ML19242B447
| ML19242B447 | |
| Person / Time | |
|---|---|
| Issue date: | 07/11/1979 |
| From: | Gilinsky V, Hendrie J, Kennedy R NRC COMMISSION (OCM) |
| To: | |
| References | |
| REF-10CFR9.7 NUDOCS 7908080536 | |
| Download: ML19242B447 (59) | |
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NATIONW1DE COVERAGE- 0 ALLY 7908080
1 CR5872 r-t DISCLADIER This is an uncfficial transcript of a meeting of the United S tates Nuclear Regulatory Cccmission held on Wednesday, 11 July 1979 in the Cc= missions 's of fices at 1717 H Street, N. W.,
Washington, D. C.
The meeting was open to public attendance and observation.
This transcript has not been reviewed, corrected, or edited, and it may contain inacccracies.
The transcript is intended solely for general informational purposes.
As provided by 10 CFR 9.103, it is not part of the formal or informal record of decision of the =atters discussed.
Expressions of opinion in this transcript do not necessarily reflect final determinations or beliefs.
No pleading or other paper may be filed with the Commission in any proceeding as the result of or addressed to any statement or ar tmenc contained herein, except as the Ccemission may authorize.
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UNITED STATES OF AMERICA CR5872 2;
NUCLEAR REGULATORY COMMISSION l
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PUBLIC MEETING f
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DISCUSSION OF UCS PETITION ON QUALIFIC TION OF l
6' ELECTRICAL EQUIPMENT AND RESPONSES TO IE BULLETIN 79-01 f
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8, Room 1130 9-1717 H Street, N. W.
Washington, D.
C.
10 '
Wednesday, 11 July 1979 11 The Cc= mission met, pursuant to notice, at 1:30 p.m.
12' PRESENT:
i 13 DR. JOSEPH M. EENDRIE, Chairman 14 i
i VICTOR GILINSKY, Commissioner 15 RICHARD T. KE:iNEDY, Commissioner 16 i PETER A. 3RADFORD, Commissioner 17' JOHN ?. AhWE, Cc=missioners 18 ALSO PRESENT:
19 Messrs.
Jordan, Butcher, Hoyle, Stello, Lieberman, 20 Snyder, Moseley, Gossick, Denton, Eisenhut, and Mcore.
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COMMISSIONER GILINSKY:
The Chairman has asked me I
3, to proceed. He is travailable. He should ccme in in the course i
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1 5
Mr. Kennedy, I understand, also asked that we 6;
proceed and he expects also to be coming in soon.
l 7f So, why don' t you go on with the briefing that you 8
have prepared.
9 MR. GOSSICK: Fine.
10 l I have asked Victor to introduce the speakers.
II '
MR. STELLO:
Okay.
12 :
The purpose of the briefing this af ternoon is to I3 crovide the Cc= mission with the status of the review of the
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Id l qualification of electrical equipment, specifically with i
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respect to the responses to I&E Bulletin 79-01.
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16 l Review is still ongoing. Therefore, the nature of l*
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the presentation today will be status report. It will be l
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18 concentrating on the two aspects of the bulletin; one which required a 24-hour report of any deviations, where there was 20 I not -- unqualified equipment identified, as well as a ccmprehen-t 21 sive review of all electrical equipment.
22 Ed Jordan and Ed Butcher will be doing the briefing.;
23 Ed?
'4 MR. JC RDAN :
Okay.
aa w aeoonm. inc.
25 May I have the first slide, please.
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(Slide)
'~r-2i The purpose of the bulletin, 79-01, which was 3i iacued in February 1979, was to cause Licensees to identify T
i I
4j all electrical equipment which may be subjected to the r
5 accident environment, and then review the qualification of i
6; each associated ccmponent and to verify that the required l
7!
safety related equipment will function if called upon.
8i The Licensees were requested by this bulletin to i
9' review the documentation against +
"SAR sccion environment, a
10 1 and against the FSAR ccmmi tment for qualiMication.
I 11 WHere documentation was not avai.able, Licensees 12 l were to perform analyses or tests to verify thatqualification 13 i was indeed existent.
14 !
The Bulletin was issued subsequent to Regional l
15 Cifice followup on the Circular 78-08, which was issued in i
16 !
May of 1978.
The Circular required essentially the same thing 17 but did not require responses 'rcm the Licensees and didn't l
18
- give the timeframe.
19 COMMISSIONER GILINSKY:
Is that the difference 20 between a Circular and a Bulletin?
21 MR. JC RDAN :
Primarily, yes.
22 The Bulletin notifies the Licensees --
23,
MR. JORDAN: Yes.
24 It requests the Licensees to perhaps perform a a E m a.oon.n.inc.
25 re.iew, but doesn't require the Licensees to advise che
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- i mm3 1l Commission of the results of that review, and it doesn't I
2 normally specify timeframe.
3 CCMMISSIONER AHEARNE:
Is it fair to say then that l
em 4!
it is a distinction of how important you daink it is?
l 5
MR. JORDAN: True. That's right.
6!
COMMISSIONER AHFR TE: Then what led to the conclusie rt 7l that what happened between May and February -- to reach the i
8; conclusion --
9 MR. JORDAN: Okay.
The inspectors were follcwing to up on the Licenseed action with regard to the Circular, and 11 they found unqualified limit switches on the safety systems 12 inside contain=ent existed in addition to those thct had been t
13 :
previously identified in another Sulletin.
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They also found chat in some casts Licensees were i
15 '
unable to provide documentation to indicate that certain 26 '
components were qualified such as transmitters, electrical t
17 l cablas, motor in ulation, cable splices and whatnot, so that 18 thing were not progressing as rapidly as we thought they should.
19 '
- dell, that was une basis --
i i
20 COMMISSICNER GILINSKY: Could you tell me why we l
21 went cut with a Circular in the first place, because this 22 l followed our learning that in fact there had been unqualified 23,
equipment on reacters, didn't in?
24 MR. JCROAN:
I believe that the thinking was that we a
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25 had several bulletins that had hit specif.
issues, like limit
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switches or components,and that a Circular which described --
nm4 2l requested the Licensees to examine the whole system, would f_
3 suffice, and then our inspection program would followup on 4!
the Ci :=ular.
5 So I think it is simply that we have matured somewhat 6:
in the way we approach this.
7j COMMISSIONER BRADFORD: Well, wasn't the maturity i
8; helped by the fact that the response rate to the circular wasn' t 9
all that good?
10 '
MR. JORDAN:
That's correct.
r II '
COMAISSIONER AHEARNE:
But I thought that you didn't, 12 '
have to have a response to a Circular.
I3 !
MR. JORDAN: Response meaning what the Licensees I
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did, not a written response.
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15 COMMISSIONER BRADFORD:
Let's see.
So that not 16 only did they not give you written responses, but they also didn't I7 do enough?
i I3 MR. JORDAN:
That's correct.
And they were doing i
I9 it at different rates.
Since we didn't specify the rate, then 20 Licensee X was taking it to heart and doing it fast, and 21 Licansee Y was taking his time.
Okay.
The objectives of the Bulletin.
23 Next slide.
- 4 (Slide) ac. e Recomn. inc.
ac We discussed it.
They were to expedite the
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Licensee review of the electrical equipment qualification.
2 And now they require reporting on the part of the Licensee.
g-3 First of all, it caused them to promptly evaluate i
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4, and report identification of unqualified equipment within I
5 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of that identification, followed by written --
6 COMMISSIONER GILINSKY:
Let me ask -- how do these 7;
Bulletins differ frcm previous Bulletins?
8 Were the previous ones specific with regard to certain 9;
kinds of equipment?
10,
MR. JORDAN: Yes, we had two previous qualification-Il type Bulletins that were specific to like limit switches, a 12 '
particular type of limit switch, a particular component.
13 ;
And now this Bulletin we are saying, look at all g.
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14 of your ccaponents that are required to function in an f
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'S accident environment and establish that they do have 16 qualifications.
l'7 So it was much, at h broader.
18 l MR. SNYDER:
Is it fair to say, Ed, that the j
19 timing on the circular new of May 31st -- in fact it does 20 quote very strongly from the Co= mission's decision of April 6
21 13th, you know a couple of weeks before, a' month before in 22 which it reflected that there was still an unsatisf actory 23; pattern ongring.
24 MR. JORDAN: Yes.
Ack m<as Reporters, Inc, 25 MR. SNYDER:
A broader kind of thing rather than
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specific and you quoted very heavily from the Commission's 1
I g-2 order in the Circular and the Bulletin which followed up on, 3'
j ust basically repeating the Circular, I think.
4; MR. JORDAN :
That's correct.
l 5
Okay.
So the Licensees were then required to 6
include in this 24-hour, 14-day report, an evaluation of a
7; the.4.: basis for continued operation if they chose to continue is' operating with components they identified as unqualified.
9; Ed Butcher will describe in a little more detail 10 later on the :esults of those reviews. Some 31 plants identified i
11 !
and reported on unqualified equipment as a r2sult of that 12 particular chase of the Bullt :in.
And this was distributed 13 '
in time over the time from issuance of the Bulletin in February,
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14 l until the recent past.
I 15 COMMISSIONER I.HEARNE: The qualifications that you 16,
are holding them to are what?
17l MR. JOREAN: The qualifications are the FSAR l
18,
requirements, the discussion in the FSAR about the accident i
19 environment.
