ML18032A379
| ML18032A379 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry, Sequoyah, 05000000 |
| Issue date: | 06/04/1987 |
| From: | NRC COMMISSION (OCM) |
| To: | |
| Shared Package | |
| ML18032A378 | List: |
| References | |
| NUDOCS 8706230028 | |
| Download: ML18032A379 (40) | |
Text
Q8tt"iML D STATES NUCLEAR REGULATORY CO SION IN THE MATTER OF:
DOCKET NO:
NRR MEETING
'I LOCATION: DECATUR, ALABAMA&,
PAGES:
1 24 DATE:
THURSDAYI JUNE 4
g 1987 4/~~+~" r~~V~~tw(~P~p4Q~ ~so~'+~~ 'y~q-t
~
8706230028 870612 PDR ADOCK 05000259 T
'ACE-FEDERAL REPORTERS, INC.
Offi'cialReporters 444 North Capitol Street Washington, D.C. 20001 (202) 347-3700 NATIONWlDECOVERAGE
4
RTH 'ALABAMA REPORTING SER ICE E
R T I F I C
A T E
STATE OF ALABAMA MORGAN COUNTY 10 12 13 I hereby certify that the above and foregoing deposition was taken down by me in stenotype and the questions and answers thereto were reduced to typewriting under my 'supervision; that the foregoing represents a true and correct transcript of the deposition given by said witness upon said hearing.
I further certify that I am neither of 14 15 16 counsel nor of kin to the parties to the action, nor am I in anywise interested in the result of said cause.
17 18 19 20 Tammy L. Hastings Commissioner 21 22 23 24 25 DECATUR'LABAMA (205) 350-2464
NOR ALABAMA REPORTING SERVICE BROWNS FERRY NUCLEAR POWER PLANT TENNESSEE VALLEY AUTHORITY RESTART CRITERIA The following matter came to be heard on the 4th day of June, 1987, at the Browns'erry Nuclear Power Plant Visitor Center Auditorium, Limestone
- County, Alabama, at or around 12:30 P.M.
before Tammy L. Hastings, Court Reporter, for the State of Alabama at Large.
- DECATUR, ALABAMA (205) 350-2464
I
NORTH ALABAMA REPORTING SERVICE P
R 0 C
E E
D MR. S.A. WHITE:
Let me start out by welcoming you to Browns'erry.
As you can tell, I'm not in the best of health.
Bear with me.
I would ask first whether Mr. Keppler has any opening 10 remarks or anything he would like to start out with before we introduce the various people.
12 13 14 15 16 17 18 MR. J.G.
KEPPLER:
No."--.I would I say it's nice to be back to Browns'erry.
I think I was here about 18, 19 years ago.
The plant was still under construction.
I had not seen it since and since discussions you and I have had that indicated that we may be considering putting this unit on the line after Sequoyah, I wanted to get 19 down here to see the site with some of my staff and 20 21 22 23 24 25 I'm looking forward to a briefing by TVA of what' to be done before the plant goes back into operation.
So, I look at this a little bit like the first meeting we had at Sequoyah, and I barely knew how to spell the word, and I think that it's time for me to do this at Browns'erry.
I guess we'e ur,<ATURg ALABAMA (205) 350-2464
TH ALABAMA REPORTING SE+v going want to try to clean up and get to the Restart Criteria.
MR. S.A.
WHITE:
That's part of the 6-general MR. J.G.
KEPPLER:
Proceed however you want to go.
10 12 13 MR. S.A.
WHITE:
Well, I thought it might be appropriate to -- if you would like to introduce your people and we'l introduce ours.
14 MR. J.G.
KEPPLER:
Why don't we just 15 16 go down the table.
17 MR. S.A.
WHITE:
Yeah, I think so 18 19 that's the best way.
20 21 22 23 24 25 Charles Patterson Al Ignatonis Gary Zech Stewart Ebneter J.
