, IEEE 323-1974, the capability of Class -XE equipment in regard to requirements that we have previously mentioned. The equipment must be qualified to operate under,all conditions and allowances made for the known potential failure modes. , We agree with that position.
Exhibit IIIB-16, having to do with one method of 10 qualification under 323,:-ongoing qualification tests and documentation for such testing, The project position is that 12 an ongoing qualification program as such is not encouraged.
13 We discourage such programs. We would like to have specific 14 qualified life established.
15 Exhibit IIIB-17, continuing on IEEE 323. There are several methods, as we have indicated, for qualification and, 17 as Mr. Bingham indicated earlier in the discussion of Table 18 1, the methods of testing, documented analysis, documented 19 operating experience, combination of methods are agreed with.
t 20 As indicated, Class IE equipment is identified.
21 Exhibit XIIB-18, methods of qualification, we have 22 discussed previously. Operating experience is one method.
23 In Exhibit IIIB-18, the document indicates that type testing 24 is preferred for Class IE items in containment and other hars 25 environments. Later in our presentation, we will further GRUMLEY REPORTERS Phoenix, Arizona
109 describe what the harsh environments are in this plant.
Exhibit IIIB-19. Operating experience when success fully documented can be used as a method of qualification.
The project discourages the use of operating experience alone 5 as a method, of qualification.
Exhibit IIXB-20. Analysis is another method 7 which can be used. The 'project discourages use of analysis alone, but it is definitely of'use in conjunction with type 9 testing or documented operating experience.
10 Exhibit IIIB-2l. Ongoing qualification methods, as ll indicated, are not encouraged as such, but if they are used, 12 we will only entert'ain programs which make use of equipment 13 which has some demonstrated qualified life, which is then 14 extended on a periodic basis through one of the methods 15 indicated, either removing portions of such equipment from 16 the main equipment periodically and retesting it under the 17 proper conditions or by installing completely redundant 18 equipment and removing it periodically for testing.
19 Exhibit IIIB-22, other methods, the combination of 20 any of the pr'evious methods indicated. The 'project will allo 21 combination methods.
22 Exhibit IIIB-23, documentation having to do with 23 any qualification method must be complete, must be supplied, and be in auditable form. The project agrees with that 25 position, but there is some problem with certain vendors who GRUMLEY REPORTERS Phoenix, Arizona
110 refuse to provide on a regular basis what they consider to 1
.2 be proprietary information, and we require that such informa-tion be maintained at the supplier's or another facility in auditable form for the life of the plant.
Exhibit IIIB-24 has to do with requirements of 6 IEEE 323 having to do with aging, sets forward the principle of aging to put the equipment, in the end-of-life condition prior to exposing it to the design basis event. Aging has to do with'mechanisms of temperature, radiation, humidity, 10 seismic vibration, whatever would affect the equipment and might cause it or some of its components to. fail. The 12 project position is'hat aging must be considered no matter 13 what method of qualification is chosen and'greed upon.
14 Exhibit IIIB-25, talking about aging, is an 15 illustration having to do with organic materials, specificall 16 electric insulation materials, and the regression line method 17 or the Arrhenius methodology. If the so-called Arrhenius 18 methodology is used, the project position is that the 19 Arrhenius methodology is considered acceptable as a method F
20 of addressing accelerated aging and that supporting data must 21 be provided to demonstrate that the Arrhenius plots are in 22 fact applicable to the materials being investigated.
23 Exhibit IIIB-26. 323-1974 sets down a specific 24 sequence in which the equipment is to be tested if the 25 qualification is achieved by type testing or the sequence that GRUMLEY REPORTERS Phoenix, Arizona
I' should be considered if you are using analysis supported by type testing or considering some other qualification method.
The project position is that type testing should be done in the sequence as indicated and should be done on equipment tha is either identical or very, very similar to the equipment being supplied for use in the plant. The first step in the sequence is to inspect the item for form, fit and function prior to doing the testing.
9 Exhibit IIIB-27, continuing the sequence, operate 10 the equipment under normal conditions ~ establish baseline. data, operate it under all of the extremes to find whether it wi'.ll 12 do its job under extreme conditions in the plant. The projec 13 is in agreement with the sequence of testing.
14 Exhibit IIIB-28. Equipment is to be aged prior to 15 exposing it to the design basis event. Ve concur with the .
16 aging of the equipment.
17 Exhibit IIIB-29. The aged equipment is to be 18 exposed to mechanical vibration and seismic events that would 19 accrue in its lifetime in its position, and then is to be 20 operated while being exposed to radiation as part of the 21 aging. The project position is that aging and vibration are 22 to be incorporated in the qualification program and that 23 existing results that exist for such equipment can be used 24 to qualify equipment for the APS project.
25 Exhibit IIIB-30. The operated equipment is to be GRUMLEY REPORTERS Phoenix, Arizona
e 112 exposed and operated during design basis event, after which it is to be disassembled to inspect for any possible damage to make sure that it is in fact capable of, doing its job.
The project is in agreement with these requirements, 5 Exhibit IIIB-31. Margins are to be incorporated.
Margins take care of possible difficulties in establishing exactly the parameters of the environment and "ake care of manufacturing tolerances and. other things. We want to 9 make sure that everything is going to operate over the range 10 of the parameters in the plant. Margins are to be included in all programs.
12 Exhibit IIIB-32 gives some indication of the margins 13 that are suggested for test programs. The project concurs 14 with those margins.
15 Exhibit IIIB-33 gives additional margins and, as 16 indicated and in accordance with one of Dr. Rosztoczy's
)7 questions, environmental transients are to be accounted for 18 during the qualification program. The project position is 19 that we will use plant specific profiles and environmental 20 conditions, and our profiles contain a single peak for
- 2) transients, not a double peak.
22 Exhibit IIIB-34, margin for vibration and the fact 23 that negative margins, if they are more severe, should be 24 included in the program. The project agrees with this 25 position.
GRUMLEY REPORTERS Phoenix, Arizona
0, Exhibit IIIB-35 has to do with another daughter document for a specific item of electrical equipment, electric motors, specifically continuous duty motors used in the plant.- The 1971 version of this document is included 5 in the Standard Review Plan. The 1971 version was specific in that it related t
only to continuous duty motors inside the 4
containment. In that regard, the project notes that there 8 are no continuous duty BOP type, motors which are provided.
We are also in, agreement that the methods of 334 can be used 10 to qualify other continuous duty motors in the plant.
Exhibit IIIB-36 has to do with IEEE 379-1972, the 12 application of the 'single-failure criterion to the plant.
13 Single failure types are defined and our project position is that other approaches are applicable, the things that we have 15 just talked about, making sure that common mode failures due 16 to environmental parameters are not going to affect the 17 equipment, the equipment will fail in a safe direction, and 18 that we are qualifying the equipment to all known environment
,19 parameters to preclude common mode failures.
20 Exhibit IIIB-37, continuing the definition of 21 failures and the definition of a common mode failure.
22 Exhibit IIIB-38, having to do with IEEE 382-1972, 23 the daughter standard having to do with valve operators, 24 safety-related valve operators, and indicating that a test 25 should be used to demonstrate compliance with the qualificatio GRUMLEY REPORTERS Phoenix, Arizona
114 The project is in agreement with this system and we note that there is a recent version of IEEE 382 which will be evaluated and recommendat'ions made to the project.
Exhibit IIIB-39, additional requirements having to do with qualification of valve operators corresponding to the requirements in IEEE 323. The project is in agreement with 1
these requirements.
Exhibit IIIB-40, having to do with IEEE 383, the daughter document specifying qualification methods for, 10 electric wire and cable to be used in safety-related systems, including field splices and connections, and requirements for 12 such qualification programs. The project position is that we 13 agree with these requirements and, in addition, fact.or+
repairs or manufacturing type splices must also be qualified 15 in addition to the long runs of cable. Flame tests are to 16 be accomplished in accordance 'with Section 2.5, the gas burne 17 method, rather than using the alternative method. The burners 18 must have at least 70,000 Btu input.
19 Exhibit IIIB-41 indicates the requirements for 20 testing field splices and for documentation in accordance 21 with 323, and the project is in agreement with the requirement 22 All of these things have to do with methods of providing 23 qualification in accordance with the general requirements os 323.
25 Exhibit IIIB-42, another daughter document, this GRUMLEY REPORTERS Phoenix, Arizona
i e'"
time having to, do with diesel generator equipment, the diesel generator equipment as applied to the supply of power for 3 'safety-rel'ated equipment. The items included are on Figure 387-1,and include. the total. scope of supply of the engine, the generator, the auxiliary systems having to do with the engine 6 and generator and control system, and only exclude the 7 interfaces having to do with oil and water, electric power necessary to flash the generator, or supply interfaces. The 9 project concurs with the scope of supply. The equipment is 10 rated either on a continuous ox short-time basis.
Exhibit IIIB-43 calls for type qualification of the 12 equipment, and this's one type of equipment which has been 13 indicated as being impractical to provide complete type 14 testing for qualification. Therefore, qualification is done 15 by analysis. and analysis. based on type testing, some reference made to operating experience well documented, and 17 the combination method of qualification. Tests will be performed in the manufacturer's facility on the assembled 19 engine generator to make sure that it operates properly.
20 There is a specific number of tests, start tests, load tests, y
21 load rejection tests, voltage tests, having to do with this 22 equipment, which are all provided prior to its delivery to the 23 site.
24 Exhibit IIIB-44 indicates again type testing and qualification tests to be accomplished on the diesel generator k
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116 equipment and, following the successful completion, the equipment is to be inspected and documentation provided.
The project is in agreement with all of these requirements.
There is a recent document, a version of 387, Draft 4, of July 1, 1980, that has been proposed, which brings together in one section of that document more specific requirements for qualification based on 323: This document will be reviewed and recommendations made to the project.
Exhibit IIIB-45 covers IEEE 535-1979 having to do 10 with qualification requirements for lead acid batteries of th type used in the plant. The project is in concurrence that 12 the principles of 323 are to be concurred with.
13 Exhibit IIIB-36, again, talking about the principles of qualification and indicating that the batteries and the 15 battery racks are to be qualified for use in the plant.
16 Type testing is to be used in regard to the batteries primaril because analysis is extremely difficult. It is essentially 1
17 18 impossible to set up a realistic mathematical model of such a 19 piece of equipment. The project is in agreement with these 20 requirements.
21 Exhibit IIIB-47. Operating experience can be used 22 or previous qualification can be used in conformance with 23 this document. The project is in agreement with this position 24 Exhibit IIIB-48. As indicated, analysis would 25 really not be justified for examination of such equipment.
GRUMLEY REPORTERS Phoenix, Arizona
Exhibit IIIB-49 indicates the accelerated aging 2 as set forth for the lead calcium type batteries being used 3 in this plant, arid the vendor is currently embarked on an 4 accelerated aging program in which ten days of operation at a 5 temperature of 160 degress F is equivalent to one year of 6 operation at the normal temperatures. The project is in agreement with this testing program with the provision that a specific differential voltage be maintained in regard to 9 the positive plate to electrolyte potential between the 10 normal operating condition and the accelerated aging tempera-11 ture condition to prevent mossing of the plates. The 12 accelerated aging test is much more severe than actual opera-13 tion at the normal temperatures and the test has to take this 14 into account to provide an acceptable method.
15 Exhibit IIIB-50. Documentation must be provided 16 and the user is to maintain the documentation file. The 17 proj ect is in agreement with these requirements.
18 Exhibit IIIB-51. The recent document IEEE 627 havin 19 to do with general qualification requiiements for safety-20 related or safety systems equipment contains information and 21 criteria and requirements very, very similar to IEEE 323.
I C,
22 The project is in agreement with the requirements of this 23, document .
24 Exhibit IIIB-52. It shall be demonstrated that the 25 equipment is to operate under all conditions. The project is GRUMLEY REPORTERS Phoenix, Arizona
in agreement.
Exhibit IIIB-53, approaches to qualification.,
Very similar to the requirements in IEEE 323. The project is in agreement.
Exhibit IIIB-54. The pressure containment and passive structures are to be handled in regard to various ASME, AISC, or ACI codes to provide for their design. The project is in agreement. Documentation is to be maintained.
The project is in agreement with this requirement.
10 Exhibit IIIB-55.having to do with IEEE 650-1979 describes methods for compliance with IEEE 323 aimed at 12 static battery chargers and inverters and contains methods E
13 for qualification. The project is in agreement with use of 1a such methods and also feels that the 650 document is a 15 reasonable method for providing qualification of other types 16 of equipment or portions of equipment which contain solid 17 state electronic components and other electronic components.
18 Exhibit IIIB-56. The effect of aging is indicated 19 as being insignificant in the 40-year life of a plant for 20 certain types of electronic equipment. The project is in 21 agreement with this position, but requires that stress 22 calculations be provided showing that all such equipment is 23 used well within the manufacturer's ratings and that types 24 of equipment used are either Mil. Spec components or the 25 commercial equivalent of Mil. Spec components using the same GRUMLEY REPORTERS Phoenix, Arizona
materials and processes in manufacture.
MR. BINGHAM: Are there any questions?
MR. ALLEN: Shelly.
MR. FREID: Yes, a few. If we go back to IIIB-19, 24, and 51 through 54, basically the question relates to aging.
On 19, you indicate that use of experience alone is discourage on 24 you indicate aging must be considered regardless of the qualification method used, and in the discussion on 627, you ignore the test for significance that is in 627 on aging.
10 I guess my question is are you going to do aging on everything .
or are you going to use the test for aging that is in 627, 12 which for a great number of mechanical components will make 13 aging a nonessential component of the equipment qualification 14 program.
15 MR. CARSON: Aging always must be addressed. It might be that when you address the aging, you find out that it is 17 insignificant,'hat the material, the piece of equipment, the 18 component does not age under the environmental parameters i
that 19 exist at its 'location, and, therefore, even though you have 20 addressed *the aging, you found out that it'oesn't matter.
4 21 But aging always must be addressed.
22 With regard to operating experience, we have 23 indicated that operating experience by itself is not considere 24 a reasonable method for qualification primarily on the basis 25 that documentation of operating experience is essentially GRUMLEY REPORTERS Phoenix, Arizona H
'0 nonexistent. Very Yew people have reasonable records and accurate records which will show that the equipment has
'perated under certain conditions for certain periods of its life which can be applied to the parameters under which we ar supposed to qualify this equipment. If someone.has minute-by-minute records over a 10, 20, 30, 40-year period which would equal or be more severe than the requirements that we have for a piece of equipment, that documentation when verified could certainly be used as a basis for a qualificatio 10 program, but we have not seen anything like that.
MR. ALLEN: Carter.
12 MR. ROGERS.: On Exhibit IIIB-12, when you were reading 13 the definition, you indicated that the electrical penetrations 14 were those that passed IE cables only, and I am not sure that 15 you intended to do that.
16 MR. CARSON: No, that is not correct. The penetrations 17 pass all electric circuits through the containment wall.
18 Some contain Class IE circuitry, some do not contain Class IE 19 circuitry, but in any case, each of the penetrations, no matte 20 what kind of circuitry it contains, must maintain pressure 21 integrity in the containment vessel.
22 MR. ROGERS: So all electrical containment penetrations 23 are subject to these criteria?
24 MR. CARSON: Oh, absolutely. All penetrations must 25 be qualified.
GRUMLEY REPORTERS Phoenix, Arizona
0 MR. ROGERS: Then on Exhibit IIIB-49, there is a figur there that shows accelerated aging and you indicate in that 3 figure a certain number of test days at 160 degrees Fahrenheit 4 is equivalent to one year at 25 degrees centigrade or 77 degrees, Fahrenheit.
MR. CARSON: Yes.
MR. ROGERS: In our program, do we correct the tempera-ture, the 25 degrees centigrade or 77 degress Fahrenheit, 9 to'the expected temperature that the component is going to 10 see in the plant.
