ML19261C835
| ML19261C835 | |
| Person / Time | |
|---|---|
| Issue date: | 04/04/1979 |
| From: | Bender M, Etherington H, Seiss C Advisory Committee on Reactor Safeguards |
| To: | |
| References | |
| ACRS-T, NUDOCS 7904190004 | |
| Download: ML19261C835 (98) | |
Text
NRC PUBLIC DOCTJENT RDDR NUCLE AR REGULATORY COMMISSION ADVISORY COMMITTEE ON REACTOR SAFEGUARDS IN THE MATTER OF:
SUBCOMMITTEE ON REGULATORY ACTIVITIES Place - Washing ton,
D. C.
Date -
Wednesday, April 4, 1979 Pages 1 - 98 Telephone:
(202)347-3700 ACE - FEDERAL REPORTERS, INC.
OfficialReporters 444 North Capitol Street 79041D00
. Washington D.C. 20001 NATIONWIDE COVERAGE DAILY
I PUBLIC NOTICE BY THE 2
UNITED STATES NUCLEAR REGULATORY COMMISSION'S 3
ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 4
Wednesday, April 4, 1979 5
6 The contents of this stenographic transcript of the 7
proceedings of the United States Nuclear Regulatory 8
Commission's Advisory Committee on. Reactor Safeguards (ACRS),
9 as. reported herain, is an uncorrected record of the discussions 10 recorded at the meeting held on the above date.
II No member of the ACRS Staff and no participant at this 12 meeting accepts any responsibility for errors or inaccuracies 13 of statement or data contained in this transcript.
14 15 16 17 18 19 20 21 22 23 24 nieral Reporters, Inc.
s 25 7904190@i:j
1 CR3741 1
UNITED STATES OF AMERICA JRB L
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NUCLEAR REGULATORY COMMISSION l
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5 ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 6
SUBCOMMITTEE ON REGULATORY ACTIVITIES 7l Room 1046 l
8 1717 H Street, N. W.
l Washington, D.
C.
9 Wednesday, April 4, 1979 10 '
11 The ACRS Subcommittee on Regulatory Activities met, 1
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pursuant to notice, at 8:45 a.m., Dr. Chester P. Siess, i
13 chairman of the sur;ommittee, presiding.
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14 PRESENT:
15 Dr. Chester P. Siess Mr. Myer Bender 16 Mr. Harold Etherington Prof.. William Kerr 17 Dr. Dade Moeller l
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I C_ O__ N. _T_ E_ N. _T _S.
2 PAGE AGENDA ITEM 3
Regulatory Guide 1.140, Revision 1, Discussion 4
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Proposed Regulatory Guide, Pre-Comment, Cable Penetra-tion Fire Stop Qualificatin Test for Nuclear Power f
5 Plants, Discussion 63 6
Proposed Regulatory Guide 1.58, Revision 1, Discussion 72 7
Proposed Regulatory Guide 1.131, Revision 1, Pre-Comment, Discussion 75 j l
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PRQ(({glggS 2
I DR. SIESS:
The meeting will come to order.
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Thi s i s a mee ti ng o f the Advi sa r y Commi ttee o n 4
Reactor Safeguards Subcommittee o n Regulatory Activi tie s.
5 I am Che ster Sies s, Subcommi ttee Chairman.
The 6*
o ther ACRS member pre sent today is Dade Moeller; and Harold Etherington will be in shortly; ard we expect a couple of o ther!
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member s befo re t he mor ning i s o u t.
I will introduce them l
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when they arrive.
10 '
The purpo se of the meeting today is to review four regulatory guide s, a rd we will take them up in the follow !
II I2 ing o rder:
i 13 Regulato ry Guide 1.140, Revision 1; a propo sed i
Id regulatory guide on Cable Penetration Fire Stop Qualification 15 Te st for Nuclear Power Plant s; a propo md Revi sio n 1 to Regu-16 latory Guide 1.5 8; and a propo md revision 1 to Regulatory I7 Guide 1.131.
18 This meeting is being conducted in accordance wi th the provisio ns of tle Federal Advi sory Commi ttee Act and the 20,
Governme nt in the Suns hine Act.
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21 Dr. Tho ma s G. McCrele ss on my immedia te right is 22l the De signated Federal Employae for the meeting.
l 23 l The rules for participation in today's meeting i
24 have bee n anrounced a s part of the Federal Regi ster no tice Aa FM Reponen, Inc.
25 published on March 29.
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f And a transcript of the meeting is being kept and I
2 h will be made available a s stated in the Federal Register 9 i no tice.
It is requested tha t each speaker fir st identify I
4' him self to the repo r te r, a nd then se the microphone if he 1
5 ha s o ne, if no t, to speak wi th suf ficient volume so he can be 6j heard.
7 Ue have received no comments in."'iting regarding i
8l the business to take up today, and we have no reque st from 9[i member s o f the public to make oral sta teme nt s, i
10 l I s the agenda order as indica ted sati sf ac tor y?
l 11' MR. MORRISON:
Ye s, that' s fine.
I2 DR. SIESS:
I think we will have no trouble getting 13 through the four items of bu sine ss today; but if we do run Id short of time, I will clo se the meeting very close to 12 15 e clock and if it looks like we will take too muc h time on g
16 so me t bing and y> u wa rt to rearrange the order on the li st,
17 le t me know.
18 We have to a tte nd a meeti rg at o re o ' clo ck a nd I I9 I wa nt people to have a chance for lunch before that.
20 Dr. Kerr ha s appeared, he is sitting between me 2I a rd Dr. Moeller.
i 22 l Reg Guide 1.140, Revision 1, wa s discu ssed at the 23 meeting la st mo nth; there were a number o f ques tions raised 24 chiefly the things that weren' t in the guide, ra tle r than a
Pral Rmortm, W.
t hings tha t were.
And we have received a revi sed version i
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-- well, tlure were a number of changes agreed to at th3 2
meeting.
Some of them were just a little bi t too complicated 3
to get th3m fixed up and brirg them back in time for the 1
4 full committee meeting.
So we asked Staff to think about them,I l
5 make the changes, and consider some other thing s and bring 6
them back to this meeting.
7 We have gotten our revised version of the revision l 1
8 and there were two extra page s, 5 and 6 were sent out by 9
Sam Duraiswamy prior to the meeting.
Did you get those, i
10 I Dade and Bill?
DR. MOELLER:
Yes.
l II I2 DR. KERR:
Ye s.
i 13 DR. SIESS:
Th3 se are two or three change s in response to a later comment that came in from Sargent and Id 15 Lundy.
I have those incorporated into my copy here.
Sam, did you give the Staff copie s of what you just !
16 i
17 pa sed ou t?
l 18 MR. DURAISWAMY:
No.
I9 DR. SIESS:
Have you got copie s you can give them?
[
20 MR. DURAISWAMY:
Ye s.
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21 DR. SIESS:
Duraiswamy tried to summarize mme of l
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the subcommittee ' s comment s from tir la st meeting, m you can 23 compare and see how much they 1 ave been taken into account.
24 The se are items I think Staff said they would like to go back i
Ac eral Reporters, Inc.
25 and think of before making changes.
They don't lik3 to make l
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change s o n the spur of the moment here.
2 As near a s I can tell, nat all cf the se did re sult 1
3 in change s in the draft.
You might take a minute to look a t 4
tha t.
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The change s that have been made are rela tively l
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minor.
Some of tho se were made, they were editorial type l
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change s that were made while we were at t he meeting in re sponse; I
8 to thing s that had come in, with additional reference s.
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Do t he o the r member s of the commi ttee have any i
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comments to make abou t the c. ange s that were made? -- no t abou t II tho se tlut weren' t made?
I2 DR. MOELLER:
Ye s.
I think I have a few comments 13 o n t hat.
i Id Let me, if I may, ju st take a few minute s and --
15 DR. SIESS:
This is about change s there were made.
I6 DR. MOELLER:
Ye s.
I7 DR. SIESS:
Okay.
18 DR. MOELLER:
I have read the transcript of the I9 previous sBacommittee meeting of March 6, and I personally 20 feel that my problems with the guide were clearly addre ssed a t l
21 tha t time; and I am satisfied that the Staff has heard my 1
22 comments.
23 I still believe, though, tha t a reg guide, 24 par ticularly when you revise i t, should be de signed to correct j Acw Pral Reporters, Inc.
25 deficiencie s that have been noted in existing systems for wrdch 4
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I this guide i s being written.
2 My own work with regard to air cleaning sy stems i
has shown that instrumentation is a problem area, rela tively l
i speaking, for the se system s.
And if according to the la st I
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transcript, then, the in strumentation i s pooperly covered l
6 in Reg Guide 1.21, that would be fine with me.
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But I would urge that a cross reference to this i
8 f act be included in the introduction to 1.140.
9 And I no te that in Mr. Durai swamy ' s comme nt, I 10 i believe that fir st i tem that he summarized --
II DR. SIESS:
Excuse me.
i 12 It sound s to me like 3ou are addre ssing changes 13 that have no t been made.
I4 DR. MOELLER:
Well, let me -- I will immedia tely 15 get to the other o ne s.
f I0 DR. SIESS:
Fir st I want to fi nd ou t whe t her the i
I7 draf t we have with the change s ir it are a problem.
i 18 DR. MOELLER:
Yes.
Okay.
I So what the Staff has done, as I see i t, i s a ttempt l
20 l to patch up Reg Guide 1.141, and I apprecia te it because in l
21 many re spect s you are a ttempting to accommodate my critici sms --
l DR. SIESS:
140.
I 22 23 DR. MOELLER:
1.140.
24 No w, let's look at your sugge stions at the ce rol Reporters, Inc.
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I bottom of page 3, you've added the words "and instruments",
to that.
3 So it say s that, in e ssence, that we must be 4
concerned about the aging and weathering of instruments.
5 Well, I am not sure tha t tha t's what I am worried aboct.
6 And then if I go on down to the next to the la st 7
line on page 3, I am worried about the poisoning of an 8
i ns trume nt.
Well, in your attempt to accommodate my cri ticism 9
by pu tting in " instrument s," you have go tten yourself into 10 tro uble ; because I don' t think it now reads right to comment on instruments in tha t f as hion, or to bring them in in tha t 12 fashion.
13 Now, on 4 at the top, since you've now included t
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" instruments" at the bottom of page 3, and made it one of the I4 15 compone nt s, you've introduced the problem I've just cited:
16 the poisoning of an instrument; you have improved it because I7 in the first full paragraph at the top of page 4, you now tell 18 me that all components, including " instruments" have to be i
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designed and maintained for good opera ting performance.
20 That's fine.
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21 So there it would be a step forward.
But I am just i 22 no t sure you can handle it the way you've done it.
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I do have many other comments of problems with it, 24 bu t not wi th regard to changes.
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25 DR. SIESS:
It seems to me that in the discussion i
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I last month we accomplished nothing in clearing up the scope 2
of this guide.
And since the guide doesn' t Inve a section in i t, 3
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" scope, " I've looked for it in the introduction, where I thinkI l
5 it ought to be -- and I've said tha t so many times, I'm getting' 6
tired of saying it -- I can't find a clear sta tement of the 7
l scope.
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It looks to me like you added instruments to the 9
scope of the discussion when you were arguing last month l
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that instruments were not within the scope of the guide, if you 11 put it in the discussion -- and I don ' t think I find anything I2 that's clearly done in the position, which is the important 13 part.
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'I A nd I am getting the uncomfor table feeling you 15 don' t really know what the scope of this guide is, because if 16 you knew it, you could say i t.
17 Now, can somebody tell me wha t the scope is, and 4
18 why it i s m t stated?
MR. STEYER:
Well, it is our position tha t the scope 20 !
o f the guide is covered on page 2 with re spect to --
l 21 DR. SIBSS:
Where on page 2?
l 22 MR. STEYER:
At the top.
23 DR. SIESS:
Which paragraph?
2#
MR. STEYER:
The very top, first, paragraph.
Ac nel Reporters, Inc.
25 Maintenance criteria for air filtra tion and absorption units.
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I We had discussion before, but not particularly i
2 emphasizing instrumentation; we felt that was covered in other i i
ou guides.
4l DR. SIESS:
Why don' t you say tha t?
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5 I have to interpret what a " unit" is -- air l
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filtration and absorption units.
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7 MR. CARDILE:
We made it clear we are not talking l
8 about the radiation monitoring instrumentation.
9 DR. SIESS:
You haven't made anything clear.
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think that is obvious.
II Dr. Moeller doesn' t understand wha t the scope is.
12 Our consultants last month did not understand wha t the scope 13 is; and I have not heard a statement this morning.
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Id Now, the scope can either be defined in words that !
15 are inclusive and positive, so tha t there is no misunderstanding; 16 or it can be defined by exclusion.
17 And let's put a very simple question:
are 18 instruments of the type Dr. Moeller is talking about included I9 within the scope of this guide, or are they not?
MR. CARDILE:
Radiation monitoring instruments j
i are no t included in the scope of this guide.
We could put a l
21 22 reference to Reg ritlide 1.21 into it.
But we have not.
23 DR. SIESS:
Well, wha t instruments are included 24 by the words "and instruments" on tne fe. 'h ne from the l
Ac wel Reporters, Inc.
25 bottom on page 37 l
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MR. CARDILE:
Only pres sure drop and flow rate 2
instrumentation.
3 DR. SIESS:
We know that or you know tha t, but tow t
4 do I know that?
5 DR. MOELLER:
Well, on the bottom of page 5, paragraph 6,
you say tha t you are going to cover the instruments c,
7 pertinent to pres sure drops and flow rates.
8 Okay, by saying that, that's good.
Include 9
instrumentation for pressure drop and flow rate; but you are l
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mi ssing some of the most impor tant instruments you could have j
II What about the instruments tha t measure the I
12 temperature?
If you are dealing with a charcoal bed, I want 13 to know the temperature.
I I4 You have had numerous incidents where the temperature 15 monitor on the charcoal bed failed, and you have diluged that 16 bed with water when it wasn't needed to be done; and the I7 applicants have had to replace the charcoal.
That is o monitor-I0 ing instrument on that bed that is very impor tant.
Wha t about the hydrogren monitors?
In a charcoal l
20 bed I want to know -- we hear of Three Mile Island -- we want i
21 to know the hydrogen concentration.
22 How can you tell me in paragraph c, at the bottom of 23 page 5, that flow rate and pressure drop is all I am interested in?
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25 I am interested in hydrogen.
I am interested in l
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moisture.
2 DR. SIESS:
This is not post-accident, now.
This 3
l is normal atmospheric.
4 DR. MOELLER:
Well, Browns Ferry had a fire in the 5
charcoal bed; it was normal operations.
6 DR. SIESS:
I want to keep that difference.
7 DR. MOELLER:
Yes, thank you; that's good.
8 That was three, six months ago.
9 DR. SIESS:
Tha t scope is clear.
t 10 I DR. MOELLER:
Yes, that scope is clear.
l Now, how -- you've hit it on the head -- we don' t l
II 12 know the scope of this guide.
I don' t know the scope of this 13 guide now.