20 COMMISSIONER AHEARNE: They don't refer specificallyl 21 then to any IEEE standard?
22 MR. JO RDAN:
The later plants would, but the older 23 plants would net.
24 COMMISSICNER AHE.3NE: And the later plants would ama.i Recomes inc.
25 end up referring to which then?
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MR. JORDAN :
To the 1974 --
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2l MR. STELLO:
'71.
The later operating plants in
'71,
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3l MR.JO RDAN :
Okay.
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COMMISSIONER AHEARNE: And none of them really i
5' referred to '74, for exa=ple.
6' MR. TELLO:
No.
7!
COMMISSIONER BRADFORD: What would typical language 1
8; be in the FSAR of a plant that was not committing itself to 9'
1971 standards, but was just making a more general commitment?
i 10 MR. JORDAN: Well there would be a statement in the 11 FSAR as to the accident environment itself, the temperature in 12 the containment.
For instance we go to general radiation 13 i levels.
s._
14 COMMISSIONER BRADFORD: So that might actually be more specific than would be involved s.mply in a commitment i
16,
to meet the '71 standard?
l' [
MR. JO RDAN:
That would be plant specific and have 7
18 less detail than the IEEE standa rd.
19 COMMISSIONER BRADFORD: What kind of detail does l
20 the IEEE standard have?
l 21 MR. JORDAN :
I will let Ed answer that.
22 MR. BUTC'iER: I think the question is, what would i
22 be in the FSAR for a plant that was not ccmmitted to the 24
'71 version of the standard.
Ac> eae a.coners. Inc.
25 And what would be there would be a specificatien i-
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2l of tnat temperature, pressure, radiation --
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3 COMMISSIONER BRADFORD: Tbit sounds more specific n
4 in fact than just the IEEE standard as of 1971.
5 MR. BUTCHER:
In those plants that did reference 6:
the standard as a basis for licensing, that information would 7i also be there.
The LOCA environment would have to be specified 3
in either case.
9i In the case of those planto that reference the standard, 10 i there woulu be a further statement that would say the equipment 11 would be qualified tofunction in this environment in accordance 12 with the provisions of the '71 version IEEE standard 323.
13 !
In the case of plants previous tc the standards, 14 ;j what it would say would be qualified to function in this 15 environment, without specifically specifying a standard.
16 i MR. JORDAN:
The next thing that the Bulletin 17 ;
required was a report in 120 days of the Bulletin on the i
18,
documentation of the determination of qualifications of the 19 ccmponents, all of the components that are subjected to an 20 accident environment.
And these responses were due Jum 15th.
21 The final objective of the Bulletin was to feed back 22 generic issues of unqualified equipment to all _icensees, 23 and we issued a revision to this Bulletin on June 4, whic1.
24 fed back to Licensees the specifi' problems with A5CC solenoid sa
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25 valves in which internal ccmponents had been found not to be
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environmentally qua.j #ied for radiation or temperature i
2l resistance at certain plants.
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3 And so, because these valves were rather widely 1
used, we provided this additional information tc Licensees
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j that perhaps scmehow had not become aware of this.
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.I fust happen to hav e a couple of the components 7
in my pocket.
81 Vince, if you would switch to the backup slide --
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CR 5872 Mimi 42 i
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This is the back-up side on the ASCO valves.
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2 MR. JO RDAN :
Okay, the circle ccmponents, the 3'
disc holder and pins are what I have.
And, for instance, em for that paIbEcular valve, they have an acetal ccmponent l
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' hat's in many of the valves and are not qualified, and those l
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were replaced with a metal component that then causes that i
7, valve to be environmentally qualified.
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So
- hose are *he two components that when exchanged i 9
makes the difference for t:
valve being environmental or i
10 not environmentally qualified.
11 COMMISSICNER AHEARNE:
When you went on the 12 6-4 supplemental, did you adj ust the reporting date of 6-15?
13,
MR. JORDAN :
Yes.
We did not change the reporting l
l 1
l 14 '
date, so we are bringing this material to the licensee's i
15 attention.
16,
We also identified in it a problem -- pos sibly 17 ;
a problem with preventive maintenance with regard to aging 18 the compcnents.
19,
The coil that's up in the box to the right, if 20 energized according to the manuf acturer, has a life of some 21 four years, so we're going to bring it to the licensee's Sc 22,
attention that these should be replaced periodically.
23 So I think one could say that that might 24 constitute a success story for that ccmpenent in that we have saa.e.cw a.coners. inc.
25 had no failures traced to that particular maintenance l l.'
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I; or to that environmental situation, and we were able, through
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i the bulletin, to identify by the licensee identifying to us, I
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3 and then we transritted to all the licensees.
i May I have the next slide.
Slide 3, please.
i 5
[51ide. ]
l 6'
The responsibility for action on the bulletin 7'
responses agreed upon within the NRC Staf f, so that I&E I
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performs the tasks on the left, and NRR w.'
the right, and we f
9 have, of course, a number of interf aces going through this 10 thing.
i 11 I&E performs the screening of the 120-day 12 repo rts.
NRR reviews the 24-hour, 14-day --
13 :
i COMMISSIONER GILINSKY:
What are the conditions i
1s l l
t for the 24-hour report?
15 MR. JO RDAN :
That the licensee identifies unqualified 16 '
compenents and that he is then reporting in accordance with 17 tech spec.
la We brought this particular reporting requirement 19 to his attention --
20 CCMMISSIGNER GILINSKY:
And NRR decides on the 21 level of seriousness, the safety significance --
2
MR. JO RD AN :
That's right.
'3
- k COMMISSICNER GILINSKY:
-- of that report.
I 24 MR. JCADAN:
Yes.
Ace-eewis asoor en. inc.
ec COMMISSICNER GILINSKY:
And that is reported on the e
7
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120-day basis?
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MR. JORDAN:
120-day basis, the licensee is i
3!
reporting the sum total of his review, that is all of the es l
4 :i components required to be qualified, the level they qualify, 5
and on what basis they qualified.
i I
COMMISSIONER AHEARNE:
Are you going to discuss I
'0 l
l 7f what kind of 24-hour reports were received?
l l
0 MR. JORDAN:
Yes.
Ed will discuss those.
So l
9; I&E screens the 120-day reports.
We are in the process of I
I 10 !
I doing that now.
We will initiate action on the deficient I
i repo rts.
That is those that are incomplete, ha7e other 12 '
I problems with them.
On that basis we would consider l
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enforcament action, if we find enforcement problems with the t
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14 '
licensee, then we would sdbsequently conduct what we are j
i l ~e calling an interim review.
i 16 This will be comparine the qualifications to the 17 '
criteria that exist in the FSAR at this particular time.
18 Then we would be conducting a final review based en guide-19 lines that NRR will develop.
20 COMMISSICNER AHEARNE:
The NUREG that you mentioned 21 the re, you mean it wo '.d be menticned in the NCREG?
22 MR. JORDAN:
Yes, this is what we anticipate as
'3 being the publishing of the results of the interim review.
24 So, in addition to feeding back to the licensees, we would ao e.rm Recomn, inc.
2~5 publish a NUREG stating what the results were.
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MR. SNYDER:
Is that for each licensee?
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2 MR.. JORD AN :
No.
3l MR. SNYDER:
It's across the board en the subject?
i i
i 4l MR. JO RDAN :
Yes.
5 COMMISSICNER GILINSKY:
Now is the failure to i
6; have qualified equipment a vio',ation of the license of j
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7l regulation or ccmmitment?
t i
3 MR. JORDAN:
Generally it's a failure to meet a 9;
commitment, to meet the FSAR requirement.
10 ;
COMMISSIONER GILINSKY:
And how do w e regard that?
11 MR. JCRDAN:
If you recall, in the Cook instance, 12 ;
that was a material fault statement that was identified, and 13 1 i
so that was the enforcement action taken on that pa rticular i
14 'i issue.
I 15 There may be instances where the f ailure to have a 16 qualified ccmponent is somewhat innocent -- maybe that's 17 the wrcng term to use, but it was inadvertent in the process,
I8 and we become smarter over a period of time.
19 CCMMISSICNER BRADFORD:
I gather that there's 20 a much more specific than I thought cammitment in the FSAR 21 fat all these plants that you have equ. ; ment qualified to a 27 clearly specified environment; is that r ght?
i 23 MR. JC RD AN :
I think it's perha;_- more implied
- 4 sc.-_ne Reconm. inc.
than specific, because the criteria require that the plant oc
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be able to sustain an accident, and the FSAR describes the l
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accident requirement, so you j ust have to put those two t
2 i
together and ast ;me all of the compenents required to i
3 function should meet that criteria.
t COMMISSIONER AHEARNE:
Are there explicit state-t 5'
ments that lay that en as a requirement?
I follcw the I
0 implication --
l 7
MR. JORDAN:
In some FSARS, there are.
I wo uldn ' t j
3' say that's the case of all.
Let me just refer to Ed.
i 9
MR. SUICHER:
I think the types of equipment 10 you find in the FSARs run the full spectrum.
The sense of 11 the commitment would be the component -- a compenent will be 12 '
i supplied that's capable of functioning in an accident i
/.
13.
requirement.
That commitment could be implied or implicitly i
f u
i stated.
15 i
One way to imply it would be for the licensee to 16 say that the plant is designed in conformance with general II ;
design criteria called a specific one, and certainly that 18 would be an implied commitment to provide a qualified 19 ccmponent.