MR. CARSON: We maintain the temperature in the 12 battery rooms in the range which we will show a little bit 13 later in the discussion having to do with environmental 14 parameters in the plant, and this is a method that has been 15 agreed upon as being a method for showing that this equipment 16 will operate for the time period indicated by the qualified 17 life. A margin is applied. Currently, for instance, the 18 vendor who is doing this qualification program for the 19 Palo Verde. batteries;.is. using 11 days at 160 degrees of 20 temperature to equal one year rather than 10 days to account 21 for such things as the temperature not being exactly at the 22 77-degree level or for errors or inaccuracies in measurements, 23 or whatever, having to do with the program.
24 MR. ROGERS: I understand you to say then that for 25 these particular batteries, it is expected that the temperatur GRUMLEY REPORTERS Phoenix, Arizona
N for aging would be at around. 77 degrees Fahrenheit.
MR. CARSON: Not for aging. Temperature in normal operation.
MR. ROGERS: For normal operation for 40 years?
MR. CARSON: It would be close in that range, yes, and we will indicate the parameter on a later slide.
MR. ROGERS: Thank you.
8 MR. ALLEN: I have one. Bob, isn't it true in our specifications on wire and cable on our flame test requirement 10 that we exceed 383 requirements?
MR. CARSON: For the bulk of the electric cables used 12 in the plant, a requirement of 210,000 Btu input, or three 13 times the minimum required by the specifications, is included.
14 For certain types of cable where it is not possible to obtain 15 such a requirement such as a coaxial cable, those are tested to the 70,000 Btu input.
17 MR. ALLEN:
~
Any further questions? George.
18 MR. SLITER: On Exhibit IIIB-13, you say that electric 19 penetration assemblies are now in progress of being tested.
20 Are these penetrations aged, and, in the aging program, are 21 they thermally'cycled "before type testing, and I mean 22 thermally cycled with respect to operational and abnormal 23 conditions.
24 MR. CARSON: Yes. The vendor for these particular 25 types is the Conax Corporation, which supplies penetrations GRUMLEY REPORTERS Phoenix, Arizona
123 for a number of nuclear power plant applications. They have a continuing qualification program in which they, have qualified portions at earlier times, have made modifications to their penetrations for additional requirements for specific plants, they requalify on these bases. They have performed all sorts of type testing having to do with temperature, temperature excursions, short circuit, all of the operational requirements of the penetration, and aging is considered for all the materials used in the penetration.
10 MR. SLITER: So can I take it from your response that this would be one of the types of equipment for which so much 12 has been done in the way of aging and testing that you perhaps 13 would not audit their actual tests for your equipment7 MR. CARSON: The equipment qualification programs to 15 be audited have not yet been determined.
MR. SLITER: My next question has to do with Exhibit 17 IIIB-21., In terms of using ongoing qualification programs, 18 could you elaborate on the expression "having an identified 19 qualified life," that is, this identical equipment would have 20 an identified qualified" life, and also what types of equipment 21 in the balance of plant have you already identified as having 22 a probable qualified life less than 40 years, some examples 23 of that, please.
24 1iR. CARSON: For an ongoing qualification program, 25 an identified qualified life would be, for instance, something II GRUMLEY REPORTERS Phoenix, Arizona
that had either been type tested or it had been naturally aged, had been used in a certain application equal or more severe as in the project to a known life. For instance, Foxboro Corporation has embarked on a program of using natural aged equipment of exactly the same type as will.be used for Palo Verde. They have had this equipment in operation in their factories under conditions which are equal or more severe than the project conditions for a period of four years.
They have used that equipment, tested it to the various other 10 requirements as applicable to this project, and on that basis have established the qualified life of four years and are 12 currently extending that life to 10 years by additional 13 testing. There are a number of items which have qualified 14 lives indicated by tests of less than 40 years and those 15 equipments will be identified and, as John Allen indicated, 16 provisions made in the maintenance procedures to replace them 17 as required.
18 MR. SLITER: From what you know today, could you give 19 me some more examples of equipment that fall in that category?
20 MR. CARSON: At the present-'time, batteries, for 21 instance, ax'e indicating a qualified life at the present 22 moment of eight years or so. The testing process is in 23 progress C right now. Various gasket or seal materi'als on 24 certain mechanical equipments have been indicated as having lives of four, five, ten years and would require periodic GRUMLEY REPORTERS Phoenix, Arizona
0 replacement.
2 MR. SLITER: Another question has to do with Exhibit IIIB-26. Could you explain, please, what you mean by the expression "type testing should be done in sequence on the same item except if impractical?" Under what circumstances would this be impractical?
MR. CARSON: The sequence indicated is to inspect, operate at normal conditions, age, operate under vibration, and such. If the piece of equipment, for instance, is so 10 very large that it is difficult to move it from this location where it has been operated under normal conditions to a testin 12 laboratory.,tobe operated under seismic conditions, we may 13 very. well call for it to be operated under normal conditions, 14 aged, apply the DBA to it, and then seismically test it and 15 analyze the situation to show that the aging would not be 16 affected by the DBA Qr seismic, so that there would be no 17 necessity to do it l strictly in the sequence indicated.
18 MR. SLITER: So you are indicating the sequence might 19 change, but it would be on the same item. Maybe the "except 20 as impractical" goes with a'iven sequence and'not with the 21 same item. My point is that the type testing should indeed 22 always be done on the same item so that you would have a 23, cumulative effect, is that not true?
24 MR. CARSON: That may not be the case for certain 25 pieces of equipment. For instance, some manufacturers of GRUMLEY REPORTERS Phoenix, Arizona
/
electrical equipment such as transformers or relays or circuit breakers with repetitive manufacture of equipment have done type testing on blocks of items and have done aging tests on this group of items and they have done mechanical wear tests on this group of items and they have. done various other tests on other groups of items of the same variety and materials, and in that case','they have not specifically done the whole series'f tests on exactly the same piece of equipment, but they have done tests on representative samples 10 of that equipment and have taken account of the total testing program.
12 MR. SLITER: In terms of sequence of environments, 13 in the aging process and in the DBA, there are existing 14 various sequences of imposing radiation aging and thermal aging and then thermal and radiation for your design basis 16 accidents. Are you aware of the latest thoughts on the 17 correct sequence of these environments such that it would 18 most closely represent the actual end point of the equipment7 19 MR. CARSON: The normal sequence that we have seen is 20 that equipment has been thermally aged and then has been 21 radi.ation aged either for a 40-year life period or for 40 year 22 plus DBA radiation all at one time prior to vibration, 23 mechanical aging, seismic, and then the application of the 24 actual design basis event.
25 MR. SLITER: I would like to point out for your GRUMLEY REPORTERS Phoenix, Arizona
~ i information, that a recent study at Sandia in their qualifica-tion testing. evaluation program has uncovered some new data on certain materials that point to the fact that the sequence of environments is important and that for certain materials you may want to alter your test plans based on their findings on which sequence to put radiation and then thermal aging.
MR. CARSON: That will certainly be investigated.
MR. BINGHAM: Could we ask that that document be made available, John?
10 MR. ALLEN: Certainly. Let's put that down as an open item. Me'll get that document. f 12 MR. SLITER: That is the document that we discussed 13 back at the last EPRI meeting. It is one of the many document 14 discussed. If you don't have it, I can make it available.
15 MR. ALLEN: Any more questions? I think, Ed, you had 16 one.
17 MR. STERLING: No, George asked my question, but I did 18 want to elaborate on just one point. On synergism, how are 19 we handling synergism in this sequence of events?
20 MR. CARSON: Synergistic effects as far as we know 21 received very little play in the testing programs principally 22 because it is so extremely difficult to apply temperature, 23 radiation, humidity, and all these other things at exactly the 24 same time except for certain items like electric cable.
25 MR. STERLING: I know there is some feeling that that GRUMLEY REPORTERS Phoenix, Arizona
is an important point. Are we going to have an analysis that would show that there is no effect of synergism or how are we going to deal with a resolution of the matter as'far as synergistic discounting.
MR. CARSON: Synergistic effects will be investigated.
MR. ALLEN: Is that all you had on that, Ed2 MR. STERLING: Yes.
MR. ALLEN: Norm.
MR. HOEFERT: I would like to know how the'eginning 10 of a qualified life is determined for the different equipment; If it is qualified for 40 years, when does the clock start fo 12 that piece of equipment? When it is manufactured, when it 13 is installed, or when it is put in service7 14 MR, CARSON: The clock would start when the equipment 15 is installed as long as the storage prior to installation has been in accordance with, the manufacturer's recommendations 17 and the storage temperatures and other environmental condition 18 are shown to not be detrimental to the equipment; that is, 19 not age the equipment unduly during that storage period.
20 MR., HOEFERT: Is that being donee Are there documents 21 from vendors which +ay that it is being stored under certain 22 conditions that don't affect its life7 23 MR. CARSON: Specifications for each item of equipment 24 require that the vendor specify storage condition for short 25 term up to six-month and for long-term more than six-month GRUMLEY REPORTERS Phoenix, Arizona
periods.'and they must specify to us any special storage conditions that must apply, humidity, temperature, whatever.
MR. HOEFERT: Would this"apply to spare parts as well?
I am thinking of things that may be in the warehouse for many years.
MR. CARSON: Yes, spare parts storage conditions are required to be specified.
MR. ALLEN: John Barrow.
MR. BARROW: If the qualification period is considered 10 to start at the time of installation and the equipment a year and one-half before the unit goes into is'nstalled 12 commercial operation, does that mean that the equipment is 13 only qualified for 38/ '.years of plant operation?
14 MR. BINGHAM: The answer to your question is it is 15 qualified for 38 years of commercial operation.
16 MR. BARROW: Then at the end of that 38 years, you 17 would have to consider requalifying it for several years?
18 MR. BINGHAM: Perhaps.
19 MR. BARROW: The reason I asked the question was it 20 is conceivable that the equipment could be installed prior to 21 commercial operation but energized only sporadically and at 22 very low energy levels or something so that it would not see 23 its normal operating parameters until such time as it went commercial.. For the most part, it would be shut down except 25 during testing intervals and, consequently, you could make the GRUMLEY REPORTERS Phoenix, Arizona
V qualification interval not start until commercial operation.
MR. ALLEN: I had one question. We indicated that IEEE 627 is just now being looked at. However, my memory serves me that in the pump and valve operability tests, some of those requirements are very similar and that.was already placed intor. the specifications. Isn't that corrects MR. CARSON: That's correct.
MR.. ALLEN: So, in a way, we have already imposed some of those requirements of 627 in our early specifications.
10 MR. CARSON: That:.'s correct, and, as indicated earlier t
in regard to the Standard Review Plan that the principles and 12 criteria of 323 were applicable, to all types of safety-related 13 equipment, all of the vendors for equipment for this project 14 have been contacted and asked to respond in regard to the 15 methods and criteria of 323, and, as indicated, that is the basis of a series of meetings that have been held and are 17 being held with the several vendors to obtain such information 18 MR. ALLEN: John.
19 MR. ROEDEL: Could I go back to the storage requirement 20 that we 'requested. from the vendors for electrical. equipment?
21 Do you feel that .these storage requirements have in fact 22 considered enviro'nmental requirements relative to aging in
'23 all cases or do we need to, go back and look at some of the 24 equipment that has been on site for some time to assure 25 ourselves that the storage requirements we have from that GRUMLEY REPORTERS Phoenix, Arizona
vendor in fact do address those items because we have had those on the site for some time when we hadn't even started the testing for qualification.
MR. BINGHAM: That's a good point, John. We have been aware of that for not only this type of equipment, but other equipment because of warranty problems that we see. -I think in general we are in relatively good shape. Of course, we do recognize that we need to take a look at some of the equipment to make sure that storage was adequate.
10 MR. ALLEN: Any questions? Karl.
MR. KREUTZIGER: With relationship to the storage or
)2 qualified life again of equipment that has been installed in 13 the plant for a period of years prior to operation, is not the 14 qualification program based on design conditions which far 15 exceed that 'of normal operation? For example, electrical 16 insulation material is based upon an aging process of 90 degre s 17 C conductor temperature for the duration of the plant's life.
18 Other insulation materials are the same. Is this not 19 considered as a'ethod in which to extend qualification beyond
\
20 the original qualified life and are there any plans to monitor 21 the environment in the Palo Verde Power Plant over the 35 or 22 life in order to see that there are design margins '0-year 23 or actual conditions are considerably less than the design 24 basis conditions as a method to extend V
some of this qualified 25 life for whatever the additional storage years might be.
GRUh1LEY REPORTERS Phoenix, Arizona
MR. CARSON: In regard to installation of equipment and temperatures, we are aware of some plants in which continuous monitor'ing equipment will be installed in various areas where safety-related. equipment is in place and the time duration of temperatures will be used either to extend or reduce qualified life. That method will be investigated with APS.
MR. ALLEN: Shelly, did you have your hand up?
MR. FREID: Karl essentially asked my question, but. I 10 would like to carry it a little further. In general, most equipment does not operate at a'design condition. There is 12 an operating condition which is generally much less than the 13 design condition. Inherently, you would expect that what you would consider a qualified life. in terms of that type of r
14 15 aging has got to be very conservative and have lots of margin in it. Xt seems to me that it would be intuitively obvious 17 in almost all cases that -- You know, the difference between 385 years and 40 years is insignificant.
19 MR. BINGHAM: We agree, Shelly, that that is the case.
20 However, we are trying to res'pond to particular questions.
21 You are quite right, there is conservatism in it, and I am, 22 sure that that is what will be used at the time you intend to
'extend the life of the equipment, but at the present time, 24 what we are trying to do is to start with a qualified life, 25 whatever it might be, and then to indicate the parameters on GRUhllLEY REPORTERS Phoenix, Arizona
~ '
133 which it is based, and then I am sure there will be subsequent programs that will be developed by APS to monitor in order to 3 assess how they might extend the qualified life at a later 4 date.
MR. KREUTZIGER: I would like to also add that I think 6 that I heard you say the reason the ongoing qualification was 7 discouraged was because of lack of do'cumentation. I thought, 8 also, I heard -- this was something which kind of surprised me -- that there was no minute-by-minute recording of 10 conditions. I would think that for the long term, if that is the project's position, that it would be almost 12 imperative to provide in some areas teiriperature nanitoring'where 13 there might be a question about ext~g qualified life. A program that determines what are yoM basic neasureaents auld be useful i'. that is the J
14 15 criterion that prevents you from using operating experience.
16 MR. BINGHAM: John, we are going to be considering that 17 point in our reviews with APS and I would expect that you want 18 to have that as an issue to respond to to the board.
19 MR. ALLEN: That's correct. it I think also was an op 20 issue that was,'ddr'essed, at the .PVNGS Units 4 and 5 hearings,-
21 too, regarding monitoring.
22 MR BINGHAM: That' right.
MR. ALLEN: So if we could ask Terry to 'record that.
24 MR. QUAN: Could we have that rephrased by Karl so we 25 could get it downV QRUMLEY REPORTERS Phoenix, Arizona
1I T
134 MR. KREUTZIGER: My concern was the utilization of the method of ongoing qualification and the fact that the project has discouraged as a general criterion its use. The basis was the lack of documented evidence of what the prior environmental conditions were, and the question .was I would take those two statements and conclude that in order to look at this plant operating many years in the future it would be advisable'. to seriously consider an environmental monitoring system so that 10 or 15 or 20 years down the road you are not 10 faced with the dilemma of looking at something and saying, "I do not know what the environment has been over this. period 12 of time. "
13 MR. QUAN: Okay, fine.
14 MR. ALLEN: Pete, I think you had a question.
15 MR. NEWCOMB: You have discussed impacts in some detail as regards thermal and radiation aging. Could you discuss 17 your position regarding the effects long term of either high 18 or low humidity, or both, on the equipment under discussion.
19 MR. ALLEN: Off the record for a second. Why don't we 20 take a .break.
21 MR. BINGHAM: Could I get that question repeated again, 22 I want to make sure we respond to it correctly, before you go 23 off the record?
