ML18029A486
| ML18029A486 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry, Sequoyah, 05000000 |
| Issue date: | 04/05/1985 |
| From: | Thompson H Office of Nuclear Reactor Regulation |
| To: | Parris H TENNESSEE VALLEY AUTHORITY |
| References | |
| NUDOCS 8504230105 | |
| Download: ML18029A486 (41) | |
Text
April 5,,1985 Docket Nos.
50-259 50-260 50-296 50-327 50-328 Mr. Hugh G. Parris Manager of Power Tennessee Valley Authority 500A Chestnut Street, Tower II Chattanooga, Tennessee 37401
Dear Mr. Parris:
Re:
Browns Ferry Nuclear Plant, Units 1, 2, and 3
Sequoyah Nuclear Plant, Units 1 and 2
On April 2, 1985, the NRC staff briefed the Commissioners on the status of environmental qualification of equipment at'operating nuclear power plants.
A representative of your staff attended the meeting.
During the discussions, remarks were made relative 4o the Browns Ferry and Sequoyah Nuclear Plants, as indicated in the enclosed excerpts from the transcript.
We would appreciate any comments you may wish to provide regarding statements in the transcript.
Sincerely, Hugh L'fhglYlpGog jF~
Qriginai Slga~l 4Ã Hugh L. Thompson, Jr., Director Division of Licensing
Enclosure:
As stated cc w/enclosure:
See next page
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Mr. Hugh G. Parris Tennessee Valley Authority Browns Ferry Nuclear Plant, Units 1, 2 and 3
CC:
H. S. Sanger, Jr., Esquire General Counsel Tennessee Valley Authority 400 Commerce Avenue E 11B 330 Knoxville, Tennessee 37902 Mr. Ron Rogers Tennessee Valley Authority 400 Chestnut Street, Tower II Chattanooga, Tennessee 37401 Mr. Charles R. Christopher
- Chairman, Limestone County Commission Post Office Box 188
- Athens, Alabama 35611 Ira L. Meyers, M.D.
State Health Officer State Department of Public Health State Office Building Montgomery, Alabama 36130 Mr. H. N. Cul ver 249A HBD 400 Commerce Avenue Tennessee Valley Authority Knoxville, Tennessee 37902 J.
Nelson Grace Regional Administrator
.Region II Office U. -S. Nuclear Regulatory Commission 101 Marietta Street, Suite 3100 Atlanta, Georgia 30303 James A. Coffey Site Director, BFNP Tennessee Valley Authority Post Office Box 2000
- Decatur, Alabama 35602 Resident Inspector U. S. Nuclear Regulatory Commission Route 2, Box 311
- Athens, Alabama 35611 Mr. Donald L. Williams, Jr.
Tennessee Valley Authority 400 West Summit Hill Drive, W10885 Knoxville, Tennessee 37902 George Jones,
- Manager, BFNP Tennessee Valley Authority Post Office Box 2000
- Decatur, Alabama 35602 Mr. Oliver Havens U. S. Nuclear Reoulatory Commission Reactor Training Center Osborne Office Center, Suite 200 Chattanooga, Tennessee 37411
Hangmen/r&t UNXTED STATES OP AMERICA NUCLEAR REGULATORv CO"PrXSSION DISCUSSION OF ENVIRON!CENTAL 'QUALIFICATION OP ELECTRICAL EQUIPMENT STATUS O.
COMPLXANCE WITH RULE PUBLIC MEETING 10 Room 1130 1717 H Street, N.N.
Nash in+ton, D.C.
Tuesday, April 2, 1".85 12 The Commission met, pursuant to.notice, at 2:05 p.m.
13 COMMISSIONERS PRESENT:
14 15 lb NUNZXO PALLADINO, Chairman of the Commission THO.':~KS ROBERTS, Commissioner JA."DIES ASSELSTXNE, Commissioner FREDERICK BERNTHAL, Commissioner LANDO ZECH, Commissioner STAFF AND PRESENTERS SEATED AT COr"1r~ISSXON TABLE:
18 19 20 21 J,
HOvLE R.
LAGRANGE DE EISENHUT N.
DIRCKS R.
VOLLMER H.
THOMPSON M.
MALSCH 22 AUDIENCE SPEAKERS:
23 24 Ace.Federal Reporters, Inc 25 ZECH B.
OLMSTEAD
PROCEEDINGS CHAIRMAN PAILADXNO: Good afternoon, ladies and gentlemen.
Members of our NRR staff and other members of the NRC are with us today to discuss environmental qualification of electrical equipment important to safety in nuclear power plants.
Section 50.49 of the Code of Federal Regulations 10 12 13 14 15 17 requires that the schedule to go for final environmental qualification is to be in place on or before March 31, 1985.
This section also allows the Director of the Office of Nuclear Reactor Regulation to grant extensions to a date no later than November 30, 1985 if good cause is demonstrated.
Beyond November 30,
- 1985, the Commiss'ion iteslf may grant extensions in exceptional cases.
The object of today's meeting is for the staff to brief the Commission on the status of environmental qualificati I
to provide the basis on which recent extensions were granted 18 19 20 21 22 23 Ace Federal Reporters, Inc 25
- and, more importantly, to discuss whether the Commission can have confidence that all plants will be finished by November 30, 1985.