20 COMMISSIGNER AHEARNE:
But you are saying that 21 there is no standard ccmmitment required that all components 22 in the plant shall be qualified to function in the environment 23 as specified in such-and-such?
24 MR. 3 CTCHER:
I'll let Vic address that.
He aa+.=== n eomn. w.
m" I certainly has had more experience with FSARs than I have, but I
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I I would say
_1 many cases I have seen such implicit -- or l
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x 2
specific ccmmitments and others I have not, depending ucon i
3' the age of the plant, the time of licensing, and the l
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1 licensing process that existed at that time.
I 4'
i 5'
MR. STELLO :
I think it's very dif ficult to try to 6
ek describe in a sentcr.ce, or a paragraph, something that 7I will cover all of the applications.
Some cases have l
application because of the questions and answers, you arc 8
t 9
(Inaudible. )
l dealing with a very specific component 10 '
l CCMMISSICNER ASEARNE:
Would you use your microphone 4 11 please.
i 1
MR. STELLO:
A very specific ccmponent, where that j
l 13 i i
i particular compenent, test conditions for it are identified 14 in quite a bit of detail.
In some cases even the test i
l 15 procedures are part of the operation, and in some cases 16 test reports.
17 So it covers a large spectrum of conditiens.
18 When they try to get it all inclusive, all ccmponents for 19 all conditions, I think there it has described it as best as 20 it can be.
It covers a fairly complete spectrum.
Up until 21 the time you get into the standard.
Well, the standard was 2
available 3-23, 1971, for the equipment that was necessary
'3 for equipment there to meet that particular standard.
24 e.eEc a.cer.m. inc.
And there the equi ment, I think f airiv -- vou had a s
25 blanke t statement to cover all safety equipment with one 5,s l i ' 's s
i io
--s o
28 I
ar7 l
i i
Il standard, but prior to the standard it really is a large l
i variety of ways that it's described.
f 2
i 3
c COMMISSICNER AHEARNE:
But after the standard --
I i'
MR. STELLO:
After the standard it's ccmprehensive 5l and inclusive.
i 6
COMMISSICNER BRADFORD:
Except any vagaries in the I
7l standard itself would then be reflected in ecmmitments to f
0 meet it.
MR. STELLO:
That's true, to the extent they 10 exist they clearly are there, yes.
11 CCMMISSIONER BRADFORD:
And the standrrd itself had 12 ;enough problems with it that it was replaced within three R
13 i
years.
14 !
MR. STELLO:
It clearly was replaced in three i
15 years.
I'm not going to sit here and argre how much of an 16 '!
improvement at the matter, but there cle.rly are some new 17 :
things that were added.
S cme o f the large st issues that la we' re faced with in the reviews was the concept of aging, and 19 that was a new concept introduced for the first time in the 20
'74 standards.
21 COMMISSICNER 3RADFORD :
The '71 standard came into 22 l being and fairly qulckly became referenced in Licensee cc=mitments 23 frc= ' 71 cn. The ' 74 standard was in place for five years,
'4 which was icnger than the ' 71 standard was ever in clace,
erederst Re0Crt9f1, Inc.
2~5 yet we still don ' t have any operating plants tha~ -a#a-ance fQ i.
s n.) :
0!
19 l
ar8 l
l I,
the ' 74 standard; is that right?
l 2l MR. STELLO:
The '74 standard was adopted for 3
reviews that were in the constructio.: ce rmit process.
l 4
MR. DENTON:
I think it might be useful to have a j
5 member et that standards committee, who is here today, Mr. Ross,
6 Moore describe what led to the development of the '74 7
standard and some of tae reasons, perhaps, why it has not l
i 3
found full adoption to date.
I i
I 9
MR. MOORE :
I'm not sure I can remember wi'k 10 great specificity what happened in those days, but i
11 certainly the 1971 standard was -- the IEEE undertook that 12 '
at the old AEC regulatory group's request because we found I3 i
just such a variety of qualification methods.
Right after I
the '71 came out, there was several issues that it didn't l
I#
I3 very well address, and one was aging, *nd that is being 1
16 able to run a qualificatien test on a piece of equipment, but I7 -
simulates a 40-year old piece of equipment.
I3 Well, '74 went into that.
That is still a very difficult problem.
20 CCMMISSICNER AHEARNE:
Went into it to the extent 21 of requiring it -- not saying how it was going to be done?
'2 MR. MCORE :
That's correct.
And there was a lot
'3 of opposition to including that in this standard when
'd nobody really knew how to do accelerated aging tests on Aa-,www R eornn, tm.
'S everything.
But our feeling was that the best way to get
'l li
,s a u. c a
20 I
ar9 l
Il progress made was to put it i., the standards so that pecple
~~
i 2l would have to start working en it, and I think that the l
3 results have shewn that to be true.
I e-i l
4i i
As I remember one of the other differences 5
between '71 and '74, I believe it clarified a little bit more i
6 the extent to which you could rely on analysis -- or a 7
stronger requirement for testing versus analysis.
i I
l
- ibic Those are, I believe, the typical areas between the l 3
l two, ' 74 still -- certainly we would like to see more 9
I.
i 10 l
specificity than is in there new, and I knew that what 's i
11 we're working on in Staff to get more specific, and margins i
to account for a variation of the units off the assembly k
I3 line, conditions -- the adequacy of the sinulation of the t.
14 accident environment, so that there was a requirement for 15 margin.
16 '
COMMISSICNER AHEARNE:
I don't understand what you 17 '
mean by =argins.
18 MR. MCORE:
Oh, I'm sorry.
It's a requirement 19 that you test out a temperature higher than you expect in 20 the accident environment pressure or for a longer period than 31 '
you expect the device to have to operate.
'2 MR. SNYOER:
Does that include, Rcss, the 23 question of double LCCA peak testing in the ' 74 standard 24 versus the single peak in the -- is that tvuical of the ac -._a:..
a.cor us, inc..
y" kind of margin you' re talking abort?
)
)u j
).) J l
]
21 I
ar10 l
I I
i MR. MCORE:
Right.
The enveloo --
i i
e~
2i MR. SNYDER:
But you hit it twice, when in f act 3l if there was an accident of that sort, you'd never see the l
4l second one; is that co rrect?
i I
5; MR. MCORE :
Right.
It covers a possible error l
6; in predicting the accident environment of simulat tng it in I
7 !
the test, of variations between units off assembly lines.
l 8
That's what it's aimed for.
f 9
It's not very rigorously derived, but enc idea 10 is to go well beyond what you think it will have to meet.
4 11 '
COMMISSIONER GILINSKY:
Thank you.
i 12 end 2 I
(-
13 j I
t 14 l 15 j 16 17 i
18 19 20 21 22 23 24 Aa Fwwm 4morun. W.
2b b i
I' u L '-
q ;g,,
CR 5872 22 MELTZER i
1 t-3&4 mte 1 l
1{
COMMISSIONER AHEARNE:
I'm not sure if this question I
n 2l is for Ross, but do we then now require the '74 standard to be 3'
met for plants that are now under construction?
^
4~
MR. MCORE:
We have a date for cps.
What is the I
a 5
cutoff date for '74, somebcdy who is closer to it than I am?
I 6!
There is a date established for cps: beyond that l
7l date, required to meet the '74 standards; prior to that, the a
1971 --
9, COMMISSIONER AHEARNE:
Aren' t we already in that date?
i i
10 Are there any plants lef t that are new being held to '74 i
11 standards?
l 12 ~
MR. MCORE:
No, not in the operating license.
l i
13 l COMMISSIONER AHEARNE:
For construction?
l 14 MR. MOORE:
4.ren't they required to -- the new cps 15 '
should -- construction permits are making cc=mitments to meet I
i 16 it.
l t
17 :
CCMMISSICNER AHEARNE:
To meet it.
I 18 MR. MCORE:
Right.
19 CCMMISSIONER AHI".RNE:
Okay.
20 MR. DENTON:
I think I can help on that a bit.
We 21 put Ccmanche Pet.k as semehcw the plant that would meet the 22
'74 standard.
I think within the staff there are sericus 23 doubts as to whether the '74 standard can be met literally.
24 COMMlSSIONER AHEARNE:
That was my next question, woe.rw a.oonm. inc.
25 MR. CENTCN:
A lot depends en hcw ycu interpret the g 3 ',
U$
23 ste 2
(
i i
i Il standard, what you think the standard means, and I think that's l
2!
why the staff has had so much dif ficulty with this issue, is s
3 taking those words in the standard and hcw do you translate l
4 !
these into tests.
I see the standard as intended to envelop 5
al.1 pieces of equipment regardless of the time it had to 6'
operate.
7!
In order to simplify the process, we have ended up 8
going back and 1 coking piece by piece at equipment, hcw long 9
it had to actually operate and what it's environment was.
We 10 have not really achieved any efficiency from the standard in 11 that sense yet.
12 :
MR. JORDAN:
The status of the responses frcm the 13 ;
licensees, the 120-day responses, I guess, are that the 57 y
14 plants that are covered by this bulletin have responded.
The l
t 15 11 SEP plants are excepted.
They are furtaer along in the 1
16 '
review of environmental qualification than the bulletin
~
17; requires.
Also, Indian Point 'l and Humboldt Bay were excepted 18 since they are operational at this time.
19 The adequacy of the responses are being screened, and 20 the responses frcm our viewpoint, in a preliminary fashion, 21 range from what we feel is very thorough to peor.