24 MR. ALLEN: Do you want',to repeat the question, please?
25 MR. NEWCOMB: The question is how do you, if at all, GRUMLEY REPORTERS Phoenix, Arizona
respond to the conditions of long term high or low humidity, or both, on the equipment that you are talking about here, th 3 long term aging effects due to humidity.
ALLEN: Mhy don't we take about a lS-minute break.
(Thereupori a brief recess was taken, after which 6 proceedings were resumed as follows: )
MR. ALLEN: Are there any more questions on the k
last subject matter before we proceeds MR. STERLING: Ne haven't got the answer.
10 MR. BINGHAM: Humidity I believe was the question.
MR. ALLEN: That's right, back to humidity.
12 MR. CARSON: In regard to humidity, humidity certainly 13 is considered in the design of all these equipments.
14 Environmental parameters provided in the specification for 15 each item of equipment indicate the range of humidity under 16 which it is to operate and the vendors take this into account 17 in their design, and we make sure that items of equipment or 18 specifically materials that would be hydroscopic are not 19 included and that equipment that might be susceptible to 20 failure due to humidity or tracking due to moisture on surface 21 terminal block spacing, electrical equipment spacing, or 22 terminal spacing within the equipment, is such that humidity 23 would not be a problem.
24 MR. NEWCOMB: One more follow-up. How does that 25 address the question more specifically of humidity'aging as in GRUMLEY REPORTERS Phoenix, Arizona
~ i 136 1 thermal aging?
MR. CARSON: We know of no method to do humidity aging other than such things as spray tests or maintaining a pool of water in the bottom of a test chamber when something 5 is being tested for temperature effects where the .humidity would be very high in that area.
MR. BINGHAM: John, are there any other questions?
MR. SLITER: On Exhibit IIIB-25, the Palo Verde positio is that Arrhenius methodology is considered an acceptable 10 method of addressing accelerated aging, but other methods are possible. What are some of these other methods and is the 12 10-degree-C rule, for example, one of these methods and would 13 consider that acceptable? II 14 MR. CARSON: The project endorses the Arrhenius 15 methodology in conjunction with the NRC's endorsement of the 16 same methodology as indicated in NUREG 0588. The 10-degree 17 rule, as such was and is a primary electrical industry use of 18 an Arrhenius type methodology, and the project position is 19 that the indiscriminate use of that 10-degree-C rule of thumb 20 is not accepted without justification that in fact the 2] equipment does exhibit a 10-degree rule as indicated by an 22 Arrhenius plot.
23 MR. SLITER: Then other methods?
24 MR. CARSON: Other methods which might be acceptable would be the TGA method or others that have been discussed, GRUMLEY REPORTERS Phoenix, Arizona
I 4
~
137 but we have not as yet seen any vendor who has suggested I
other methods than Arrhenius.
MR. SLITER: Thank you, MR. ALLEN: Bob, as a follow-up on that, how about 5 Mil. Handbook 217? What is .the project's position on the use 6 'of it and its data?
MR. CARSON: Mil. Handbook 217 has to do primarily 8 with electronic type components and has been put together through extensive data gathering by military systems oriented 10 companies, NASA, the Air Force, Bell Laboratories, various 11 other people, and has to do'with factors of stress and 12 derating factors for various types of electronic components.
13 As indicated in the discussion of IEEE 650, the project's 14 position is that data from Mil. Handbook 217 would be 15 applicable to discussions of electronic equipment as long as 16 the equipment items used are in fact identical'o those for 17 which the data in the handbook has been prepared or, as 18 indicated in the 650 document, are the commercial equivalent 19 of such Mil. standard components using the same materials and 20 the same manufacturing processes.
21 MR. ALLEN: Are there further questions by the board?
22 DR. ROSZTOCZY: Could we have Exhibit IIIB-13? We 23 have criticized various things'ere today and I think we 24 ought to give credit when it is appropriate. If you look at 25 this slide, the right-hand side, the position side, of this GRUMLEY REPORTERS Phoenix, Arizona
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i
138 slide is one of the better ones in the whole package. It gives certain information to the reader. If I take Item 2) as an example, then there are two pieces of information that I
one learns from this, One of them is how it is going to be enforced by saying you are going to enforce it through your specifications. Every possible requirement we will have in the specifications. The second piece of information given there is where you stand right now as the testing is in progress. In the cases where you are going to revise the f
10 entries in this column, you can probably use this as an example, and if you would provide the equivalent of these two 12 pieces of information, namely, how do you enforce it and where 13 do you stand with it, I think it will be very useful.
14 MR. CARSON: That information can be provided.
If 15 MR. ALLEN: Could I just ask could that be an item 16 to provide that information7 17 MR. QUAN: It would be part of the previous item..We 18 had an item to correct the slides which state "in compliance" 19 to wording which is appropriate.
20 MR. ALLEN: We will just add to use IIIB-13 as a guide.
21 MR. QUAN: As a guide, right.
22 MR. ALLEN: Do you have another question7 23 DR. ROSZTOCZY: 'es. Exhibit IIIB-23. In the right-24 hand side column, there is a statement which says, "Proprietar 25 data may require audit in supplier's facility." I am aware of GAUMLEY REPORTERS Phoenix, Arizona
'I 139 1 this type of problems in the past and I was under the impxession that most of those have been resolved. There is maybe one possibly outstanding at the present time, but that 4 would not affect you because of youx water reactors. What 5 is the purpose for the sentence here? Do you have any 6 problems of this sort at the present time? Do you have any supplier who is not willing to give you the proprietary reports or test reports or whatever it is?
MR. CARSON: We are going to be covering that 10 particular item in our discussion of problems later in the 11 presentation, but, yes, we have had and are having problems 12 with vendors who refuse to supply data but will allow us to 13 audit. One case in point is the General Electric Company, 14 of San Jose, in qualification of motors. They have refused to 15 provide us with the specific data on which their qualifica-16 tion is based. We know what the data is. It has been 17 identified for us specifically and we have audited that data 18 at their facility to determine that the data was in fact applicable to the qualification and did correctly reflect the I
20 positions taken in their qualification documents, but we are 21 not able to get that data. GE is not the only vendor for 22 whi'ch that situation exists.
23 DR. ROSZTOCZY: You do have other vendors, also?
MR. CARSON: Yes.
25 DR. ROSZTOCZY: GE is the one that I was formerly GRUMLEY REPORTERS Phoenix, Arizona
1 aware of. I didn't know that you had components from them, so that 's why I said--
MR. CARSON: Westinghouse is another one, DR. ROSZTOCZY: I suppose that has been resolved and
~I now they are complying.
MR. CARSON: We have had no such indication. Ne are constantly asking them to provide this information. We have had meetings with the vendors and they have flatly refused in 9 many cases to provide the data, and we have in fact asked 10 them to specifically identify the data so that it can be audited by the NRC or'by others who have a need to know.
12 MR. ALLEN: Do you have a further question?
13 DR. ROSZTOCZY: Yes. Exhibit IIIB-36. The requirement 14 talks about the single-failure criterion. The single-failure 15 criterion in itself is very complex. It is very complex because it requires that you consider that, depending on what 17 is the purpose of your evaluation, the first single failure i's 18 different. For, example, if you are looking at the consequence 19 of a- condenser cooler accident and if you are concerned about 20 the containment overpressurization, then you find the certain single failure that gave you the worst or the highest contain-22 ment pressure. If you are dealing with the very same accident 23 but you ask the question whether the core is protected, then 24 you find that another failure is limiting in that sense that gives the worst condition in terms of water level in the core GRUMLEY REPORTERS Phoenix, Arizona
J" or whatever you are interested in. When we get to equipment qualification, it becomes a lot more complex. There are many different equipments and those equipments are being used for 4 different cases. Could you describe for me at least briefly 5 how do you use the single failure criterion for. equipment 6 qualification? Could you explain it through an example?
For example, how did you select the single failure for limiting the chemical environment and what single failure'ou 9 ended up with, which other ones did you consider?
10 MR. BINGHAM: John,,we seem to have not quite a unanimous approach on the answer that we want to give, so 12 what I would request is that at the next break, we will 13 caucus and come back with a correct example responding to the 14 particular question you had.
15 MR. ALLEN: Do you have that down, Terry?
16 MR. QUAN: Dr. Rosztoczy; could you repeat that 17 ques tio'n?
18 DR. ROSZTOCZY: Let me just phrase the question in 19 brief terms and ask an explanation for it. I would like to 20 know how do you apply the single-failure criterion for 21 equipment qualification in general terms and then I would 22 like you to take an example and illustrate through this 23 example the application of the single-failure criterion. I 24 am suggesting as an example the selection of the single 25 failure for predicting the chemical environment. What GRUMLEY REPORTERS Phoenix, Arizona
l42 1 failures did you consider to predict what kind of chemicals 2 'could come into the plant through the spray system or by 3 other means?
MR. ALLEN: Do you have additional questions?
DR. ROSZTOCZY: Yes. Exhibit IIIB-43. ht the time 6 when this slide was presented, it. was mentioned that this is 7 a case which will be done by the combination method. Earlier today when I asked the question if there is any case where 9 you have already decided to use anything but the preferred 10 mode, which was type testing, the answer was you haven' arrived at such a decision yet. ~,If t.his is being done by 12 combination, then those two answers don't completely jibe, so 13 somewhere along the line, I would like to have an explanation.
14 MR. BINGHAM: Okay, we will provide, that.
15 MR. ALLEN: I believe that is coming up in your
.presentation.
17 MR. BINGHAM: Yes.
18 DR. ROSZTOCZY: That was my last question.
19 MR. ALLEN:, Vince, I think you raised your hand a whil 20 ago. You had a question?
21 MR. NOONAN: He already covered it.
22 MR. ALLEN: Are there further questions?
I have one question regarding qualifi.cation program 23 I think I know the answer before I ask the question, but I'l 25 ask it anyway. It is not project policy to accept GRUMLEY REPORTERS Phoenix, Arizona
~ i certification of qualification data, is that correct? In other words, a vendor cannot send us a certification that says, "I certify that this is qualified 'to your spec."
MR. CARSON: A certificate of certification by itself is not acceptable. We require that the actual documentation be provided.
MR. ALLEN: If no further questions, you can continue, Bill.
MR. BINGHAM We will now present Section B.4.,
10 equipment environmental qualifications, regulatory guides.
MR. CARSON: Another set of criteria having to do 12 with qualification, as indicated in the Standard Review Plan, 13 has to do with several NRC Regulatory Guides which provide 14 interpretation of various IEEE standards. Exhibit IIIB-57 15 has to do with Reg. Guide 1.32 in relation to IEEE 308 having 16 to do with Class IE electric systems for the plant. The 4
17 project concurs with the requirements of Reg. Guide 1.32 and 18 the equipment is qualified for the operational requirements 19 indicated.
20 Exhibit IIIB-58. Reg. Guide 1.40 has to do with 21 IEEE 334-1971, specifically for continuous duty motors .inside 22 the containment. This Reg. Guide is not applicable for 23 BOP equipment, since no safety-related BOP machines are 24 provided inside the containment.
25 Exhibit IIIB-59, Reg. Guide 1. 53, application of GRUMLEY REPORTERS Phoenix, Arizona
144 single-failure criterion. Qualification requirements of IEEE 379-1972 to be met. The project is in agreement with that requirement.
Exhibit IIIB-60, Reg. Guide 1.63 having to do with IEEE 317 covering electrical penetrations. The Reg. Guide gives some guidance in terms of certain tests and values which are to be used in the'ualification program. The project is in agreement with these requirements.
Exhibit IIIB-61, additional requiremen'ts 'for 10 electric penetrations. The project is in agreement. There
.is an open item having to do with electric penetrations which 12 came up at the AC system review which is being studied and 13 response will be made at a later date.
14 Exhibit IIIB-62, Reg. Guide 1.73 having to do with 15 IEEE 382 covering electric valve operators'sed for valve 16 and various other equipment indicating that the auxiliary 17 equipment having to do with the valve is also to be qualified.
18 The project is in agreement with this requirement and equipmen 19 suppliers are being required'o qualify the entire equipment 20 for its use. Test sequence is to be used., The position 21 stated the project agrees with.
22 Exhibit IXIB-63 continues the discussion of Reg.
23 Guide 1.73 having to do with testing of valve operators and 24 the radiological source term which is to be used in accordance 25 with Reg. Guide 1.7. The project is in agreement with these GRUMLEY REPORTERS Phoenix, Arizona
N 14S positions and the effect of Beta radiations is under review for organic materials.
Exhibit IIIB-64, Reg. Guide 1.89, clarification of Reg. Guide 323-1974 having to do with radiological source terms and applicability of IEEE Standard 344 for seismic testing. The equipment is being qualified in accordance with the requirements of 1.89 with the exception that equip-ment that had been seismically qualified prior to aging on some of the older programs is being reevaluated to see that 10 aging will not cause a problem or will not have'roblems caused by sub'sequent application of seismic events. This may 12 require some retesting.
13 Exhibit IIIB-65, again on Reg. Guide 1.89. The use 14 of thermal and vibrational techniques are difficult to apply 15 and: are not valid or practical for many type tests. The project agrees with the requirements of 1.89.
17 Exhibit IIIB-66, Reg. Guide 1.131 having to do with 18 IEEE Standard 383 for electric wire and cables. All design 19 basis events are to be considered, environmental service conditions 20 are to.envelope plant specific conditions, and ongoing.gualific 21 tion programs are to be used as a possibili.ty for gualificati n.
22 The project is in agreement with the requirements and, as 23 indicated before, use of an ongoing program is discouraged ~
24 All electric cable used in the project has been qualified 25 by type testing.
GRUMLEY REPORTERS Phoenix, Arizona
~,
MR. BINGHAM: Are there any questions on the Reg.
Guidesf MR. ALLEN: Ed Sterling.
MR. STERLING: On Exhibit IIIB-64, and maybe Vince can help me out on this, at the regional meeting in. Dallas on qualification, a question was raised by a gentleman from SMUD that the source term calculations -that were addressed in 0588 were in conflict with the source term calculations called for on the TMI lessons learned, and I guess my question 10 is what source terms are we using for Palo Verde, and I don' have the answer to that question that the SMUD gentleman 12 asked.
13 Vince, you said you had those lists of questions.
14 If it has been determined, maybe you can shed some light on 15 what source terms were the ones that were applicable or the 16 most severe.
17 MR. NOONAN: I have a list of the questions, but I 18 think Dr. Rosztoczy can answer it, very, clearly.
19 DR; ROSZTOCZY: Basically, the question was raised.
20 what are the .requirements for the use of source terms to 21 predict how much. Xadiation a certain equipment is exposed to.
22 The basic ground rule is very simple. Mhen you start to 23 apply it, it becomes a little bit more complex. The ground 24 rule is that following an accident, there are two possibilitie 25 One possibility is that you blow almost everything from the GRUMLEY REPORTERS Phoenix, Arizona
0 0
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147 1 primary system out into the containment, and in that case, 2 the activity is mainly in the containment. Another possibilit is that you have some core damage, but you terminate the 4 blow damage to the containment, so most of the activity stays 5 in the water in the coolant system and is being recirculated 6 in the system. The basic ground rule is you have to be 7 covered for both of these events, so when you look at a given piece of equipment, then you have to ask the question how much radiation would this equipment have if the activity was t
10 blowninto the containment and you have to ask the question ll how much radiation would this equipment have if the activity 12 sta'yed within the coolant loops, including the RHR system.
13 Whichever gives the higher result, you have to qualify to 14 that value. Normally, the equipment within the containment 15 gets the higher dose if the activity was blown into the 16 containment. There could be some exceptions. If some equip-17 ment is installed on the coolant loops or is very close to it, 18 it might get the higher dose when. the activity stays in. When 19 you are talking about the equipment that is outside contain-20 ment, then normally the'econd one is more limiting; namely, 21 the proximit'y of the coolant loop is what determines the 22 radiation rather than what is in the containment. You have 23 to be covered for both cases. The question then is have.you 24 done this and, if you haven', then w'e certainly would like 25 to bring it to your attention to do it.