I would also like to explore with the staff, if time allows, various enforcement actions or alternatives such as integrated scheduling that should be considered for those plant which do not complete environmental qualification by November 30 of this year.
34 CHAIRMAN PALLADINO: Is the number 39 or 42?
MR.
LAGRANGE:
The number today is 42.
It was, as of March 15, 39.
MR. EISENHUT: It's 93 total plants because we went up to the OLs. It is 42 in the category without extensions
- beyond, and that literally transpired as we negotiated through the weekend.
MR.
LAGRANGE:
Right.
10 12 13 14 15 17 18 19 20 21 22 23 24 Ace Federal Reporters, Inc 25 MR. EISENHUT:
Some plants may decide to stay shut down now and will not start.
up the plant until they are in conformance.
COMMISSIONER ROBERTS:
How many would that number be'?
MR. EISENHUT:
- Well, some of the 42.
I don't know how many additional--
MR.
LAGRANGE:
Well, currently Brown's Ferry, two Brown's Ferry units will be staying down until they complete qualification.
COMMISSIONER ASSELSTINE:
Yes.
COMMISSIONER ROBERTS:
What time period are we talking about,
- days, months?
MR.
LAGRANGE:
Months.
COMMISSIONER ASSELSTINE:
Yes.'rown's Ferry is still into long outages, yes.
MR. EISENHUT:
Nell, but it's fair to say that as of meetings last week with their management, they have changed
35 their commitments and that's why later on it changes in slides.
COMMISSIONER ASSELSTINE:
Okay.
COMMISSIONER ROBERTS:
Was this issued, a pacing item for these plants, for Brown's Ferry, to restart?
MR.
EISENHUT:
Not as of March 31, but it will certainly extend the outages.
CHAIRMAN PALLADINO:
So, it will be a pacing item.
MR.
LAGRANGE:
They had plans COMMISSIONER ASSELSTINE:
I thought they had some 10 other concerns.
MR. EISENHUT:
Is environmental qualification the 12 13 14 15 17 18 gating item to the restart of Brown's Ferry unit today.
MR.
THOMPSON:
For Unit 1, I think it one of the major issues.
There were a number of issues that they took into consideration, work that they had to do in fire protection, equipment qualification, and just operating, gettin their hands around improving the operation of that facility.'nd as a management
- decision, they elected to
)9 20 focus their attention on getting that unit and that site up to the par which their management felt was appropriate.
So, 21 I think I would consider this probably "the" pacing unit on 22 Unit l.
23 CHAIR~N PALLADINO:
- Okay, why don't you go on, 24 Ace Federal Rtporterl, Inc 25 Darrell?
MR. EISENHUT:
Okay, the next line.
i t!
COMMISSIONER ASSELSTINE:
Okay.
MR.
EISENHUT:
But it's different equipment.
CgMMISSIONER ASSELSTINE:
All right.
39 MR.
THOMPSON-But I think the answer is, yes.
And it is Brown's Ferry l which withdrew there, and I think it' 6
Fort St. Vrain which I think we tried to clarify the status of 7
their request.
So, those are the two plants, I think, that 8
make the--
CHAIRMAN PALLADINO: Darrell, you didn't include 10 equipment that they felt was qualified in your list.
You said 11 those that were -- I forgot.
12 MR. EISENHUT:
Right.
You see, we'e got to 13
- remember, the: only thing we were responding to was where a
14 utility sought relief.
So, this list doesn't focus on the "qualified list" where they didn't come for relief.
COMMISSIONER ASSELSTINE:
But for the 42, there are 42 plants where they are not asking for relief.
They think 18 19 they are in compliance right now. with the rule.
MR. EISENHUT:
That is correct.
20 COMMISSIONER ASSELSTINE:
Good.
21 22 23 MR. EISENHUT:
Roughly half the plants COMMISSIONER ASSELSTINE:
So, it's half the plants.
MR. EISENHUT:
-- c3aim to have all of the equipment 24 Ace Federal Reporten, Inc 25 qualified as of this point in time.
COMMISSIONER ASSELSTINE:
Yes, okay.
50 categories, you made the list.
And then we went across filled in the pieces.
That's how we really came up with this.
- Bob, why don't you walk through category by category'HAIRMAN PALLADINO:
When you say, "extension pending,"'is that. extension pending with some date between now and November 30?
10 12 13 14 15 17 MR. EISENHUT:
No.
Again, it was as of March 15, if the plant had an extension pending or not.
CHAIRMAN PALLADINO:
Okay.
MR. EISENHUT:
And I guess the easiest for me to make the point is, if you look at Sequoyah at the bottom of the list, Sequoyah Unit l, at the time we made up the chart, they still even owed us their last submittal on environmental qualification.
There were only two plants at the time we made this up who owed us the submittal on environmental qualification, one was Fort St. Vrain and one was Sequoyah.
Sequoyah had 18 19 20 21 an extension for some pieces of equipment already, November 30, so they got an "x" there.
- Sequoyah, we determined for other pieces of equipment where they had come in, they had submitted their extension request after the deadline had passed.
So, the 22 got an "X" there.
And the way progress was going, at least 24 Ace.federal Reporters, Inc 25 there was a question in our mind whether or not they were going to have everything wrapped up by November 30.