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I4 You say instruments are covered in 1.21.
Fine.
15 And yet Mr. Collins in the transcript of the March 6 meeting said tha t 1.21 needs updating.
It is not complete.
It does 16 17 no t do the j ob.
i 18 MR. CARDILE:
I believe the statement was that meant; i
I9 Reg Guide 1.21 needed to be upda ted.
20 DR. MOELLER:
Yes.
I 2I MR. STEYER:
Not this one.
l 22 DR. MOELLER:
Oh, this one needs a lot of work.
23 l DR. SIESS:
One confusion, it seems to me, is tha t l
24 although this is limited to normal ventilation systems, it is ce ral Reporters, Inc.
l 25 no t clear that -- I think sometimes you are trying to limit l
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it to normal opera tion of normal ventila tion systems, and not 2
to those times when there might be abnormal operation; and yet youhaeinc[uded abnormal operation because of your comments 3
4 about paint and things of tha t sort are not normal conditions. i l
5 Jo it is obvious the scope is not clear to some 6
- people, 7
Now, I am not sure that the public comments, the 8
industry comments, show any real confusion about the scope.
9 Maybe they have worked with you enough tha t they understand i
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i t.
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11 But tha t bothers me a little bit, too.
If you and i 12 industry can talk to each other without a reg guide, it is h
clear -- do you really need a reg guide to get along with?
13 Id But you have added " instruments" here without a 15 qualifica tion.
I look for a position and I find only two 16 types of instruments mentioned.
17 Ye s, I could deduce from tha t that those are the IO only instruments you are talking about, but that to me is a i
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hard way to find out where the scope is.
j 20 MR. STEYER:
Well, I agree that the scope probably could be improved.
f 21 22 However, I think the reason we had " instruments" --
23 this is my understanding -- and Mr. Weinstein's understanding 24
-- of the directions that I believe are on page 79 of the I
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25 transcript.
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DR..MOELLER:
Excu se me.
2 There is a third type of an instrument mentioned 3
j at the top of page 10.
You mention the samplers lou have to d
look for.
5 DR. SIESS:
What about temperature measurements?
6 Isn' t tha t part of the system? -
such as Dr. Moeller referred 7
to?
8 MR. CARDILE:
As the guide is written now that 9
doesn't indicate they have to have temperature instrumentation.,
i 10 I DR. SIESS:
Does the standard review plan call for l I
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instrumentation for temperature?
I2 MR. CARDILE:
I don' t believe it doe s.
I'm not 3
sure, though.
I I4 DR. MOELLER:
You are encompassing here charcoal 15 filters as well as heat filters?
1 16 MR. CARDILE:
Yes.
I7 DR. MOELLER:
I think most of them have a temperature i
I8 monitor.
I may be wrong.
I think they do.
DR. KERR:
There is a question as to whether they 3 9 'p 20 i
are required.
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2I DR. SIESS:
They are not safety systems.
l 22 To what extent is the conf usion rela ted to the fact 23 tha t this is a normal ventila tion system, this is not considered 24 a safety system.
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25 MR. CARDILE:
Tha t's right.
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jrbl5 15 DR. SIESS:
You are sure it's not a safety system?
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DR. KERR:
It's not a safety system, -- Appendix A, I
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Appendix I? -- how could it not be a safety system?
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MR. CARDILE:
Well, I used the wrong terminology.
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It's not an ESF filter system, as it is indicated in 10509.
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DR. SIESS:
The only instruments Staff requires t
7 for the se systems are the pres sure and flow rate instrumenta tion?
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8 Now, from a safety point of view, as long as you l
9l got pressure and flow, you are satisfied?
You don ' t care wha t,
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the temperature is?
MR. CARDILE:
I guess.
I2 DR. SIESS:
There are temperatures given on the l
13 table s in the back, aren't t he re, tha t the se are cualified for?
Id Table II?
15 DR. MOELLER:
Table I gives the ignition tempera-16 ture s.
17 Wha t about rela tive humidity?
Does that have to 18 be measured?
Or is that controlled by something else?
I9 I MR. CARDILE:
That has to be measured.
20 DR. SIESS:
It's not a part of this system?
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2I MR. CARDILE:
It mentions relative humidi ty as i
i 22l part of the system.
23 DR. SIESS:
Is it a part of the systems covered by 24 this guide?
Ac setal Remners, tnc.
25 MR. STEYER:
It is not in this guide.
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DR. SIESS:
That wasn't the question.
2 DR. MOELLER:
It says tha heaters or cooling coils 3;
should be designed to reduce the relative humidity of the 4
incoming atmosphere to 70 percent, in part 3, page 6.
5 DR. SIESS:
Is tha t important to the operation of 6
the filter s?
7 MR. STEYER:
They operate best at a relative 8
humidity of 70 percent, although they can operate higher.
9 DR. SIESS:
You say they should have it, you don't i
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say i t should be measured.
l II I am trying to get a perspective on what is 12 impor tant.
You've told people they've got to have three-foot 13 I
I4 clearance s and so forth -- which I don' t think is at all 15 important to tM opera tion of the filter; it make s it pos sible I0 to maintain them with less work, I guess.
j I7 But is the humidity important for safety?
I8 MR. CARDILE:
To continue to keep this charcoal working, keep the heater running, it probably is.
I9 20 MR. STEYER:
If tM humidity in the room is I
i 21 controlled elsewhere -- but what the heater has to do is be i
22 sure to be able to reduce it.
23 DR. SIESS:
Well, let me back off.
24 You say that these are important to safety, they Ao eral Reporters, Inc.
25 are cited here under general design criteria, Criteria 60 and
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61, I gue ss -- I forget wha t they are.
So the safety we are i
2 talking about here is really the occupational safety of the l
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staff of the plant?
4 MR. CARDILE:
No, i t would be the of f site l
5 radiation dose.; for normal operation.
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DR. SIESS:
Of f site do se s.
7 MR. STEYER:
Exhausts from the building.
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DR. KERR:
You also refer to Appendix I.
f i
9 DR. SIESS:
And that's offsite, ALARA.
10 I And the filters are important to this; right?
II HR. CARDILE:
Yes.
12 DR. SIESS:
But they are not covered by this guide.
What are they covered by?
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I4 MR. STEYER:
You said " filters"?
15 DR. SIESS:
I meant " humidity ".
I0 MR. STEYER:
Oh, I7 DR. SIESS:
Which rela tes to filter efficiency.
18 MR. STEYER:
I don ' t know, myself.
It ' s no t I9 covered by this guide.
But the industry standard, 10509 20 reque sts the relative humidity be monitored.
I 2I DR. SIESS:
Wha t I am trying to understand is l
22 l this guide gets very specific in some things; it tells them I
23 exactly hou to design these things.
In fact, it almost designs, l
24 it for them in a coup]e of places; how to test them, how to eral Reporters, Inc. ;
Ac 25 maintain them.
And you have drawn a box around this somewhere.
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To my way of thinking, you have tried to limit the 2
scope of i t.
Obviously, you've got to draw a box around it i
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somewhere; otherwise you are covering the whole plant in one l
4 reg guide.
I How did you gox this in?
Did you take certain l
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6 paragraphs on the standard review plan, and say, now, we wa11 7
addre ss the se in the reg guide?
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Or did you take some base of supply to limit the l
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secpe of this?
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How did you decide on what you are going to cover in ;
II this guide?
-- as opposed to something else?
I2 MR. STEYER:
Based on the branch position that is 13 in the same area.
i I4 DR. SIESS:
How did the branch position get defined?
15 Is there somebody here from the branch?
I0 MR. CARDILE:
What they went to was the, it I7 primarily started as a charcoal filtration unit itself, and 18 also looked at the N509 document, and looked at the other components which are essential to this charcoal filtra tion unit, 20 namely, the fans, dampers, housing, et cetera-2I With regard to the instrumentation de sign, one of I
22 the comment s from Dr. Bender was to talk to the people back 23 a t NRC Staf f in the instrumentation area.
And a comment also 24 made was tha t the air cleaning handbook was not specific in i
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j i ts requirements on instrumentation design.
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And those two i tems together, the instrumenta tion i
people have recommended the air cleaning handbook recommends l
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only quality instruments, which is a very nebulous term.
The I
instrumentation people on the Staff have indicated that i
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5 the instruments should be purchased based on industry standards, I
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codes.
l So I gue ss the point is, that is the guidance l
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8 the instrumentation peop?- at URC or Staff gave.
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9 DR. SIESS:
I am getting a little bit of an idea 10 !
here tha t the scope of a guide is sometime s defined, is II I
limited, by the way the branches in the NRC are set up.
If a branch is dealing with only one part of a l
12 13 sy stem, then the guide deals only with one part of the sys tem.
Id (No response.)
15 Is that right?
16 MR. STEYER:
That's probably frequently true; 17 ye s.
18 DR. SIESS:
I don't know that I get a heck of a 19 I
lot of comfor t from that or not.
20 The committee has been talking a lot about systems 21 design.
I am not sure whether I know wha t " systems design" l
22 l are, but -- how do you draw the line between the system and 23 the instruments that relate to it, such that they come on i
24 different sheets of the plans?
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25 And I put the whole thing together and you put a I
l I
r b20 20 I
box around it; that box, I think, would contain the 2
in struments.
l 3
Now, the fact that the filtration units are on one 4
shee t, and the instruments are on another sheet, and they are 5
reviewed by different branches -- are you sure we get the 6
interfaces taken care of?
7 MR. CARDILE:
I think maybe that's one of the j
l 8
problems here.
Instrumentation is in one branch; filtra tion 9
design is in ano ther branch.
10 '
DR. SIESS:
. sight now I do no t think you have helped Il the situation any by adding " instruments" on page 3.
And I guess what it was for us at the last meeting, l 12 l
13 at le ast the impression I got, was tha t you did no t want to i
Id include any instruments except pressure and flow; and that you 15 might find some way of saying tha t clearly, and referring to 16 wha t would cover the o ther type s of instruments.
17 Now what you are saying is there is really not 18 anything tha t covers it.
Wha t's reg guide 1.21, the scope?
20 MR. CARDILE:
Radiation monitoring, i
2I DR. SIESS:
Tha t's radiation monitoring.
1 22 That's not really wha t we are interested in.
We 23 are interested in monitoring the equ..pment for moving radiation.
i t
DR. MOELLER:
Well, of course, we are interested Ac eral Reporters, Inc.
25 in radia tion monitors to the extent tha t on a number of the i
i e
o
jrb21 21 I
systems, if I remember correctly, there are monitors on the 2
effluent from the cleanup system, and these could even trigger 3l an isolation of tha t system if the effluent is above limits 4
in tech specs.
l 5
So in that sense ve would be interested in that, 6
also.
l 7
But as our Chairman has pointed out, apparently, 8
there is a range of instrumentation such as moisture, hydrogen, 9
temperature, s o f or th, that may have farlen through the cracks; 10 !
instruments tha t are as sociated with these systems:
air j
i 11 cleaning systems.
I2 MR. CARDILE:
Well, --
13 DR. MOELLER:
And to repeat what I have said many 1
Id times before, in a review of about three years of LER's on 15 air cleaning systems, we found over half of the failures in 16 BWR's and over 30 percent of the failures in PWR's, were failures 17 of air cleaning systems and associated components, which were l
18 failures not in the system but in the equipment tha t's I
I9 I monitoring the performance.
20 And that's why I am quite interested in seeing that i
I 21 somewhere we attack this problem and try to help the utilities l 22 improve the monitors that are watching over the performance 23 of their sys tems -- whether they be moisture, tempera ture,
i 24 hydrogen, flow rate, pressure drop, or activity, radioac tivity. ;
A eral Reporters. Inc.
I 25 DR. SIESS: Since this guide has been out for l
jrb22 22 i
I comment and opinion and views, i t seem s to me one approach 2
is simply to make clear what this does no t include; and not I
3 necessarily to rewrite this guide to include those other things.
l 4
Bu t I think the point has been made, at least to i
l 5
some people, that no one has been looking at the thing and l
t 6
seeing what's going on.
j It's not clear what this guide does not cover.
7 i
I 8
( Laughter. )
9 MR. CARDI'4 :
I think the other guide brought 10 !
before you on radwaste systems was much more definitive in 11 saying, this doe s not cover thi s, this doe s not cover that.
I2 DR. SIESS:
I think it's very important that we 13 know what is no t covered by tle guide.
If this guide is i
I4 followed completely, it does not guarantee the systems are 15 going to work properly all the time.
16 If you don' t believe that. just look at some of 17 l
the LER's that show they haven't been working properly, and 18 for reasons that are not covered by this guide.
19 If you use it, you should not get the impression tha t 20 this is all you have to do to assure the normal ventilation 21 systems are doing the job they should.
They interact with j
l 22 l
other things, and they may not be working right.
23 I assume there's a tech spec item somewhere in which 24 you realize tha t.
A(
mal Reponers, Inc.
25 I think the thrust of the discussion is there should l
l I
jrb23 23 I
be something in this guide that makes it clear what its limits 2
are.
3 Now, the second question:
wha t to do about 4
in s trumenta tion?
Another guide is needed through a branch l
position, or standard review plan.
You've got many ways to 5
6 encompass these things.
And there will have to be guides, as l
7 we know.
l 8
But addressing those questions, whether it's a 9
problem of standards-- I don't know.
When you get to the 10 !
reg guide stage, it's a systems safety problem.
If there's i
a branch technical position -- and I don't know who writes the I II 12 standard review plan.
13 MR. MORRISON:
Basically, it was written by NRR.
l i
Id Right now we are being asked to help in writing revisions I
15 to the standard review plan, Office of Standards Development.
i 16 DR. MOELLER:
It is intersting that since our I7 Chairman had mentioned moisture, and you had concurred tha t 18 too much moisture could degrade the performance of an air cleaning system, that on the top of page 5 in item 1, sub-l 20 paragraph (e), just about the middle of the page, it says, I
21 the design of the atmospheric cleanup system should consider I
22 any significant contaminant, such as dust, chemicals or 23 other particulate matter that could deleteriously affect the i
24 cleanup systems operation.
ce
'ral Reporters, Inc.
25 I would suggest moisture be added there.
l i
jrb24 24 I
DR. SIESS:
That's not a contaminant.
li 2
DR. MOELLER:
I see.
3l MR. CARDILE:
Section 3a, rela tive humidity levels. !
I f
4' DR. MOELLER:
Oh, all right.
i l
5 Now, ANCI N509 covers what?
The title tells me j
what it covers, but does it cover design and maintenance?
l 6
i 7
510 is testing.
I'll back up.
f I
8 This guise says design, testing and maintenance, l
9 three things.
l 10 MR. CARDILE:
Right.
DR. SIESS:
ANCI 510 is testing?
I2 MR. CARDILE:
Right.
13 DR. SIESS:
ANCI N509, it doesn't say whether it's Id design or wha t.
1 15 F1R. CARDILE:
It's basically design and some 16 maintenance.
.~
17 If you look under section 4 of the reg guide, under 18 maintenance, you find 4a, there is a reference to 509, 4.7, and 4.11, which is the requirement for testability.