GRUMLEY REPORTERS Phoenix, Arizona
There was some reference here or questions asked at the regional meeting and responses to them. At the time of the regional meetings, we promised that these would be provided to all parties involved, including the utilities, in written form. We have written up some of the most important questions, we have provided written answers for them, and those are presently being mailed out. I believe they started to mail them out today; Somewhere in the very near future, you are going to receive them in written form.
10 This was one of the questions and, basically, the same answer what I gave you is in written form in that package.
12 MR. ALLEN: Additional questions?
13 MR. NOONAN: Yes.
14 MR. STERLING: We didn't'get an answer.
15 MR. ALLEN: Bill, anything else to add to it?
MR. BINGHAM: As I understand, the question was have 17 we considered it. We are considering it. We have had 18 discussions with Dr. Rosztoczy on this very point and we are 19 looking at it to make sure that we have used the correct dose 20 for the limits.
21 MR. ALLEN: Anything else?
22 MR. NOONAN: On the same exhibit, IIIB-64, Part A here, 23 I wonder if you could walk me through that. I am not quite 24 sure what you are telling me here regarding the aging and the 25 seismic qualification question. Could you just briefly describe your answer on Part A, just what you are talking GRUMLEY REPORTERS Phoenix, Arizona
149 about .
MR. CARSON: We are addressing equipment that may have 3
I been seismically qualified prior to an aging mechanism being applied and indicating that for such equipment, aging is to be considered to determine by analysis, if possible, that the aging would not have resulted in a failure of such equipment in the event that the aging had been accomplished prior to seismic events. If no successful analysis can be made in that regard, that is, if aging cannot be shown to be non-10 existent or insignificant and, therefore, not affected by seismic activity, as indicated, 'some additional supplemental 12 tests may be required.
13 MR. NOONAN: I guess as a personal opinion if you coul show that aging has no'-; effect on equipment, then you are 15 probably in pretty good shape. If you cannot show that, then I don't see how you can possibly dp anything by analysis.
17 MR. CARSON: That is what'e are indicating, If it 18 cannot be shown that aging is nonexistent for the material, 19 we would require additional testing to confirm the qualifica-20 Cion of the equipment.
21 MR. NOONAN: Okay, I understand. Thank you.
22 MR. ALLEN: Any further questions?
23 Seeing none, would you like to continue, Bill?
24 MR. BINGHAM: We next would like to cover under 25 Section B., Environmental Qualification Criteria, Items 5, '6, GRUMLEY REPORTERS Phoenix, Arizona
0' I
150 1 7,'nd 8. That would be on Enclosure ii, Item 5, NUREG 0588, Item 6, Commission Order CLI 80-21, Item 7, IE Bulletin 79-01B, Item 8, 10CFR50 Appendix B. At that time, we will entertain 4 questions, John.
MR. CARSON: Exhibit IIIB-68 has to do with NRC NUREG 0588, which was issued earlier in 1980, and covers positions which are involved with safety-related electrical equipment 8 specifically. The positions are applicable to plahts in the 9 operating license stage, which is the PVNGS situation, and 10 indicates that the requirements set forth must comply with ll one of two versions .of 323, either the '71 or '74 version.
12 Because of the date of the construction permit for this 13 project in p97'6, the requirements of 323-74 must be handled, 14 and those are covered in Category 1 of the NUREG. As indicate 15 TMI type recommendations have not been addressed in this 16 document. The positions provide guidance for use in determin-17 ing service conditions for qualification. Seismic qualifica-18 tion is not covered. Equipment refers to safety-related 19 electrical equipment only. As indicated, PVNGS must conform 20 with Category 1 having to do with Item 323-74. As indicated 21 earlier, that is the basic document for qualification on this 22 project.
23 Exhibit IIIB-69. Calculations hiving to do with 24, temperature and pressure should use one of the computer codes 25 indicated. The project uses the COPATTA Code. Main steam GRUMLEY REPORTERS Phoenix, Arizona
151 line breaks are to be calculated from plant specific model.
Plant specific parameters have been used. Chemical sprays to be addressed inside containment.
're The project addresses chemical sprays in qualification of balance of plant equipment allocated in the containment. Radiation environment should be based on normal environment plus that associated. with the accident, .
and the project complies. As Dr. Rosztoczy just mentioned, there is further guidance being indicated as to source terms to be used.
10 Exhibit IIIB-70. Type testing is preferred and ll it is indicated that type testing is essentially the only 12 method of qualification which will be accepted for any 13 equipment inside containment. The project is in agreement 14 with this method of qualification for in-containment equipment 15 Temperatures are to be defined on or very near the surface 16 of the equipment being qualified by use of thermocouples, 17 The project indicates that separation precludes the failure of redundant equipment,'and the determination of temperature, on the surface of equipment is under study at this time.
20 Equi~t that is required.'to operate within seconds or minutes 21 of the imposition of a design basis event, is called to 22 operate for at least one hour in addition to the actual 23 operating time. That requirement is under review. Aging 24 effects are to be considered. All of the qualification 25 programs for the project consider aging. The Arrhenius GRUMLEY REPORTERS Phoenix, Arizona
methodology is considered an acceptable method of addressing aging. The project agrees with that provision.
This is Exhibit IIIB-71. Periodic surveillance "testing under normal service conditions for ongoing qualifica-tion, as indicated earlier, is discouraged as a principal or prime method of qualification and, if used, is only endorsed on the project u'sing equipment which has some previously demonstrated qualified life. Documentation requirements of 323-1974 are considered adequate. Documentation in accordance 10 with that standard is required for all programs. The additional information required'from Appendix E of the 12 0588 document has been worked into Table 3E-2 of the FSAR 13 and will be presented in a later amendment to that document.
14 Exhibit IIIB-72. Commission Order CLI-80-21 was 15 issued in late May of 1980 and has to do with operating 16 plants. At the workshops: which were mentioned earlier by 17 iver. Noonan and Dr. Rosztoczy, certain information having to 18 do with operating licensed plants, primarily the timetable for 19 review of qualification information, was given. The project 20 is using the requirements of 0588 in terms of qualification 21 programs and will follow the guidance of Category I of that 22 0588 document.
23 Exhibit IIIB-73. IE Bulletin 79-01B was issued 24 in early 1980 andhas to do specifically with qualification 25 of the electrical safety-related equipment in operating GRUMLEY REPORTERS Phoenix, Arizona
153 plants. It indicates that 0588 is to be used for operating plants. It is indicated, also, for plants in the OL stages.
The FSAR service conditions are to be reviewed. The project has reviewed all design basis accident conditions and these are stated for equipment qualification programs. Beta and Gamma radiation are to be considered and the 79-01B document indicates that Beta doses less than 10% of Gamma doses need not be further considered. Gamma doses are being investigate and, as indicated, the FSAR reflects the TID 14844 sources..
10 Exhibit IIIB-74. Beta doses have not yet been included in the FSAR. Effects of Betas are being reviewed 12 in relation to organic materials. Submergence is to be 13 addressed in regard to safety-related electrical equipment.
14 In the project, all safety-related electrical equipment has 15 been located such that it is not subjected to submergence.
Spray chemistry is to be addressed. Spray chemistry is 17 addressed in the design basis accident parameters.
18 Exhibit IIIB-75 having to do with 10 CFR 50 19 Appendix B, quality assurance criteria. The project maintains 20 a quality assurance program and fully meets the requirements 21 of Appendix B.
22 MR. BINGHAM: Are there any questions, John, at this 23 time2 24 MR. ALLEN: Ed 'Sterling.
25 MR. STERLING: Back on Exhibit IIIB-69, the radiation GRUMLEY REPORTERS Phoenix, Arizona
154 environment. Part of that was the 10 to the fourth cutoff limit for neglect of radiation. How has that been addressed'?
MR. CARSON: We have indicated in the environmental designators for the plant areas which are reflected in the specifications the anticipated and calculated radiation dosage for the areas in which the equipment's located. If the area indicates doses less than 10 to the fourth, that is indicated to the vendor and the vendor must respond to what-ever doses are indicated in the specifications.
10 MR. STERLING: So you are not neglecting theme MR. CARSON: We are not neglecting radi.ation. The 12 vendor may tell us that for materials in his equipment that 13 10 to the fourth or some other value of radiation is no 14 problem, but he must address the radiation specified.
15 MR. STERLING: Another question on the next exhibit, 16 IXIB-70, the second item. You talk about the temperature of 17 the .thermocouple readings on or near the equipment surface, 18 and I have gone back. As you did in the previous exhibits, 19 this separation precludes failure. If you are qualifying to 20 have equipment not fail at all, not necessarily have one 21 fail and then, because another one is not in the same 22 environment, it would continue operating, you -'still have not 23 protected that piece of equipment from failure due to the localized environment.
25 MR. CARSON: As we indicated, we are reinvestigating GRUMLEY REPORTERS Phoenix, Arizona
1 temperatures to see if the programs that have'been completed or are in process can provide us with information specificall on surface temperature= and the type of equipment 'is being 4 analyzed on the basis of thermal mass and temperature gradien to see if high temperatures for short periods of'ime will affect such equipment.
MR. STERLING: I have one more question on Exhibit IIIB-74 on submergence. You have indicated that you are goin to locate electrical equipment above the flood level. Have 10 you -iso looked into localized submergence, something that 11 is not below the flood level, but due to sprayage might be 12 covered.
13 MR. BINGHAM: I think we will have Dennis Keith 14 respond to that particular question.
15 MR. KEITH: Let me just tie this in with the previous 16 question, also. Let me just add a little bit on that, becaus 17 it is my understanding that the concern "about having the t
18 thermocouples reading at the .surface temperature is a 19 steam jet impingement concern, a steam jet impinging directly 20 on the piece of equipment. We do a high energy line break 21 analysis throughout the power block, and this also includes 22 moderate energy line breaks where the concern is flooding.
23 You can have certain failures. You can still take a single 24 failure and shut the plant down safely, so as part of that 25 analysis, we look at jet impingement, flooding GRUMLEY REPORTERS Phoenix, Arizona
~ '
1 and all the effects from the pipe break, and that analysis 2 is very well along, as you know. We have not identified anything that we cannot -- we either protect it from the 4 pipe break or, based on the equipment's function, we can 5 let it fail, and we have not identified anything where we have had to environmentally qualify it for the effects of jet impingement or submergence.
MR. BINGHAM: Thank you,,Dennis.
Any other questions, John2 10 MR. ALLEN; Any further questions7 George.
11 IK. SLITER: One of the requirements of NUREG 0588 12 that you did not highlight in your exhibits concerns 13 synergistic effects. You already said earlier in the proceed-14 ing that, synergistic effects will be considered. However, 15 0588 goes on to say investigation should be performed to assure that no known synergistic effects have been identified 17 on materials that are included in the equipment being 18 qualified. What is your intended approach at this investiga-19 tionf What -is your interpretation of thatZ I
20 .MR. BINGHAM: That is -still under review.
21 That could be an open item, John.
22 MR. ALLEN: Fine. Let's make that an open item to 23 determine how we are going to go about investigating the 24 synergistic effects.
25 MR. SLITER: Also, may I make the comment that NUREG GRUhILEY REPORTERS Phoenix, Arizona
t 157
'588 is still out for comments and will be published in final form at an early date, I understand.
DR. ROSZTOCZY: I would like to comment on that.
NUREG 0588 was issued in December of 1979 in a draft form.
Later on, through the Commission order issued May 23, 1980, the draft version has been accepted by the Commission as an interim requirement until a more permanent rule can be generated through the normal rulemaking process. So the draft version of NUREG 0588, which is presently the require-10 ment, is the one that you have to work with until some new regulation comes out. The new rule will be generated through 12 the normal rulemaking process, which will invite comments 13 from industry as well as anybody else. This process normally takes a few years, so we don't expect that to be finished 15 earlier than maybe 1983 or so. In the meantime, it is possible that we will reissue the NUREG, but we will not 17 change the requirements. The draft version is the required 18 version.
MR. ALLEN: Vince, you had a question?
20 MR. NOONAN: More: of a comment. I guess it is really 21 not addressed to Bechtel, but it is addressed mostly to 22 Arizona Power. If you go back to your Exhibit IIIB-67, 23 Items 5, 6, and 7, which are addressing flame resistance, 24 fire'tests, et cetera, if you have been following the recent 25 proceedings that are going on in the Commission in the GRUMLEY REPORTERS Phoenix, Arizona
k licensing of one of the plants, the question of hydrogen burn has been raised. While it is more serious in certain types of plants than it is in other types of plants, it is getting quite a bit of Commission attention and the staff has been asked to address the hydrogenburn question as it affects equipment qualification. We ar'e working on that right now. It is not a requirement being placed on the utilities at this point in time, but I think .it would behoove you to follow closely those proceedings to see what is being 10 done and what kind of requirements may fall out of that thing.
Since you are talking about two years'to go .before you load 12 fuel, you might be getting additional requirements in thi.s 13 area, so I think it would be wise that you pay close attention 14 to the work that is being done back there in Washington on 15 this item and the types of questions that are being asked.
16 MR. ALLEN: Fine. Thank-you.
17 Any additional questions?
18 MR.'LaGOW: On IIIB-69, Item 2, you note for the main 19 steam line break that you are using plant specific parameters 20 to compute, I guess, pressure, temperature, and rate of 21 change of pressure. Are you going to provide that data ox 22 show how the tests you ax'e performing are relating to that?
Maybe that is coming up later.
MR. BINGHAM: You will see it in the environmental 25 parameters, but the answer is yes, we will provide that data.
GRUMLEY REPORTERS Phoenix, Arizona
MR. LaGOW: Do you do so testing for the rate of change of pressure?
MR. BINGHAM: Yes, we,do test to the ramps.:that 4 are shown. We will talk about that when we talk about 5 environmental qualification.
MR. ALLEN: Are there any further questions? Pete.
MR. NEWCOMB: I have two questions. One relates to 8 Exhibit IIIB-68. Item No. 2 states staff recommendations "9 resulting from review of the TMI are not included. What 10 precautions or what provisions have you taken in the set up 11 of your program -to maintain enough flexibility to address new 12 requirements as they come along? Your previous discussion 13 clearly points out'he sequential nature of testing where you 14 must do each thing in step and each thing must be properly 15 done before you move on to the next step. How do'ou address 16 a situation where an early part of the program may have to 17 be modified?
18 MR. BINGHAM: I believe, Pete, your question was how 19 flexible are we going to be.
20 MR. NEWCOMB: Ts there flexibility in your program 21 set-up to accommodate additional requirements, for example, 22 coming from TMI concerns.
23 MR. BINGHAM: Generally, we always have some flexibilit 24 Of course,'he closer you get to wanting to start the plant 25 up, the less flexibility you have. I would say in general GRUMLEY REPORTERS Phoenix, Arizona
that our philosophy is to be aware of what is going on in the industry and at the Commission and to try to assure 3 ourselves through our discussions with our customer that we 4 haven't precluded ourselves from later incorporation of at least some escalation in requirements. However; our basic goal is to get on with the job and get this, done. If we sat around and waited and "what if 'd" ourselves, .we could not proceed.
MR. NEWCOMB: Well, as I understand, what you are 10 indicating is close communication with NRC regarding potential future requirements, 12 MR. BINGHAM: And with the utilities, through all the 13 agencies, and the industry, that's correct.
14 MR. NEWCOMB: My second question is really in general.
15 One of the topics discussed in 0588 that you have not 16 discussed here, and it was brought up previously, is the 17 question of the nonsafety-related equipment. There is a 18 requirement in there where nonsafety-related equipment whose 19 failure could make events worse following an accident must be 20 qualified to show that it will not fail in-an adverse mode.