So, they got an "X" there.
51 10 Now, I think you have to look at it in terms of its different equipment that they received the previous extension request on to November 30, and it's different equipment that they had filed a late request for equipment on.
So, you have a multiple "X" across the table.
Maybe l have made that totally unclear.
COMMISSIONER ASSELSTINE:
That's good.'OMMISSIONER BERNTHAL: I don't want to give the impression I got up on the wrong side of the bed this morning, but what in the world is going on down in my adopted State of Tennessee?
12 13 14 (Laughter)
COMMISSIONER ASSELSTINE:
That's an excellent questio And other places where TVA plants happen to be located.
15 16 17 18 19 (Laughter)
COMMISSIONER BERNTHAL: I mean, this is one of the biggest utilities in the world. It ought to be one of the most capable.
It' the only one, I might add, that the Federal government has a stake in and continues to appropriate 20 21 money for.
And here we have one of the biggest outliers, apparently, certainly with Brown's Ferry and apparently 22 Sequoyah.
23 Is there anv explanation?
24 Ace Federal Reporters, Inc 25 MR.
EISENHUT:
Nell, I think different people would have different perceptions of that.
(&at we did, to answer tha
52 very question
- was, we went down the list here and ended up last week calling the management of a number of these companies in.
We called in TVA, for example, Hugh Parris came up.
We went through the issues on Brown's Ferry-l, Brown's Ferry-3, and
- Sequoyah, and Hugh, would you care to characterize the feeling you got of what the problem is, sort of the general 12 13 15 16 18 19 20 21 22 23 feeling?
MR.
THOMPSON:
I think generally TVA recognizes that the performance of Brown's Ferry units in almost all areas is substandard and I guess that's earlier when we talked
- about, in view of the concerns that we expressed about this is one of the bases for their decision, management
- decision, to keep the Unit 1 shut down until they had a better control on that facility.
We have been -- I think there is some new management at, TVA who are focusing on the performance of all their facilities in a broad scope, and in fact they are taking actions to improve their overall performance.
This has been the subject of concern both by Region I and headquarters, both I6E and NRR, in this area.
To the extent that you have a fairly major problem at Brown's Ferry, I think it is one which they are taking some action on now.
MR. EISENHUT:
Well, let me address it broader--
Ace federal Reporters, Inc 25 oh, go ahead.
MR.
VOLLMER: I think one of the reasons, i you
53 are looking for that particular area, I think was perhaps recognition, a lack of recognition of the size of the job and 12 13 15 16 17 18 19 20 21 perhaps the-lack of getting outside assistance.
I think most of the people who'ave been into it up until recen ly had been home-grown guys within the utility that just took this on as another assignment and it got out of hand, I think.
They found themselves in a position w'sere they were far behind the rest of the lot.
COMMISSIONER ASSELSTINE:
I remember when I was down there not too long ago, I was told by the project manager, the NRC project manager, that there were something like 800-plus pieces of equipment for the three Brown's Ferry units where they have asked for extensions.
That is amazing, plus when you throw in Sequoyah as well.
There are a lot of smaller utilities that appear to have either done the job completely or narrowed it down to just a few components.
It is incredible that you would have that poor performance on something like this.
COMMISSIONER BERNTHAL:
Well, in fact, I'm not even clear on just exactly how bad it is here. I'e got two sets of information and I wanted to ask which is accurate.
22 COMMISSIONER ASSELSTINE:
How many items are there 23 for the TUA plants, can you give us--
24 Ace.Federal Reporters, Irtc.
25 COMMISSIONER BERNTHAL:
What do your parentheses mean here?
54 MR.
EISENHUT:
The parentheses mean the actual numbers of individual pieces of equipment.
COMMISSIONER ASSELSTINE:
Okay.
MR. EISENHUT:
And, granted, they vary a little bit, they get updated.
As of March 15, if you look at Slide C--
COMMISSIONER BERNTHAL:
Let's see, Darrell, without 7
getty,ng into the numbers so much, is it accurate to look at this and say that Brown's Ferry 1, 2 and 3, and Sequoyah-1 and 2 all have more than a hundred open items; or is that not 10 accurate?
MR. EISENHUT:
That, is correct, open pieces of equipment that have not been shown to be qualified, individual 13 pieces
~
And I think Commissioner Asselstine '
numbers are generally where we feel for Brown's Ferry it's over 200 items per plant, 200 pieces of equipment at each plant.
17 18 COMMISSIONER ROBERTS:
Of a population of what, 800?
MR. LAGRANGE:
Close to 1,500, that's correct.
MR. VOLLMER:
An item is like a limitor valve, and there may be ten of them.
So, the number of pieces is ten 20 per item.
The number of items for a particular plant may range from 100 to 150, and the number of total pieces
- what, 1,200 to 15,00.
23 24 Ace Federol Reporters, Inc 25 MR. EISENHUT:
Right.
MR.
LAGRANGE:
About 1,475 for these plants.
COMMISSIONER ASSELSTINE:
But there really are only a
55 10 12 13 14 15 handful of plants where vou get into the hundreds of items MR.
EISENHUT:
That is correct.
COMMISSIONER ASSELSTINE:
-- hundreds of items of equipment.
CHAIRMAN PALLADINO:
On Slide C you show a number of items and you give a number like 90, and then you put in parentheses 362; what does that mean?