I9 20 In other words, you keep the por ts, you should 21 have aerosol injection ports and the software.
I I
22 MR. STEYER:
509 covers functional design and 23 component construction, radiation resistance, and primarily 24 the dasign phase; not so much maintenance.
erst Reporters. Inc. g ce DR. SIESS:
The ANCI documents are not complete 25 l
l
jrb25 25 I
enough to be referenced with conceptions like you do in other 2
ca se s of ANCI.
3 MR. STEYER:
Our intentions is when these are finally g
4 out to consider tnem for reg guide endorsement.
l 5
DR. SIESS:
A new revision.
6 MR. STEYER:
Another one; yes.
I I
7 We dor. ' t expect them, as we said, for approximately 8
four to six months.
9 DR. SIESS:
They do not cover instrumentation, 10 I either?
j MR. CARDILE:
The new version of N509 does cover II I2 instrumentation.
It calls out, it's much clearer, calls out 13 the ESF number versus nonESF instrumentation that would be i
i I#
required.
15 DR. SIESS:
I think the question was asked last t
I0 time, the ANCI document is going to be out in a few months; I7 and you do intend to rewrite a guide to utilize those more 18 correctly and more completely.
And since you have made rela tively few changes in l
I 20 this guide as it was originally issued for comment, is there l
21 that much of an advantage in getting this thing out now?
l 22 MR. CARDILE:
The point made by Collins last month 23 was that it is out only for comment right now; and the standard 24 review plan now references it as a reg guide, and no longer i
ce tal Reporters, Inc.
25 references it as a branch position.
irb26 26 I
DR. SIESS:
So what does tha t do?
Leave you in 2
limbo?
3 MR. CARDILE:
It leaves you without a specific 4
docume nt, it leaves you in limbo.
l MR. STEYER:
It'll be about 15 months before these l
5 t
6 will go out for comment.
7 DR. SIESS:
When this went out for comment the 8
branch technical position was revoked?
9 MR. CARDILE:
Tha t's right.
10 !
When this was written as a reg guide and sent out l
II for comment, the position was taken ou t of the standard review !
I I2 plan.
l l
13 DR. SIESS:
So what has been going in the last i
I Id year, where you had a for-comment-guide and no branch technical!
15 position?
A regulatory vacuum?
16 MR. CARDILE:
We referred to this reg guide.
i I7 DR. SIESS:
And if the reg guide was lef t fo.
ien t 18 for another year, wha t would you do?
It's not that dif ferent from the originkl MR. STEYER:
20 branch position; we could continue to refer to i t.
i 2I MR. CARILE:
I am not sure of the mechanics of tha t. !
\\
22 In other words, the standard review plans were 23 recently revised, and --
i 24 DR. SIESS:
It must have a couple of years on it, i
ce trat Reporters, Inc.
25 because I've been getting it a feu pages a week.
l i
jrb27 27 I
MR. CARDILE:
My only point was that up until the 2
point when the standard review plan was revised recently, the 3
old standard review plan had this branch position in it.
4 DR. SIESS:
I think it was.
l 5
Now, since you had relatively few changes to make 6
in this -- well, I can't say there were rela tively few 7
comments, -- but relatively few changes, that you feel you might 8
as well get it out as effective, and be able to refer to it 9
as an ef fective guide, ra ther than a proposed guide?
l l
10 '
MR. CARDILE:
Ye s.
j II I
MR. STEYER:
Yes.
I2 DR. SIESS:
If you had to make extensive changes 13 in i t, would you have said, well, I will hold it up and I
Id instead of duplicating the ef fort af ter N509 and 510 is 15 changed, I'll just let it ride?
l i
Or would you have tried to make it ef fec tive, 16 17 anyway?
i 18 MR. STEYER:
If they were extensive enough, we may l
i j'
have to put one out for comment again.
20 DR. SIESS:
Yes.
l 21 MR. STEYER:
I don't think we considered holding l
22 it up par ticularly until we talked to you people.
1 i
DR. SIESS:
Well, with as few changes as you.had j
24 I would say, you know, go ahead and get it out as effective; a
,r i Reporters, inc.
25 but if you had to make a lot of changes in it before you made l
jrb28 28 I
it ef fective, and then you could see in a year and a half 2
you were going to have to go through it all over again, would f
3 you have gone ahead with the first stage?
d MR. CARDILE:
Well, --
5 DR. SIESS:
Or would you have paid attention to 6
something tha t was more impor tant?
7 MR. CARDILE:
As we discussed last month, we first 8
star ted out with this thing for comment, it was a year ago.
9 About this time last year when the guide went out for public 10 I comment.
j So at that time, we were 27 months, 2-1/2 ytars i
II i
away from being able to incorporate the N509.
l 12 i
13 I
DR. SIESS:
When this came through before, it was I
Id reviewed by Dr. Moeller's subcommittee, and I recall some of 15 these questions did not come up with respect to scope, between !
l 0
this and the instrument safety features, the filter systems.
17 rade, have we got a fairly clear statement in here 18 about wha t is included and what isn't?
Would you be satisfied to let this go o.. out?
20 DR. MOELLER:
Yes. -- Rephrased, please?
i 2I DR. SIESS:
If we had a clear statement of scope, i
22 and if we clearly stated that the types of instruments that 23 we have been talking about this morning, those types are not 24 covered in this repor t, or in this guide, then I would find it ;
cr
.ral Reoorters, Inc.
25 i
acceptable, l
i I
jrb29 29 I
And I think that would mean, though, removing the 2
word " instrument" at a couple of points where they had inserted I
i 3!
it.
l 4
They haven' t got it in the position; they put it i
{
5 in the discussion.
6 It seems to me the kind of statement you need t3 7
make it clear -- and whether you put it in the introduction i
8 or discussion -- I guess I would have to leave that up to you. I l
9 I think the scope should be in the introduction, 10 !
not discus sion.
i But you need a statement somewhere that the only l
II I
I2 instrumentation related to these uni ts or these systems that l
D is covered by this guide is tha t listed in position c2c.
l Id And I believe t int is a correct s ta tement.
15 This does not give a person any guidance about the 16 other instrumentation, but it makes it clear tha t there is 17 other instrumentation; and there may be some guidance somewhere'.
18 And if there is not, then he has got to be able to justify wha t he does.
l l9 20 Now, that is the way the system operates.
l 21 MR. CARDILE:
Yes.
l 22 DR. SIESS:
And he can point to whatever indus try 23 standards there are, or whatever other guidance he has in the 24 standard review plan.
ce est Reporters, Inc.
25 But if a question is raised, he cannot say, I am i
l e
i
jrb30 30 I
I I
1 all righ t, because I followed Reg Guide 1.140; 1.14 0 doe s 2
not address that instrumentation.
It only addresses flow l
3, and pressure.
l I
I 4'
Now, it may turn out there is not any other I
5 instrumenta tion that is important; but I do not think I have 6
been told that -- to my satisfaction, -- that there is not l
7 other instrumentation that is impor tant to the opera tion of I
I 8
this system.
l i
9 MR. STEYER:
We can certainly include a scope.
10 !
DR. SIESS:
Either in the first paragraph, put in 11 what it does include; or in the second paragraph, put in wha t 12 it does not include.
i l
13 But you might not want to put it in the second l
l 14 paragraph.
You might want to put a paragraph in between.
Or 15 you might want to add it to the first one.
16 I don't think the second paragraph ought to be deleted 17 by this.
It makes it clear it does not apply to engineered l
18 safety feature ventilation systems.
It seems appropria te to 19 I me a sentence at the end of the first paragraph, to say only 20 that instrumentation in a particular section is covered.
i 21 Would you be agreeable to that' i
l 22 (Chorus of "yes.")
l l
23 l DR. SIESS:
I think it is a true statement.
It saysj lI 2d what is in the position, just calls attention to what is in Ao ef al Rmornfs lm.
25 l the posi tion.
I l
jrb31 31 I
MR. STEYER:
What is covered, what is not covered.
2 DR SIESS:
Okay, what else?
Dade?
3l DR. MOELLER:
Let me add one final comment, very 4
minor:
5 On page 5, in part la, the second sentence which 6
begins five lines down -- I had to read that about four times.
7 It says, the cleanup systems should be designed -- past tense -
B based -- past tense -- on continuous operation -- da-da-da-dee-l 9
da.
10 i DR. SIESS:
I believe there was mme public comment l
to the effect tha t tha t sentence was less than clear; and I 12 do not recall whether there was a suggestion as to how it might 13 be improved.
Id MR. CARDILE:
It probably would say the design of i
15 the cleanup system should be based on --
l 1
DR. MOELLER:
That would help tremendously.
l 16 I
I7 DR. SIESS:
Yes.
l 18 I had tha.t highlighted in my original copy, that l
I9 there was a comment that that sentence could be rewritten.
20 Staff says, why should we rewrite it?
I 2I MR. STEYER:
I think we can make that change 22 casily.
2 DR. SIESS:
The design of cleanup systems should 24 be based on a continuous opera tion over tne expected life of Ao erst Reporters, Inc.
25 the plant; or cleanup sy, : ems should be designed for continuousi
jrb32 32 i
i l
I operation.
2 DR. MOELLER:
Tha t would be even better.
I i
3l DR. SIESS:
Over the expected life of the plant, l
4 or the maximum anticipated service life of the cleanup system. !
l 5
DR. MOELLER:
That would be better.
6 MR. STEYER:
Operating for 40 years?
We're operatinlg 7
off and on for 40 years.
I don't follow that.
i I
8 DR. SIESS:
Right now it should be based on l
9 continuous operation for the expected life of the plant, 10 !
for the maximum anticipated service life of the c;- 2nup system.-
11 Now, let us back up a minute:
i 12 I can read this, the design should be based on 13 the assumpuion the system will be opera ted continuously for the expected life of the plant, or opeta ted continuously for l
I4 15 the maximum anticipated life -- service life -- of the cleanup 16 system.
I7 Is that what it means?
You just said intermittent l
l 18 operation, which doesn't say anything.
It says continuous I9 I operation.
20 MR. CARDILE:
Well, continuous doesn't mean i
I i
21 continual, which means nonstop.
Continuous means it is used l
22 throughout the life of the plant.
23 DR. SIESS:
Then why is it necessary?
What do you j
24 mean?
.r.i seporms, inc. ;
c.
25 MR. CARDILE:
It's not really necessary to have that i
jrb33 33 l
I word there.
2 DR. SIESS:
The systems should be used to design 3
for the life f ar the plant or the life of the system. If that 4
is what is means, the whole sentence can come out.
There's l
5 no other choice.
l See, a system either lasts its life or some other l
6 7
life; and those are mutually exclucive, 8
(Laughter.)
9
-- and all-inclusive, I think.
i l
10 Think about that sentence and tell us what it i
11 l
means?
I2 You tel! me what it means, and I'll rewrite it for f3 you, to say tha t.
I I4 (Laughter.)
15 MR. CARDILE: It just says design the system the best you can to make it work as long as it works.
It doesn' t l 16 l
I7 say very much.
18 DR. SIESS:
Yes, it doesn't say very much.
MR. CARDILE:
Perhaps it could just as easily not l
20 be there.
2I DR. SIESS:
As I recall the comment you got on it, 22 it was that it was just not clear.
23 Did anybody find that?
24 (No response. )
4 Ac wal Reporurs, lm.
25 '
I don' t think it offered an alterna tive.
If it did, I
t
jrb34 34 0
I it would help, because it would tell us what they tluught i t 2
meant.
3 Thit is always a cpod way to find out from.<omebody,
d el se, h3w they read it.
1 5
liR. CARDILE:
T here i s a omment f rom ASME.
l 6
DR. SIESS:
How far back i s t hat in thi s stack?
I 7
MR. CARDILE:
The O venth, near the back of tln l
i 8
stack.
9 DR. SIESS:
I' ve found i t.
10 '
The mntence i: poorly co nstructed, sugge st the i
11 following wording:
cleanup system de sign slould be based on i
I2 continuou s opera tion --
I3 MR. CARDILE:
That ' s still a statement tha t doe sn' t I4 say very much.
I 15 MR. STEYER:
It' s no t ce nyeying much information.
l I0 DR. SIESS:
Are you sure i t doe m' t say something I7 we haven' t figured out let?
i 18 I f ro t, delete i t.
l I91 (Laug h ter. )
20 MR. CARDILE:
Like yau are saying, it' s either l
I 21 de sign for its own life or for the life of the plant.
I I
i 22 l DR. SIESS:
It's obviously replaceable.
23 MR. STEYER:
We think we should delete i t.
24 DR. SIESS:
Try that.
Shall we delete i t?
ce eral Reporters, Inc.
25 DR. MOELLER:
Yes.
l 3
jrb35 35 I
DR. SIESS:
So that nobody will read into it any-2 thing we didn' t see?
3; Anything el se, Dade?
4 DR. MOELLER:
Speaking of deletio rs, do we agree 5
t rat i t is probably be st to delete the insert at the bottom or 6
page 3, w he re you added "and instruments"?
7 If you clange the scope, I think then if you just 8
put t hi s back t he way i t wa s, you are in better shape.
9 (Choru s of "Ye s. ")
l 10 !
MR. STEYER:
Because it will be explained more l
Il l
clearly elsewhere.
i 32 DR. MOELLER:
Ye s.
13 13en y) u don ' t ge t into t re problem o f sa ying you i
Id are poi sa ning a n trument s.
15 DR. SIESS:
You get into the same problem I mentioned be fo re :
you have statenent s made in the discu ssion that are l
16 I
I7 no t clearly related to portiors of the positio n.
If y3u want 18 to mentia n instrument s in the discussion in rela tion to c3b,
{
19 l fine.
But general statemer. s are just going to confuse people. l 20 Okay.
We have an addition at the end of the para-l 21 grap h, next to the la st paragraph in the introduction.
I 22 And we deleted o rn sentence, and the word s "and 23 instrument s".
24 Anything else yau would like to propo se?
A wal Roorters, lM.
25 DR. MOELLER:
No.
l I
I
jrb36 36 1
l DR. SIESS:
Bill Kerr?
I I
2l DR. KERR:
Yes.
i 3
i On page 3, on tie scond paragraph in which there I
d' is a li st of environmental conditio ns that are to be wi th stood, 5
six line s down, "atno spluric pre ssure" -- what doe s thai.
l 6i me n?
7 Doe s it mean o ne side of the fil ter to the o ther?
i i
8 One slould be able to with stand 15 or m p si?
Or 9
doe s i t j ust mean it should be able to operate in the atmosphere 10 '
rather than in a vacuum?
MR. CARDILE:
It mer n s the conditions around tle I2 filtration uni t, it l'a s to sur' ive.
13 DR. KERR:
Is i t supposed to give a differential Id pre s sure?
15 I do n' t krow what i t' s telling me.
16 MR. CARDILE:
No, it's ro t differential pre ssure.
I I7 DR. KERR:
Then what does i t tell a de signer that 18 would guide him in de signing i t?
I9 !