21 How do you do that'7 22 MR. CARSON: 'Nonsafety-related equipment is designed 23 in the plant in such a manner that its failure in any mode 24 will not affect safety-related equipment. It is placed, it 25 is supported,. or it is barriered, or whatever, such that its QRUMLEY REPORTERS Phoenix, Arizona
161 failure will not affect safety-related equipment. Another way of saying this is that all safety-related equipment is 3 looked at in terms of its location, its support, and the 4 things around it to see if there are any nonsafety-related 5 equipment in the area whose failure could affect the safety-6 related equipment.
MR. ALLEN: George.
MR. SLITER: Although you said that you are still evaluating the effects of TMI on your program, to date was 10 any equipment reclassified as IE as,a result of your 11 evaluation of TMI or were there'any additional types of 12 equipment added to your plans as a result of TMI2 13 MR. BINGHAM: There have been some items. Ve did 14 discuss that at the board of review last month on the 15 auxiliary feedwater system that we were adding some Class I 16 or Class II flow meters. I am sure that there will be some 17 other items added as a result of TMI; MR. ALLEN: Any further questions?
19 DR. ROSZTOCZY: Exhibit IIIB-68., induc'ates;.'the"..:"- i:. '.
20 time when 0588 was issued and the statement. was made that 21 this does not, include lessons learned from Thxee Mile Island.
22 Since that time, we had time to look at what possible additional requirements are needed because of Three Mile 24 Island and the proposition that has been preferred is presentl 25 under NRC management review. Whenever it is in final form, GRUMLEY REPORTERS Phoenix, Arizona
0 4
0
I am sure it will be made available to the industry, includin yourself. I can't recall all the items mentioned in this position paper, but I can recollect four of them, and there aren't so many that four will probably represent most of them. There could be one or'two extra. I would like to comment on those. One of them'applies to new equipment that has been installed on the plant because of the lessons learne from Three Mile Island. This equipment in general are safety-related equipment. That is why they had to be installed, and 10 they fall under the same rule as all other safety-related equipment. It will qualify the'same way as you are qualifying 12 the rest of the safety-related equipment, including instrumen-13 tation that has to be installed for the benefit of the 14 operation of the equipment.
15 The second item mentioned is just simply the list of safety-related equipment. We learned certain things in 17 Three Mile Island and now we are including on the list of 18 safety-related equipment certain equipment that was not 19 included prior to Three Mile Island. It would be important 20 that you review your own list and see if it has been updated 21 and if it includes all of those items that should be included 22 after Three Mile Island.
23 The third'tem is stratification both in terms of 24 radiation and temperature. It'has been observed during the 25 Three Mile Island accident that rather high radiation doses sho~ied GRUMLEY REPORTERS Phoenix, Arizona
up in certain portions of the containment, higher elevations in the containment~ and this indicates a certain amount of stratification, that one part of the containment might have higher dose rates than an average dose rate would be calculat for the completely distributed source. We don't know exactly what is the best way to handle this, but we expect you to take this into.:consideration at the time when you establish your environmental zones. The same for temperatures. You might elect to divide the containment into more than one 10 environmental zone and you might specify higher temperatures and higher radiation levels, for example, for the higher 12 zones in the higher elevations in the containment and then
.13 check if there is any different equipment at that location 14 and whether it is qualified'for those higher zones. Normally, 15 the higher elevations in the containment don't have safety-16 related equipment. However, if there is a possibility, it 17 should be kept in mind.
18 The fourth item which I recall from this position 19 paper relates to the hydrogen burn. I think Mr. Noonan 20 mentioned that earlier, so there is no need to discuss it 21 any further.
22 There could be one or two other things. If you are 23 interested, if you check with us, then we can check if there is anything important for you.
25 MR. ALLEN: When do you think that paper is going to GRUMLEY REPORTERS Phoenix, Arizona
be out?
DR. ROSZTOCZY: Well, I would expect it within a few weeks, probably; maybe within a month. It is a two-page type of thing, so it won't be very long.
MR. ALLEN,: Do we have- further questions from the board before we proceed?
DR. ROSZTOCZY: The next one is Exhibit IIIB-70. The third bullet down the line talks about the minimum one-hour qualification requirement, if certain equipment is expected 10 to operate only for five minutes after the accident, it should be qualified for one hour and five minutes. Under the 12 position column, I see the words'hat the requirement is 13 under review. Since this requirement exists on NRC's behalf 14 and since you are performing your tests, I am not sure what 15 these words mean. Are you performing the test to one hour and five minutes for the example case or are you doing 17 something else? Time is running out on you. You can' 18 consider this requirement for too long. They have to be 19 in foice, and there is no change in this. This is a require-20 ment., We expect that it is going to stay this way, so the 21 recommendation would be that you should test all of your 22 equipment to this requirement.
23 MR.'LLEN: Does anyone want to comment on that?
MR. BINGHAM: Yes. The reason we put. "in review" is 25 because we are having a great deal of difficulty understandin GRUMLEY REPORTERS Phoenix, Arizona
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o
the rationale of applying that criterion to some of the equipment, and we have not yet had an opportunity to discuss this in detail with APS or, indeed, with the NSSS vendor or vendors throughout all the projects. We presently are of the opinion that that may be,a severe requirement for qualification, and until we have our review completed, we would not be in a position for those discussions. What. I understand that you have said is that regardless of the rationale that the utility might provide, that still is as far as NRC is concerned. Is that correct? the'equirement 10 DR. ROSZTOCZY: Yes. In terms of the operating plants, 12 we are looking at what information is available, and so .on, 13 and I am not sure exactly what the outcome might be for a 14 piece of equipment that wasn't qualified all the way up to 15 'this time period, but for all new tests, we certainly would 16 expect that they will be performed to this time period. Now, 17 I am not sure what you meant when you indicated that this 18 might be a- very severe requirement. Do you mean that it is 19 very severe in terms that the equipment might not be able to, 20 withstand the environment for this long?
21 MR. BINGHAM: No, I did not mean that. What I was 22 referring to was the fact that the bulk of the= equipment on 23 Unit 1 is installed and, therefore, would not be available for 24 that sort of testing. If I understand what you are saying, 25 it is that this criterion would be applicable to tests that GAUMLEY AEPOATEAS Phoenix, Arizona
k n
would be conducted or tests yet to come up and we would conduct it in that manner. That puts a different perspective on our interpretation of the requirement.
DR. ROSZTOCZY: I'm sorry, I didn 't mean to imply that. I meant to imply more in terms of the 1971 requirement or the 1974 requirements. You fall under the '74 requirement You know this now for a number of years and we expect you to meet this one hour plus test requirement. I am not sure if I follow you in terms of the equipment which has already 10 been installed. The question is has this equipment already been tested. If it has been tested, that includes tests 12 under the '74 requirements, meaning that you preaged it, 13 you preradiated it, you have shaken it, and then after that 14 you have underwent a blown core or appropriate environment 15 of that. This last. portion of the testing should be performe 16 for this extended period, and if it wasn't followed, then you 17 might have a serious problem at hand.
18 MR. BINGHAM: I believe we understand your question 19 and Mr. Carson will respond.
20 , MR. CARSON: In terms of g5y equipment, the primary 21 items would be isolation valves operated by Limitorque" operato s 22 for this project. Limitorque has provided qualification 23 which shows that they are capable of not only operating for 24 one hour in the accident environment, but throughout the 25 accident environment and post-accident, and this has been GRUMLEY REPORTERS Phoenix, Arizona
1 demonstrated in their qualification programs. For other 2 equipment, it is still under study.
DR. ROSZTOCZY: Exhibit IIIB-73. Under Item 2}A, you are talking about temperature and pressure steam conditions.
You didn't mention humidity. One of the concertos that we have is that sometimes the humidity affects the test for the equipment, whetQer the equipment will survive the test, and it is not always clear whether the dry or the humid atmospher is more limiting or whether a combination of dry and humid is 10 more limiting than either the dry or the humid if it applied as a single atmosphere. How did you assure that your equipment will be tested for the most limiting conditions'?
13 Let me give you an example . If you have some kind of equip 14 ment, let's say electrical equipment, inside a box. and the box is sealed in such a way that humidity can't get to it, 16 then testing't at high temperature in a dry atmosphere could 17 fail the seal material. Xf after. that, it is exposed to a 18 humid atmosphere, the" humidity penetrating into -the box could 19 fail the electrical equipment inside. If this equipment 20 together with its box is being tested only in dry atmosphere, 21 there will be no failure. If it is tested only in a humid 22 atmosphere, there will be no failure again. But if it is 23 tes ted in a dry and then in a humid atmosphere, then it wi1 l fail. What have you done to cover this type of cases and to avoid the possibility of qualifying something at the same tim GRUMLEY REPORTERS Phoenix, Arizona
1 it might fail in the plant because of the combination of dry 2 and humid atmosphere.
MR. CARSON: In the specifications for equipment, as indicated, the environmental parameters are stated including 5 the expected range of humidity at the location of the equip-6 ment. The vendors'ualification programs are reviewed to 7 see that humidity has been considered. We have had programs in wnich with large equipment, for instance,;nator control centers o switch gear or such as that, or relay cabinets, the vendors have 10 responded to humidity by actually putting open containers of water in the equipment while it is run through temperature ranges such that the humidity would vary over the appropriate 13 range and the operation of the equipment has been checked 14 under those conditions. As indicated earlier in another 15 discussion on humidity, humidity is primarily looked at by
]6 the selection of the materials used to make sure that non-hydroscopic materials are used and that the design of the 18 equipment would not provide surfaces on which humidity 19 condensation would provide for low tracking resistance or 20 for reduced insulation resistance.
21 DR. ROSZTOCZY: Have you specified for any of your equipment testing at relatively elevated temperatures in a 23 dry atmosphere which would be followed by tests again in 24 elevated temperatures in a humid atmospheres 25 MR. CARSON: We have not made any specific test GRUMLEY REPORTERS Phoenix, Arizona
requirements in that specific sequence. As indicated, we have indicated to the vendor the total range of parameters which he must address and have made sure that the qualifica-tion programs and the qualification testing have addressed that range of parameters, but we have not been specific in saying that you must closely follow a high temperature dry operational period by a high temperature wet or a low temperature wet operational period.
DR. ROSZTOCZY: I would like to recommend that you 10 review the qualification specifications for all of your equipment that is exposed to this high temperature possibly 12 dry and humid environment and see if there is a need for such 13 a specification.
14 MR. ALLEN: We will take that down as an action item.
15 DR. ROSZTOCZY: Exhibit 73 and 74 together kind of 16 list the various environments that I assume you consider.
17 Here they are mentioned because they were mentioned in the 18 bulletin, but maybe this is an appropriate time to bring up 19 some other environments that have not yet been mentioned and 20 which should be considered. If you are planning to discuss 21 this later, then please just let me know and then I will wait 22 for that. Two items that are not mentioned here'are, one, 23 what I would call a dynamic environment. This is an environ-24 ment of expected vibrations created by the accident in 25 various portions of your plant or your system. For example, GRUMLEY REPORTERS Phoenix, Arizona
1' if the expected course" of the accident is that two-phase 2 flow is going to pass through pumps or valves, then you 3 expect to vibrate'nder this condition, as they did at 4 Three Mile Island. How do you account for this dynamic or vibration environment . and how do you represent this in your specifications when you specify the environmental conditions?
MR. BINGHAM: Dr. Rosztoczy, we are not exactly sure how we have covered that particular issue. We do look at som vibratory motions, and what I would like to do is to check on 10 that particular issue and get back during this proceeding, perhaps during Mr. Schechter's presentation, which I am 'sure 12 will touch a bit on it, but we will provide the answer.
13 MR. ALLEN: I would like to request that that be put on 14 the open items list.
15 MR. QUAN: Could we have that question repeated, your f
I concern?
17 DR. ROSZTOCZY: In the expected course of an accident 18 or event, various things can happen in the plant, including 19 vibrations or any kind of dynamic loads. How did you account 20 for these environments in your evaluation of the plant and 21 the specifications that you prepared for various equipment7 22 The other environment that is not mentioned in this 23 slide here is dust. I think earlier we mentioned sand storms.
24 Since Arizona is an area where this is kind of a more frequent y 25 expected event than in other areas, are you going to discuss GRUMLEY REPORTERS Phoenix, Arizona
sometime today or tomorrow how you handle dust and what kind of specifications you have prepared for various eouipment in terms of duse?
MR. BINGHAM: Dust is near and dear to our hearts on this project and we have through studies and actual measure-.
ments at the site determined the dust loadings, for example, that would affect the diesel generator, both intake and cool-ing. There is a considerable amount of information available and that has been presented as part of the licensing 10 document.
Dennis, help me on this.
12 MR. KEITH: I think it is primarily in Chapter 9 in 13 the ventilation.
MR. BINGHAM: Chapter 9 in the ventilation. There is 15 information 'there that discusses what we have given to the manufacturers that- would see dust environment. They have 17 responded back with a statement that their equipment is 18 safisfactory for the dust loadings that we would expect.
DR. ROSZTOCZY: Could you prepare a summary, let's say, 20 for tomorrow in terms of how did you'andle dust, what kind 21 of equipment did you specify.". dust for, and give us some 22 examples of what was in the specifications?
23 MR. BINGHAM: Yes.
24 DR. ROSZTOCZY: I'would like to include equipment,-
25 for example, such as pump seals.
GRUMLEY REPORTERS Phoenix, Arizona
e
~
l72 MR. BINGHAM: Pump seals?
DR. ROSZTOCZY: Yes.
MR. ALLEN: Dust effect on pump seals?
DR. ROSZTOCZY: Yes.
MR. ALLEN: Vince.
MR. NOONAN: I guess I would like to go back to IIIB-7 the slide that Dr. Rosztoczy talked about before when he was talking about the requirements out of NUREG 0588 including testing't least one hour in excess of the time assumed for 10 the accident analysis. I don't find the answer that you gave 11 to be acceptable. I guess I would consider this to be an 12 open item. The requirement exists. It is a requirement out 13 of 0588. Ne are talking about a qualification test, we are 14 not talking about acceptance testing. You made a'statement 15 you didn't quite understand where the requirement came from.
16 In qualification testing, you define tests in excess of 17 what you expect to see. I guess what I am trying to say is 18 that the requirement is- there and it has to be met and the 19 answer that you gave I don't think was satisfactory.
20 MR. BINGHAM: I may have caused some confusion. I am 21 advised that for the balance of plant equipment that all of 22 the equipment that falls under this concern is or will be 23 qualified with that one-hour requirement. There was a 24 concern on our mind as at what. time we were into the design 25 basis event and how to properly apply the'one hour. - Since GRUMLEY REPORTERS Phoenix, Arizona
1' 1 we seem to have things in order, let me say for this particul r 2 issue that we will correct the record and the chart to ref lee 3 compliance for balance of plant.
MR. NOONAN: That is acceptable.
MR. ALLEN: Did you get that, Terry?
MR. QUAN: Yes.,
MR. ALLEN: Bill, again, that is strictly for BOP.
MR. BINGHAM: That is strictly for BOP.
MR. ALLEN: Any further questions?
10 If not, I had one. On Exhibit IIIB-74, Item C, it 11 seems to me that at one time we were discussing putting in 12 some submersible pumps in the safety-related sumps. Is that 13 not the case now?
MR. BINGHAM: John, Dennis Keith will respond to that 15 question.
16 MR. KEITH: John, we don't have any sump pumps in 17,the containment that are safety-related., However, as a 18 result of all the work that has beeni~done post Three Mile 19 Island, we are looking at the possibility of getting 20 submersible sump pumps, but that evaluation has not been 21 completed.
22 MR. ALLEN: And if we do 'A get them, then they will be 23 qualified for the flood levels?
24 MR. KEITH: They would be qualified, yes. That would 25 be the purpose of changing our design.
GRUMLEY REPORTERS Phoenix, Arizona
'0 174 MR. NOONAN: John, when you answered me on that last question, you made the statement for balance of plant when he was talking about the one hour, but the requirement still exists for Arizona Power for its plant.
MR. ALLEN: Right, I understand that, but what I f
clarified that for was for the record of this system review, which is balance of plant.