MR. VOLLKZR:
The item is like a limitor valve; the item, and there may be ten of them.
That's why the number of items is the smaller number than the number of pieces in the parentheses is bigger.
COMMISSIONER ASSELSTINE:
Or like cable, rock-bestos cable could be one item, and there could be lots of cables.
MR. EISENHUT: It's down another notch, though, it is not just limitor valves.
It is limitor valves model number.
17 COMMISSIONER ASSELSTINE:
Okay.
18 19 20 21 22 MR. EISENHUT:
So, you had to go one step.
It's a
little more complicated.
But I think it is fair to say that the TVA plants, most of them, had a very large number.
I also, in answer to the Commissioner's
- question, we are doing something a little broader also on the TVA plants.
23 24 Ace Federal Reporters, Inc 25
~
We have been doing somewhat of an audit of how they do busines I
down in TVA.
We have had some management down there last week.
We are going to be looking at a number of areas that
56 have come up, not relating and not originating from the EQ area.
But we have a number of other concerns where we are lookinq at, one of which has a spin-off from environmental qualification.
COMMISSIONER ASSELSTINE:
All right.
10 12 13 14 16 17 18 MR.
EISENHUT:
But we are taking a hard look at a
number of other issues, management
- issues, responsiveness, effectiveness at TVA.
MR.
THOMPSON:
We look at the EQ as one symptom maybe COMMISSIONER ASSELSTINE:
And there are other
- symptoms, yes.
COMMISSIONER BERNTHAL:
Well, I have to say that is troublesome because the Tennesee Valley Authori'ty was meant to be the leader in these
- areas, the test bed for advanced technologies in many things.
I see no other utility, in fact, where all of their plants are just falling far short of the mark in this particular area.
MR. EISENHUT:
I think that is the same message 19 that we tried to give to TVA's management last week.
As 20 21 22 23 24 Ace Federal Reporters, Inc 25 Hugh said, I think they agree with that.
Seeing them move on to do better things, of'course, is the test.
They have agreed on Brown's Ferry-l, in fact, since we made this slide, they withdrew their extension request on Brown's Ferry-1 and agreed that the plant will stay shut down until it's fixed.
That's plant we were talking about before.
\\
57 7
10 12 13 14 15 17 18 19 20 21 22 23 24 Ace federal Reporters, Inc.
25 As of right now, today, in fact, all three Brown's Ferry units are shut down.
Unite l and 2 are in long duration outgages.
Unit 3 is having the problem with level indicators, and that may go on for some time.
We have now granted relief on Brown's Ferry-3 for a set of equipment up to November 30 -- largely because there is also the phasing consideration of the three plants.
If we ask them to shut down Brown's Ferry-3 today for EQ, they really could not do anything to it.
They don't have the equipment.
They just could not phase from one unit to the other, to the other.
It would be in fact the fall of this year before they would get to Unit 3.
- Secondly, the utility had submitted a'justification for continued operation.
So, there may be a window of time if Brown's Ferry-3 wishes to restart, let's say, in the
- summer, the next couple of months, it would operate for some period of time until November 30.
So, those are the types of discussions we had on a
number of these plants.
But, I think it was a very difficult
- decision, obviously, for TVA to agree to keep a.plant shut down for a number of months to solve this issue.
MR.
THOMPSON:
But I should say that their management made that decision, it was not at our request that thev shut
'I down. It was one, I think, which indicates an improvement, think, in their readiness to step up and face the issues
58 associated with the Brown's Ferry.
I have been encouraged 2
by the new management that they have down there.
They 3
recognize the problem and I think that is the first step.
They have taken some difficult steps that normally 5
people do not do.
COMMISSIONER ASSELSTINE:
Yes, I have to say when 7
I was down there, the impression I had that the new people 8
they had brought in for the site at least least were saying 9
the right things.
10 MR.
THOMPSON:
Right.
COMMISSIONER ASSELSTINE:
- Now, some of the events 12 that have happened since then trouble me a bit, about whether 13 that message has really gotten across.
I get the impression 14 that it wasn't just EQ that led to the decision on Unit 3
]5 to take a hard look at what needs to be done in terms of their ability to operate that plant, that there are some other factor as well.
18 MR.
THOMPSON:
Right.
19 COMMISSIONER BERNTHAL:
Is there an undrlying problem 20 because they well, perhaps reflect Federal bureaucracy 21 in their internal structure, but certainly are tied to the Federal pay scale in that they may be unable now to compete 23 with the private sector in recruiting and retaining employees?
24 Ace FederoI Reporters, Inc MR. DIRCKS:
I thought they had lost a considerable 25 number of people.
Their turn-over--
59 COMMISSIONER ASSELSTINE:
They have, yes.
MR.
DIRCKS:
Like everything, though, I think you 10 12 13 14 15 17 18 19 20 21 22 23 see it in phases.
You see the management focusing its attention and it always takes a while now for to cascade down into the operational end.
And from everything I have heard, it is more in the operational end of it than on the management end.
The management now has dedicated itself to doing something about it.
But it always takes time to get backed down into the operations, and that involves training, and motivation, and all the other management techniques and leadership techniques that management wants to apply.
Now, I gather they have had discussions, too, with INPO to get some help down there.