And we will 22 be centacting licensees.
We have contacted scme licensees 23 already, reqcesting additional information necessary for us 24 to perform our review.
sesw-c amomn. w.
25 COMMISSL VER 3RACFORD:
What would a poor respcnse --
EJJs i" "
24 nte 3 P
i l
?
1l what would the characteristics be that would make it poor?
l I
~'
2l MR. JORDAN:
In not providing the information that 1
i 3'
was requested.
We requested a very extensive listing of l'
l i
4l components and the environment to vnich they are subjected and l
l the manner of their qualification.
And some licensees have 6'
made what I would say are blanket statements that don't give 7l us the information we need in order to evaluate adequacy.
l 8
COMMISSIONER BRADFORD:
So if a licensee listed a 1
9 particular component and then decides what's qualified by i
i 10 analysis, is that sufficient?
f i
11 !
MR. JO RDAN :
That's going to be the basis of our 12:
review, so that we can correlate across the 57 plants.
For 13 !
instance, if we have a specific componet that another licencee I
14 l has qualified that particular component by test, then perhaps I
15 we can determine adequacy and be able to feed that information 16 '
back to the licensee.
i 17; So we're going to have a very large matrix of l
18 information.
19 COMMISSIONER BRADFORD:
But will you ever actually 20 check either the analytical methcds of the tests that lie 21 behind the assertions that they. qualify?
22 MR. JORDAN:
We may.
We're not far enough into it 23 -
to say at this point.
24 The inspectior. process intent is to determine the sco Fecwas Recorwrs, Inc.
25 validity of the licenJee's assertions in his bulletin respense.
e
j 25 mte 4 i
i i
I COMMISSIONER BRADFORD:
How long would a typical i
2l j
bulletin response be? How many items are covered?
Ecw many i
3
-s j
pages?
i 4
MR. JORDAN:
Hundreds of items, and the responses 5
are ranging to a half an inch thick.
So a. proper response is 6
a quite lengthy document.
7 May I have the next slide, please.
8 (Slide.)
l 9'
Af ter the screening that we were just discussing, l
10 we are going to conduct the interim review, and this is being 11 perfcrmed by a task group consisting of IE headquarters, 12 '
IE regional and NRR personnel.
And the object there is to t
I provide the widest possible perspective and to ensure :ctsistend I3 i
I
's !
review of all licensees.
l i
i i
1 ~5 This process will facilitate verification in ques-i 16 ;
tionable areas by acapection.
And I believe if we esecunter, I7 for instance, problems with a component that was stated by the i
18 licensee to be qualified by analysis, through our experience 19 that we didn' t feel was correct, then certainly we would 20 review that in more detail.
21 So there is geing to be judgment involved in these.
9" '
The final reviews, once the final acceptance
^3' criteria and guidelines are generated, will be performed by 24 the same task group.
So that this will be a relatively long-
. c.-_. cure n.oor n. inc.
,c life task group.
This is a very large effort.
We anticipate
') J j D
26 mte 5 l
l l
1!
several man-years of work will be required to complete the i
2}
reviews.
And as far as the schedule, projection is that the l
3:
final review will be ccmpleted by March of ne.<t year.
The
,s l
4; interim review will be cc: spleted by September.
And we plan i
S:
to try to resolve the open issues by June 1980, by one Iwar 6:
from ncw.
l 7l At this point Ed Butcher will discuss the results 8-of the review of the licensees ' 24-hour notifications and 9
development of guidelines for our final review.
i 10 MR. BUTCHER:
Could I hava the next slide, please?
I' 11,
(S lide. )
12 To date, in connection with the 24-hour reporting 13 requirement on bulletins, we have received reports of five 14 different types of components.
These reports are sicnificant 15 ;
in that they are different frcm those ccmponents where the l
i 16 '
question is one of adequately documenting its qualification.
17 '
In the case of these ccaponents, the licensee has declared l
18 that he has reason to believe that these components are not 19 suitable for function that they are to perform in the LCCA 20 environment.
21 Specifically, the ccmponents are NAMCO stem-mcunted 22 limits, which are the limits we have identified in the 23 bulletins, and the licensees in turn reported them where they 24 have them, in accordance with the 24-hour requirement.
There Ac.-s.e.rw n.oor.m. inc.
25 have been seme containment isolation valve operators reported, t
f
),j j fL I
mte 6 27 i
l i
i l'
three plants at one station.
2l COMMISSIONER GILINSKY:
What is a valve operator?
l 3'
MR. BUTCHER:
Excuse me, I didn't hear you.
i 41 CCMMISSIONER GILINSKY:
What is that component?
5 What is c valve operator?
i i
6; MR. BUTCHER:
In this case, I bel.ieve it was an 7l electric valve, a motor to drive the actual valve di sk.
l 3'
There has been two plants at one station that 9'
reported an insulated instrument control cable terminal lugs l
10 l where they had scme insulation on the --
l 11 COMMISSILHER GILINSKY:
What kind of isolation valves l 12 are these?
Are these the large purge valves?
13 l MR. BUTCHER:
These particular valves, my recollection t
14 f is that they were drain valves.
They weren't large purge I
i 15 l valves.
They were process type valves.
I i
l l
16 In two plants at one three-unit station, aluminum l
l 17 l limi t switch hous'.ngs on containmenu isolation valves were j
i 18 ;
found which were subject to degradation in the chemical sprays.
i 19 And the ASCO pilot solenoid valves which we spoke about 20 earlier were also discovered, at ten plants and seven stations.
21 May I have the next slide, please?
e-22,
(Slide.)
23 In summary, there have been 31 plants at 19 stations, 24 ope-rated by 13 dif ferent utilities, that have repcrted saa.f.re a.conm, inc.
25 unqualified equipment, j
[i j j Odb
ste 7 28 i
i 1
CCMMISSIONER BRADFORD:
In how many cases is that 2
unqualified equipment equipment that was called to their 3
a ttentiot, by NRC as being unqualified?
,~.
4 MR. BUTCHER:
The only one -- I believe the limit l
Si switches were the only ones that were called to their 6l attention by the NRC.
Now, af ter the first ASCO solenoid 7j valve problem was reported to us by one utility, it would be 8
im=ediately turned around and reported to others, and it was 9
disseminated throughout the industry by word of mouth and by thd I
i 10,
manufacturer, and they began to come in.
11 So I guess you might consider that one kind of --
I i
12 ;
ch, yes, the 14 and 10 plants.
In all cases, the licensees l
l i
13 i have agreed to replace the equipment where a safety-related u_
i 14 l function was involved.
l 15 !
COMMISSIONER AHEARNE:
Ncw, I notice that you have i
I i
16 :
your 31 plants, you add up all these 31.
So I conclude that i
17 '
no one plant had two of these things?
18 MR. BUTCHER:
No.
In some cases there were plants i
19 that had more than one of these items.
20 COE1ISSIONER AHEARNE:
Well, is it then that there 21 are more plants than are listed on thi.s slide, or is it the 22 31 that's the wrong number?
23 MR. BUTCHER:
There are 31 plants that have reported 24 unqualified equipment.
In scme cases, they have reported more ka foowel Rooorters, Inc, :
25 than one type of unqualified equipment.
,?
%}[
O
- u. /
mte 8 l
29 I
I 1
MR. EISENHUT:
Steve, the numbers don't add up 2
correctly.
3 CCMMISSIONER GILINSKY:
What you're saying is, it's
, _s 4,
less than 31 plants.
l 5,
COMMISSICNER AHEARNE:
It's either less than 31 i
6i plants or there are mere numbers here.
7j MR. EISENHUT:
We'll get you the actual numbers.
l al I assume the slide before was more accurate.
It certainly I
9i delineates the right numbers.
I 10 t COMMISSIONER GILINSKY:
Let me ask you hcw yom would j 11 handle a situation where there is unqualified equipment.
Say 12.
the licensees have agreed to replace equipment.
What happens?
13 l Do you order them to do that or what?
t t
14 j MR. BUTCHER:
So far, it hasn' t been necessary to i
l 15 do that, With the 24-hour report, the licensee is also i
I 16 l required to report his proposed action to correct the prcblem
{
17!
and his basis for continued operation, it in fact he dcesn't
{
18 i elect to shut down immediately and replace it.
19 CCMMISSIONER GILINSKY:
So he tells you hcw f ast he 's i
20 going to replace that piece of equipment?
21 MR. BUTCHER:
That's correct, and he tells us why 21 that doesn't represent a hazard to the health and safety of the 23 public if he propcses to continue to cperate that plant during 24 that ceriod.
Ace-%.rw a.comri, inc.
25 COMMISICNER AHEARNE:
And this is vhat NRR is
~
E) J s f i..u;U
e mte 9 l
30 l
l 1i reviewing?
~
2 MR. BUTCHER:
That's correct.
3 CCMMISSICNER AHEARNE:
Now, in each of these cases i
4' he has to respond in 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
Does NRR have a similar windcw I,
5l in which they reach a judgment as to whether or not to accept 6
that?
7l MR. BUTCHER:
I would say that our response -- we I
8 are aware of it, we immediately examine it and make a judgment l
9j as to the significance, and that's done immediately, say within 1
10 j the hour of one receiving or one or the other individuals 11 working on it.