G. Keppler John Zwolinski DECATUR'LABAMA (205) 350-2464
N TH ALABAMA REPORTING SERV 7
9.
10 12 13 14 Gerry Gears John Stang Cordell Williams G. Paulk Bob Lewis Ronnie Young Paul Speidel John Walker Charlie Fox S.
A. White Chuck Mason R. L. Gridley Mike May Hugo Pomrehn 15 16 17 18 19 20 21 22 23 24 MR. S.A.
WHITE:
Again, Mr. 'Keppler, we welcome you and your team to Browns'erry.
Based on the very successful meetings we'e had at Sequoyah which were mentioned, at least from our perspective, these meetings are clearing the air of a lot of issues.
I think they were very productive and we hope that today will be as productive.
We are going to talk about two topics today:
The Restart Criteria, and secondly, to give 25 you an update on where we are at Browns'erry, Unit DECATUR'LABAMA (205) 350-2464
0 I'
RTH ALABAMA REPORTING SER CE Two.
First, to discuss the Restart Criteria, we have the manager of licensing from Sequoyah, Mike Harding.
~ ~
MR.
MIKE HARDING:
Thank you.
TVA has recognized the need and the importance to establish a consistent set of Restart Criteria.
Restart Criteria would be to evaluate potential problem 10 areas and to determine if the problem areas needed resolved prior to restart.
The criteria has been developed and established and it's being used both 12 13 at Sequoyah and Browns'erry to evaluate issues.
The Restart Criteria has also been docketed 14 15 16 17 18 19 20 21 22 23 24 25 in the Sequoyah and the Browns'erry nuclear performance plants.
The slide here is a
summary of the Restart Criteria.
Criterions one and two are aimed at technical specification system operability concerns both from a specific standpoint and a
programmatic perspective.
Criterion three and four were developed to address compliance with NRC regulations and commitments to the NRC and criterion five, I think it's worth pointing out, weren' developed and aren't aimed at specifically addressing issues required by NRC regulations, but there are additional areas that TVA feels are very DECATUR'LABAMA (205) 350-2464
RTH ALABAMA REPORTING SE CE important to us and we'e identified those.
Those criteria address primarily industrial safety
- concerns, as well as plant reliability issues.
10 12 13 14 Slide two, please.
This slide summarizes the key implementation aspects with respect to the Restart Criteria.
I won't read them go down and read
- them, but I think it's important to point out that the key elements assure a consistent and a
disciplined approach in determining what issues or corrective actions require resolution or completion prior to plant restart.
That's -- Thank you, that' all I have to indicate on the Restart Criteria.
Are there any questions?
15 16 MR. J.
G.
KEPPLER:
Don't go away.
17 Go back to your Restart Criteria.
18 19 20 21 22 23 24 Item number three.
TVA and its submittal to NRC made an interpretation that that did not need to include a deviation from the
- FSAR, and I guess I'd like to know, if that's the case, how many examples would pass that definition so that they could be exempted from having to meet that criteria.
Do you know where I'm coming from with that question?
25 DECATVRi ALABAMA (205) 350-2464
RTH ALABAMA REPORTING SER CE sir.
MR.
MIKE HARDING:
Yes, sir.
- Yes, MR..J.
G.
KEPPLER::
Okay.
10 MR. MIKE HARDING:
I think I'd like to start off first by saying that it's TVA's intention to meet all of its regulatory commitments and applicable requirements for restart.
Okay.
There are -- and if a FSAR deviation were to be 12 identified, that deviation would result in a
CAQR being prepared.
13 14 MR. J.
G.
KEPPLER::
What's that?
15 16 MR.
MIKE HARDING:
That's a Condition 17 18 19 20 21 22 Adverse to Quality Report.
And that is.our program where anything that -- any condition or event that would result in or is a condition adverse to quality, is -- results in a generation of a report.
That report would go through an evaluation to determine its safety significance.