MR. NOONAN: I understand that, but I want to be sure you understand what I was looking for.
10 MR. ALLEN: I understand it very well.
DR. ROSZTOCZY: One more'comment on this last slide 12 in connection with the flood level. One lesson learned from 13 Three Mile Island is that maybe under some conditions, the 14 flood level will be higher than" it showed for three years 15 ago or five years ago. Have you looked carefully at your 16 plant to see what is the maximum flood level that you would 17 be able to flood the containment to under extreme emergency 18 conditions?
19 MR. BINGHAM: We have looked very carefully at that 20 possibility. As I told you, we have everything on a very 21 large scale model, so we have reviewed to make sure that 22 needed equipment had a considerably safe::margin that we added.
23 MR. ALLEN: Any further questions?
If not, continue with the presentation, Bill.
25 MR. BINGHAM: All right. That gets us to Section B.9, GRUhllLEY REPORTERS Phoenix, Arizona
4 175 PVNGS Environmental Classifications.
I would like to make one correction to the record, John. Early, in the presentation, I believe it was in Section 5, Mr. Carson indicated that the CP date was 1966.
The date is 1976.
MR. CARSON: In Exhibit IIIB-76, we discuss the environmental classification of the equipment, and this will be in conjunction with some earlier questions raised at thi's meeting. The parameter values which led to the environmental 10 conditions for all of the equipment are calculated using appropriate conservative analyses. The values have been 12 grouped on the basis of plant arrangement and the maximum 13 values have been applied to the entire area that is identifie Figure 12 shows an overall view of Unit 1, which is exactly the same as Units 2 and 3, for the plant -- the main buildings, the containment building, the main steam support 17 structure, auxiliary building, fuel building, wadwaste,buildin 18 control'. building, diesel generator building, and the turbine 19 generator building. The areas of concern have been designate 20 with different environmental designators as shown on Exhibit 13.
21 The containment building is Environmental Designator I. These 22 parameters, as indicated in Table 2, are the parameters 23 associated with the containment building taken as a whole for both normal and abnormal service and as a result of the design basis accident with the design basis accident indicated.
GRUMLEY REPORTERS Phoenix, Arizona
176 In answer to an earlier question, the profile for temperature and pressure has been indicated in terms of time 3 'nd the ramp rates for the various pressures indicated as 4 well as temperatures. Relative humidities have been specific 5 integrated dose rates for the 40-year life and 40-year life 6 plus accident, chemicals indicated in the spray system for the containment. These are all specified in the information given the vendor for any equipment which must operate in this 9 atmosphere and the -qualification will be handled accordingly.
10 The second area, the main steam support structure, 11 Environmental Designator II, is'indicated in Table 3 with the same sort of presentation: temperature, pressure, 13 humidity, radiation, chemicals for both normal and abnormal 14 operations plus the design basis accident, the LOCA main ste 15 line break, *in which case temperatures above 100 elevation in this building rise to a 300 degree level, pre'ssure above 100 17 elevation only goes to 21 pounds, humidity specified, 18 radiation specified, again ~ higher level above 100 elevation, 19 and in this area, no chemicals are involved.
20 Designator III has to do with the auxiliary building 21 surrounding the containment. Shown in Table 4 is Designator 22 III indicating that conditions are the same under normal and 23 abnormal conditions and the effects of the LOCA with the exception of radiation. Radiation in this area as a result 25 of circulating radioactive fluids would raise the value to
. GRUMLEY REPORTERS Phoenix, Arizona
0 10 to the sixth power. No chemicals are involved in the auxiliary building.
The control building, Environmental Area IV, is shown in Table 5 with normal and abnormal and the conditions which exist as a result of a LOCA or main steam-line break.
Of course, there is no main steam line break or LOCA applicab to this area as such, but the effects of the LOCA or steam line break in another portion of the plant will affect the control building as indicated. Me see that there are no 10 effects in normal or abnormal conditions and the accident conditions are exactly the same for this area. As was 12 discussed previously in relation to the batteries, the 13 battery rooms are maintained at a temperature of between 60 14 and 85 degrees Fahrenheit, well within the operating range of 15 temperatures, which have a normal rated temperature of 77 16 degrees F.
17 The diesel generator building, Environmental Area V, is shown on Table 6, the conditions for normal and 19 abnormal service. For the accident in another portion of the 20 plant, the same conditions apply with a slight bit of 21 increased radiation going from something lower than 10 to the 22 third rads to a 10 to the third rad level, which is not considered.
23 detrimental to=- equipment and is being confirmed by tests and 24 analyses of all equipment in this area. In addition to the parameters shown here, Mr. Bingham indicated that the dust GRUMLEY REPORTERS Phoenix, Arizona
r,
178 loadings applicable to the ventilation and combustion air systems have been incorporated into the specifications for th diesel generator.
11 The fuel building, Environmental Designator VI, is shown in Table 7, conditions for normal and abnormal and the accident environments with a slight increase in radiation, which is taken into account for equipment located in that area.
There is one other area, which is all of the outsi 10 areas and is called Environmental Designator VII shown in Table No. 8, indicating that there will be some slight 12 increase in radiation, and any safety-related equipment locate 13 outside the actual plant buildings will be qualified 14 accordingly.
15 MR. BINGHAM: Are there any questions?
MR. ROGERS: On the last environmental area, the outsid 17 area, are there any pumps or valves located outside of the 18 ,buildings shown that are safety-related?
19 MR. BINGHAM: There are pumps and valves for the 20 essential spray pond.
21 MR. ROGERS: Thank you.
22 MR. ALLEN:. How about pumps and valves on the condensat tank?
24 MR. BINGHAM: Yes, they are in the same designator.
MR. ALLEN: George.
GRUMLEY REPORTERS Phoenix, Arizona
I 179 MR. SLITER: Some of your tables for environmental designators indicate normal and abnormal in a range. Is the lower number nomha1 and the upper abnormal? An additional 4 question would be what basis or what temperature profile do you use for aging equipment in these environments? Is it a combination of both, or what?
MR. CARSON: The range indicated is the range covering both the normal and abnormal conditions. The lower temperatu is not the normal; the upper is not the abnormal. Me have 10 taken the envelope of the entire normal/abnormal situation and said this is the range of temperatures over which you 12 must operate. The vendor is required to respond to that and 13 they would normally envelope that condition with margin and 14 operate.- above the upper and below the lower indicated 15 temperatures, so they again operate over a wide range of 16 temperatures.
17 MR. SLITER: And the aging question. Shat value 18 normally would be used to age the equipment?
19 MR. CARSON: Normally, the value that would be used 20 would be the upper temperature.
21 MR. SLITER: The one with the margin in addition to
'I 22 your upper value?
23 MR. CARSON: Yes
..'5 MR. SLITER: This you recognize could be extremely conservative in terms of aging.
GRUMLEY REPORTERS Phoenix, Arizona
180 MR. CARSON: Extremely conservative. Some programs address an average temperature, but those are normally at the higher levels, also.
MR. ALLEN: Norm, did you have a question?
MR. HOEFERT: Yes, I have. a question on Table 8. You stated the high range of the temperature for, outside areas is 116 degrees., Is any equipment that has to be qualified being exposed to the sun and, if so, how do you justify the 9 116 degrees?
10 MR. CARSON: No equipment is exposed to sun. All is 11 in covered areas.
12 1'K. HOEFERT: Does this include the ESF service 13 trans formers?
14 MR. CARSON: ESF service transformers are not safety-15 related items. All safety-related equipment in outside areas are covered and are not exposed to sun.
17 MR. HOEFERT: It has been my understanding that they 18 are Class IE. Is that not correct?
19 MR. CARSON: The ESF service transformers are not 20 specifically Glass IE. They are the preferred source of 21 power in the event of a design basis accident. Class IE 22 equipment is incorporated in the AC and DC systems, which 23 were reviewed earlier, and start really with the batteries 24 in the case of the DC system and the DC distribution equipment 25 all of which is indoors, and start with the source of safety-related AC power, which is the diesel generator and the GRUMLEY REPORTERS Phoenix, Arizona
distribution system, again which is all indoors.
MR. HOEFERT: I have another question. On your tables, for chemicals, you list none for I think all of those. Did you consider chemicals which are used for firefighting?
MR. CARSON: Environmental qualification programs do not cover the inadvertent actuation of firefighting systems involving chemicals. The only chemicals used for such system in this plant are Halon in certain areas and carbon dioxide in certain other areas. Other firefighting apparatus includes 10 water.
MR. HOEFERT: It would seem we could expect sometime 12 in the life of the plant to have these chemicals used 13 Halon if that is the chemical. Must that be looked at on a 14 case-by-case basis or is there some justification that this 15 already--
MR. CARSON: We would expect not, since both Halon 17 and carbon dioxide are essentially inert gases and the selecti n 18 of Halon is made on the basis that it does not really affect 19 anything and, in fact, in the concentrations used, is not 20 harmful to human beings.
21 MR. HOEFERT: What about the temperature effects of 22 C02.
MR. CARSON: The temperature effects of CO> are not 24 involved, since CO> is not directed directly onto safety-25 related equipment, but into the areas, and it would not be GRUMLEY REPORTERS Phoenix, Arizona
I
,f
1 expected to severely lower temperatures or inpinge on the eltuipmmt and 2 cause freezing temperatures, for instance, that might damage 3 equipment.
MR. ALLEN: Vince, did you have a questionf MR. NOONAN: Following on the same question he is bringing up here, it is pretty hard to believe that in the 40-year life of your plant that you,would not expect to have chemicals outside unless some particular procedure is in plac to make sure that this never happens. It is just hard for 10 me to believe that over 40 years of plant life that you will 11 not at some point in time find chemicals in outside areas.
12 MR. BINGHAM: We have looked at chemicals outside, 13 Vince, from time to time. All of this equipment is protected 14 from missiles, so that means it would be "enclosed from direct 15 impingement, although there could be some leakage. One of 16 the major concerns was chlorine gas and we have opted on this'7 project to use sodium hyperchloride to do away with that 18 particular concern. I guess I would have to say that at 19 leastto our knowledge, it is quite unlikely that this safety-20 related equipment would experience direct impingement of 21 some chemical. Here I am assuming some chemical is outside.
22 If you have some examples that we should consider, please 23 state them so that we can assure ourselves that--
24 MR. NOONAN: I guess I don't really have an example, but if you just think of things that happen over 40 years of GRUMLEY REPORTERS Phoenix, Arizona
time, -- You are saying that there is no way that we are ever going to get any chemicals in outside areas.
MR. BINGHAM: I am not saying no way. I said it is unlikely.
MR. NOONAN: If I go to Table V, can you-tell me how 6 the control building environment is controlled?
MR. BINGHAM: Yes, we can.
John, the reason we are taking a minute, this is a 9 little outside of the scope of this particular meeting. Me 10 can take a minute and make sure we describe it properly to ll Vince or we could in the morning if we are getting together 12 sometime later give you an exact description.
13 MR. NOONAN: Nell, the point I am getting to, if you 14 have a control system here to control temperatures, and so 15 forth, inside the building and you lost that system, do you have a redundant backup system?
17 MR. BINGHAM". Yes, we do.
18 MR. NOONAN: Okay, that's sufficient.
19 MR. BINGHAM: Is that sufficient?
20 MR. NOONAN: Yes.
21 MR. BINGHAM: All right, fine.
22 MR. ALLEN: Did you have a further question, Vince?
23 MR. NOONAN: No. Thank you.
24 MR. ALLEN: Ed Sterling, have you got one?
25 MR. STERLING: Yes. Dennis had answered before about GRUMLEY REPORTERS Phoenix, Arizona
the impingement studies that you had done. Is there any othe "2 case that you know of or have you addressed stratification 3 or local hot spots in any of these particular areas?
4 Dr. Rosztoczy had pointed out the fourth item in his list 5 that stratification in the containment, but say.in the other buildings as well.
MR. BINGHAM: I believe this is an issue that is 8 coming up to assure that we have been covered, and when it 9 comes up, we will take a look at it.
10 MR. ALLEN: We will put that on the open i'tern list, stratification, and make sure we review it. We will have to do it because of 0588 anyway.
13 MR. B INGHAM: Yes .
MR. NEWCOMB: On Table 3, which is the main steam 15 support structure environmental conditions, you identify a 300 degree temperature above 100 feet, 21 psi, et, cetera, 17 above 100 feet. Is there anything below 100 feet? In other 1
18 words, you give a certain level in that structure a temperatur 19 and pressure.
20 MR. BINGHAM: The auxiliary feedwater pumps are below 21 100 feet and, as we discussed at the last system review board 22 meeting, that is a contained area that is completely separate 23 from the upper portion of the main steam support structure.
24 MR. NEWCOMB: Do you 'address that environment? I mean do you have an environment for that area, the-auxiliary GRUMLEY REPORTERS PhoenixArizona
18 feedwater pumps'R.
2 BINGI1AM: Yes, we do.
A MR. NEWCOMB: Is it here somewhere and I missed it?
MR. CARSON: Well, it is this environment right here.
The only place where you have a possible problem is due to the 'design basis event, which only occurs above 100 feet.
MR. NEWCOMB: There is no design basis event below 100 "feet2 MR. CARSON: No.
10 MR. HOEFERT: Bill, wasn't there some discussion in the meeting on the auxiliary feedwater system about a break 12 or leaks in the steam supply line to the turbine driven pump 13 and that Bechtel was going to look at that as far as the 14 effects on the equipment in that area.
15 MR. BINGHAM: Yes, there was.
16 MR. ALLEN: Are there any further questions on this 17 before we proceeds Karl.
18 MR. KREUTZIGER: I would like to refer to Table 4.
19 Under the radiation zone, the ion exchanger, is that correct, 20 2'.7 times .10 to the ninth?
21 MR. BINGHAM: Yes.
22 MR. KREUTZIGER: Are there any electrical cables in 23 that arear'hat equipment is located in that area?
24 MR. BINGHAM: Just a moment. Let me check to be sure.
25 No, there is no electrical equipment in there.
GRUMLEY REPORTERS, Phoenix, Arizona
/
186 There might be some pipes, of course, and valves.
MR. KREUTZIGER: My question is how does the project 3 preclude routing in these areas by the field since they do field routing 4 conduit- Ho> do you preclude anything from going through that 5 area? To the best of my knowledge, the cables Chat you have 6 purchased have not been qualified to this level, and my 7
J question is how do you assure that something does not get 8 in there?
MR. BINGHAM: We may be confusing the boar'd with this 10 particular issue. This is just a small compartment, it is not safety-related, and I am not exactly sure why that is I
12 put on as an example.
13 To answer your other question, we do review the 14 routing of the conduit by the field and make sure that we 15 don't have safety-related conduit and cable where i" would exce 16 its qualification.
17 MR. KREUTZIGER: My question is how do you assure that.
18 The electrical designer that might check the conduit route, 19 how does he know that the area is 2.7 times 10 to the ninth?
20 How is it assured in the review process?
21 MR. BINGHAM: There are reviews, Karl, of the model, 22 our ALARA 'reviews, separation reviews. All of the groups get 23 together, including the nuclear group, which is responsible 24 for the radiation, and that gives us some assurance that somebody has not misapplied the criteria. am advised that 25 ORUMLEY REPORTERS Phoenix, Arizona
0 4
187 1 this particular area really doesn'0 pertain to the issue at hand and, if necessary, we could go into why the purification'on exchanger would not fall in the category where we would 4 have to worry about a designer running some safety-related 5 conduit through that area.
MR. KREUTZIGER: Table 6, you have l40 degrees F in the
.7 diesel generator area 'as a maximum temperature. This to my
.8 knowledge is one of the few places on power plants, even on other nuclear power plants, that have exceeded the level of 10 about 50 degrees C for normal operating temperatures. My
/
question is how do you assure that the design temperature has 12 been factored into t'e design of equipment ratings? For 13 example, we have a general temperature for cable derating.