At that point we may make a judgment tha t there 'is t
12 i not enough here to determine hcw significant it is, so we i
13 i immediately contact the licensee. I would say within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 14 we make a pretty firm judgment in our own minds as to how 15 l significant it is.
2 16 l Again, all we're dcing is auditing his prccess,
,I 17 !
because he has already made this judgment.
l i
18 :
CCMMISSICNER AHEARNE:
But it's not nas respcnsibility l
l 19 -
to determine whether it's adequate to protect the health and l
20 safety.
l 21 MR. BUTCHER:
litimate judgment, I suspect it's 22.
up to us to verify his judgment.
But he has the first respon-l 23 sibility.
24 CCMMISSICNER AHEARNE:
New hcw many times did you
%CB-Est ral Recorters, f rw,
25 agree with -- I guess what I'm trying to get at is, were there s-ijJ u
l l
)._) s u
mte 10
{
31 l
l 1l any cases in which he identified a piece of equipment, you 1
I 2l guys thought that's really serious and you disagreed with his -
I 3
MR. BUTCHER:
In some cases we -- we have yet to I
t 4!
disagree with his judgment that the plant can be cperated I
5l!
safely.
In some cases we disagreed with the extent of his 6l actions to be taken in the interim.
Then we suggested he t
7l should take seme other actions, and we furthermore strongly i
l 8',
suggested if he didn' t then we would have to take scme appro-i 1
9l priate action to see that he did.
10 And in all cases we were able to very shortly 11,
implement what we felt was necessary.
I 12,
MR. EISENHUT:
I think another reason for these is i
i 13 i most of these -- it turns out most of the items we saw in the 14 previcus chart were rather insignificant.
That is, there was 15 something pretty straightforward to do.
If a valve has a 1
16 problem where you're not sure that the valves are closed j
17 l during an accident environment, you can c1cse it ahead of time f
18 and lock it shut.
I 19 '
There were, of course, a number of events over the 20 last year or so cn environmental qualification issues where 21 we have taken action where we have had a difference of opinion, 22 starting, I believe with the Cook situation.
So there has 23' been a number, both in connecters -- there's been scme en 24,
terminal blocks.
So those, I think, are the examples where ic. sar.,
a.mmn, inc.
25 there were ones where there's been a differer.,e of agreement I
r.> s r.
I
32 mee 11 l
I i
i i
I i l between us and the licensee on these.
They 've been rather i
2.
straightforward.
3 So in all of these cases I think we agree.d eventually, p
i 4
af ter scme discussion with the licensee.
5 MR. BUTCHER:
On this slide is summarized the 6
general f actors that went into the licensee's determination 7
and our subsequent evaluations.
And in all cases, it was some 8
combination of these factors, more than one, that led to the 9
determination that there was a basis for centinued operation.
I BU-s2 10 If there are no further questions, I will go to the Il next slide.
l l
12 (Slide.)
I l
1 13 !
The other ajor activity that NRR has in connecticn i
Id j with response to the bulletins has been to develop the guide-15 lines which IE will use in the final reviews of the 120-day i'
16 '
responses.. These guidelines will be developed by the Division 17 !
cf Cperating Reactors in NRR.
In conjunction with cur i
18 preliminary review, we will undertake a review in parallel and i l9 '
in concert with I&E of a few selected 120-day responses, and 20 we will continue with the reviews of the SEP information, 21 which is very similar in nature to that which we requested in 22 the 7 9-01 hulletin.
23 And frcm these reviews we will develop a set of 24 guidelines which will identify acceptable methods of qualifica-ac.a.o.r. a.comn. nc.
25 tion for plants of this particular vintage, with these
%. s,.';
U ) l)
33 mte 12 l
l 1{
particular applications.
These general guidelines will be 2i established with particular emphasis on the follcwing -- the 3l aspects that we have listed here of IEEE 323 1974.
It is not 4
our intent to attempt to backfit per se the standard.
It is 5
our intent to look at the standard as kind of a benchmark in 6!
establishing the criteria, and where we feel it is not necessary 7i to come to the letter of the srandard, the 1974 version, we 3.
will establish a basis for not having to ccme to the letter of l
9 that standard.
l 10 In many c ases, it may be impractical or not 11 desirable to implement the letter of that standard on an 12 -
cperating reactor.
13 l COMMISSIONER AHEARNE:
Such as in aging we don't I
14,
run --
i 15 MR. BUTCEER:
Aging is probably a fairly good i
l i
16 example, because in our reviews what we will be able to do l
l 17 :
with aging is we'll probably be able to identify scme particu-1 la lar ccmpenents that we will require aging.
In fact, we have 19 already identified one, the ASCO solenoid valve.
We have 20 already established a qualified lif= for that.
And ccmpenents 21 of materials of a nature similar to that, where we have iden-22 tified those materials as subject to sging degradation, we 23 '
can establish that as a requirement.
24 COMMISSIONER BRADFORD:
When you say "a qualified s
>=-74-w awcrvt w.
25 life," am I right in understanding that means it's qual _fied, b
-)
s
~
34 I
mte 13 i
I!
for a period of time, but then it will have to be tested again l i
2,!
before it can be used any longer than that?
3 MR. BUTCHER:
It's qualified such that if a LOCA i
4l were to occur at the end of its qualified life, the component 5,
would still perform in its LCCA environment.
l 6!
COP 21ISSIONER BRADFORD: If that period were five yearsh 7j what would the licensee have to do at the end of five years?
He'd have to perform maintenance to repll ce 3,
MR. BUTCHER:
a 9'
the component.
In this case, it would be to replace that 10 particular internal, if that were the thing; or scme other II mitigating action, place it in an enclosure so it won't see 12 '
the LOCA environment, scmething to mitigate the acing problem.
I3 I think that's about all we have.
Id '
COMMISSIONER AHEARNE:
On this list of 24 items, 15 are there any that NRR viewed as being sericus?
16 MR. BUTCHER: I think we view the ASCO solenoid 17 problem as being probably the most significant, in that its i
18 failure mcde was a bit tricky.
It was difficult to estaclish I9 a fail-safe mcde.
It was difficult to predict which way it i
20 would f ail, and therefore that was significant to us.
In the 21 case of the ASCO solenoid valve, there was a whole spectrum 22,
of things
- hat we made the licensees do in order to satisfy 23 us that they were acceptable.
24 The factors that I have listed here that would sce rwe a. con.n. inc.
2'"
form a basis for continued operation of all these components,
E U )-
J., 3
I mte 14 35 l
l l
1 we looked at.
The ASCO solenoid valves -- I see here in front i
2; of me, it looks like four of those valves played a role in 3
that decision.
So we piled layer upon laver.
F 4
COMMISSIONER AHEARNE:
As far as equipment, those i
5 are the ones on that list that you viewed as being mest serious?
l 6
MR. BUTCHER:
Yes, that's correct.
It took us the 7;
longest to resolve that one.
I won' t say that decision was 3
hard and firm made as easily as the others.
9 COMMISSIONER GILINSKY:
I wonder if you can give us 10 some indication or at least your impression of why there was 11 equipment out there Sr.at isn ' t
- wasn't qualifief?
Is it a i
12 failure of quality assurance?
Is it lack of attention, or a 13 f ailure to understand the requirements, or our not having Id stated the re'quirements precisely?
i 15 MR. BUTCHER:
I think I probably could give you an i
i example cf each one of those, and I susp ;t all the other l
14 r
17 members of the staff here could also cite e:iamples that would 18 be -- would say that each one of those is a factor.
I don't l
19 think I could point to one specific thing that occurred in i
20 every case.
21 Certainly a heightened awareness of the qualification' 22 problem brings thesa things to our attention in recent years.
23' I would have to say that perhaps there could have been a QA --
24 I don' t want to use the word " breakdown," but let's just say sc.-% a.co,=,. inc.
25 at the small individual component level, in the early days of ji s;
) N) b d'
m 15 36 l
i i
i 1!
the indus try, I think perhaps it was easy to forget those kinds i
2' of things.
There are hundreds of them in the plant and it's 3;
quite possible that one could have been lef t out in the design 1
4 specification.
5; CCMMISSIONER BRADFORD:
Is there a pattern in the l
6l answers you actually got that in f act indicates the problems 7l tend to be greater in the earlier plants, the 11 earliest, a
because they would have responded in this context?
9l MR. BUTCHER:
I couldn' t answer that question.
I i
10 haven't analyzed the data.
11 -
There is one aspect that we prcbably ought not to 12 ov6. vok, and that is in the case of the limit switches.
It's i3 only been in recent years that we have ccme to recognize the i
i 14 '
importance of pcst-accident monitoring and things like that, I
i 15.
at least in the level of detail that we have gone into in 16 recent years.
And therefore it is not surprising that you would i
17j find a thing like a limit switch, that provides position t
18,
indication, not having been given a great deal of consideration l
19,
when they were qualifying equipment in the earliest plants.
i I
20 l' I think that accounts for 14 of these dif ferent cases, whatever 21 is wrong with my arithmetic.
22 '
(At 2:20 p.m., Chairman Hendrie entered the room. )
23 CCMMISSIONER 3RADFORD:
Did you get responses from 24 all the plants?
ac. s
,e m.oo:ws inc.
25 MR. BCTCHER:
Yes, there nave been responses, at s) 1
ste 16 l
37 I
least 120-day responses.
They have at least responded to the 2;
bulletin.
The question of adequacy, I think I can' t speak to 3'
that.