So, they are reaching out to correct the problem.
But I am sure it is going to take some time to do it.
COMMISSIONER BERNTHAL:
But isn't it true that five, or six, or seven years ago they were considered -- they were one of the leaders in fact; or is that not a--
MR.
THOMPSON:
I won't say -.-with respect to the Sequoyah plant and some of the leadership effoxts they took in the training area to get simulators there, I certainly consider that to be some of the leadership activities that Ace FederoI Reporters, Inc 25 they demonstrated in that period of time.
I will say that Brown's Ferry has been less of an
60 10 12 13 14 15 operational performer, it, was a big plant, big demonstration 1
and leadership in trying to put three units on one site and operate it in North Alabama.
COMMISSIONER ASSELSTINE: It is the biggest plant in the country.
MR.
THOMPSON:
Correct.
But I am not sure that their leadership aspects went to Brown's Ferry.
COMMISSIONER ASSELSTINE:
I do get the sense--
CHAIRMN PALLADINO:
We are getting a little bit off the subject.
I think we ought to--
COMMISSIONER ASSELSTINE:
Actually, maybe we should.
CHAIRMAN PALLADINO:
Yes, I think we should.
Let me ask a question,
- Bob, on Slide 4.
Are there any of these plants that you would now emect not to meet the November 30 deadline?
MR. EISENHUT:
I guess the most difficult one on 17 here--
18 CHAIRMAN PALLADINO:
Would the Brown's Ferry be included in it?
20 21 22 23 24 Ace Federal Reparten, Inc 25 MR. EISENHUT:
Brown's Ferry would be, the staff has reservations; the utility has clearly made a commitment.
All of these plants have made a commitment now to meet November 30.
CHAIRMAN PALLADINO:
Well, I am not all that sure of that because the commitments are accompanied by a statement, "We
61 foresake our ability to request an extension in November."
So, I am trying to get an assessment.
MR.
EISENHUT:
Well, I was going to go on and qualify the answer.
CHAIR<>N PALLADINO:
Oh, I 'm sorry.
I i
7 10 12 13 14 15 16 MR. EISENHUT:
Because they officially have committed to November 30.
Let me give you a simple example, though, that relates to Oyster Creek.
Oyster Creek came in with a request that said, "We fully and well plan to make November 30 the best we can.
However, it may well stretch on to April 1986.
n This is the plan, of course, we ran into on Friday where, I think it was the staff 's legal opinion'hat the Director of NRR does not have the authoiity to grant relief past November 30 unless the utility has clearly given us a
firm commitment that that is in fact. his drop-dead date.
17 We negotiated extensively. on Oyster Creek, for 18 19 20 21 22 23 24 Ace Federal Reporters, Inc 25 example.
It goes without saying, the utility certainly has the opportunity and option to come back in to the Commission later.
But we had considerable dialog and Oyster Creek gave us their firm commitment that they do plan at this time, their target is to move to have everything qualified by November 30, period, in a straight, flat commitment.
MR.
THOMPSON:
Or shut down and stay shut down.
MR. EISENHUT:
Or shut down as they saw it at this
80 COMMISSIONER ASSELSTINE:
In mid-83?
MR.
LAGRANGE: April of '84, actually.
10 12 13 14 MR. VOLLMER:
There was one that had just started up after March of '83 -- or just had a shutdown after March of '82 So, the second refueling outage, it was surprisingly close to '83.
MR.
LAGRANGE:
Yes, I think that was Cooper.
But I think that on this list here of five plants with late
- requests, one of the earliest Seauoyah-l submittals came in a couple days after they were granted the extension on other pieces of equipment, and there have been about four or five since.
That was April of '84.
MR. VOLLMER:
But this is one as far'as enforcement action is concerned, this is one avenue of non-compliance and I don't expect it will be better defined what there might be after November 30.
17 COMMISSIONER ASSELSTINE:
Yes.
18 19 20 21 22 23 MR. VOLLMER:
But the other avenue is one that has already been talked about, and that's where compliance was thought to have been achieved and we find problems after-wards.
One is when the NRC could find the problems; when the licensee could find it by avenues of data becoming available or something like that.
24 Ace-Federal Reporters, Inc 25 In the interim between now and November 30, there is one posture we could take.
If they haven't had a good
justification for continued operation, there could be somehow a process of extension granted if the Commission wishes.
10 12 13 14 15 17 18 19 20 22 23 Ace FederoI Reporters, Inc 25 After November 30, when the EQ rule sort of drops dead, if the licensee finds a piece of equipment not qualified it is likely he would have to declare if that system is covered by the tech specs, declare that system inoperable and then go the tech spec route.
And this is a different situation in which, for example, if he declared the system inoperable because of unqualified equipment, he may have a week in which to take action to do something, or shut down.
CHAIRMAN PALLADINO: Let me make the following suggestion:
Normally, enforcement actions start with the staff And I say, why not let it start there?
You know the circumstances and you may decide that something -- that it was an acceptable situation and you don't want enforcement.
Otherwise, we are liable to put out some general principles that don't cover the cases.
And I am getting to the point where you are talking about 1,500 items or there-abouts, 98 percent inay be an acceptable situation and you might want to, after thinking about it, make some recommendation.