DR. SIESS:
It says in normal environmental condi-20 tio n that tlu m atnospluric c eanup s should wi thstand, or 2I atmospheric pre ssure is one of tle normal environmental I
i 22 co nditio ns.
j l
23 Do e s t hat mea n 14. 6 ab olu te, o r something elm?
l 2d DR. KERR:
I am ro t disagreeing with anything; I A
al Reponm, Inc.
25 j u st don ' t know wha t t he statement i s telling me.
i l'
1 i
jrb37 37 I
MR. STEYER:
I gue ss it's telling you there's no 2
higher pre ssure than atno spheric involved here; "with stand "
3 may be a little strong.
" Experience" might be a better word.
4 DR. SIESS:
What abou t a subatro spheric containment?
l 5
MR. STEYER:
There still i s a dif ferential between 6
in side and ou tside.
7 DR. KERR:
If it's telling me abou t differential, 8
tha t' s o ne thing; but if I am just being told normally it will 9
operate in t h3 atmosp here?
l f
10 '
MR. STEYER:
The atmosphere of the compartment or II room it' s in.
I2 DR. KERR:
Well, it still isn' t telling me anything.I 13 I am ju st trying to find ou t what i t i s telling me; because l
Id I don' t krow what it's telling me.
i 15 DR. SIESS:
Bill, are pu no t clear -- you make 16 l the distinctio n between atmospheric pres sure and the pre ssure l
17 of the surrounding atmo sp hare?
l 18 DR. KERR:
I thought maybe i t was giving me mme t
I9 indication of maximum pressure drop, I would say at some point 20 the difference be ' feen atmospheric and zero, sa y.
l 2I Apparently, i t' s no t saying that.
I just wanted to l 22 be sure what it is sa ying.
23 DR. SIESS:
Sometimes when you see "atmo spheric 24 l pre ssure " you translate that in your mind to 14.5 psi, ab solute',
i ce!
real Reporters, Inc.
t 25 as being the pre ssure of tln surrounding atmo sphere, which muld I
i t
jrb38 38 I
be something elm.
2 MR. CARDILE:
For instance, inside a subatmo spheric 3
containment.
j 4
DR. KERR:
I'm just not sure what a designer doe s l
l 5
when he see s t ha t tha t i s dif fe re nt than he wo uld do if it l
1 6
weren' t there.
I I
7 DR. SIESS:
Yo u mean o ne o f the conditions it must 8
wi thstand is pre ssure in the atmosphar of the containment 9
under normal opera ting conii tions?
10 I MR. CALDILE:
Ye s.
II DR. SIESS:
It cbesn' t have to withstand accident 12 condition s?
13 DR. SIESS:
Right.
l I4 (Pau se. )
15 DR. SIESS:
It really doe sn' t tell }ou tha t, I
16 gue ss.
I7 MR. C ARDILE :
Well --
18 DR. SIESS:
It's defining Inrmal environmental l
co nditions it' s no t calling it a Inrmal enviro nme ntal condi tiohl.
1,-
It says "the normal environmental co:ditions that i t should i
20 I
21 wi th stand are : ".
I 22 MR. CARDILE:
Well, in other words, I gue ss the i
23 i
point is, they don' t have to design for the LOCA pre ssure s; i
24 that is why it is excluding LOCA pre ssure, for ins tance.
cv val Reoorters, Inc.
I 25 MR. ETHERINGTON:
Why don' t you make ano ther sentence l
t
jrb39 39 I
o u t o f i t?
Systems will be de signed for operatio n in atmos-2 pheric pre ssure.
3 MR. CARDILE:
It's more of an exclusive statement 4
than i t is --
l You see, v7 en you talk about the normal !
5 DR. SIESS:
h 6
atmo spheric pre ssure, you can say if p u want to, repeat
" normal", and i t ' s to t a repe ti tion, but it' s a 10-6 microcurie!s 7
O per centimeter is no t rormal; that' s a condition tha t exi st s 9
in reactors; 100 percent humidity of 125 F is not Iormal.
i 10 l MR. CARDILE:
Tha t's right.
I 11 i
DR. SIESS:
An atmospheric pre ssure is 14-1/2 i
12 p si ab solu te.
That 's to t what p u me an; i t's whatever is norm 1 13 for that containment.
I I4 I
MR. CARDILE:
Right.
15 MR. STEYER:
Remove the word " normal"?
l I0 DR. SIESS:
I was going to put " normal" in front 17 of "atmospharic pre ssure s" or something like tha t; I am stil IO not sure, though.
I mean putting " normal" there means ro t " accident".!
l9 20 MR. CARDILE:
Tha t's the meaning of what we want to I
21 say, thoug h.
22 DR. SIESS:
I don' t know if tl'a t helps, Bill, or 23 rot?
Do you know wha t they mean?
24 They mean i t doe sn' t have to wi thstand accident ci
'rsi Reporters, Inc.
25 pres sure s.
l i
I
jrb40 40 I
DR. KERR:
Ye s, now I understand.
2 DR. SIESS:
Now, if you know that, do you get i t I
i 3
I out of wha t i t says?
4 DR. KERR:
I could with an exegisis of the kind we l
5 have j u st he ard.
I i
6 MR. CARDILE:
Put " normal" in front of the word 7
" a tmo s phe re " ?
8 DR. SIESS: It wouldn' t hurt i t.
i 9
DR. KERR:
And then the next senten ce, I am not 10 I sure what i s me ant by t he system should be operated in such a II manner that radiation level s and radioactive ma terials do not 12 deleteriously affect the operation of the filter system and l
13 compone nt s.
14 How doe s one operate?
What operational maneuver s 15 does one carry cu t to make sure t hat t ha t ' s t he ca m?
16 Wha t am I being told?
17 MR. STEYER:
I don't believe there ' s any opera ting 18 maneuver involved.
l9 l DR. KERR:
What is meant by the p hrase " sho Ad be 20 l operated in such a manner that- "?
21 DR. SIESS:
ilhy doe s this guide discu ss operation, 1 22 l if it' s de sign, maintenance and te sting?
I 23 l
MR. CARDILE :
That is just a general reference to tej l
24 f act that you reach -- when you do your radic ion test, or At wat Rmorurs,1N.
25 l testing on the c larcoal absorbers -- it's pointed out later on !
i i
jrb41 41 1
in the guide that if you come across a si tuation where you 2
need to replace the ab sorber bed, tha t's w hat you will do.
3 DR. SIESS:
I sa ' t that mai nte nance?
4 MR. CARDILE:
It's maintenance, but, in o ther words,l 5
you would have to change ou t a t tha t time.
You could not 6
co nti nue.
7 DR. SIESS:
It ha s nore than Gne meaning.
8
" Operation", a s you know, is the day to day running l l
9 o f t he t hing, how ya u turn i t o n and of f, I gue ss; opera tion l
10 !
also includes maintenance and te sting; right?
l Il Those are operating functions of the plant.
12 MR. CARDILE:
Well --
13 DR. KERR:
I am not disagreeing with wha t you are I
14 saying.
I am just no t sure what the sentence means.
15 MR. CARDILE:
Another way to say i t would be the i
l 16 system should be maintained in such a manner, in o ther words,
(
17 if you find it needs to be changed out, change i t ou t; don't 18 continue to run.
19 DR. SIESS:
I think Dr. Kerr was inferring j
20 operational meant how you turned i t on and off, how you controlled l
21 thi s, or the f an rate s, or something else.
i 22 DR. KERR:
I wasn't sure what i t meant.
23 MR. CARDILE:
It's just no t really discussed in thisl I
24 guide.
l Ac wal Rmorters, lm.
25 DR. SIESS:
No.
jrb42 42 I
I i
I MR. CARDILE:
In the context of this guide, it 2
really should say " maintain".
3' DR. SIESS:
That's what I would think.
I i
I 4
MR. STEYER:
Do you have ano ther wording?
8 l
5
" Maintain"?
Do you have a preferred word there?
i 6
DR. KERR:
Uhen I knou wha t you are trying to tell 7
then I am better able to say it.
me, 3
What you are saying is filter s should be changed 9
before radiation levels become harmful, or something of tha t l
10 i so r t.
I would understand that statement, if I knew at what j
II level radiation became harmful; and pe rhap s t ha t ' s so well i
12 understood one doe sn' t have to redefine i t.
13 If tha t is what you are trying to tell me, then the i
Id sentence like tha t would tell me that.
15 DR. SIESS:
I gue ss it could also mean if you got t
16 more than one train, you should cut one train out and put the 17 other one in, if you reach those levels.
l IO And that's a tech spec type item.
I9 DR. MOELLER:
Is it the expo sure levels what i t 20 should have said?
Is it the exposure level?
Is that when you ;
i 21 shu t a bed o f f ?
Or do you watch for breakthrough of activi ty, l 1
22 and when a bed is saturated, you swi tch over to the othar one? l 23 DR. SIESS:
Tha t is operation.
?#
DR. MOELLER:
Well, then, I don't follow this,
.m._....,
ei ther.
l 25 I
jrb43 43 l
l i
I Because when have you ever shut of f a bed or maintained 2
a bed because the radiation absorbed iodine and noble gasses 3
o n it go t so high tha t the radiation was too much?
I 4
MR. CARDILE:
I don' t think that's the determining l
5 factor; I think it's tre breakthrough.
l 1
6 DR. MOELLER:
Bre akthro ugh, sure.
7 And, fur the r, if you have a bed where the radiation I
8 is deleterious to the components, we long ago, you know, looked; i
9 at the binders for filter s, the frames, all of this, to make 10 I sure th3y would not be damaged by the radiation they were going Il to experience.
12 That was a problem years ago, which was solved.
13 MR. CARDILE:
Yes.
I 14 In fact the N509 document calls for certain 15 material s; ye s; t hat ' s ano the r t hing.
16 DR. MOELLER:
Ye s.
17 MR. CARDILE:
1 c this statement is alluding to.
18 DR. SIESS:
If you change it to " maintenance" would i
19 I tha t do i t?
20 DR. MOELLER:
Until I know wha t is being said --
i i
21 DR. KERR:
Yes.
l 22 MR. STEYER:
It's in the discussion, which is suppos5d 1
23 to sort of clarif y things.
We can remove i t.
j 24 l DR. MOELLER:
As you are speaking now, you are saying 6
real Reporters, inc. '
j 25 the systems should be designed and co 1structed in a manner i
i s
jrb44 44 l
I and using compo nents such that the exposure levels they are l
2 i
going to experience won't deleteriously affect the operation i
I of t he system.
f 4
Is tha t what you are telling us?
If so, that's
[
l 5
good.
l 6
MR. CARDILE:
De sign, test and maintain, which is 7
the title of the guide.
8 DR. MOELLER:
Ye s.
i 9
DR. KERR:
This is a subjective thing, but I 10 1 like " degrade" the performance rather than " deleteriously i
11 affect the opera tion".
But that's purely subjective.
l I2 DR. SIESS:
Would you rather replace "oparating" by design, testing and maintaining?
13 I
I4 MR. CARDILE:
Ye s.
15 MR. STEYER:
Okay.
16 DR. KERR:
On page 4, all components of the atmosphere 17
-- this is the fir st full paragraph -- is tha t j u st a i
18 "mo therhood " stateme nt?
Or --
19 First se nte nce, first full paragraph on page 4, 20 beginning "all components".
I 21 MR. CARDILE:
Tha t gets back to the f act tha t t ha l
22 spe cific, good, de sign s, if you will, are in po sibion and 23 this se nte nce is really j u st saying in general terms you should, 24 follow the posi tions.
Ao.
nel Reporters, lm.
25 I
DR. KERR:
This is a statement tha t could be made l
l i
jrb45 45 I
about any statement; it's.4o t spe cific.
2 MR. CARDILE:
Ye s.
3, DR. KERR:
Okay.
I 4
On page 5, I gue ss we ' re down to " position"; the t
5 third line in la, based on maximum -- it seems to me it would 6
be better to talk about the range of anticipated parameters, I
7 rather than the maximum.
t 8
I can anticipate, for example that the se things 9
might freeze; that may be a ridiculous example; but it seems 10 '
to me you want to operate over a range of parameters, not II nece ssarily at t he maximum.
12 Do n ' t you want them to be able to be operated at 13 minimum and maximum?
-- unle ss y3 u only want to look at the I4 i
maximum?
15 But I would think tha t one would want to ba se it 16 on the range of operational parameters -- wha t was your word, I7 Harry?
18 MR. ETHERINGTON:
" Extreme".
I9 MR. STEYER:
Substitute " extreme" for " maximum".
20 DR. KERR:
I j ust want to make sure I know what I
21 the y are a sking.
22 l I would think they would want it to operate, 23 the design ought to be ba sed on 6e complete range of opera ting ;
24 pa rame ter s.
Ac
'ersl Rmorters,1%
i 25 MR. CARDILE:
Ye s.
Last month we talked about not i
l I
i
jrb46 46 I
putting in the lower range on the iodine level, but only put 2
in the maximum range on the radia tion level.
Here, I can see 3
your point.
It is important to have both ends of the range.
4 DR. KERR:
I don' t know wha t the intent is.
Wha t 5
am I being told?
Wha t, for example, is an area of "high 6
radia tion" during normal plant operation?
7 MR. CARDILE:
If a particular filter unit is 8
located near another component which is radioactive.
9 DR. KERR:
No, but is " high" one mr per hour, 10 '
or 100 r per hour; or is it clear fro m some o ther guide l
II w hat i s " high" ?
12 I mean, for example, how do I know how much shielding 13 I need to install?
Id MR. STEYER:
We added " components and personnel".
15 DR. KERR:
Yuh, bu t what shielding do you require l
l 16 for a person?
I7 MR. CARDILE:
Shielding for a particular loca tion, I
18 whe re they locate their filter -- the frequency of maintenance I9 needed in this particular area, whether they de sign --
l 20 DR. KERR:
So you are really not concerned about the:
l 2I sy stem, bu t abou t the people; is that it?
I 22 I
I s that the intent?
23 MR. CARDILE:
That's wha t we added la st time, 24 people are the controlling factor here.
l 4e r.i n. corms, inc.
25 DR. KERR:
I s it po ssible you could locate one of i
1
jrb47 47 I
the m in a radiation field high enough that it would degrade 2
the performance of the system, with no people around?
3l MR. CARDILE:
It's possible if you put very little i
I l
shielding between it and another higher radioactive component. i 4
At 10 mr per hour, would i t be degrad'ing?{
5 DR. KERR:
6 MR. CARDILE:
At 10 mr per hour?
7 DR. KERR:
I am a designer, n3w:
I am being told i
8 something -- at 100 r per hour, would it be degrading?
l 9
MR. STEYER:
I think we are leaving tha t up to the 10 !
de signer, him se lf.
II DR. KERR:
Then you are noc giving him any guidance.
I You are just leaving it up to him.
Maybe you don' t need to giv'e 12 13 him any guidance.
Id MR. STEYER:
You're not giving him any detailed 15 guidance.
16 DR. KERR:
As a de signer, I would not know what 17 guidance I was being given h3re.