It would go 23 24 25 through an evaluation to determine its operability, its reportability, and it would also be evaluated against the Restart Criteria itself specifically,
- DECATUR, ALABAMA (205) 350-2464
RTH ALABAMA REPORTING SER CE and we feel that that program and process would be sure to capture anything that would be required for restart that was a deviation from the FSAR.
I would also point out that anything that deviates from the FSAR would receive an unreviewed safety question evaluation, Tennessee FR-5059 evaluation, to be sure we evaluate it for safety impact on the plant.
10 MR. J.
G.
KEPPLER::
That let me draw two examples.
When you received your license 12 13 back -- and let's talk Sequoyah -- when you receive a license, the regulations permit you to make 14 15 16 17 changes to the FSAR consistent with the criteria of Tennessee FR-5059 and you have to go through certain things.
You'e got to make sure that's not an unreviewed safety question and you'e got to make sure that it's got the appropriate reviews and 20 21 22 23 24 what-have-you.
If today you found something not in compliance with the FSAR and it had been reviewed by that process, then I have no question about it, but I'm looking today at, are there examples as part of TVA's review that you find something today not in 25 compliance with the FSAR, but which did not go DECATUR'LABAMA (205) 350-2464
RTH ALABAMA REPORTING SER CE through a valid 5059 process, would you then put that to a 5059 process and say, therefore, we don' need to have it meet the criteria for restart or would you say,
'Hey, that wasn't reviewed properly.
We need to make sure that's taken care of prior to restart'2 Do you understand my question?
10 12 MR.
MIKE HARDING:
Yes, sir.
We would put it through the review process.
It would go through the process to evaluate it and see if it was required for restart.
If there were an item that were discovered that we felt did not. meet the 13 14 15 16 17 18 19 regulations, if it did not pass those tests, then that would be brought to the NRC, it would be reported to the
- NRC, and we would let you know either our intentions of correcting that problem for restart or we would tell you what we thought was appropriate for restart, but you would have the final say one way or the other.
20 21, MR. J.
G.
KEPPLER::
So it would be 22 23 your intention to bring that kind of matter to the 24 25 MR.
MIKE HARDING:
Yes, sir, yes, sir.
DECATUR'LABAMA (205) 350-2464
RTH ALABAMA REPORTING SER CE 10 And an example of that would be the interim acceptance criteria on the alternate analysis program.
That was an area where we declined--
where we realized some civil counts on Sequoyah didn't meet the full requirements and that was submitted to the staff, discussed with the staff and we got to the point where we could agree on what would be required for restart.
10 MR. J.
G.
KEPPLER::
Do you have any
'feel at this stage of the game of your reviews for 12 13 both Sequoyah and Browns'erry, how many fit that category?
14 15 16 17 18 MR.
MIKE HARDING:
I guess the only ones that I am personally aware of that would fit that category on Sequoyah would be the interim acceptance criteria.
19 20 MR. C.
C.
MASON:
On alternate 21 analysis 22 23 MR.
MIKE HARDING:
On an alternate 24 25 analysis and cable trace supports.
Those are the only ones that I am aware of right now and both of DECATUR'LABAMA (205) 350-2464
RTH ALABAMA REPORTING SER CE those were identified to the staff.
MR. J.
G.
KEPPLER:
So you are saying your review were the items that you'e separating out pre-restart versus post-restart.
You actually found very few of that type of category'R.
MIKE HARDING:
Very few of the 10 category that says we don't meet the requirements or regulations as defined in the FSAR.
That's right.
12 13 MR.
C.
C.
MASON:
Mike,...you are just speaking for Sequoyah.
I don't know if Brown's 14 Ferry 15 16 17 18 19 20 21 MR.
MICHAEL MAY:
My name is Michael May and I think we can make the same statement as Sequoyah in terms of numbers, the same area the size of this unit, calculations, those kinds of things, very few.
It's -- generally we have the same problem.
22 23 MR.