4 COMMISSIONER BRADFORD:
Well, in cases where the 5'
responses were inadequate, have they been notified that they I
6!
have more to do and been given a schedule to do it?
7 MR. JORDAN:
That is what we are doing new with the 8
screening.
Scme of the licensees have been notified, that 9
where there was an cbvious problem.
And we are continuing to i
4 10 notify the rest of them.
We have a task group meeting temorrow II to continue screening.
We do it on a regional basis.
I2 ;
COMMISSIONER BRADFORD:
Is there an overall staff I3 view on the feasibility and wisdem of taking enforcement action I4 '
against a licensee who has unqualified equipment?
Can it he j
i 15 !
done, and if so, should it be done?
I i
16 MR. JORDAN:
This is on the general case where, i
17 let's say, the 31 licensees that reported having unqualified 18 equipment?
Is that the example you are proposing?
I9 COMMISSIONER BRAEFORD:
Well, that's a good starting I
20 place.
21 First of all, does the current regulatory structure i
22 give a basis for action of that sort?
Are the FSAR commitments 23 clear enough?
Is the '71 standard clear enough to enforce
~.
anything against anycne?
And follcsing that, if the answer ace-scus n.conm. :ne. ;
'S '
is yes, should we be taking actions of that sort?
i
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38 t
i I
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MR. JORDAN :
Well, the later plants that do indeed I
t I
2l have the equivalent of the '71 standard, the answer is yes.
+
I 3l And as far as our plans for scme action, that's part of the
(^
\\
l 4I review process.
We will look at that aspect of it.
That's i
5l not foremost in our review process.
i 6
Foremost is verifying that the components are 7l qualified.
i 8
COMMISSIONER BRADFORD:
But the issue isn't really i
I 9
a new one at this point.
It's been what, la months since the 10,
D.C.
Cook connecters --
11 MR. JORDAN :
That's right, and that one was a 12 relatively clear case.
i 13 MR. SNYCER:
You found there that you had no grounds i 14 for strong enforcement action, right, as I recall, at Cook?
I 15 !
MR. MCSELEY:
In that case we did take the enforce-1 I
t 16 ment action.
17 :
MR. SNYDER:
I'm sorry, excuse me.
18 MR. MCSELEY:
The response that we have to give is 19 that it varies by licensee, and we will have to lock at them 20 almost on a case by case basis.
2.
COMMISSIONER BRADFORD:
Let's see.
Can I ask that 22 1 one of the things that you -do he to try to bring that situatica 23l to an end.
Cbvicusly, it is not acceptable to be able to
(
24 :
take enforcement action against a licensee in one place for waw. a.oor m i,ine.:
25 '
a set of events that you couldn' t enforce against another p a, G w
I, e, w, s
=te 18 39 I
I I
i i
i l'
licensee in another place.
i 2
MR. MOSELEY:
But we can't retroactively place i
i 3l requirements that did not exist, ei ther.
4I COMMISSIONER BRADFORD:
I understand that, but I i
5l think we would want to have the regulatory framework be such 1
i 6:
that regulations, at least as to the future, can be enforced i
7 formally in this area.
8' MR. MOSELEY:
Yes, sir.
I think we have that.
I 9
think the early answer is certainly true, but for the newer 10 plants these things are much more uniform and standard, and Il '
we would have a better basis --
I2 '
COMMISSIONER BRADFORD:
My point is that if a LCCA 13 l occurred, it isn't going to worry about whether it's occurring Id in an older plant or a newer plant, and wa've got to have a IS '
way of making sure the equipment is qualified in the oldest 16 )
plant as well as the newest.
I7 MR. MCSELEY:
Yes, sir.
I8 CCMMISSICNER BRADFORD:
It just doesn' t make sense l9 l to me to say that we have no way to enforce the requirement 20 for qualified equipment in an old plant --
21 MR. MCSELEY:
I think we are not communica ting.
I 22 was talking about enforcement in terms of saying, what are you 23 going to do, why did you let this happen, and so on.
The 24 bulletin itself is going to result in having qualified rceau seconm. noc.
'S equipment, no question about it.
O, a. i L
a u.] s
f 40 l
ate 19 i
1l COMMISSICNER BRADFORD:
Okay.
s i
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2.
MR. STELLO:
Let there be no question, we are going i
a 3
to establish that all plants have qualified equipment.
Given l
l 4
that that purpose is acccmplished, in the process of acccmplish-l l
5 ing it you can ask the question whether or not there needs to l
6 be an enforcement action against a particular licensee for 7
scmething that's flagrantly cmitted, not done.
And I think 8
that has to be done based on the license conditions that were 9'
issued with the plant when it was licensed, and it will have 10 '
to be in that context to decide.
i 11 I don't believe it's appropriate to try to take an 12 enforcement action for a plant that is very old that dcesn' t v
13 have clear language as to what was required using today's i
14 views.
But I think it is accropriate to make them all meet l
I i
15 the sarety requirements, irrespective of time of licensing.
i 16 COMMISSICNER BRADFORD:
Yes, I think I would agree j
17 ;
with that.
But what I understand you to have said is that i
18 the bulletin will, in effect, sweep aside the situation as it 19 exists now, which is that the different commitments in different 20 FSARs, depending on the time, depending on whether or not they 21 reference the '71 standards, makes uniform enforcement 22 difficult, if not impossible, as of today.
23,
MR. STELLO:
Uniform enforcement to me is a concept 24 where you enforce the license requirements that were imposed sc -o a.comn. inc.
25 cn the particular licensee and do that uniformly, reccgnizing e-4 that the license requirements do indeed vary.
t i l' i i
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CR 5872 45 MIMI?pv 41 i
1 i
l' COMMISSIONER AHEARNE:
I thought I understood it.
Now l
/
2' I don't.
i 3
(Laughter.)
I 4,
COMMISSIGNER BRADFORD :
I think I understand it, but t
5 don't like it.
{
6' (LLaghter.)
i 7,
COMMISSIONER AHEARNE:
Let me see.
I would like to 8
separate -- I am not asking about penalties against scmeone, so 9
if that is what you mean by enforcement ac' ion, that's not the c
10 question I am asking.
So, you might ask a question:
Can you 11 take enforcement action?
And the question really would be:
Can 12 you exact a penalty against scmeone?
That's not my issue.
13 '
The question, though, is:
Can you require all of the 14, plants, independent of what level of ccmmitment they might have, 15 whether it is pre-71 standard or '71 standard, can you recall all.
16 the plants to meet scme uniform level of qualification of equip-17 - ment?
18 MR. STELLO:
Yes.
Now, enforcement, though, covers a 19 different spectrum of things, up to and including civil penalties.
20 The way in which you apply that obviously needs to depend --
21 CCMMISSIONER AHEARNE:
Right.
That wasn' t my question.
22 So that you will be requiring the equipment in all of the plants 23 to meet scme minimum standard of operability in the environment 24 that the plant might be expected to be in in an accident?
ac.-L = =.oomn. inc.
25 MR. STELLO:
Yes.
I thought tha t was the curpose of ii-
pv2 42 t
i l
I 1, Ed's last slide.
You might want to put that up again, i
l 2
COMMISSIONER AHEARNE:
That's what I thought I under-3 stood.
4 4
(Slide.)
5 MR. STELLO:
That's the purpose, as I understood it, 6; of your last slide, Ed.
I 7:
MR. BUTCHER:
The second statement there is:
"We S
attempted to find the criteria upon which they would be measured."
9 COMMISSIONER AHEARNE:
That would be independent of 10, which plant and when.
Il MR. BUTCHER:
Right. And there may in some cases be 12 some enforcement necessary to bring them up to that level.
13 COMMISSIONER AHEARNE:
That's what I thought I under-j i
i 14 ' stood.
15 MR. JORDAN:
That's why we have the interim review and 16 then the final review, because in a short time frame --
17 CCMMISSICNER AHEARNE:
Okay.
IS MR. STELLO:
Everybcdy understand it?
19 COMMISSICNER BRADFORD:
That's what I understood, as 20 well.
But that looks entirely to the future.
We till are in 21 the situation at present in which it is basi - > _ the one tha t 22 Vic has described:
Consistent enforcement consists of enforcing 23 ! inconsistent conditions or inconsistent amendments by different 24 licensess.
AaCee a.cor m. inc.
~c COMMISSICNER AHEARNE:
Is your point, Peter, as to when 9J)
O' U
pv3 43 i
I will the equipment in the older plants be qualified?
i 2'
CCMMISSICNER BRADFORD:
That's the next question.
3 I was talking earlier about enforcement action, includ-i ing civil penalties or whatever, in the context of the regula-5 tory framework that we have now.
And it sounded -- I was think- ;
i 6
ing it would be very difficult to be doing uniformly, and that 7' haan't changed.
What l
3 What about that next question, as to that last slide?
Y When do you see that program being completed?
10 MR. BUTCHER:
We have set a goal of September for 11 ccmpleting the guidelines, and that's not to be a simple task, 12 ' it's not to be taken lightly, because we do anticipate there I3 v.
could be some backfitting involved in that.
COMMISSICNER AHEARNE:
That's quite likely.
15 MR. BUTCHER:
I would say it's quite likely.
16 CCMMISSIONER AHEARNE:
If there would be backfitting 17 - required, wouldn' t that sort of make it more important to get I3 it done as soon as possible?
19 MR. BUTCHER:
We regard September as as early as pos-20 sible to do the kind of adequate job we believe is necessary.