18 MR. CARDILE:
I think the guidance would be he has I9 to check the radia tion levels, damage levels --
20 DR. KERR:
But you don' t say that, i
21 DR. SIESS:
You don' t say tha t.
On one you say l
22
" deleteriously affect" and here you say " adequate shielding".
23 You don' t give him any criteria.
If you have to cut the life i
24 of i t down to two year s, is tha t "adequa te s hielding"?
r i neoonm, ene. ;
25 l DR. KERR:
Put yourself in the shoes of a man 8
i i
jrb48 48 i
1 i
l I
who goes to this guide, as people sometime s do, a reviewer, l
2 [I l
who ha s seen the per son commit to this guide; what does this j i
i 3
tell the reviewer to look for?
And what does it tell the i
i de signer?
I l
5 It doesn't tell me much.
l i
6 The designer may say, I know I have good shielding; l 7
the. reviewer says, no, you don ' t.
I 8
How do you settle the argument?
I l
9 MR. CARDILE:
Well --
i 10 !
DR. SIESS:
Number of rems?
II MR. CARDILE:
The de signer has to check the I
i 12 radia tion tolerance s of the uni t, the charcoal, and depending l l-13 on the area that it is in, he has to make sure he ha s enough I4 shie lding.
l 15 DR. KERR:
You are pretty certain your reviewers 16 would know this, jus t by looking?
l I7 MR. CARDILE:
No.
Wha t the radiation tolerance s IO are?
DR. KERR:
They have to review using this guide, 20 if somebody commits to it.
I 21 MR. CARDILE:
Tha t's right.
l 22 l
DR. KERR:
They will know what radia tion levels the h
23 l guide refers to?
2#
MR. STEYER:
They are suppo sed to know from other nel Rmorms, W. l j
o 25 '
area s.
l I
I
jrb49 49 I
DR. KERR:
You gentlemen apparently don't know it.
l to give you a specifilc 2
MR. STEYER:
We don' t know i t, 3ll i
figure; that's correct.
l l
4 MR. BENDER:
Are you suggesting they add some thing l
5 like, to take account of radiation damage effects and per&>nnel 6
exposure?
7 DR. KERR:
If that is the intent.
l t
i 8
MR. BENDER:
It seems to me a couple of qualif ylng i
l 9
statement s like that would help the guide out; and no t interfere 10 !
wit h the intent.
II Although, as a de signer, I wouldn' t be bo thered 12 by not having it; but I can understand Bill's point.
13 DR. KERR:
Ye s.
14 DR. SIESS:
How do we settle tha t?
15 DR. KERR:
I don' t know how to settle i t.
16 If what I am being told is one must design a system 17 so it won't be degraded by the radiation field in which it 18 operates, that is one thing.
DR. SIESS:
And that personnel can get to it for I9 20 maintenance?
l 21 DR. KERR:
That doe sn' t say anything about shieldingl i
22 at all.
I think you need to say it, if you de sign i t so it 23 will operate in the radiation field in which located, you don't i
24 need shielding.
e n i neoorveri inc.
25 And, obviou sly, if you can ' t do tha t, then you have i
jrb50 50 I
to use shielding.
2 MR. CARDILE:
I think generally the se filter uni ts l
3 are located in areas which are -- have low radia tion levels, d
per sonnel radiation levels, a ssocia ted with them.
I think tha t l
5 would be the more stringent requirement, namely, the personnel l 6,
shielding requirement s.
l t
7 DR. KERR:
I don't disagree, if tha t's what you f
I 8
have in mind.
f 9
MR. BENDER:
I am not sure you stated the case 10 '
to tally; normally, you are right:
per sonnel.
But that is II because most of the time th2re is no radioactivity there of 12 significance.
13 But if you had an event occurring in which you are really fil tering radioactivity, and you might not be able to Id 15 get at th3 filters for a long time because of radioactivity, 16 you might want to think abou t tha t:
whe ther things that were I7 there that were organic in nature, for example, as wood is, 18 whether it would maintain i ts integrity all along.
DR. KERR:
Mr. Be nder, I don't want to disagree 20 wi th you, but we' ve been told this addresses normal opera tion, 21 and not post-accident opera tion.
22 l Am I interpreting your comments correctly?
I l
23 l
MR. CARDILE:
Ye s.
MR. BENDER:
I gue ss I would have to say it depend s ce
>ral Reporters, Inc.
25 eventually on what the filter's purpose is.
Is tha t really I
i i
jrb51 51 I
all we are saying?
We are dealing with these filter s only 2
with every-day events, nothing else?
3 DR. SIESS:
Right.
Normal ventilation filters.
t I
You are not going to pay any attention l 4
MR. BENDER:
t 5
to what they are going to be used for in o ther circumstances, 6
even right now, with some of the events going on around the 7
country?
l 8
DR. SIESS:
I think that got se ttled, Mike.
l l
9 MR. BENDER: Okay, sorry I got ht.re la te.
10 !
DR. KERR:
I have indica tnd my puzzlement.
I do not know what to do with it.
12 Le t me go to 2 a5, e:
the sentence following 2a5, 13 I gue ss it's part of 2a3, now.
Id The stateme nt, if it is de sired to reduce the 15 particulate -- what?
-- doe s that sentence mean to tell me 16 I
if I don't want to reduce the particula te, I can ignore i t?
i I7 But if I want to reduce the par ticulate, I should put 18 in a prefilter?
1 MR. STEYER:
That's right, if you don' t put the 20 prefilters in.
i 2I DR. KERR:
This sort of says, hey, if you want them i 22 to last long enough, put in prefilters; but it's a matter of 23 choice.
It is not a position.
h.R. CARDILE:
That.s a preferred way of doing it.
l Ac eral Reporters, Inc.
It's not a position.
l l
4
jrb52 52 l
I DR. KERR:
Seems to me as it is worded, it is not a position; if it is not a position, it ought to be in the 2
i 3l discu ssion.
I i
4 I don't feel strongly about it.
It just seems to l
l 5
me it really shouldn't be in the position.
l i
6 Tlrn in par t b of 2, apparently some of our consul-l t
7 tants commented that there were indeed testing systems avail-l 8
able for more than 30,000 cubic feet per minute.
I don't know 9
about this.
10 !
But if tha t is the case, i t seems to me 30,000 l
II cubic feet per minute is rather arbi trary.
And I do not see 12 the need for the arbi trarine ss.
IS Dr. Moeller, you do not have difficulty with that?
i l
I4 DR. MOELLER:
It! s been argued back and for th l
l 15 many time s.
I guess I have nothing additional to contribute 16 l
to the discussion.
I7 DR. SIESS:
There are some words there.
At the beginning we added some.
DR. KERR:
Adding that doesn' t give you the I9 20 significance, unle ss it ha s significance.
I 2I MR. CARDILE:
We looked at the nuclear air cleaning I 22 l handbook and talked to some people back on the Staff and 23 at the pre sent time they feel there is sufficient confidence 24 in testing at hi gher flow rate s than that.
As we discussed ce tal Reporters, Inc.
l I
25 last time, this is the number we feel reasonable.
There is l
t
jrb53 53 I
nothing to say someone can' t come in and demonstrate, take 2
an exception to this reg po sition; and demonstra te.
3 l
DR. KERR: Is 30,000 feet based on some existing 4
system which system will handle 30,000, and you are pretty I
l 5
certain -- or is it a reliable system that will go beyond that?'
6 MR. STEYER:
Certainly there are 30,000 feet per 7
minu te systems that are reliable.
I am no t cer tain about othe 8
higher ones.
9 MR. BENDER:
How is it you know tha t?
l 1
10 i MR. CARDILE:
One of the ways we've been looking through the air cleaning handbook.
I2 MR. BENDER:
I know.
I don't know if it can back 13 up that number.
I#
What you are trying to do is make sure your filters 15 dn't get so big the air distribution is hard to control and i
16 channeling doesn' t occur.
I think there have been engineering I7 judgments made about this 30,000.
I am somewhat doubtful tha t 18 it is meaningful, or that there is engineering experience to verif y tha t nun.ber.
20 If I am really doing it seriou sly, I would probably:
l 21 look to see whether there are some flow distributions that I
l 22 would be desirable.
I think for this kind of applica tion, i t' s:
23 not tha t important; if the filter leaked occasionally, weren't 24 all that ef ficient, it might no t make that much dif ference, A
al Reporters, Inc.
25 if it's just normal ventila tion systems.
l I
jrb54 54 I
I don' t think the guide has to be all that rigorous.
2 DR. KERR:
30,000 is okay; ye s.
"q DR. SIESS:
In the previous discus sions, Staff 4
had argued the reason for the 30,000 is that they were not l
5 generating; and it was pointed out they were, and Staff simply 6
came back and said, well, we still think 30,000 ought to be 7
a limit, and put the words in here to insure reliability in 8
testing.
9 DR. KERR:
I think we ought to help the Staff be 10 happy.
Il MR. BENDER:
I don't mean to argue abou t tha t I2 particular point, but I am concerned about the sacredness of 13 statements in tha t manual.
That's not a bad manual to use.
t l
Id But I promise yo0: the information in it is far from perfect; 15 and some of it may be wrong.
16 There ought to be some cautionary thought given to 17 th a t.
18 DR. KERR:
On page 6, under 3b, why must a test be done by the manufacturer?
I9 20 DR. SIESS:
There was a lot of concern before, if it:
i 21 had to be done by anybody else, it was a problem; tha t's why j
22 the manuf acturer was put in.
23 MR. BENDER:
I sugge st you add "or an independent 24 testing agency".
o tral Reconers, lre.
MR. CARDILE:
Wasn't that the concern before?
I l
l
55 jrb55 I
They were concerned they had to go to the DOE.
2 MR. BENDER:
I am not pre _luding the use of 3
manufacturers; I just say as an alternative it ought to be 4
in there.
5 DR. KERR:
l'here may be good reason for this.
I am ;
I 6
not being cri tical, I just don ' t know what it means.
7 DR. SIESS:
It just means a test has to be made a test can be arranged by the manufacturer l.
8 by the manufacturer; 9
DR. KERR:
As I read it, it says to me it should i
l 10 t be tested by the manuf acturer.
How come?
There may be a very ;
I II good reason?
I2 MR. CARDILE:
It was put in there as a result of 13 public comment which said, they didn' t want to have to send all; I
I4 of this to the DOE station.
T hat is not to say, that the 15 manufacturer, if he has a station close by, cannot --
i i
16 DR. KERR:
Gentlemen, I know reviewers use this l
17 guide, and a reviewer who is a stickler for legal language i
18 he finds an applica tion committed to this guide is going to I
I9 interpret that to mean it has to be tested by the manufacturer.
l 20 DR. SIESS:
I am not sure what you mean, though.
1 21 You mean he is going to interpret it that the manuf acturer, f
22 l persanally, must make the test?
l 23 DR. KERR:
It says " tested by the manufacturer. "
i l
24 I don't know wha t that means.
a, tral Reoorters, Inc.
25 DR. SIEf'S:
I'll tell you what it means.
jrb56 5F t
I Maybe we can find better words:
the original l
words were interpreted to mean they would have to be tested 2
i i
3 I by the utility or the AE.
I I
i 4
MR. ETHERINGTON:
Where would they get that l
5 inference?
6 DR. KERR:
I don't see how you can interpret it l
1 that way.
j l
8 DR. SIESS:
Let me find i t, i t will take a minute.
9 (Pause.)
I i
10 !
MR. CARDILE:
It was a manufacturer or his agent.
j i
II DR. KERR:
If that's your intent...
l 12 MR. CARDILE:
That's our intent.
13 DR. KERR:
It would no t be acceptable, for example,,
i Id for it to be tested by the agent of a utility, or the agent 15 of an AE?
i 16 DR. SIESS:
The reference I find in here is to 17 c3a, that is on the hea ters.
l l
18 DR. KERR:
Ye s, sir?
I9 DR. SIESS: I haven' t found the other.
Have you found 20 i t?
I am looking at your response to the comments.
i i
l 21 MR. CARDILE:
Page 11 of our re sponses.
l 22 Further testing at DOE sta tions will result in 23 needless cost; tha t was the comment.
I 2#
MR. STEYER:
Looking at it now, maybe it would have l hel Recorters, lm.
a 25 been better to just have lef t it as it is.
We want it to be I
I i
jrb57 57 l
I tested, and leave it up to th9m.
2 MR. MORRISON:
I agree we ought to take it ou t --
l 3
"by the manuf ac turer" -- I don ' t think we care who does it.
4 DR. SIESS:
Consumers Power said this sec tion 5
require s testing -- is tha t the one?
6 The practice of testing each filter by the 7
manufacturer in combination with in-place testing as required 8
by posi tion c5 is adequate in itself; f ur the r testing of a 9
filter by the DOE Quality Assurance would result in needless l
10 cost.
l' And so he wa s interpreting it that this required l
II 12 f ur ther testing than the manuf acturer's testing.
Staff 13 changed it to testing by the manufacturer to remove that i
I4 argument.
15 MR. STEYER:
Rethinking i t, I think we would have 16 been better off to have left it out.
I 17 DR. SIESS:
I think so.
l 18 MR. STEYER:
We'll delete it.
I i
DR. KERR:
On page 7, position 4b, I gues s I am I9 l
20 the only one who considers three feet a very arbi trary l
21 specifica tion, which I don ' t understand.
I 22 DR. SIESS:
We've had that comment before.
23 DR. KERR:
I want to be consistent.
I 24 DR. SIESS:
Yes.
ce
'ral Reporters, Inc.
25 DR. KERR:
The wording -- I would like to know why l
l I
jrb58 58 l
l I
Staff said "for ea sy maintenance. "?
2 It could be three versus two-feet-ten-inches.
l 3
p DR. SIESS:
They didn' t get much flack from the 1
4 industry on this.
l l
5 DR. KERR:
It just seems to utterly illogical to l
4 6
me.
I hate to see something go out tha t says you don' t like I
7 to see Staf f designing those.
j i
8 I think Staff wants to be log. cal, but it seems to l
9 me on.his point they are no t being logical.
I want to help I
10 !
them.
DR. SIESS:
I think that's a statement I would like!
II 12 to have you prove.
We can debate that sometime.
13 (Laughter.)
I4 MR. BENDER:
Another way to do it would be to say 15 space shall be provided adequate to perform maintenance.
16 MR. CARDILE:
That's why we set a minumum of three I7 feet.
We don't think it should be less than three feet.
I 18 DR. KERR:
4a says accessability of components and I
maintenance should be considered.
Tha t's a good sta tement.
20 l You've got to worry not only about building, but maintaining.
1 21 I don't see b is necessary.
I 22 MR. CARDILE:
We say we want a minimum of three 23 feet.
24 DR. SIESS:
You are not being consistent.
Before Ac eral Reporters, Inc.
you were saying we are not specific enough so the reviewer would l
I
jrb59 59 l
I i
I have a basis for acceptance or rejection.
Here they are being 2 l!
very specific.