MIKE HARDING:
So, that's why 24 25 today we feel confident that'we've uncovered and identified those as it should be and for the future DECATUR'LABAMA (205) 350-2464
RTH ALABAMA REPORTING SE CE we believe that the CAQR process will definitely put -- identify them and get them out in the open and have them evaluated.
5 MR. J.
G.
KEPPLER:
Can I rephrase what they say?
Can I infer that the mammoth review of all the items for restart attest to the fact that TVA is in compliance with the FSAR?
10 12 MR.
MIKE HARDING:
I guess -- all of the programs that have
- been, being implemented do not specifically go back to all of the FSAR 13 requirements, but many of the important ones do.
14 15 16 17 18 19 20 21 22 23 24 25 For instance, the design baseline verification program and the engineering calculations program specifically went back and evaluated all our regulatory commitments, all our FSAR requirements, identified those, developed a criteria based on those and then evaluated the systems and the calculations against that criteria.
So in some of the very important items that has specifically been done.
Now some of the other programs may not have specifically went back and compared the FSAR to the
- programs, okay, but the mechanism was there that if something were identified and it was recognized to
- DECATUR, ALABAMA (205) 350-2464
N RTH ALABAMA REPORTING SER CE 13 be a deficiency against'the FSAR, that would have been brought out.
MR. J.
G.
KEPPLER::
I guess I'm a little bit confused.
We went through all of these safety systems as part of your review efforts.
You did all of those
- programs, design reviews and all these other programs that point them to potential 10 areas of concern.
I guess I'm -- I don't know what it is that causes you to hedge a little bit on that
- comment, that position.
You'e not wouldn't your 12 13 reviews by necessity compare the plant design
\\
intent, operability intent with its tech specs and everything else?
I don't understand the 15 16 17 18 20 21 22 23 24 25 MR.
MIKE HARDING:
Yes, it would.
I guess what I was trying to indicate was that a
specific programmatically defined comparison with the FSAR to what we were finding wasn' programmatically defined in all of the programs.
It was clearly part of the program for design based on verification and the calculations program and is part of the calculations program.
And that's where you would be looking at the design and the design basis of the safety systems and you would be DECATURi ALABAMA (205) 350-2464
N RTH ALABAMA REPORTING SER CE 14 verifying that those systems did meet,all of the FSAR and regulatory commitments and requirements.
That was the only the distinction I was making was that I know specifically in those
- programs, there was a it was part of the program to go back and pick up all of the FSAR and other commitments.
And the other programs -- I'm not saying that that evaluation wasn,'t
- done, but it wasn't clearly part of the program.
10 MR. J.
G.
KEPPLER:
With regard to 12 criteria one and two, the offer of potential for 13 lack of agreement between TVA and the staff because 14 15 19 20 21 23 of the words 'significant probability',
'high probability'nd those types of things can mean different things to different people.
I -- my staff has dreamed up their own criteria to check yours with, and I guess has done so without turning up any discrepancies, but I would say to you, why wouldn' you write those without those -- Why wouldn', you call number one, "Specific deficiency with probability of system inoperability as measured by technical specification requirements"'P 24 25 MR.
MIKE HARDING:
I think it DECATUR'LABAMA (205) 350-2464
RTH ALABAMA REPORTING SE CE 15 MR. J.
G.
KEPPLER::
You see, I have a
lot of people who help me with my decision-making process MR.
MIKE HARDING:
Yes, sir, and I think it would MR. J.
G.
KEPPLER::
And I have to 10 answer questions like this.
12 MR.
MIKE HARDING:
I think it could 13 14 have been written that way, but 15 MR. J.
G.
KEPPLER::
To me 16 17 18 19 MR.
MIKE HARDING:
To go back to your
- analyzer, we have tested our criteria and the way we'e implementing it with the analyzer that your 20 21 staff has developed, and we believe 'that the way 4
we'e commanding criteria and the way our people are 22 23 24 25 identifying items, that we are pretty much in line with that and even identifying items that the analyzer would not identify.