MR. VOLLMER:
The letter that is coming out, we could include enforcement in that package i you wish, suggestions.
MR. EISENHUT:
I think it sort of has to because I want to make it clear, there are at least four of these plant
82 10 there was a request for relief for March 31, or from the date they had, and the staff has not taken action on four of plants -- has not taken action on any of those plants.
Kewaunee is now shut down.
But there are four plants which submitted the request and the staff took no action.
CHAIR~N PALLADINO:
Did Kewaunee shut down for this. reason or some other reason'?
MR.
LAGRANGE: I think it was a refueling--
MR. EISENHUT:
-- compliance at that point in time.
But there are four plants who submitted justifications for 12 operation which we those shortly, and have not yet reviewed.
We will be reviewing they have requested relief on the extension 13 14 15 16 17 18 19 20 21 22 23 24 Are.federal Reporters, Inc 25 date and the staff took no action.
So, one of the things we would put in the package is a proposal on how the staff should treat those.
CHAIRMAN PALLADINO:
Yes, I think it would be well for the Raff to look at enforcement and decide wh'.= ought to be done.
If it needs help at a particular point, then come to the Commis s ion.
COMMISSIONER BERNTHAL:
Let me just give a thought here for what it's worth. It seems to me that the objective I'm sure we all agree is to get compliance and get this stuff finished up.
Ultimately, the weapon that the Commission has to force compliance is to shut down a plant.
I think that is probably not the most desirable solution from anyone'
83 10 12 14 15 standpoint.
But what we ought to try and do, it seems to mer is say now, early, as soon as possible exactly what enforcement steps the Commission intends to carry out, let's say, at the end of next November.
Make it very clear what the cost--
and I may mean literally as well as figuratively -- to the utility will be in enforcement so that people can plan and prepare for that.
I certainly will not favor at the last minute coming in and making decisions on exactly what the penalty is going to be, We ought to give them fair notice now, six, eight months in advance, on that, it seems to me.
CHAIRMAN PALLADINO:
This was the thrust of my opening comment on this.
MR. DIRCKS:
We can maybe prepare something and demonstrate enforcement policy on this.
We can handle it.
CHAIRMAN PALLADINO: All right, let me ask how 17 much more--
18 19 20 21 MR. DIRCKS:
I think we are almost finished.
MR. EISENHUT:
I was going to suggest we are finished.
(Laughter)
MR.
EISENHUT:
I think we have amply, at least from 22 23 our standpoint, aired the points that we thought were appropriate to bring up.
24 Ace-Federal Reporters, Inc 25 CHAIRMAN PALLADINO: All right.
Well, in the process I think I got a better feel for the situation.
I
84 covered most of the questions.
I did write one that I guess I have implied the answer to, and maybe I ought to ask you.
Do these plants, particularly plants in Slide 4, really have programs leading to compliance with the November 30 date'?
Is it a truly good-faith effort on the part of each one of these?
10 12 13 14 15 16 17 18 19 20 21 22 23 24 Ace.Fecterol Reporsers, Inc 25 MR. EISENHUT:
Well, I don't think we have gone out and actually looked at the program to have the confidence that they are going to make November 30.
Based on what we have
- seen, though, on most plants as we have discussed, I think the utilities are making reasonable efforts.
One thing we may well want to look at, and we are focusing on this, the plants on Slide 4, is look in greater depth at just that.
In fact, I think it's fair to say that during all the discussions last week one of the considerations
-.I had was, if I could have, I would have granted 60 days relief, granted everyone a 60-day extension on here and I would have gone out and tried to do a little more depth on what I think you are suggesting, Mr. Chairman.
But I think it was also felt that the staff did not have that authority to grant the 60-day relief and then come back and regrant more later.
CHAIRMAN PALLADINO:
What I was trying to establish is whether their programs, as far as you can tell, really are reigned at meeting a particular deadline.
85 10 12 13 14 15 MR. EISENHUT:
I think it is something we will have to look at, on those'particular plants.
MR.
THOMPSON:
I think the answer is, certainly, for the majority of them, they are.
I think. there are one or two plants in which I think the staff's original evaluation included a statement that their progress to date was kind of not what we expected and we would oppose any further extension of the deadline, even if they came to the Commission.
I.think there are maybe two plants in that category as I remember.
But those particular plants indicated a
commitment to shut down and stay shut down.
I anticipate that is what they would do.
I mean, that's based on their statement COMMISSIONER ASSELSTINE:
Which were those two'R.
THOMPSON:
The only one I know for sure is Brown's Ferry-3.
Bob, there may have been another one.
MR. LAGRANGE: I think Brunswick.
17 (Simultaneous conversation.)
18 19 20 21 22 MR. EISENHUT:
The original one was Brunswick, which occurred over a year ago.
We told them at the time we didn' see any basis to go beyond November 30 and we would oppose it.
Of course, to amplify on what Hugh said, of course there is the clause that under exceptional circumstances the 23 regulations permit them to come forth and do that.
24 Ace FederoI Reporters, Inc 25 CHAIRS'PALLADINO: Well, shutdown is not always the necessary enforcement action.
86 10 12 13 14 15 16 17 18 19 20 21 22 23 24 Ace.federal Reporters, Inc 25
'MR.
EZSENHUT:
I agree.
COMMISSIONER ASSELSTINE:
Yes.