21 CCMMISSICNER AHEARNE:
But you wouldn't want to let it 22 slip beyond that, t
23 l MR. BUTCHER:
I would say next September; the following l
24 September would probably be too long.
I agree with you.
That's i
aceva a oo,.n. !nc.
'S the conclusion we have ccme to also.
l R
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i 44 i
I COMMISSIONER BRADFORD:
And then there's a period 2: beyond September which would be required actually to bring the 3
plants into compliance with whatever you've done?
,s 4
MR. BUTCHER:
That's correct.
l 5
COMMISSICNER BRADFORD:
You propose to be specifying 6;
that time, whatever it was, after September?
7 MR. JORDAN:
I estimate that time as being March of l
3 1980 that we would ccmplate the final review process against 9
this criteria for all those 57 plants, and then by June of next 10 year we would have resolved the issues that were developed by 11 imposing that review.
12 (Ccmmissioner Kennedy arrived at 2:32 p.m.)
I3 i CCMMISSIONER BRADFORD :
In reviewing responses ncw, Id does the '74 standards play any role in your method of review 15 to be used informally?
16 MR. BUTCHER:
In reviewing the responses to date?
l7 CCMMISSIONER BRADFORD:
Yes.
13 MR. BUTCHER:
To date, we didn't make judgments as to I9 the likelihood of the ccmpenent failing in its environment.
We 20 concluded that it -- the probability was that it would fail.
21 Now, what is the consequence of its failing.
So, really, there 2
was no need to apply a standard to determine whether it would 23 fail or not fail.
24 Maybe I didn't understand the question.
In review-ace-U m 1.oo,.n. inc.
2 ~c ing the 24-hour responses, we weren't making a judgment as to bb; f) /l
pv5 i
45 l
i 1
whether the qualification of the equipment reported in the 24 2I hours was edequate or not.
The licensee declared that he 3
believed it was not qualified.
gs 4'
COMMISSIONER 3RADFORD:
The question I had in mind:
5 When you get a response, you have different people working, meet-6 ing different responses.
They have the licensee 's commitments j
7: in front of them; they have the 1971 standards.
3 COMMISSIONER AHEARNE:
Are pu talking about the 9
24-hour or 120 days?
10 COMMISSIONER BRADFORD:
120 days.
And they have to II make scme kind of a judgment as to whether or not these responses 12 are adequate or not and the equipment is qualified.
13 Now, there isn't necessarily a lot of the '71 i
I4 standards to go by, and, in scme cases, at least, there isn't-15
. very much in the FSAR.
What are they using, then, in the situa-16 tion in which different reviewers ccme to different conclusions I7 on similar information?
I3 MR. JORDAN:
I think I can answer that.
The review 19 is being done by a task group so that they're going to be hold-20 ing hands essentially and doing the review, and the interim 21 portion of the review is where there will be dif ferences because nhey will be using as criteria the licensee's commitments and 23 the accident environment for that particular plant. And it will
'4 be the final review that this is, you know, all brought together ac Ae neocrwn. x.,
,5 and the influence of hte 1974 standards will be in the criteria u.
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pv6 46
- 1. for that review.
So, there are two parts.
2 COMMISSICNER AHEARNE:
Peter, may I?
3 COMMISSICNER BRADFORD:
Certainly.
4 CCMMISSIONER AHEARNE:
More in the sense of clarifi-t 5
cation, in the process you will end up, I guess, finding that 6
there -- or you have already found -- the 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> were those 7-where the licensee felt the equipment wasn't qualified.
3 MR. BUTCHER:
The licensee or his supplier.
9 (Commissioner Gilinsky leaves room at 2:35 p.m.)
10 COMMISSIONER AHEARNE:
And the 120 days, possibly 11 you might find some other components which you conclude where 12 the licensee didn't, but NRC may conclude, that they aren't 13 qualified.
14 Now, to some extent, that means the plants are, and 15 I don' t know what the right term is -- out of compliance with 16 the tech specs or whatever requirements are laid on.
Now, does 17 that require a formal waiver from the director of NRR or the la director of I&E in order for the plant to continue to operate?
19 MR. STELLO:
Let me try to answer your question.
I 20 think, if it follows classically, as most reviews do, you look 21 at something and the licensee thinks it's okay.
You argue that 22 you don't think it's okay.
Then the natural thing is to try to 23 find out a way to resolve it, which means you may have to run a 24 tent which, hopefully, both parties agree to, this is the test i
ac.- se a.comn. inc.
25 to run.
And if it does indeed turn out okay, we both accept it.
~_
i i
i
pv7 47 i
l 1l If it doesn' t tarn out okay, something needs to be done depend-l l
2 ing on the components, such as the examples before you.
Then 3
you decide what the right course of action might be.
If it can 4
be something where you can lock a valve closed or whatever, it i
3' may allow the time to go in and replace the compoent.
If not, i
6 then you ray have to go ahead and replace the compoent reasonably i
7 quickly.
(
3 As far as whether or not you need to cover at that 9, point you might have to order them to change it if there's disa-10 greement.
If he says "No,"
then you're faced with the need to 11 order them.
12 COMMISSIONER AHEARNE:
But the situation -- I think 13, what I am at least concluding you are saying is that this doesn' t i
14 fall into the category of items which flip a switch and that 15 switch being either the plant has to autcmatically because of 16 the legai requirements shut down, or that some one of, the direc-17' tors has to have a waiver to stay up.
18 MR. STELLO:
You could give it a waiver, if that were 19 appropriate.
I think where I would see most of the issues come, 20 they ccme to the point where a licensee thinks it's okay, he has 21 done something he thinks justifies the qualification of the ccm-22 ponent, and there is going to be a difference in view.
23 If we feel strongly enough, then we have the tools to l
24 l eake the action we need to require him to do something.
4c -,vw a.comes. inc.
25,
COMMISSICNER AHEARNE:
I was wondering more of a l
)' '. I oI) l s -
r 1
'.) j
pv8 48 i
I different situation:
You both agree this is something that 2l must be changed, and the licensee wants to have it continue to 7-3 operate.
Is there a situation where, in order for that to 4
happen, there has to be a formal waiver given?
5 MR. STELLO:
You could give an exemption to it, if 6
that's what's appropriate.
7-CHAIRMAN EENDRIE:
I think the answer must be, John, I
8 that it certainly is within the realm of possibility that tho se 9
circumstances could arise.
It may not occur in a great many 10 cases, or it might not even occur in any.
But I think it would Il be very hard to say, "No, no, that's just not a configuration 12, which can possibly arise.
I3 COMMISSIONER BRADFORD :
When you described this 14 earlier as an audit typ e of review, which it clearly is, but 15 let me get a feel for the secpe of the audit, you will have 57 16 half-inch thick responses to deal with.
A lot of things can 17 be qualified by analysis and scme qualified by testing.
18 Have you any feel for what percentage, if any, of M
those analyses and tests you are going to be able to verify 20 yourselves?
21 MR. JORDAN:
What we were asking for was the for the 22 licensee to provide the documentation for his position of the 23 qualification so that we have through the Circular 78-03 the
'a inspection program verified scme of those documents already.
ACS., el Recor+ers Inc.
- 5 COMMISSIONER 3RADFORD:
It's not so much the 3 _) [
04i
pv9 49 i
i I
documents.
What I am curious about is actually do we need 2' somewhere in the research program we have asked for before a 3
testing program of our so that we indicate we could do some of 7,
4 !
these tests ourselves?
5 MR. JORDAN :
Yes.
And, of course, on connectors, we 6
did scme tests ourselves.
l i
7-COMMISSICNER AHEARNE:
We have been attempting --
3 (INAUDIBLE) 9 (Laughter.)
10 MR. JORDAN:
Wei be in a better position, I think, Il to identify additional tests that we ought to be doing inde-12 pendently after reviewing these packages.
I don't know at 13 this point.
I4 MR. SNYDER:
That's still an open item, I think, on 15 the list for the April Commission decision.
I6 MR. STELLO:
Yes.
I7 MR. EISEMHUT:
That's still an open item.
I think la the response will be coming up shortly.
It may entail sort of 19 a ccmbination; it may entail, after we go through these reviews, 20 we may ccme down and say certain of the items should be tested, 21 and we may go out to an existing lab and suggest that we inde-22 pendently test certain typical components in addition to the
'3 l Sandia approach that Research is doing.
'4 We may also, ycu will see in this proposal coming 2#.
a.comes, inc.
,e forth, we certainly have several alternatives or options in it.
,, [,
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pv10 50 t
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l' One of the options would be having our own testing facility 2
where we test a large number of them.
3 I think these reviews will help give us an input into 4
where we really want to go for that kind of testing program.
5 COMMISSIONER BRADFORD:
At the moment, what you get 6
would be something that's qualified by testing, you would learn 7, the data of the test and where it had been done?
8 MR. STELLO:
Typically, there would be a test report f 4
9 documenting the results 10 COMMISSIONER BRADFORD:
And might the tests have 11 also been done by the licensee?
i 12 MR. STELLO :
I know, in some cases they have been, 13 - and in other cases they have been in labs.
14 COMMISSIONER BRADFORD:
It sounds like a situation 15 that cries out for scme mechanism for independent verification.
16 MR. STELLO:
The whole question of independent 17, verification is a very difficult one of how much of that you do 13 do, talk about environmental qualification --
l9 COMMISSIOENR BRADFORD:
The first step we have to get 20 over is the decision to do some.