DECATUR'LABAMA (205) 350-2464
16 MR.
KEPPLER:
Well, and I understand that and I don't want to make a big point of it, but to me, when you use the words, "As measured by technical specification requirements",
that sort of replaces the word 'significant'ecause I assume, or like to assume there wouldn't be any tech specs if they weren't significant, you know, debate that a
f little bit, but is it your intent 10 12 MR. S.A.
WHITE:
There has to be let me try this -- There has to be some method to preclude any deficiency, no matter how 13 insignificant, from becoming insignificant 14 15 16 17 18 19 20 21 22 23 probability, I think is opposite of that, of deficiency, insignificant probability, which would then become a restart item.
There has to be some way, whether it's judgmental, it's a system set up with checks and balances, but there has to be some way in which you could screen out things that are truly insignificant and then check your system through its checks and balances to make sure that that is your problem and that's what we'e tried to do.
And I might add in a very conservative fashion.
24 25 MR. J.
G.
KEPPLER:
If it's in the DECATUR'LABAMA (205) 350-2464
EI ORTH ALABAMA REPORTING SE ICE tech specs, does it meet your definition of significant and high?
MR.
MIKE HARDING: If there was an item identified to create a deviation from the tech specs or there was a system or component in the tech specs which we identified a deficiency, specific C
deficiency, with that complement, absolutely it 10 would meet that criteria.
I think the important thing is that not only'do we identify things that 12 are inoperable or are deficiencies, but we'e identified things that even have the.~robability of 13 14 15 16 17 18 19 20 21 22 being a deficiency.
Okay.
So if there was something in the tech specs that a component or something in the tech specs which we specifically did not meet, clearly we meet that, but we'e even gone an extra step and identified something that just has the probability of not meeting it. It may, you know, we not even have identified a specific instance where it doesn't meet it; we have said,
- Hey, even if it has the probability, we are going to put it on as a Restart Criteria, so, we'e purely 23 gone beyond 24 25 MR. J.
G.
KEPPLER: If I were to write DECATUR'LABAMA (205) 350-2464
RTH ALABAMA REPORTING SER CE you a letter approving your Restart Criteria and took out the word 'significant'nd took out the word 'high', would that be contrary to what your intent is7 MR.
C.
C.
MASON:
Again, there will always be some measurable probability--
MR. J.
G.
KEPPLER:
I'm not trying to 10 be cute with the comments.
12 MR. S.A.
WHITE:
No, I understand I
13 just 14 15 16 17 MR. J.
G.
KEPPLER:
There are people who wonder what is the intent of those words and I'm trying to avoid a problem.
18 19 MR. C.
C.
MASON:
To reiterate what 20 21 22 23 24 25 Mike said, the origin of these first two criteria really grew out of a desire to treat it like an operating point.
If we were operating and found a
deficiency, we would evaluate that deficiency and if that deficiency caused the tech spec system to be unable to perform its intended functions, we would DECATUR g ALABAMA (205) 350-2464
RTH ALABAMA REPORTING SER CE take the action required to eliminate this problem and complaint, but you only do that once you determine that it actually made the system inoperable.
In other words,
.we put the significant and the high probability in the criteria because most of the things we are looking at require a lot of evaluation before we get to that point.
If we had said,
- okay, you only look at them if in fact they cause the system to be inoperable, we would end 10 up waiting until the very last to really get in and evaluate.
With 'significant'n there, we evaluate 12 13 14 15 16 17 18 19 20 21 22 them, identify they have a significant, probability, to evaluate them to see what falls out of them.
And that's conserative on our point, on our part.
If we took that totally out and just said 'probability',
anybody can argue that there is always'some probability, no matter how small the deficiency, there is some probability, it may be close to infinitely small, but that that would cause an LCO.
We feel like the 'significant'akes it conservative from our standpoint as far as considering it as an operating point.
23 24 MR. J.
G.
KEPPLER:
I think it doesn' 25 do that.