MR.
THOMPSON:
But if you are asking where we thought they were,'
guess those were the two programs that maybe are the outliers.
COMMISSIONER ASSELSTINE:
You know, a substantial and escalating penalty every day that this goes on beyond a
certain point in time where they are not in compliance, is something that also could be an effective tool, quite apart from whatever we decide about the continued operation of a plant.
CHAIRMAN PALLADINO: Just a sizeable chunk per day may--
COMMISSIONER ASSELSTINE
- Yes, and have it go up every day, the longer it goes on.
CHAIRMAN PALLADZNO:
Well, I think these are some of the questions we ought to give thought to.
All right, are there other points that we ought to cover this afternoon?
COMMISSIONER ASSELSTINE:
I had one other area of questions, and that had to do with the justifications for continued operation.
When I heard about the Oyster Creek situation, I asked you all to send us copies of the Oyster Creek JCOs.
I looked through those and had a few questions on them.
One of them is sort of an overall question about how thi
UNITED STATES NUCLEAR REGULATORY COMf"I SS ION COf'lYiISS I ON MEETI NG APRIL 2, 1985 ELECTRICAL EQUIPMENT ENVI RONMENTAL QUALIFICATION PROGRAM STATUS
SLIDE 2 OVERVIEW o
LOflG HISTORY TO THE Ef'VIRORlNENTAL QUALIFICATION (EQ)
ISSUE BULLETINS AND INFGRYiATION NOTICES TECHf'ICAL REVI E1,'S EQ RULE 10 CFR 5O,49, ISSUED o
PLANTS TO DISCUSS:
92
~).. rT.
3',((,~".l (ir
/ lg
".c. (<
NRC EVALUATION COf'iPLETED:
73 PLANTS NRC EVALUATION CONPLETED EXCEPT FOR yq<
PRESSURE/TEYIPERATURE PROFILES l 9 PLANTS g prie.
STILL UNDER REVIEW:
10 PLANTS
( INCLUDES ONE PLANT h'ITH PROFILE STILL UNDER REVIEW)
)
Z o
GENERIC LETTER 84-24 (COYiPLI ANCE CERTIFI CATIONS) g p)-)g)( '.<
o INSPECTION OF If',PLEYiENTATION 7. y~. I/.
SLIDE 3 STATUS SUt'INARY o
TOTAL f'IUYBER OF OPERATING REACTORS:
92 PLANTS WITHOUT EXTENSIOf'S BEYOND f,ARCH 31, 1985:
(SEE SLIDE A)
. PLANTS GRANTED EXTENSIONS UP TO tllOVEhBER 30, 1985:
22 (SEE SLIDE B)
PLANTS PITH PENDING EXTENSIONS UP TO AfiD BEYOND NOVEt',BER 30'985:
28" (SEF SLIDE C)
PLANTS LICENSED WITH A NOVEY(BER 3Q.
1985 CONPLETION DEADLINE:
5
" Tk'0 PLANTS ARE INCLUDED Ih BOTH CATEGORIES NITH DIFFERENT EQUIPf'lENT It'! EACH
SLIDE 4 PLANTS WITH A LARGE NUMBER OF ITEMS AND COMPONENTS REMAINING TO BE QUALIFIED WHEN EXTENSIONS GRANTED/REAUESTED AND PLANTS k'ITH LATE EXTENSION"-RFt'UESTS PLANT EXTENS ION GPANTED TO 13./30/85 EXTEl<!S I ON PENDING LATE" FXTENS I ON CONCERN 1'1 ITH REQUEST MEETING 11/30/85 BRO~!res FERRY 1
BRowHs FERRY 3 BRur svlIcK 2 CALVERT CLIFFS 2
CooK 1
CooK 2 tOPT ST, YRAIN HATCH 1
ViEl'!AUNEE LASALLE 1 OYSTER CREEK PI LG RIM SEQUoYAH 1
X X
EXTEl'FUSION REQUEST SUBMITTED AFTER EXPIRATION OF Pl ANT SPECIFIC DEADLINE
" EXTEttS ION REQUEST EXPECTED FOR FORT ST, VRAIN
t SLIDE 5 IE EQ INSPECTION PROGRAN 1,
DEVELOP DRAFT INSPECTION YODULE (COl'PLETE) 2, PERFORl"i PILOT INSPECTIONS IE LEAD l<ITH NRR/REGIOf".AL OFFICE
( IN PROGRESS)
CALVERT CLIFFS 1
ZION 2 CRYSTAL RIVER. 3 OCT 15-19, 1984 JAN 14-18, 1985 YAR 4-Bi 1985 3,
EVALUATE RESULTS OF PILOT INSPECTIONS 4,
ISSUE INSPECTION NODULE FOR REGIONAL USE (HID 1985) 5, PROVIDE TECHNICAL ASSISTAf'ICE TO REGIONAL INSPECTIONS (1986) 6, CONTINUE INSPECTIONS AT VENDORS AND TEST FACILITIES 7.