3 DR. KERR:
Well, --
Back up on the shielding it 4l l
was all deleterious and here you are being -- looking for a l
t 5
reason for it; if they can convince me three feet is necessary,'
l 6,
the n --
l 7
DR. SIESS:
Now you are putting Staff in a tough l
i 8
spot, and everytime they give specific advice, you want a 9
reason.
I 10 i DR. KERR:
Sure.
II MR. CARDILE:
We consider three feet to be the i
12 minimum anyone should try to put a human being in.
13 DR. KERR:
I thought six feet was the standard.
Id (Laughter.)
15 MR. CARDILE:
That's lying down.
I0 (Laughter.)
I7 DR. SIESS:
Yuh, they don't hire basketball 18 player s, huh?
I9 I (Laugh ter. )
l 20 DR. KERR:
You really think tha t three feet is l
important to safety?
l 21 i
22 MR. CARDILE:
It's not important to safety, it I
I 23 is important to maintenance.
24 DR. KERR:
This is a reg guide having to do with Ac wel Reporters, Inc.
25 sa fety.
8 I
i
jrb60 60 l
I MR. CARDILE:
We've got sections like 8.8 on layout,1 2
things like that.
I 3
l DR. KERR:
Then there were several statements from ;
i 4
industry about testing frequency of 18 months; Staff said l
5 we think 18 months is reasonable.
Then they referred back to 6
that comment the second time, which says we think 18 months I
7 is reasonable.
l l
1 8
Do you think it is reasonable because you see filters i
9 tested every 36 months, and that wasn ' t enough?
Or is 18 10 !
monti.m just trying to be a good, round, number?
l I
MR. CARDILE:
One of the things I noticed in reading I2 Dr. Moeller's report on the LER's is that when they checked 13 the ESF filter systems for the regular testing, they did find l
I4 some degradation in the LER's repor ted.
15 So I think the 18 months was arrived at as actr'lly 16 every refueling occurs.
I think you have a strong case for the i
17 18 months.
t 18 DR. KERR:
It seems to me in your commenc you didn'tl I9 make a strong case.
You just seid Staff thinks this is 20 reasonable.
You could have said LER's or something, some da ta, :
21 indica te tha t 18 months is needed for reliability, it seems to !
22 me it would have been more convincing to the people whom you 23 are addressing the se comments to, ra ther than just saying 24 Staf f thinks 18 months is rea sonable.
c.
rei neoornri, inc.
25 Those are all the comments I have.
l l
i
jrb61 61 1
DR. SIESS:
Mike, do you have any comments?
2 MR. BENDER:
A couple of points came up at the 3l last meeting that didn't seem to be addres sed.
4 One was, some discussion was held concerning whether l
5 the isotopic masses trapped ought to be identified in the 6
guide, or somewhere else.
7 You evidently decided that that wasn't necessary; 8
and I won.dered why?
9 11R. CARDILE:
We did some calculations.
We had 10 !
some calculations before the last meeting.
I think one of the j II big things that came up, iodine-129 levels; Dr. Parker pointed i i
12 out he wasn ' t sure of the numbers and the ght that might be i3 a de minimis questions for reactors.
i 14 We had some calculations we had done prior to that 15 on EPA criteria on iodine-129 levels, krypton.
i MR. BENDER:
Is it that iodine-129 is the only one I0 17 of interest?
18 MR. CARDILE:
Yes.
MR. BENDER:
Well, if that's the case, it puts the l
I9 20 matter to bed.
I just wanted to be sure of what.
l 2I ;
MR. CARDILE:
All right.
I 22 MR. BENDER:
The other question I wanted to ask 23 about was there were a number of comments about instrumentation i
24 being available to insure the filters were in good operating em trol Reporters, Inc.
25
~
condi tion.
l, e
jrb62 62 I
Did you give any more thought to that?
2 MR. CARDILE:
We just eliminated it.
Tha t's another' 9
j reg guide.
4 MR. BENDER:
I am sorry, if it's covered.
5 DR. SIESS:
Take my word for it.
6 (Laughter.)
7 DR. KERR:
I do have an additional question:
page 8
8, Sc, the sentence beginning a filtration system satisfies 9
this condi ti on can be considered to warrant -- if I substitu ted 10 I
" achieved", it would have the same meaning?
I wasn't sure i
11 wha t was meant by " warrant"?
I2 DR. SIESS:
I think when they warrant 99 percent i
13 the expect to achieve 99.9.
I MR. CARDILE:
" Warrant" only in the sense of its I4 1
15 use.
i I0 DR. KERR:
Okay, I just winted to be sure.
I7 DR. SIESS:
It:'.s really to warrant or justify the i
18 assumption of a 99 percent.
I9 2
( Pause. )
l 20 DR. SIESS:
Bill, I think that is editorial.
Do 2I you want to leave it?
22 DR. KERR:
I don't object to it.
23 DR. SIESS:
Do you have any more?
DR. KERR:
No.
ce tral Reporters, Inc.
j 25 DR. SIESS:
I a ssume Harold doe sn ' t, either; he just
jrb63 63 I
I walked ou t.
2 The changes proposed are to add a sentence end 3l of tha first paragraph, page 2; and to exclude "and 4
instruments" except the two type s mentioned on page 3; the l
5 word " normal" was to be in ser ted before " atmospheric";
l 1
6
" opera te" was to be replaced by " design, test, maintain" at i
l 7
the bottom of the page, and " instruments" was deleted; a i
I 8
sentence was removed from position la, page 5; "by the 9
manufacturer" was removed from position 3b on 6; those are i
10 all the changes I had.
Are all those change s agreed to be Staff?
11 I2 MR. STEYER:
Ye s, the y are.
13 DR. SIESS:
Does the subcommittee have any addi-I#
I tional comments?
15 (No re sponse. )
Those changes, is t he subcommittee ready to l
16 l
f I7 recommend to the full committee for full concurrence?
18 (Indications of assent. )
I9 There are no objections.
l 20 Can you get a marked copy to us by noon Friday?
I 2I l
MR. STEYER:
Ye 3, we can.
22l DR. SIESS:
Okay, then we will recommend to the 23 full committee.
I 24 The next item will be tle proposed reg guide ce tral f4eporters, Inc.
25 title:
" Cable Penetration Fire Stop Qualification Test for i
6
jrb64 64 I
Nuclear Power Plants".
This endorses IEEE Standard 634-1378, 2
IEEE Standard Cable Penetration Fire Stop Qualifica tion 3
Test, and it endor se s that with some exceptions.
In addition 4
we have been provided a copy of the IEEE standard as is 5
in accord with the Staff practice and they'd like to have the se 6
back when you are through with them, because they cost money.
7 To save time, if we just go through this and ask 8
what questions we have --
9 MR. MORRISON:
Yes, that will be fine.
I 10 !
DR. SIESS:
I've got few.
I'll take it page by j
l 11 i
page, and let anybody on the subcommittee comment.
Page 1, i
I2 any comments?
13 (No re sponse. )
i Id Page 2?
15 DR. XERR:
Mr. Chairman, l
DR. SIESS:
You are supposed to wait until I get I0 I7 to page 2, then go back to page 1.
l 18 (Laug hter. )
I9 DR. KERR:
Yes, sir.
20 I would suggest the discussion begin on line 11 of
\\
l 21 page 2.
I 22 MR. BENDER:
I was going to make the same comment, 23 for the same reason, -- which has not been stated.
24 It's superfluous and does not tell anybody anything.;
a nei nmarms, im.
25 MR. SULLIVAN: I am not sure of the comment?
l i
6
jrb65 65 I
DR. SIESS:
Tin first part of the paragraph should 2
be part of the introduction.
3 DR. KERR:
No, it should be, having wri tten it down 4
and gotten it out of sombody's system, it should now be 5
discarded.
6 DR. SIESS:
You want to propose deletion of the 7
first paragraph of discus sion?
8 DR. KERR:
Yes, sir.
9 MR. BENDER:
I have a particular reason for sugge st-'
l 10 I ing it be taken out; it's very embarrassing to look at something II identified in 1975 as being " urgent", and having taken until 12 1979 to get it out on the street.
~
13 MR. BATHROP:
That 's true.
l i
I4 DR. SIESS:
Any objection to deleting it?
i 15 (Chorus of "No".)
16 DR. SIESS:
Okay, delete it.
I I7 I have a question:
the paragraph beginning at line '
_____.__J___
18 16, line 17, it talks about when mounted in rated fire barriers, the followin[u'ordsare, the fire rated barrier.
l 19 20 Is there a dif ference between a fire rated barrier, i 21 and a rated fire barrier?
22 MR. BATHROP:
No.
23 DR. SIESS:
Fire rated barrier is used everywhere 2#
else.
e mi neoorms, inc.
25 Now, on page 3, line 7, you are back to rated fire I,
i
jrb66 66 I
barriers.
2 MR. SULLIVAN:
I believe " rated fire barriers" would 3
be the preferred term.
I believe it's the accurate term.
4 MR. BATHROP:
We'll change thu all to " rated fire 5
barrier s".
6 DR. SIESS:
The only tire ra ted barrier is on line 7
17; the o thers are all ra ted fire barriers.
8 Anytidng else an page 2?
9 (No response.)
10 1 Page 3?
j I have a problem with section 2.
Is the reference l II 12 to 512 on line 13 correct?
I have a great deal of difficulty 13 correlating a: finding that in the IEEE.
Now a 2 refers to 1
cable selection -- I found that; I don't think you mentioned I4 15 523; and I found 532; but I couldn' t find the cable penetra tion 16 fire stop module in 512.
i I7 MR. BATHROP:
Yes, sir, to an swer your que stion, it!
18 is a typo error; and it should be 513.
I I
DR. SIESS:
Okay, 513.
Tha t takes care of that.
20 Line 7, these requirements should be interpreted l
21 to include a s applicable -- and I understood a and b, but j
I' 22 I did not understand the "as applicable" as it referred to 23 e on the next page.
MR. BATHROP:
Applications in the plant where the f
- 4....,.. 24 25 cable will be terminated within two feet of barrier, then hooked l
i i
hrb67 67 I
up to some device like a junc tion board, or anything at all.
2 DR. SIESS:
If that cable termination is within 3
j two feet, you want that reproduced?
4 MR. BATHROP:
Yes, exactly.
5 DR. SIESS:
Tha t's what it means?
That's wha t I 0
thought it meant, but I wasn't quite sure; okay.
7 Let's go back to page T, any other comments?
l 8
I made mine.
9 DR. KERR:
No otner comments.
10 l DR. SIESS:
Page 4?
l i
MR. BENDER:
There's a couple of items I want to 12 ask about.
13 First, item 3, you have discussed intentional Id destruction of fire stop as one of the thing s that happens if v
15 you put in a penetration.
i I
16 My inclination is to question whether you are giving' i
I7 thought to the fact the fire stops may get degraded in some 18 form?
How perfect do they have to be installed, as compared
[
to their condi tion when tested?
l 20 That's the problem tha t came up at Browns Ferry, i
I 21 you know; they tested okay, if they were made right; but if 22 they weren ' t made right, they didn' t do too well.
23 MR. BATHROP:
We haven ' t addre ssed in there a s i t l
24 is installed compared to testing.
We have a procedure for l
a
<.i nmorms. ix.
25 building the test specimen, and you simply follow the plan.
l
jrb68 68 1
I think it would be worthwhile to put something 2
in to draw attention to that.
3 Now, there is a great tendency in the te sting 4
industry to generate a te st circumstance tha t is ro t repre en-5 tative of the field installation.
6 MR. SULLIVAN:
That's a gercral problem anywhere 7
in qualification of pro to type.
You always have the problem of 8
installing, a ssuring that the se are carbon copie s.
9 MR. BENDER:
I think a cautionary no te would be 10 I helpful.
Il DR. SIESS:
I do n' t kInw w ha t t he an swer is.
l 12 Build somet hing and te st it, and i t's probably going to be l
13 built better than the wor st thing in the world, probably betteE i
14 than t he average; but I don' t know how you do i t, unle ss you 15 know all the ways people can do it wrong, and incorporate those i
16 into the te st specification.
17 Nobody is that smart.
18 MR. SULLIVAN:
Prototype te sting really verifie s 19 de sign, it prove s tha ba sie de sign is capable of working.
YouI 20 have to rely on quality assurance and o ther technique s.
21 MR. BENDER:
- Again, the te st conditions ought to f
22 take into consideration the fact that it's ro t a perfect 23 installation.
That' s all I am trying to poin t ou t.
24 Tha other thing I though you ought to define better,
cr rel Reporters, Inc.
I 25 is the term " unsymmetrical" in i tem 4.
l i
I
jrb69 69 I
DR. SIESS:
That's what th3y tried to do.
2 MR. BENDER:
Let ' s ge t it straightened out.
3 DR. SIESS:
Item 4 refers to 535 in the standard, 4
and 535 ref er s to Figure A-7 on page 18 of the standard; 5
Figure A-7 shaw s a fire stop runsymmetrical with re @ect to 0
material; it shaw s material B on one side and material A on 7
the other side.
~
B go Mike's que stion wa s, i s mction 4 trying to say 9
that this is a " shall-should" problem?
Or is it trying to l
10 I redefine " unsymmetrical"?
j 11 i
MR. SULLIVAN:
Section 4 of the reg guide is trying i 12 to say it' s a " shall-should" problem, and may require te sting; 13' and we say we want to do it.
It' s no t the same on both side s.
I4 DR. SIESS:
Do you accept the definition of 15
" unsymmetrical" t*
have a s j u st a "may" versu s a " shall" ?
I0 MR. SULLIVAN:
Ye s.
j i
DR. SIESS:
Doe s that help you, Mike?
17 I
18 MR. BENDER:
Ye s.
I l9 DR. SIESS:
Okay, I wasn' t all tha t clear.
That 20 wa s my interpretation.
I don't me any way that I arrived at ;
l 21 tha t when I looked at it, though.
l 22 MR. BENDER:
You can' t fix th3 industry guide.
23 DR. SIESS:
It' s a " shall-should" type thing.
The next page?
l 4
ce eral Reporters, Inc.
25 DR. KERR:
Back to page 4?
Wht.is an interf ace l
jrb70 0
70 1
I I
type?
An interface is an interface.
I 2
MR. SULLIVAN:
For example, a cable jacket versus 3
copper; t hat ' s one t ype ; a fire stop interf acing with the wall !
l 4
is another one.
I I
5 Tiure are any number of kinds.
Now an interface 6
is a change in tin boundary between two materials; ye s,
- sir, f
7 i t i s a boundary.
I 8
Bu t we are no t saying you have to moni tor each l
9 interface, but representative type s, a s we say, a cable jacket '
10 !
versus copper interf ace.
And then you moni tor are ther II repre mntative type.
I I2 DR. KERR:
Well, an interface type is defined to be l l
13 any physical contact between dissimilar material; a rd to me,
i I4 that is any boundary.
15 So that says to me that an interf ace type is an 16 interface.
I mean, tln definition seems to say tha t; doesn't i
17 i t?
18 MR. SULLIVAN:
Yes.
I think we are no t as precise I9 as we meant to 1.3.