I think it makes it non-conservative in
- DECATUR, ALABAMA (205) 350-2464
4
('K
20 terms of what's going to be required for restart.
That's my problem.
MR. S.A.
WHITE:
Well, let me ask this.
If 10 MR. J.
G.
KEPPLER:
Maybe we'e making more out of it than what needs to be because my people tell me that how they would interpret it is consistent with what you are doing, but I guess the only point I'm making is that that, those need to be 12 13 interpreted conservatively.
14 MR. S.A.
WHITE:
And I believe that 15 16 the record will show that they are.
17 MR. J.
G.
KEPPLER:
Yeah.
18 19 MR. S.A.
WHITE:
And my comment is the 20 21 proof of the pudding is in the eating.
22 MR. J ~
G.
KEPPLER:
That's right.
23 24 25 MR. S.A. WHITE:
And if you audit this and look at it and don't find the hardened fact DECATUR'LABAMA (205) 350-2464
, ~
MR. J.
G.
KEPPLER::
That 's why I don't want to bitch about it.
MR. WHITE: If we'e not doing it
- properly, then we have to do something
- else, you know, with the checks and balances that we have built into this thing, I think we'e been very conservative.
10 12 13 MR.
JOHN ZWOLINSKI:
John Zwolinski.
Mike, what measures are in place to.insure uniform and consistent application of the criteria for TVA?
14 15 MR.
MIKE HARDING:
First of all< I 16 17 18 19 20 21 think it's important to recognize that the process is procedurized both at Sequoyah and Browns'erry.
The CAQR program, which I think is the real measure, the real program to insure that things are identified, evaluated and corrective actions identified, that is in place at both plants.
22 23 24 25 MR.
JOHN ZWOLINSKI:
So the roots of success is through the CAQR and how your staff utilizes the CAQR process and then the question is, I
DECATUR'LABAMA (205) 350 2464
'1
RTH ALABAMA REPORTING SER CE 22 is that process being implemented effectively?
MR.
MIKE HARDING:
Yes.
MR.
C.
C.
MASON:
Corporate process.
MR.
JOHN ZWOLINSKI:
Yes, sir.
And if I understand, on Sequoyah you feel that it may be overly conservative.
10 MR.
MIKE HARDING:
Right now we are 12, 13 being conservative.
14 MR. J.
G.
KEPPLER:
Are you using the 15 16 same thing for both of these projects?
17 MR. S.A.
WHITE:
Yes.
18 19 MR.
MIKE HARDING:
Uh-huh, it's a
20 corporate
- program, the CAQR program.
21 22 MR.
C.
C.
MASON:
And the Restart 23 Criteria are the same.
24 25 MR.
MIKE HARDING:
And the Restart DECATUR'LABAMA (205) 350-2464
k
~
RTH ALABAMA REPORTING SERW CE 23 Criteria are the same.
Thank you.
MR. J.
G. KEPPLER:'kay, all right.
MR.
MIKE HARDING:
Thank you.
MR. J.
G.
KEPPLER:
We'l go ahead and 10 I want to get the Restart Criteria approved on the table.
12 MR. S.A.
WHITE:
I do.too.
13 14 15 16 17 MR. J.
G.
KEPPLER:
So we'l do this, we'e going to tell you how we'e interpreting those things as part of our approval process so that there is 18 19 MR. S.A.
WHITE:
Consistency.
20 21 MR. J.
G.
KEPPLER: Right.
22 23 MR. WHITE:
That's fine.
Okay.
24 25 MR.
JOHN ZWOLINSKI:
Just as an DECATURi ALABAMA (205) 350-2464
4
. TH ALABAMA REPORTING SER 24 administrative matter, the first meeting was on Restart Criteria.
That meeting is over for transcribing purposes.
We!11 get on to the next meeting.
END OF PROCEEDINGS 10 12 13 15 16 18 19 20 21 22 23
- DECATUR, ALABAMA (205) 350-2464
0 4
n