ISSUE I NFORHATION NOTICES AS APPROPRIATE TO BRING IDENTIFIED DEFICIENCIES TO INDUSTRY ATTENTION
SLIDE 6 INSPECTION RESULTS 1,
NO SIGf",IFICAf'iT EQUIPf'ENT DEFICIENCIES IDENTIFIED VARYIflG DEGREES OF PROGRAM IYPLEMENTATION OBSERVED o
If'!PLEYiEf'TIl'lG PROCEDURES IN PLACE AND BEING USED AT SOME t LArtTS IMPLEY'ENTING PROCEDLiRES NOT COl'"PLETE OR INADEQUATE AT SOME PLANTS TYPICAL DEFICIENCY F I ttDINGS 0
EQUIPMENT QUALIFICATION FILES DEF I CI ENT/INCOYiPLETE o
EQUIPYiENT MAINTEt'ANCE/SURVEILLANCE PPOCEDURES NOT IN PLACE OR INCOMPLETE o
INSTALLED CONFIGURATION OF EQUIPMENT DIFFERENT.
F ROYi THAT USED TO ESTABLISH QUALIFICATION o
REPLACEMiENT EQUIPf~iENT NOT FULLY UPGRADED IN ACCORDANCE WITH 10 CFR 50,49
SLIDE 7 CONCLUSIONS o
ALf".OST HALF OF THE OPERATING PLANTS ARE SCHEDULED TO COMPLETE QUALIFICATION BY MARCH 31'985 o
ALf'iOST ALL REYAINIf'.G PLAf!TS ARE SCHEDULED TO COMPLETE QUALIFICATION BY NOVEYBER 30'985 o
STAFF REVIEl'S FOCUSING ON PLANTS WITH LARGE NUYBER OF ITEMS AND COMPONENTS REMAINING TO BE QUALIFIED AND PLANTS lfITH LATE EXTENSION REQUESTS RECENT MANAGEMENT MEETINGS
SLIDE A
STATUS OF EXTEt'iSIONS TO 10 CFR 50.LI9(G)
PLANTS I'!JTHOUT EXTENSIONS BEYOND MARCH 31, 1985 (AS OF MARCH 15r 1985)
PPKANSAS ARKANSAS 2 BRUNSWICK 1 BRowNs FERRY 2 CATAwBA 1 CRYSTAL RIVER 3 DAVIS-BESSE 1
DIABLO CANYON 1 DRESDEN 2 DUANE ARNOLD FARLEY 2 FITZPATRICK 6 I NiNA
'NDIAN POINT 2 KEWAUNEE LACROSSE LIMERICK 1 MAINE YANKEE McGuIRE 1
MCGUIRE 2 MILLSTONE 2 OCONEE 1
OCONEE 2 OCONEE 3
PRAIRIE ISLAND 1 QUAD CITIES 2 ROBINSON SALEM 1 SALEM 2 SAN ONOFRE 2
SAN ONOFRE 3 ST, LUCIE 1
ST, LucIE 2 SuMMER 1
SURRY 2 TURKEY POINT 3 TURKEY POINT LI YANKEE RowE ZION 1
SLIDE B PLANTS WITH EXTENSIONS FOR SELECTED EQUIPt,ENT GRANTED TO NOVEl'lBER 30, 1985" (AS OF NAPCH 15 1985)
NO.
OF ITEMS BEAVER VALLEY 1 BRUNSNICK 2 CALVEPT CLIFFS 1
(APRIL 30, 1985)
CALVERT CLIFFS," (APRIL 30.
1985)
COOK 1
COOK 2 DRESDEN 3
FARLEY 1 HATCH 1 HATCH 2 INDIAN POINT 3 NINE NILE POINT 1
PALISADES POINT BEACH 1
(JUNE 7i 1985)
POINT BEACH 2 (JUNE 7i 1985)
QUAD CITIES 1
SAN ONOFRE 1
SEQUOYAH 1
SEQUOYAH 2 TROJAN VERMONT YANKEE 2ION 2 UNLESS NOTED OTHEPh'ISE 2
45 (>318) 2 3
5 5
6 20 (188) 6 2
5 4
4 2
9 10 (166) 5 5
1
~ ~
~ <
~
P SLIDE C
PLANTS WITH EXTENSIONS FOR SELECTED EQUIPYiENT REQUESTED i
(
S OF iARCH BIG ROCK POINT BR01'fNS FERRY 1
BRONfiS FERRY 3 CALLANAY COOPER FORT CALHOUN FORT ST, VRAIN (REQUEST EXPECTED)
GPAND GULF 1
HADDAM NECK""
HATCH 2 LASALLE 1 LASALLE 2 f'lILLSTOt<E 1""
NONTICELLO NORTH ANh!A NORTH ANNA 2 OYSTER CREEK (APRIL'986)
PEACH BOTTOM 2 PEACH BOTTOM 3 P I LGR IM PRAIRIE ISLAND 2 RANCHO SECO SAN ONOFPE 1
SURRY 1
SUSQUEHANNA 1
SUSQUEHANNA 2 THREE f~iILE ISLAND 1
WNP-2 (APRIL 30 AND NOVEMBER 30p 1985)
NO.
OF ITEMS 90 (262) 83 (211) 1 1
UNKNONN 8
2 1
15 (179) 7 1
1I 1
Cn (21~)
1 5
100 (200) 2 1
2 1
6 8
UNLESS NOTED OTHERWISE
""POSSIBLE EXTENSION REQUEST TO BEYOND NOVENBER 30, 1985
>' 4 t W~
V
/