21 CCMMISSIONER KENNEDY:
Is it not true we are doing 22 some?
i 23 j MR. STELLO:
We have done 'ne first -- or attempting, 24 as Commissioner Ahearne says; I don't know what the status is --
Acs-
. ai 4 000 rTers, I MC.
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" ' to test connectors ourselves, and where some consideration has I
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been given to testing additional components beyond that, wl.ich 21 components are selected and hcw much of that to do, I think, is 3, something that is owed to the Commission.
I think that will 4
have to be considered.
The Commission will have to decide how 5
much of that it does want to do.
And I guess the appropriate 6: time to discuss it would be when this paper backup --
7 CCMMISSIUNER BRADFORD:
Could you give me a back-8 ground on what the drawbacks are?
What are the arguments 9
against some testing?
10 MR. STELLO:
I don't have any against doing some 11 te s ting.
I think, to me, it's a decision of how much of the 12 ' resources you want to put into that particular activity.
If it 13 ' turns out to be a tenth of a percett, it might be well worth-14 while.
But I think it needs more thought than I want to be 15 able to say 1 have given it sitting here.
16 And there is a paper.
It is a particular issue that 17 I have been giving a great deal of thought to, the whole ques-i 18 tion of independent testing and verification,frem an inspection l9 coint of view. And philosophically, I clearly believe more of it 20 is needed.
21 CCMMISSIONER BRAOFORD:
Lee, do you know offhand 22 when that paper is scheduled to come up?
23 j MR. GOSSICK:
That standards paper on qualification 24 l testing?
_em a.com,s. :ne. l 4c.,
25 l MR. STELLC:
I thought Research had the lead on that.
('
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MR. EISENHUT:
I am not sure exactly what the s
2, detailed schedule is, but I know I read the draft report about 3
a week ago. So it's getting close, I think.
COMMISSIONER AHEARNE:
Let me ask a 2t lated question.'
5 Is there any money being proposed in the next year 's budget for 6! it?
I.
7:
MR. GOSSICK:
I can't answer you.
O MR. STELLO:
Inspection and Enforcement has some 9
money for additional independent verification testing.
But it 10 '
covers, again, a broader picture.
Radiographs of piping systems.
11 So, we have some staff in that ares and have the start of a prc-12 gram.
I think it is one htat decerves more thought and 13
- deliberation than we can give here.
14 i COMMISSIOENR KENNEDY:
Could you sort of outline the 15 general ccmponents of such a program?
Wouldn't one have to 16 ' determine which items you want to cover. and that would be a I7 function of their significance to various safety systems, I 18 suppose?
19 Secondly, I suppose, you would also take into account
'O
-- and I am just thinking out loud at this point -- it would 21 take into account the likelihood of failure and the consequences 2 ;of that failure of that system.
If it's not of any consequence,
,, l you could spend a lot of resources on that for not too much 24 benefit.
aca-.
m =.cor,n me. j And thirdly, wouldn't you want to take account of hcw i,
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pvl3 53 i
l 1; much testing you would have to do in a statistical sense to give 2, you any kind of assurance of the quality of a whole batch?
1 3
are those some of the things you would have to -- there
- mean, 4
must be others.
i 5
MR. STELLO:
Oh, yes, but it's even broader.
I 6
i n e.l u d e, for example, independent radicgraphy, and the whole 7
concept of independent verification testing.
It's again, how a
big is the sample size, or how big does it need to be?
How 9
much of it do you want to do?
Do you want to take concrete 10, samples and bring them to a laboratory independently, measure II concrete strength?
I2 COMMISSIONER KENNEDY:
Is that what this paper is I3 ad.drensing?
Id '
MR. STELLO:
Ihis is strictly on the environmental 15 testing of components.
That's a big order.
16 COMMISSIONER M IE:
Are you thinking abcut time 37 '
tests?
13 MR. STEILO:
Yes.
I9 end45 COMMISSIONER AHEARNE:
Which is different in the 20 sense that some of the testing program is more generic, at 21 least to research.
22 23
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24 sa "s swomn. Ix.
25 5J y
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11 MR. STELLO:
I think the question of environmental MELTZER
' -5872 i
2, testing has generic implications.
I 3
There are a large number of plants thar use similar 7
4 components as indicated on one of those slides. So it dcas l
{
5 have the capability to go across many lines.
6l COMMISSIONER BRADFORD: One other question.
7l What will the legal basis for uniform enforcement i
a ultimately turn out to be?
That is, as a result of the j
i 9
Bulletin process, you will have come up with a requirement and !
I I
10 apply it across the board,backfitting if necessary.
i 11 But then if a year from new you find unqualified 12 equipment is still in place, what will you be enforcing against 13 at that point?
I 14 Will it be a Bulletin, a Regulation, revisions to 15 the FSARs?
i 16,
MR. STELLO:
Again it goes back to the earlier 17 ;
question Cccmissioner Ahearne asked.
If we make a formal la backfit requirement proposed as a licensing requirement, 19,
the arrr.y of things the Licensee has to do, then they become 20 part of the license and you enforce them in that context.
21 If he adopts them as part of his license, then they 22 are again enforceable.
23 If he just agrees to adopt them in some informal 24 way, then ycu have covered the whole spectrum of problems I am ac.-
e a.oomn. inc.
25 sure the attorneys will see in terms of the degree of ii. l "'
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enforceability.
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And I think we are probably going to wind up with j
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that spectrum of plants.
I 3
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I COMMISSIONER 3RADFORD: But in the case of scmeone 4,
i who simply agrees to put the equipment in place, what happens i
then if that didn't get done, if it hasn't formally been made l
6; part of the licensing?
l 7,
ME. STELLO:
I have a feeling that is a legal question.
i 9
1 1
CHAIRMAN HENDRIE: I presume we can get an order l
10 saying we consider it a propriate to the health and safety i
requirements of each clant to do it, i
12 -
t COMMISSIONER 3RADFORD: You can get it done, but is l
13 I
that also a situation where penalties can be invoked?
I MR. LILBERMAN: No, the Chairman is correct.
Obviously you can issue an order, but if it is 17 ;,
only a commitment to do something a civil penalty couldn' t 1
ce imposed.
A material false statement could not be found unless the state:nent is clear in a license applicaticn that g
a Licensee will, in fact, have a sp
.fic component qualified to some standard.
21 COMMISSIONER BRACFORD:
Well, le: me just leave it, for my own part then I feel that whatever cc aes out of your effort in September, it ought to include a enforceable a s-et Recorters, loc.
including the possibility across the board 3 c
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1l-penalyzing those who, after the time they were supposed to have mm3 i
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2j qualified equipment, still don't.
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I must tell you I also have the thought l 3i MR. STELLO:
r 4,
in mind of whether or not you ought to raise that question of j
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5' need for a change in Regulations to enhance or elevate the I
6' status of Bulletins and their response.
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7; (Commissioner Gilinsky arrived at 2:50.)
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COMMISSIONER BRADFORD: The final thing, I guess, as I
9 a result of TMI I gather there is some talk of equipment that i
10 :
didn't used to te considered safety related may now be.
1?
Would that process conceivably have an impact on 12 -
the work you are doing here as well?
I 13,
MR. BUTCHER:
In the initial planning for the i
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14 '
development of these criteria, we proposed a systems approach. j i
15,
And that certainly would involve things like that.
i 16 '
The first thing in the systems approach would be I
17:
to make a determination of what ought to be qualified in 'he i
la ;
plan t, notwithstanding what the license originally required.
19 That's our thinking at this point.
As the criteria develop 20 we may determine it is not practical to do that.
That is quite 21 a job. So, at least we are thinking in that direction.
22 COMMISSICNER AEEA. ':
I want to make sure I under-23 -
stood that last answer.
24 YOu are saying, your conclusion is it would be a very ac.
., p,on m.inc.
25 big job to decide what equipment ought to be qualified at the I
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s 5t mm4 I
plant?
m
'd 2!
MR. BUTCHER: No, I don't think I meant that.
i 3'
What I meant to say was the first step in determining em i
i 4l whether equipment is adequately qualified or not is to 5
determine what you need to be qualified.
6' In order to do that, you go about it in a systems i
7*
l approach.
One shortcut has been determined. Everything in 8
the containment ought to be qualified.
That would certainly 9
l be a shortcut to elim inate the need to do that kind of 10,
review.
11 l
MR. STELLO:
I think what comes out of the Three i
12 Mile Island Lessons Learned, the identification of equipment I3 that will have to be elevated in a safety status, will be i
I 14 specifically identified.
And that equipment would just add l
1 15 to the list of equipment.
I 16 And I suspect since it has not new been qualified, I7 documents would have to be supplied showing how it would be, 18
- or modified so that it would become qualified.
19 But I would think that would be a specific list 20 of equipment.
2I CHAIRMAN HENDRIE:
Anything further?
2 (No response) 23-Let me seize then on the pause and say, thank you
'4 very much, even though I wasn' t able to be cresent at the f
a sere a.comn. inc.
,c
'~
front end of this discussion.
U-
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58 i
mm5 I
COMMISSICNER AHEARNE: Well, having been here t
's 2l throughout all, thank you very much.
1 CHAIR W HENDRIE: I assume the front end was 4
useful.
5 (Whereupon, at 2:53 p.m.,
the hearing in the l
6 above-entitled matter was adjourned.)
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