14 Let's say that the cable that leaves a diesel generator 15 to go back to wherever the safety-related switch gear is 16 probably runs in trays. That cable is sized for an ambient 17 condition. Again I am bringing this point up because it is 18 the'irst time that I have ever seen an ambient condition 19 above 122 degrees F, which is 50 'degrees C, and I would like 20 to know what assurance you have that if I were to look at the 21 cable sizing calculation, derating calculation for that 22 cable, how is it assured that the electrical engineer has 23 used for this area 140 degrees F?
24 MR. CARSON: In this particular area, safety-related 25, cables are run primarily in conduit'hich act partially as GRUMLEY REPORTERS Phoenix, Arizona
heat sinks. The 140 degree temperature indicated is one that: is an extreme temperature and occurs only very periodica 3 and for short periods of time and is not,a long-term 4 operational temperature. Cable sizing is done to accommodate in these cases primarily the average temperature or above average temperature which may occur in the area and the cable are oversized to.,compensate for increased temperatures.
MR. KREUTZIGER: I would assume that these diesel 9 generators are assumed, at least, to operate for extended 10 periods of,time during loss of off-site power in an accident condition. Is this the temperature that comes from this 12 140 degrees FV My assumption is and my concern is that the 13 140 degrees F is occurring when the plant is requiring the 14 diesel generators for operation, which could be over a relatively extended period of time on loss of off-site power.
Is that correct? Is my assumption correct that the 140 degree 17 'F does occur each and every time that the diesel generator operates?
19 MR. BINGHAM: I am not sure that's correct.
20 Let me take care of two of the questions that you 21 had. One was how do we assure ourselves, and I think we left that question open, that the designer includes the 23 informati on in the design. This information is part o f the design criteria and, as I have indicated before, there are 25 procedures and checks and balances to assure ourselves that GRUMLEY REPORTERS Phoenix, Arizona
l89 1 the designer is aware of it and has included it in the design.
2 The 140 degrees is based on the peak summer temperature that 3 you might see, so for a short period of time when the day 4 was the hottest and the diesel is operating, you would see 5 the 140 F.
MR. KREUTZIGER: But that 140 degrees F, were an accident or the use of the diesel for loss of off-site power to occur during the summer months -- I guess that would assum 9 during the day.
10 MR. BINGHAM: ,The heat of the day.
MR. KREUTZXGER Then the temperature in that room 12 would be 140 degrees F7 13 MR. BINGHAM: It might be as high as 140.
14 MR. KREUTZIGER: The question was then the design 15 basis for cable derating is something less than that.
)
16 MR. BINGHAM:" Based on the proper use of the criteria, 17 we would expect that that had been properly accounted for.
18 I cannot answer that question, John, without furthe 19 review. If you would like to have that as an open issue, we 20 will go back and confirm whether indeed we did cover that 21 properly ..
22 MR. KREUTZIGER: I would like to have that as an 23 open issue, because there are other parts in here that we 24 show also 122 degrees as being the design temperature. The 25 same with things like the steam support structure. These GRUMLEY REPORTERS Phoenix, Arizona
temperatures 'are higher than the normal derating that we use in our designs. I think historically they have been 40 degrees -- well, 40 degrees C in the outside areas except containment, which was 50, which equals 122 F.
C So I would like to have confirmed that the parameters that. have been "t utilized in the design calculations have been properly addressed.
MR. ALLEN: Okay.
John Barrow.
10 MR. BARROW: I want to clarify something. A coupleam of times in this discussion, somebody has made reference to<'-"
12 140 degrees C. I want to make sure that it gets into the ay 13 record that we are talking about 140 degrees F.
14 MR. BINGHAM: Yes, that's right. '6, 15 MR. CARSON: All temperatures listed in the tables are 16 degrees F.
17 MR. ALLEN: Further questions? Vince?
18 MR. NOONAN: I am going to really address this to 19 Arizona Power, and it is the same concern that I had earlier 20 when I raised the 79-14 bulletin of the. as-built conditions, 21 and the question just asked on Table 4 about the purification 22 ion exchanger. Is there some quality assurance program that 23 you have in place to assure yourself that that plant that r sits out there is built like your dr'awings say they are built 25 and is it periodically going to be updated to assure yourself GRUMLEY REPORTERS Phoenix, Arizona
that you don 't five years from now run cables through some of these areas where you have these very high radiation levels?
MR. ALLEN: I think I would have to address that in two parts, number one from our quality assurance standpoint and the program that John Roedel has in effect, and then the program that Bechtel has in effect at the present time to make sure that the as built is actually like the design.
John, why don't you comment on your activities and 10 then I will have Bill say a few words on the Bechtel program.
MR. ROEDEL: Our whole quality assurance program which 12 filters down from Arizona Public Service Company all the way 13 down to Bechtel and all the way down to the subcontractors 14 is to assure .that the pl'ant is built in accordance with the 15 design requirements, and in that program, we have various and 16 very numerous management checks and balances to review.
17 drawings and specifications to assure that we do accomplish 18 that fact. We also have quality control inspection at the 19 site. We have vendors'urvei3;:l!ance inspection at the shops, 20 and we have: receiving inspections for articles at the plant 21 to then assure that'. that equipment and articles are installed 22 in accordance with the design criteria. Also, the design criteria are expressed in the construction specifications.
24 They are again expressed, in the work plan 'Jrocedures/
25 quality control instructions, which is the document that GAUMLEY REPORTERS Phoenix, Arizona
19 the quality control inspectors work from and-the engineers work from at the site. So I believe very strongly that our program is sufficient to accomplish that objective. In the 4 six years that I have been on this project, we have verified "many times that the implementation of the design review process at Bechtel for our project is functioning correctly.
That activity is covered by the EDP's, which is the engineeri department procedures, the project quality control program manual, and in those documents, it describes how these 10 functions are carried out. That is a means by which the engineering manager implements that program, and we have 12 many instances documented from reviews and from audits that 13 that is being implemented.
14 Now, if you will, let me answer the second part of 15 your question: What will we do in the operation of the 16 plant that we would not make a modification of that plant that would preclude or interfere with the design criteria 18 that we installed the plant to? The corporate quality assurance program has not yet been completed, although we are 20 working on that at the present time, and I will assure you 21 that we will have such management checks and balances to 22 assure ourselves that we do not'iolate our design criteria 23 when we perform major modifications of the plant. I'uess 24 that's all I can say.
MR. NOONAN: I guess the only other comment I will have GRUMLEY REPORTERS Phoenix, Arizona
0 0
~ I
1 on that subject is when we had Bulletin 79-14,and we started getting the results of that bulletin in, industry as a whole did not have a very good track record when it came to looking at those plants and finding out that those plants were not 1
actually built according to the way they were designed and 6 we invalidated a number of particularly the seismic areas 7 because of displaced supports, wrong supports, things hung 8 completely different than what the drawings had shown. The 9 industry as a whole did not have a very good track record.
10 I would hope now that; based on that experience, that is being taken into account and as these new plants. come on line 12 that there is a gradual update of the as-built conditions to 13 show that you haven't done anything to that plant in either 14 modifications or field corrections during the building that 15 would invalidate this environmental program.
MR. ROEDEL: I would like to respond to that statement.
17 The design of,this project has taken into consideration some 18 of those items. The design of this project precludes the use 19 of cinch anchors, concrete 'anchors commonly called cinch 20 anchors. You can't find one in our plant, because they are 21 not allowed to be used. We do have the caveat that you can 22 use one, but it takes engineering approval by Mr. Bingham and 23 APS to use one. Therefore, we have precluded that problem, 24 and there are some other designs that we have put into the 25 plant in controls to preclude some of those. For instance, GRUMLEY REPORTERS Phoenix, Arizona
all the electrical cable for the plant is bought to the Class IE requirements even though some of it is for the balance of plant not safety-related. All the rebar is bought to the same requirements, so, therefore, we don't have to keep segregation of that. The weld rods the same way. All the concrete is produced the same 'way.
Another feature that we might include here is that, regardless of the qualification, the articles in the drawings and the specifications for the most part are handled the 10 same way. Just because a specification happens to be for a Quality Class Q item or a Quality Class S item, it is handled 12 the same way in Bill Bingham's shop with Bechtel Engineering 13 as it is in APS. Now, we may do some things different 14 relative to vendor inspection because of the quality classifi 15 cation of that equipment, but the rest of it is handled the r 16 h
same.
17 Now, the item in particular of as-built drawings, 18 I am glad you brought that question up, because I have a 19 packet xight here of how we are studying to make sure that 20 the as-built drawings are going to actually depict the 21 condition, of. the plant and the plant is in fact built to the 22 drawing requirements. These happen to, be quality control records of how they had taken the drawing and gone through 24 and made sure that all the conditions on that drawing are
\
25 reflected in the plant. This one happens to be a>>el'tatus GRUMLEY REPORTERS Phoenix, Arizona
log. 'll the we1,ds on this isometric drawing, all the field 2 wells and all of the shop wells, are in fact in accordance with the drawing and it shows that the actual weld is in fact in accordance with the drawings requirement.
I can't say for certain that we will always be that way, but we sure are making an attempt to be correct. Maybe I might use our record for inspection by NRC as additional proof that we have in fact done that. If I can remember the numbers correctly, this year we have been inspected 10 approximately every four weeks, and that amounts to -- I am having to guess, because NRC is"two reports behind -- I would 12 say on the order of 650 manhours of actual NRC inspection at 13 the site verifying that we are in conformance with the drawing 14 and specifications. We have, and I might be one off, three 15 infractions and one deviation. In addition to that, we have one resident inspector and his reports indicate to me now 17 that he has spent over 600 manhours of actual out in the fiel I(
18 inspection, and of the results of that, we have had one 19 infraction and no deviations, which I think, considering that 20 we have thr'ee units under construction at the same time, is 21 a fairly decent record.
22 MR. ALLEN: John, did you have a question7 MR. BARROW: I just wanted to add something specificall 24 in talking about Item 2 of that question, which was how can yo 25" be sure after you go into operation that you are not going to GRUMLEY REPORTERS Phoenix, Arizona
violate the environmental qualification by installing Class I U
equipment in high radiation areas or in areas where there is a violation of the temperature, the specific example of that one room that is 10 to the ninth rads and how can you be sure later you are not going to install anything in it. Well, 6 once you get into operation for any period of time, your 7 health physics department is going to keep you from installing anything in high radiation areas, because they are going to be so hot you couldn't have a crew in there long enough to 10 install stuff. As far as the temperature areas, that' different, but that room I don't think we have to worry about.
IL 12 MR. ALLEN: Are there additional questions? Norm.
13 MR. HOEFERT: I just want to mention that we will have 14 a modification control program at the plant which Operations 15 will follow to be sure that all the design requirements for 16 modifications are met to prevent overlooking this type of 17 thing.
18 DR. ROSZTOCZY: Could we have Table 2 up on the screen?
19 Under the normal/abnormal temperature column, there are two 20 numbers, 50 and 120. The question was asked what do they 21 mean, and I believe the answer given was that both the normal 22 and the abnormal fall within this range. Then the question 23 was asked what value did you use for aging, and the answer 24 given was that you used the 120, which would mean to me that 25 every single piece of equipment that is, going to be tested or GRUMLEY REPORTERS Phoenix, Arizona
197 has been tested was preaged to the temperature of 120 degrees for 40 years. Similarly when I go to the other zone. These are generator areas. Then it was preaged to 140 degrees for 40 years; for example, the table which was discussed. If that is the case, then you are certainly doing a conservative job. If you are making any exceptions to that, I don't know what exceptions you are making and I have no idea whether I
the exceptions you are making are acceptable. I would like to recommend that you include a separate column there and, 10 in addition to temperature, show aging right in there, the excess value that you use for aging. If there is a certain 12 reason for it, it has to be explained somewhere.
13 MR. BINGHAM: Dr. Rosztoczy, this is a criteria. table 14 and really isn't suitable for that information. The informa-15 tion is presented in the data summary, which we will show 16 you later on in our presentation, and in the check-off lists 17 that we have for each of the qualification requirements, so 18 I would suggest that you take a look at that information and if F
then there is still, some benefit to the suggestion of 20 modifying this table, we will take that under advisement at 21 that time.
22 DR. ROSZTOCZY: I am looking at this table, but these 23 are the tables which tell me that a certain part of the plant in a certain environmental zone, what are the conditions 25 that the equipment has to be. qualified for if it is installed GRUMLEY REPORTERS Phoenix, Arizona
e' 1 in that zone, and since we mentioned earlier that we have 2 counted up to 10 different environmental parameters, I cannot 3 conduct a program or I cannot write the specifications 4 without having the values for all 10 of them.. The slide 5 shown counts up to only 5 out of the 10, so, obviously, information is missing which has to be provided to every 7 equipment supplier or everyone who is performing tests for you in order to do his job.
9 MR. BINGHAM: Would you indicate the other five that 10 you have on your list, pleasef DR. ROSZTOCZY: Flooding, which, for example, in this 12 case it would give the flood level for the containment indica 13 that everything has to be located above the flood level; otherwise it has to be qualified for submersion. Dynamic, 15 seismic, dust, and aging.,
16 MR. BINGHAM: John, let's see if we can do something 17 this evening to clarify that particular issue. The informati 18 is available and I do understand Dr. Rosztoczy's point.
19 MR. ALLEN: Fine, we will take that into consideration 20 tonight and see if we can't report back tomorrow on it.
21 DR. ROSZTOCZY: If I go to the last column or the 22 temperature column which gives the time for the LOCA and the 23 main steam line break environmental profiles, it 'ends at 24 42 hours4.861111e-4 days <br />0.0117 hours <br />6.944444e-5 weeks <br />1.5981e-5 months <br />. What is the value beyond 42 hours4.861111e-4 days <br />0.0117 hours <br />6.944444e-5 weeks <br />1.5981e-5 months <br /> and what is the 25 time period that equipment has to be qualified for that you GRUMLEY REPORTERS Phoenix, Arizona
are using on the long term after a given accident like, for 2 example, certain pumps which you rely on even a year after 3 the accident? What time period do they have to be qualified 4 for and to what temperature?
MR. BINGHAM: We would like to leave this one open.
6 I believe we can respond to it tomorrow on this particular point.
MR. ALLEN: Why don't we take about a 15-minute break and go off the record here. Before everybody breaks up, I 10 would like to discuss what we are going to do tomorrow.
(Thereupon a brief recess was taken, after which 12 proceedings were resumed as follows: )
13 MR. ALLEN: We have investigated where we could hold a 14 meeting tomorrow and we want to'do the following things this 15 evening before we break, Number one, we want to finish any questions we may have on the environmental qualifications 17 side before we go into the seismic. Number two, I believe we 18 have a couple of answers to questions that we can clear up 19 before we break. Number three, before we break, I want to 20 indicate where we will be meeting tomorrow and what time we 21 will be meeting tomorrow. Our intention is to finish this 22 up and adjourn the meeting for today and then reconvene 23 tomorrow morning at 8:00, so we can continue on with the 24 questions and get that first part of it out of the way.
25 Go ahead.
GRUMLEY REPORTERS Phoenix, Arizona
P, V
DR. ROSZTOCZY: Ne were talking about Table 2. Could 2, we have that back? The third entry is relative humidity, and 3 under the design basis accident column, it just says steam/ai mixture. This is maybe the part where you should spell out 5 more specifically the dry atmosphere as opposed-to humid or any combination of them if it is required, which we discussed earlier. I think that should show up in this column.
The next entry is radiation. There is a normal/
9 abnormal part for radiation and then there is a design basis 10 accident radiation, and under the design basis accident, there is a statement that it includes 40 year integrated. Does this 12 mean that the number in the right-hand column includes the 13 number in the left-hand column plus whatever is the result of 14 the accident?
15 MR. CARSON: Yes.
DR. ROSZTOCZY: I will come back to this in connection 17 with another table. In the accident column, there is one 18 ,single number given. This environmental zone is the contain-b 19 ment building. Our expectation would be that in the contain-20 ment building radiationwise, there would be more than one 21 environmental zone. I mentioned eailier the stratification 22 observed in Three Mile Island indicating that the dust blowout 23 carried more activity up to the top..than somewhere else.