20 Dh. KERR:
I think I understand now what you mean.
I 21 Tha t was my que stion on 4.
22 On 5, on lire 4, there is a typo between stripped 23 and to?
2#
MR. SULLIVAN:
Ye s, sir, tha t should be within.
Ac eral Reporters, Inc.
25 DR. KERR:
Yuh.
I l
t i
jrb71 71 I
DR. SIESS:
Tha t took care of mine.
2 Line 5, temperature should be mea sured by thermo-l couple one inch away from each interface type mentioned above; 4
does everybody know in which direction that one inch is 5
me a sured?
6 DR. KERR:
Is that meant to be on each side?
7 MR. BATHROP:
It's under activities.
We would like 8
it to be on the surface of the fire stop, one inch away from 9
the interface type.
{
l 10 I DR. KERR:
One inch in either direction?
Do you j
l II want one one-inch on this side and one on the other side?
I I2 MR. BATHROP:
Only on the fire stop of the interface.
I 13 DR. SIESS:
You agree it's no t clear?
Id MR. BATHROP:
Ye s, sir, the thrust of it is to l
15 comment on tousekeeping violations that could generate a fire 16 on both side s -- a carboard packing box put against the stop.
I I7 DR. SIESS:
Couldn' t you say it a little more l
l 18 clearly?
i 19 MR. BATHROP:
Yes.
20 DR. SIESS:
If you can, I suggest you might do i t l
21 before you ge t it out for comment.
It might save you a couplel 22 of dozen comments.
23 Anything else on page 5?
2d (No re sponse. )
rol Reoorters, Inc.
Why doe s section 8 appear where it does?
l 25 l
jrb72 72 I
It refers to 533 of the standard, and i t follow s 612 ?
2 MR. SULLIVAN:
TMre's no particular reason.
3 DR. SIESS:
You can' t keep them all in order, 4
becau m you' ve got some of them lumped in that first one.
5 Perhaps you'll fix tha t up.
6 MR. SULLIVAN:
Yes.
7 DR. SIESS:
Page 6, any comments?
8 (No re sponse. )
9 Are there any other s?
i l
10 I (No response. )
Any objection to this going out for comment?
l II I2 (No re Eponse. )
13 Should we keep the m until we get it back?
I I4 MR. SULLIVAN:
That's entirely up to pu, sir.
15 DR. SIESS:
Okay, gentlemen, we 'll go on to the i
next one, which is Reg Guide 1.58, Revision 1.
T hi s,
- again, l
16 l
I7 endor m s ANCI Standard, ANCI ASME Standard N45.2.6-1978.
l 18 Actually it's a revision to update this from 19 the N45.2.6 - 1973.
20 And there are fairly extensive change s simply I
21 becaum a number of things that the previous guide covered l
22 have now been covered in the revimd standard; and there 's no 23 longer a need to mention it in tha guide.
2 The value-impact statement is a very clear statement; ce tal Reporters, Inc.
25 of the ba m s for all the change s in the guide.
Tha t is I
jrb73 73 I
extremely helpful; I appreciate it.
It's why positions have 2
been added, why po sitions have been deleted.
3 l
I personally didn't have any trouble with it.
4 Rat her than go through i t page-by-page, since these are fairly 5
extensive change s, I would like to a sk each member to comment 6
or raise que stions tha t they might have.
7 DR. KERR:
I found the material to be well-prepared 8
and straightforward.
9 I really have only one specific que stion:
I gue ss 10 I I have a general question to which there may not be any answer,j II as to why the standard required so many exceptions?
12 You adopt a standard and you can almos t rewri ts 13 the standard; and I get the impre ssion the original standard 14 must not have been sui table.
15 Is this standard worse than usual?
i MR. MILHOAN:
I think you are looking at the wrong l
16 17 document.
18 DR. KERR:
Sorry, I was looking at Qualifications of Elect: ic Cable s.
T hi s i s 1. 5 8.
I9 20 MR. MORRISON:
Were the complimentary remarks for 2l this one or the next one?
22 DR. KERR:
For 1.131.
23 MR. ETHERINGTON:
Is tha t " complimentary" with an 24 "i" or an "e"?
l cv mi neconen, Inc.
25 (Laugh ter. )
l l
1 i
jrb74 74 I
t I
DR. KERR:
I'll decide la ter.
I 2
(Laughter.)
3 MR. BENDER:
I'd like to act on wha t Dr. Sie ss said:,
4l l
I think it has been well done, really there ' s ver y li ttle to i
I i
5 say abou t it.
6 I would be interested in knowing what is going to 7
be at 1. 8; but i t's no t real impor tant.
8 MR. MILHOAN:
That's correct.
We have 1. 8 ou t for 9
public comment now; it should be back very s hortly to the 10 '
j committee.
II DR. SIESS:
Is there any objection?
I2 MR. ETHERINGTON:
Just one que stion:
Page 2, line 11, t he standards contain requirements !
13 i
Id indicated by tM verb " shall" and the set of recommendations 15 are indicated by tle verb " should".
It's kind of a statement i
16 of a fact.
DR. SIESS:
That's what they have been doing.
17 t
18 MR. ETHERINGTON:
Don' t you say what this mean s I9 I m f ar as tle guide i s concerned?
l 20 DR. SIESS:
Yes.
l 21 MR. MILHOAN:
I think it's amplified in tle following.
22 DR. SIESS:
It would be be st to point that out.
23 MR. ETHERINGTON:
I see it; right.
2#
DR. SIESS:
Is there any objection to putting this Ac_
wel Reporters, Inc.
25 out for comment?
l I
i
jr b75 75 l
l I
( No re sponse. )
i 2
DR. SIESS:
Okay.
l 3
The next guide, and the last one on our list, l
4
" Qualification Te sts of Electric Cable s and Field Splice s i
l 5
for Light-Water-Cooled Nuclear Power Plants"; this was issued 6
for comment and we've got comments back.
7 And normally they would have put out Revision 1, 8
including changes resulting from those comments; but this was 9
postponed because of the re search that was ongoing on the l
10 !
fire qualifications te sts the Underwri ters Lab was conducting. j II And when they got the results of those te sts, I2 there was apparently an evident need for changes in the guide; 13 and those have been made; since it was issued for public comment, i
Id and because of the nature of the change s, i t should be
(
15 reissued for comment at this time.
16 This endor se s IEEE 383, 1974, and I guess because I7 of the te st re sults tha t came in, you got extensive change s.
l 18 So le t ' s go by number, here, I think, rather than l9 bypage; is tha t all right?
The page s are rather long.
20 Bill, pu are our electrical expert; we'll let you l
2I start it off.
I 22 DR. KERR:
I reiterate my earlier comments.
23 And I am curious about the departure from the 24 standard, e ssentially because there are an unusual number of a
k i neoomn, ene.
25 departures.
I l
l l
jrb76 76 I
MR. HINTZE:
I believe we got on that the la st time 2
the same que stion, and the answer is the same:
the standard 3
was written initially as a guide without using standard 4
word s a s " like ", " should" and " shall"; and when i t got before 5
the IEEE Standards Board, it was somehow mysteriously changed 6
from a guide to a standard without changing the contents or 7l the sub stance.
8 DR. KERR:
IEEE will probably rework it.
9 MR. HINTZE:
There's been a working group on it in 10 I l
the la st two year s; ye s.
l II DR. KERR:
The only other comment I have has to do I
12 with re spect to public comment, comment number one, in which 13 the comment comments the air gas ratio was not reduced, and so I4 on.
I 15 And the Staff's response is the comment is correct, l l
however, the remaining required air come s from the a tmospMre. l 16 l
I7 I didn't understand what I was being told.
There 18 is a specification now. not of a five to one, but a five to eight l9 to one air-ratio.
But apparently that doesn't have any real 20 significance, because that air is some air, and there 's apparently 2I some other air coming from the atmosphere?
22 Can you tell me what's going on?
23 MR. HINTZE:
Being burned in the atmosphere, the 24 oxygen would come from the atmospMre, the one part of air to l
Ac:
mi neoonm. anc.
25 the part of gas is to M1p control the flame size and its l
'rb77 77 I
shape rather thru.
2 MR. ETHERINGTON:
I think the commenta tor was 3
perfectly correct.
You aren't burning oxygen.
Nobody in a 4
sense is burning oxygen and propane in an ordinary burner.
5 MR. HINTZE:
I talked to tin commentor on the phone 6
and he was satisified.
7 MR. ETHERINGTON:
Well, he shouldn't be.
8 You are burning air, you are feeding air into tha burner, and propane.
l 9
i 10 i l
MR. HINTZE:
Correct.
I 11 MR. ETHERINGTON:
And the amount of air is 28 1
12 cubic feet, the amount of air tha t you mix.
13 MR. HINTZE:
The amount of air that we mix inside i
I4 the burner itself is 5.
15 MR. ETHERINGTON:
If you burn 5 of air with 1 of propane, you have a smokey flame, you'll smoke up everything l
16 t
I7 completely.
You burn a stochiometric mixture of air and l
18 propane in a burner.
I9 MR. HINTZE:
I gue ss I don' t know.
It works.
20 MR. ETHERINGTON:
Where did you take your number 1
2I from?
l 22 MR. HINTZE:
From wha t? -- the 5 to 1 or 25?
23 MR. ETHERINGTON:
No, the 5 to 1?
DR. KERR:
It's been changed, by the way.
m tal Reporten, Inc.
25 MR. ETHERINGTON:
Ye s, probably because there 's a h
jrb78 78 I
little butane mixed wi tn it.
I 2
I mean, I understand you can get it just by writing 3
an equation.
But if you get it from a burner manufacturer's 4
handbook, you get 28 to 1.
You are mixing air.
All the air l
5 goe s into the burner, then you get this clear, blue flame.
6 MR. HINTZE:
You are mixing 5 to 1 within the 7
burner.
8 MR. ETHERINGTON:
No, sir.
9 MR. HINTZE:
Where does it come from, then?
10 l MR. ETHERINGTON:
You put all 28 of the air in the l
II burner and mix it and you get a blue flame with complete 12 combustion at the burner face.
13 If you only have 5 percent of air, you've only i
I#
got a fif th of the amount of oxygen you require for combustion.
15 MR. HINTZE:
I understand you are saying you can't burn the propane torch without mixing air with it first?
16 17 MR. ETHERINGTON:
Icanseeifyoudo,youjustgot; 18 a long, yellow, smokey flame.
You will soot up the whole burne,r I9 in a hurry.
i 20 MR. HINTZE:
I don ' t know wha t yo u a; _. tal king abou t, i
21 It works the way we've described it here.
l 22 MR. ETHERINGTON:
I am sure I don 't know wha t you 23 are talking about, ei the r.
I 24 (Laughter.)
ral Reporters, Inc.
25 DR. KERR:
Isn't it possible to use compre ssed air, l
jrb79 79 I
and pick up additional air from the atmosphere; the stuff 2
goe s in the burner, burns, has a 28 to 1 ratio.
3 MR. BENDER:
Harold's point is you don't get good 4
air mixing by using the air surrounding the flame.
If you 5
do t mix the fuel and air before you put it in the burner --
6 if you don't, i t probably doesn' t mix a t all.
A lot of the 7
fuel doesn't burn and you get a lot of sm6ke.
8 MR. ETHERINGTON:
Yes.
9 MR. FEIT:
I am Feit from Re search.
I 10 I The data cane from an experimental program where II the mixtures of air and propone were varied to see how it 12 affected the stability of the flame.
13 It is true you get a blue flame or a very yellow, i
I4 sooty flame if you oversupply oxygen and so forth.
15 But I think we are operating in a range, in a normal 16
~ ro le, whe re you ' 11 ge t a r e a sonable flame.
l I7 The problem the people have been having sound the 18 country in different facilitie s is the stability of the flame.
i I9 And by that I mean the size of the flame, or the f act that the l 20 flame becomes di storted wi th air currents in the room.
l l
21 DR. KERR:
Excuse me, but have you read Staff's l
22 response to the comment?
23 MR. FEIT:
No.
DR. KERR:
Would you please read it?
Tha t's what Act erst Reporters, Inc.
25 we are addressing.
l i
i
jrb80 80 I
MR. FEIT::
I'm not supporting what Staff said on 2
this; I didn' t know this meeting was taking place.
3l DR. SIESS:
Let's hold that until we settle the 4
discussion between the committee on Staff's response.
In the 5
meantime, yoti might read it.
I 6
DR. KERR:
Read Staff's response and see if you agree 7
with Staff's response.
I don' t understand Staf f's response.
8 DR. SIESS:
There 's a reference, it says in lieu 9
of section 2.5.4.4; is that correct?
10 l And 2.5. 4. 4 is followed immedia tely by 2.5. 4.1, l
l II and I am not quite sure what this is in lieu of.
i 12 MR. FEIT:
I think the respence is reasonable.
13 Wha t they are saying is true:
l l
14 The oxygen, part of the oxygen come s from the l
15 surrounding environment.
16 DR. KERR:
That doesn' t really eliminate it from the 17 air to propane ra tio.
l 18 MR. FEIT:
No, it doesn't.
[
I9 DR. KERR:
So it seems to me if you are speaking 20 of the air to propane ra tio you have to say air burned in the k
21 burner; whether it come s from the atmospinre or wherever.
l 22 MR. HINTZE:
Well --
23 MR. BENDER:
The question is whr ther you are getting 24 complete combustion or not, not -oncerned about smoke; to try cm est necorters, Inc.
25 to put a certain amount of heat in there; and determining that l
jrb81 81 I
heat by putting in a stochiometric mixture of air and fuel, 2
then it has to all burn.
3 But what if it comes out as smoke and is carried 4
away?
I don't know whether you'd have a representative 5
burning or a reproduceable one.
6 MR. FEIT:
The objective of the re search was to 7
establish conditions that were reproduceable at 72,000 Btu 8
per hour is not important.
The important thing -- that was 9
arbitrary to start with -- the importan+. thing is that you 10 I reproduce this f acility to f acility.
l II DR. KERR:
But if you have aa undetermined amount 12 comimg from the a t2nosph2re, how does that get to be reproduceable?
13 MR. FEIT:
I don't think it is.
I 14 DR. KERR:
Then why not spe:ify tha t?
15 MR. FEIT:
That would be an approach.
16 l From the tester's point of view, he has equipment se't i
17 up, and he wants to know what measuremnts he can make, I
i 18 and what settings he should make in his equipment to get a l
19 reproduceable condition.
20 DR. KERR:
The the guide refers to an air to l
21 propane or wha tever, ratio in the burner, presumably where the l 22 burning is taking place.
23 Now, is tha t ratio --
24 MR. FEIT:
There might be better ways to specify ca eral Reporters, Inc.
25
- sir, l
l
jrb82 82 l
I DR. SIESS:
This says a gas burner, flame source,
2 shall consume propane gas, approxima tely 70,000 Btu per hour, 1
3 i
air-gas ra tio 5. 8 to 1.
4 What does " flame source" mean?
As it goes into the l 5
pipe?
0 MR. HINTZE:
As it come s through the pipe.