24 There could be an accumulation of activity in the sump. Some 25 equipment close to the sump would have a combination of GRUMLEY REPORTERS Phoenix, Arizona
t materials, one from the atmosphere of the containment and one from the sump, so that might be a different environmental zone. Then, finally, we discussed earlier the case when the radioactivity stays in the system as opposed to going out through the containment and being recirculated.- Any equipment close to those lines where it is being recirculated would .. ~
have a different environment or zone based on those. It is also,my expectation that some of these zones will have numbers significantly higher than the one presently shown in 10 the accident column and then they will have to be qualified at those higher values.
12 One more question on the radiation. What time 13 period was used to establish the radiation number in the 14 accident column? How much time after the accident?
15 MR. BINGHAM: Thirty days.
16 DR. ROSZTOCZY: How about equipment that has to operate 17 beyond 30 days?
18 MR. BINGHAM: Like 200?
19 DR. ROSZTOCZY: Well, one of my earlier questions was, 20 and you'will answer it tomorrow, what is the time period that 21 you used as your design criterion, if you wish, for equipment 22 that is needed on the long term. Whatever that number is, 23 that should show up in this radiation column, also.
MR. BINGHAM: We will respond to that tomorrow.
25 DR. ROSZTOCZY: In connection with the chemicals, there GRUMLEY REPORTERS Phoenix, Arizona
I~
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1 was a question earlier which asked you whether you considered firefighting equipment and you provided some answer to that.
Basically, the answer was that you considered it and there 4 was no need to include those as a chemical atmosphere. My 5 question is how do you document the decision? How do you document it in table form? For example, if I would pull out the fi3:e on the environmental tables like this one, would there be something in the fi1e,indicating that this other 9 chemical type of atmosphere was considered and the decision 10 was made that it is not needed for the following reasons, j
giving the reasons? Would I find such a document there?
12 MR. CARSON: Not at this moment.
13 MR. BINGHAM: I don't believe at this point.
14 DR. ROSZTOCZY: It would'be important to document 15 some of those decisions.
16 MR. BINGHAM: Let's note that comment.
17 MR. ALLEN: Terry, do you have that?
IP 18 MR. BARROW: He's getting the previous one.
19 MR. BINGHAM: This next question'was that it would 20 be important to document that we have considered other 21 chemical environments and have assured ourselves that the 22 qualification criteria are satisfactory.
MR. CARSON: Specifically, the firefighting :'chemicals.
24 DR. ROSZTOCZY: That theie was no need to include that 25 in the environment because the chemicals weren't the type GRUMLEY REPORTERS Phoenix, Arizona
203 1 which would have any effect.
Now could I have Table 4? Earlier, I asked on the radiation what is the difference between the first column and
,4 the second. If you look at the numbers in the first column, 5 they are not one number, there are about three numbers. On 6 the right-hand side column, there is only one number.
Obviously, if I follow the same principle that you described before, then that one number cannot cover all thre'e of these, 9 so something has to be done to this table to accomplish that.
10 MR. BINGHAM: We have to clarify that table. The doses that you see here are in small compartments that are 12 around the purifiers or the ion exchangers, so we will clarify 13 that.
14 DR. ROSZTOCZY: But those small compartments. exist 15 after the accident, also and they do have a dose rate, also, 16 so they probably should show up in the other column, also, 17 with the appropriate number. For example, a purifier might 18 accumulate a fair amount of radiation as a result of the 19 accident and if it needs to operate after the accident, then 20 the number would be a different number than present in the 21 left-hand side column.
22 MR. BINGHAM: That's correct.
23 MR. ALLEN: Terry, do you have that to clarify Table 4 24 regarding the dose rate?
25 .MR. QUAN: Yes, I do have it.
GRUMLEY REPORTERS Phoenix, Arizona
DR. ROSZTOCZY: Mr. Chairman, I am finished with my 2 questions.
MR. ALLEN: Are there further questions on this issue?-
I had one if no one else has any.
When we specify design values such as-temperature 104 degrees, for example, we qualify the equipment to that, but, as in any design, there is room for error. How do we go back after the plant is in operation and verify that we 9 are maybe not seeing 120 -degrees in there when we assumed it 10 would be 104?
MR. BINGHAM: I believe, John, that falls in the same 12 category as the question about continuous monitoring as a 13 benefit to extended qualified life and perhaps we should deal 14 with both those issues at that time.
15 MR. ALLEN: Norm has a question.
16 MR. HOEFERT: In line with your question, what do we 17 do if in plant operation we lose the heating and ventilating 18 system and exceed these numbers?
19 MR. BINGHAM: You will have to evaluate it, Norm, at 20 that time,to assure that there has been no significant 21 degradation, and probably that again would tie in with the 22 question of do you have the data to know what happens so that 23 you can analyze it.
24 MR. HOEFERT: Are we covered by redundant heating and 25 ventilating systems in all these areas?
ORUMLEY REPORTERS Phoenix, Arizona
0 205 MR. BINGHAM: Yes .
MR. ALLEN: Are there any further questions?
MR. BINGHAM: He had one clarification, John.
MR. CARSON: I would like to clarify a question that was asked by Mr. Kreutziger earlier as to what constituted the"harsh environment. If we could make reference again to Figure 13, harsh environments are the inside of the contain-ment building, the upper level of the main steam support structure, and the accessible areas of the auxiliary building 10 as shown, for instance, here in Table 4 for the auxiliary building and the accessible areas. The only thing that would, 12 change is the radiation dose in the containment building, 13 and in the MSSS the parameters were indicated in the tables and showed the difference between normal/abnormal and the 15 design basis event parameters. Those are the harsh environ-16 mental areas.
17 MR. ROSZTOCZY: Could I ask a clarifying question 18 there? You described which part of the plant falls into the 19 harsh environment. If you use a definition for the harsh 20 environment saying that those parts of the plant which are 21 directly affected by the accident environment, meaning steam, 22 humidity, pressure, temperature, radiation, those contain the 23 harsh environment, is the description that, you just gave 24 consistent with that definition?
25 'MR. CARSON: Yes, because the environment changes GRUMLEY REPORTERS Phoenix, Arizona
A 206 due to the design basis event in those areas, as indicated in the tables.
DR. ROSZTOCZY: And the design basis means not only the loss-of-coolant accidents, but it also includes high energy line breaks like feed line and steam line breaks?
MR. CARSON: Yes.
MR. ALLEN: Any further clarifications?
MR. BINGHAM: One thing I want to make sure, John, you didn't mention it earlier, is that we have a review of the 10 open items from today.
MR. ALLEN: I intend to do that before we break.
12 MR. BINGHAM: That completes this part of our presenta-13 tion.
14 ALLEN: I guess, if the board agrees, we could 15 close that last item out off the open item list regarding the definition of harsh environments.
17 Before we go any further, I guess. this would be a 18 good time to go over the list of open items so we can try to 19 resolve as many as possible tonight and report on the resolu-tion of them tomorrow, so I would like to ask Terry Quan to
't 20 21 read off the open items and make sure they are properly 22 closed.
23 MR. QUAN: Open Item No. l was to correct Figure 8 to 24 show the submittal of CENPD-255 to be July, 1980. That was just a correction on those figures.
GRUMLEY REPORTERS Phoenix, Arizona
20 Open Item No. 2: Send to Dr. Rosztoczy a list of equipment to be qualified taking into account any necessary changes due to post-TMI concerns.
Open Item No. 3: Correct Figure 7 from Qualifica-tion "Test" Review to Qualification "Team" Review.
Open Item No. 4: IGE Bulletin 79'-ll be considered in the qualification of equipment. This bulletin dealt with as-built changes which may affect qualification, changes such as change in location or position.
'10 MR. BINGHAM: Excuse me,, John. I believe that was one that Mr. Noonan asked.
12 Is that question stated as you had intended?
13 MR. NOONAN: I guess I heard it from Arizona Power.
14 I don'0 think Bechtel had that.
15 MR. BINGHAM: But as he stated the open issue.
16 MR. NOONAN: The question, yes.
17 MR. QUAN: Open Item No. 5: Correct all slides which 18 state "in compliance" to more appropriate descriptive wording.
19 Use IIIB-13, Item 2, as a guide.
20 Open Item No. 6: Further clarify the PVNGS position 21 in Exhibit IIIB-7, which address General Design Criterion No.
22 4.
23 Open Item No. 7: Obtain through George Sliter the 24 Sandia qualification testing report dealing with testing 25 sequence effects and cumulative effects.
GRUMLEY REPORTERS Phoenix, Arizona
Y 208 Open Item No. 8: Also, this incorporates John' last concern on the environmental, monitoring. Investigate continuous environmental monitoring to determine if it should be implemented to ensure design qualification parameters were within reason and to supply historical environmental data on which extension of qualification may be based.
Open Item No. 9: In general terms, how would singl failure criterion apply for equipment qualification?
Illustrate this application through example such as a single 10 failure used to determine the chemical environment.
Open Item No. 10: Investigate how a possible 12 synergistic effect as outlined in NUREG 0588 will be considere 13 in equipment qualification programs.
14 Open Item No. 11: Review the possibility of 15 including the test sequence of high temperature accompanied by low humidity followed by high temperature accompanied by 17 high humidity in the equipment qualification procedures.
18 iOpen Item No. 12: How is vibration or dynamic fluid 19 flow from the event taken into consideration in the equipment I
20 qualification plans.
21 Open Item No. 13: How does dust in the environment 22 affect equipment, especially pump seals.
23 Open Item No. 14: 'n Exhibit IIIB-70, the third 24 bullet is to be considered to show intent to comply with the 25 one-hour requirement.
GRUMLEY REPORTERS Phoenix, Arizona
0
'l
209 MR. BINGHAM: Excuse me, John. I believe we responded 2 to that question.
MR. ALLEN: I think he closed that one out,'Terry.
MR. KOPCHINSKI: We were asked to correct the slide.
MR. ALLEN: Oh, that's right, correct the slide.
MR. QUAN: Open Item No. 15: Was proper cable degrad g
'I used for 140 degree environment.
MR. BARROW: Correction. That should be derated, I 9 think.
10 MR. ALLEN: Derated.
MR. CARSON: That was in regard to the diesel generato 12 building.
13 MR. ALLEN: I think that should be expanded on. I 14 think that was in general, too.. Didn't Karl say in general?
15 MR. KOPCHINSKI: It was expanded to include the 122 16 degree areas.
17 MR. QUAN: Open Item No. 16: Add environmental 18 designators submergence, dust, seismic, dynamic, and aging.
19 I have a question. Was that in reference to the 20 tables?
21 DR. ROSZTOCZY: Yes.
22 MR. QUAN: On these next few, I'e just got notes.
23 They are not quite complete.
t 24 MR. ALLEN: Why don't you go ahead on them and then 25 Gerry probably has some he can come up with.
GRUMLEY REPORTERS Phoenix, Arizona.
MR. QUAN: Open Item No. 17 was in reference to the table on containment environment designator. Investigate 3 LOCA temperature past 42 hours4.861111e-4 days <br />0.0117 hours <br />6.944444e-5 weeks <br />1.5981e-5 months <br />. Is that correct?
Open Item No. 18: Respond to time period assumed for equipment required post LOCA on which the LOCA radiation 6 disc us based, DR. ROSZTOCZY: That question is a little bit broader.
~ 8 It asked for the time period that was used for equipment 9 qualification following an accident. It includes other 10 'arameters like temperature, also.
MR. QUAN: Open Item No. '19: Verify documentation that 12 other chemical environments have been considered, specifically 13 fire protection chemicals.
14 Open Item No. 20: Clarify the radiation dose rate 15 in Table 4.
16 Gerry, do you have any others?
17 MR.'OPCHINSKI: The only other one I have is the 18 question of stratification. I am not sure if that was asked 19 twice or on<<.
20 MR. QUAN: I have that one.
21 MR. ALLEN: Vince, do you have an additional one?
22 MR. NOONAN: Yes. Xt is really not an open item, but 23 a reminder that sometime.'tomorrow when you start talking 24 about your equipment qualification and the environmental and 25 seismic, I want to include a discussion on relays.
GRUMLEY REPORTERS Phoenix, Arizona
0 211 MR. QUAN: To clarify that last open item, 21 was to investigate the effect of temperature stratification in the 3 containment environmental designator per NUREG 0588.
MR.'EITH: It wasn't really radiation stratification, 5 was it?
MR. CARSON: . Temperature, also.
MR. QUAN: Gerry, were there any others?
,MR. KOPCHINSKI: No.
DR. ROSZTOCZY: I h'ave two more items. One of them 10 I identified later, but it didn't show up in the list. I 11 asked for the treatment of dust'relative to environmental 12 qualification.
13 MR. CARSON: Dr. Rosztoczy, that is No. 13.
DR. ROSZTOCZY: Oh, I'm sorry. The other one I believe 15 we didn't identify as an open item, but I think it would be 16 appropriat'e to identify it as an open item. It related to 17 the radiation source term. Questions were asked and the 18 answer was that, based on some discussion that. we had, you Ii 19 are looking at radiation source terms whether they have been 20 evaluated consistently with the approach that in an accident, 21 everything goes into the environment or it stays in the 22 recirculation system.
MR. BINGHAM: That's right.
24 DR. ROSZTOCZY: You said that one is presently ongoing.
25 I think it would be appropriate to put it on the open item GRUMLEY REPORTERS Phoenix, Arizona
F 212 ll list.
MR. QUAN: Could you repeat that?
DR. ROSZTOCZY: Yes, an evaluation of the radiation source terms in view of the two possible courses of the accident, one being that the radiation is released to the environment and the second possibility that it is retained in the recirculation system.
MR. ALLEN: Bill Quinn.
MR. QUINN: I would like to go back to Item 2. Could 10 Terry read that one again?
MR. QUAN: Item 2 was send .to Dr. Rosztoczy a list of 12 equipment to be qualified taking into account any necessary 13 changes due to post TMI concerns; 14 MR. QUINN: It seems to me that the open item should 15 be clarified slightly to review the particular table in 16 Appendix 3E'and, if there are any changes, to provide those changes. It would not seem necessary to provide something 18 that is already correct, since it is in the licensing I
19 document. It, of course, would have to be upgraded.
20 MR. ROGERS: Furthermore, 1 t ink that we slid that 21 that was to be submitted to'ha board, not )ust to Sultan, 22 for the board's review.
23 DR. ROSZTOCZY: It should definitely be submitted to 24 the board, and let me maybe further clarify what it is I am 25 looking for there. In our presently ongoing reviews, we are GRUMLEY REPORTERS Phoenix, Arizona
I f
l l'
ending up with two lists. One list is the safety-related systems list. This lists various systems that you depend on 3 for the treatment of the plant following certain accidents.
4 We have a second list that we call the displacement instrumen-tation list. ,This lists instrumentation that are needed for '
the operator to perform his action appropriately. All 7 equipment, every component in those systems listed in either 8 of those lists, has to be environmentally qualified. So I 9 am looking for these two lists or the combination of these two.
10 I will be very surprised if your FSAR's have a complete list ll of that nature.
12 MR. ALLEN: Was the latter list you are talking'bout 13 the SPDS system?
14 DR. ROSZTOCZY: The latter" list includes every instru-N 15 ment that you include in your emergency procedures and use 16 for operator action.
17 MR. ALLEN: I understand.
18 Are there any additional items or questions that 19 anyone would like to ask before we adjourn for the evening?
20 If not, our plans are to reconvene tomorrow morning at 8:00 21 in the Valley National Building in downtown Phoenix.
22 (Thereupon a brief off-the-record discussion ensued, 23 after which proceedings were resumed as follows: )
24 MR. ALLEN: Are there any questions regarding tomorrow?
25 If not, I will declare the meeting adjourned until 8:00 tomorrow morning.
GRUNILEY REPORTERS Phoenix, Arizona
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