7 DR. SIESS:
You don't say it shall be provided, l
8 but it shall " consume ".
So it comes out of the hole as a 9
mixture of 5.8 to 1?
10 !
MR. HINT 2,E :
I think we had it stated differently, 11 i
and got an objection.
12 DR. SIESS:
Yo u had " so a s to relea se ".
13 MR. HINTZE:
Release, right; and tha t was too It was easier to expre ss it in terms of !
Id dif ficult to measure.
15 how much it consumed rather: than how much was released.
6 DR. KERk:
That make s sen se.
i I7 MR. ETHERINGTON:
Originally you didn' t care how I
i 18 much air was in the burner; all you needed was the Btu's and l
I9 this is a means of measuring Btu's?
l 1
MR. HINTZE:
We are trying to establish criteria l
20 l
21 which is reproduceable.
22 l DR. KERR:
Wouldn't you get better reproduceability 23 if you supplied enough air to get complete combustion, rather 24 than supplying enough to get partial combustion?
l Aes vral Reporters, Inc.
I 25 MR. BENDER:
There are several things involved:
i I
i e
jrb83 83 I
One is the flame temperature; and another is the 2
amount of heat.
And I wouldn't be surprised if what you are i
1 1
3 I
i describing here is a fire that's more representative of what l
4 the installation might see in service.
I l
~
5 The document doesn' t convey the me ssage.
l t
6 MR. ETHERINGTON:
What we are trying to get is a i
1 7
long, smokey flame, and don't care much about Btu's, then this i
8 is what you'll get.
If this is a substitute for a sta ted 9
number of Btu's, ther. it's wrong.
10 !
MR. HINTZE:
I am still unclear on how we can say i
11 it dif ferently, because it works the way we've got it stated.
12 If we just used propane, nothing else but air, it would burn 13 okay, and we could establish a flame size tha t way.
I Id It's more controllable if we add some air with it.
15 MR. BENDER:
What do you mean, "it" works?
I MR. HINTZE:
We are trying to get a standard sized I0 I7 flame to produce the right amount of heat.
18 MR. BENDER:
What's being described, the flame of
{
I9 certain length?
20 MR. HINTZE:
A gas burner.
I 2I MR. BENDER:
With a certain distribution in the l
22 flame, tempera ture distribution?
23 MR. HINTZE:
We don't measure that, although it l
24 ha s been measured.
ce rei neporms, inc.
25 DR. SIESS:
Held s the ANSI standard.
l 1
i
jrb84 84 1
DR. KERR:
Why is any remaining air required?
2 MR. HINTZE:
Only one-fif th of it was supplied 3
under a controlled condition.
4 DR. KERR:
Apparently under this controlled condition 5
you don't get complete combustion.
6 MR. HINTZE:
No, you get this long smokey thing; 7
tha t ' s why I said I don't know what he's talking about.
8 MR. ETHERINGTON:
Then you don't know much about I
9 burner performance.
i 10 l MR. HINTZE:
Absolutely not, I don't understand.
j i
DR. SIESS:
Is this what you all used?
l II 12 MR. HINTZE:
Right.
13 DR. SIESS:
Is tha t the way they described it?
i You are talking about a tempera tur'e Id MR. ETHERINGTON:
15 of about 1500 F.
i l
MR. HINTZE:
It varied the air ra tio from others.
l 16 17 MR. ETHERINGTON:
e s.
I i
18 DR. SIESS:
That's the old standard, I am not sure 1
l I9 if it still applie s.
20 MR. ETHERINGTON:
Can you tell me where the 5 to 1 l
l 21 ra tio came from?
Perhaps that would help me?
22 MR. HINTZE:
The 5 to 1 came wi th just using 23 enough air to get -- well, le t ' s se e.
24 It came from the old standard.
Ac
- eral Rmorwrs, lM.
25 MR. ETHERINGTON:
Did it?
l l
jrb85 85 1
Oh, you mean in your standard -- in the old standard.
2 DR. SIESS:
It couldn't be in the IEEE. 3 Where did you get it from?
f 4
MR. HINTZE:
Re search from UL, 5.8 is the optimum.
5 MR. BENDER:
Lc't's leave this and get it later, 6
MR. FEIT:
I may be incorrec t, but I think the 7
standard was originally set up to specify a flame tempera ture 8
which people found difficult to reproduce; and they found that 9
they could get tha t same flame temperature with different 10 '
type s of flame s, different sized flames.
II Nominally at tha t point they generally used a 12 5 to 1 mixture to achieve that, even though it was not in the 13 s tandard, that was general practice for most laboratories.
1 Id They would end up using about a 5 to 1 mixture.
15 So it was a nominal setting.
That was general 16 practice.
17 MR. ETHERINGTON:
If that is the case, that would 18 make sense, because they mention a very low temperature, 1500 l9 degrees; and that's the kind cf tempera ture you get in a long, 20 smokey incomplete combustion.
I 21 And if it is to reproduce that kind of condition, l
l 22 I wouldn ' t have any fur ther quarrel.
23 l
But if it's to reproduce a number of Btu rates, 24 then I would disagree completely wi th the statement, because c_
nel Reporters. Inc.
I 25 you are not getting complete combustion under these conditions. l l
i i
jrb86 96 l
l l
1 MR. FEIT:
Under 5 to 1.
2 MR. ETHERINGTON:
You are not burning it, you are 3
cracking it.
l l
4 DR. KERR:
Well, wha tever.
I I
I 5
MR. ETHERINGTON:
Well, cracking it, then you get l
6 the soot; and soot doe sn't burn so well.
Tha t's wha t you are l
I 7
going to get.
Now, maybe tha t's what you want.
I 8
MR. FEIT:
The flame now -- the flame before --
4 9
I have seen tests with the old set-up that people used, UL I
10 I and others; and when you talk about it as a long sooty flame, j
II maybe it's just semantics.
12 It is yellow --
13 MR. ETHERINGTON:
Ye s.
I Id MR. FEIT:
But it was not completely sooty.
15 MR. ETHERINGTON:
Was it a long flamo?
16 MR. FEIT:
I'd say the flame height was about, oh, 17 maybe 18 inches or so.
18 MR. ETHERINGTON:
Less than 2 feet?
MR. FEIT:
Yuh, less than 2 feet.
20 And there was some soot, but I wouldn' t use that l
21 as a major description.
l 22 The flame that we're getting now would be, with the 23 UL work, is not quite so yellow.
On the other hand, it's not 24 a blue flame.
We don't want that kind of a flame, because c.
mi neoonm inc.
25 that 's not indica tive of the type of flames that you'll see l
I i
jrb87 97 I
the cable will be exposed to in a flame fire.
2 MR. ETHERINGTON:
If this number gives you the kind 3l of flame you want, then I withdraw my objection.
4 MR. FEIT:
A little less yellow and certainly less 1
5 sooty than the old flame was --
6 MR. ETHERINGTON:
We are not talking Btu's at all; 7
we are talking a kind of flame.
8 MR. FEIT:
Right.
9 One of the objectives was to get away from the Btu 10 !
rating, because it was very dif ficult if not impossible to 11 i
specify; and really, it was arbitrary to start with as a basis >
I I2 for it; because there was never any correlation between the 13 70,000 Btu per hour burner and a design basis fire.
1 Id MR. ETHERINGTON:
Then the ef fect of this 5 to 1 15 is the stochiometric oxygen ratio, and it's just a coincidence; I0 is that right?
l 17 MR. FEIT:
That's right.
18 The objective was to get a stable, reproduceabln flame, I9 fire, but not go so far as to have a completely blue flame 20 which would be not representative of what cables would see.
l 2I MR. ETHERINGTON:
Then I have no further objection. l 22 DR. SIESS:
Is this wording by the UL?
Are you 23 sure it's descriptive?
2#
MR. HINTZE:
Yes.
ce rol Reporters, Inc.
l 20 MR. BENDER:
On page 3, item 5, it seems garbled.
i l
t
jrb88 88 I
Aren't you trying to determine synergistic effects 2
of aging and environmental conditions, rather than syngergistic 3
effects on aging?
4 It seems to me you are trying to find < It wha t the 5
insulation properties are, as a function of the combina tion of 6
aging and environmental conditions.
7 MR. HINTZE:
This is particularly syngergistic 8
ef Sects on accelerated aging.
9 Maybe I misunderstood your question.
l 10 !
MR. BENDER:
Wel1, I don' t think you want the ef fec ts II on aging.
You want the effects on the insulation.
I I2 MR. HINTZE:
I understand what you are saying.
13' MR. BENDER:
It comes across differently; you need Id to reword it.
15 MR. HINTZE:
Okay.
i 16 MR. BENDER:
Now --
I7 DR. SIESS:
In that paragraph yc.1 are talking about; 18 at the top of the page, gas burner flames shall consume I9 propane gas approximately -- should there be an "at" or I
20 something?
i 23 MR. HINTZF, Ye s.
22 MR. BENDER:
On the same page, the term ongoing 23 qualification procedure, which I guess comes out of some kind 24 of reference standard; it seems like not a good term; use es Jel Reporters. Inc.
25 something like "in-service surveillance".
t
jrb89 89 I
MR. HINTZE:
It's in 323, another document for 2
qualifica tion; it is ongoing qualification as opposed to 3
qualifying once for presumably 40 years.
In this particular 4
case it's 5 years or something.
5 MR. BENDER:
Okay.
6 The next page, item 10 -- oh, let me start on 9, 7
first.
8 It would be helpful to have it explained why thi.=
9 particular test enclosure is specified?
It's a nominal size, 10 I but I don't know vaat it relates to.
l Explain it?
l II 12 And i:em 10, the same point, you selected a parti-13 cular tray configaration; I don't know whether that configura- !
I tion will -- is standard, whether it brackets the conditions I4 15 you are involved in.
But I think you ought to say it.
16 I7 MR. HINTZE:
Good point.
I 18 The purpose is just to standardize, not real fine tuning.
20 MR. BENDER:
It has to be one that is representative' i
i 21 of the application.
So you ought to say that, some guy might l
come in with a dif ferent tray, and you would have an interminablle 22 23 argument.
24 The same point applies to 11.
I am inclined to l
tal Reporters, Inc.
25 believe some kind of generic test would satisfy this I,
jrb90 90 I
requirement.
j 2
Is tha c the intent?
3 MR. SULLIVAN:
I don't understand your question.
4 A generic test?
And what requirement?
5 MR. BENDER:
I am trying to recall what. I was trying 6
to figure out when I wrote this and read it last time.
7 What is that representative of?
Is that some typical 8
arrangement?
9 MR. HINTZE:
It is just what was included in the 10 I standard.
Most of that was previously in the standard.
We l
II are going to modify it by including the ties, which were not l
I2 included.
13 MR. BENDER:
Okay.
I My point is just like the one about the trays.
l I4 15 I don' t know what it is representative of, but there isn't i
i anything in the guide that tells me; and I think you ought to l
16 l
17 provide a frame of reference so that if somebody wants to i
18 compare the application of the guide with a particular 19 I
installation, he knows whether the tests that have been recommende here are appropriate.
l 20 2I MR. HINTZE:
This is just a test, not representative, 22 of any installation.
23 MR. BENDER:
Well, I know, but when you are 24 qualifying something and, as Dr. Kerr mentioned a little while l d
'ral Reporters, Inc.
25 ago, designers are trying to use this -- they have to have
jrb91 91 1
a way of correlating it with something.
And your reviewers i
2 have to have a way of correlating.
3 And I think they would lose it without some kind 4
of reference.
5 DR. SIESS:
Let me try something:
6 If a cable and connection qualify according to this 7
test, does that then mean it can be installed in the plant 8
within certain limits and you will consider it safe?
Are there 1
9 limits?
I 10 1 MR. SULLIVAN:
Yes, sir, implicitly there are.
l I'll try to explain that:
II i
12 When you qualify a cable for the particular qualifi-13 cation, you are electrically qualifying the materialr you are 14 saying, this is a certain amount of fire resistance.
15 Now, based on tha t, you have the best cable for i
i 16 the application, fire resistant cable; and based on that, there!
17 are other design considera tionF fc2 the installation, such 18 things as physical separation.
l 19 DR. SIESS:
Wait.
I I
20 If you qualify it by this with a separation of half I
I 21 the cable diameter between each cable, could I then install it l 22 with no separation between each cable?
23 MR. HINTZE:
That's right.
24 DR. SIESS:
Can I install it with one-inch Am _ssl Rmorun imt 25 separation between each cable?
jrb92
~
92 I
MR. HINTZE:
This has no relationship ~to the way 2
it's installed.
This is a screening test for cable only.
r 3
Other factors that go into fire prevention or spreading 4
prevention are taken up in Reg Guide 1.75.
5 DR.SIESS:
For example, half the cable diameter 6
spacing, was that chosen as an optimum or pessimum spacing?
7 MR HINTZE:
I think it was chosen co make sure 8
there was good opportunity for the cab]le to burn.
I 9
Here we are qualifying material.
This is strictly l
ma terial qualification, to detern 'ne what is relatively fire l
10 I II retardant.
In other words, you select the best fire retardant I2 materials.
13 An attempt was made in the research to try to 14 change tha t, to say make it more representative of a full 15 cable train, and we filled it completely rather than spacing it 16 p. " a diameter apar t; and the test results were inconclusive. l l
17 There was some variation from one test to another.
18 So we went back to the original standard which IEEE has been using for a long time, and said, okay, since l
l9 l
everybody does it the same --
l 20 l
21 MR. SULLIVAN:
And it does appear to work.
l 22 DR. SIESS:
Yes, you make it pretty clear.
23 It's the flame retardant tendency of the cable.
2#
j MR. SULLIVAN:
That's all it is, based on tha t, a
c_
sral Reporters, Inc.
25 system could subsequently be designed with, say, physical l
l
jrb93 93 i
i i
I separation.
l 2
l DR. SIESS:
You got that pretty well spelled out.
i i
3 It's arbitrary for selecting materials.
Okay.
f i
i d
I MR. BENDER:
I was only going to say, it may be l
5 well spelled out for Dr. Siess, but not well spelled out for I
6 designers.
l 7
DR. SIESS:
Designers of what?
8 If he is selecting cables, not designing cable 9
trays, this makes it very clear.
It says he may selec t any 10 !
ma terials that meet these qualifications.
11 And that seems to me very specific to a designer.
l I
MR. BENDER:
Ycs, in one sense it is.
And in one l
13 sense it isn't.
i i
l#
It takes all the decision-making away from him.
15 But we really can't tell whether he's using the standard in the 16 right way.
DR. SIESS:
I don't understand.
l I7 18 MR. HINTZE:
The reason we specified it was it wasn't specified in the standard, because it did make a difference 20 in comparative testing whether the cable tray was 12 inches or :
I 21 14 or 16 inches; the test results were influenced by cable l
22 tray design.
23 MR. BENDER:
That is going to make a difference, i
1 24 but because of that, some cable will behave better in one l
wal Reorwrs, lm.
25 configuration than in another; and you are saying if I use the l a
b94 94 I
standard I get the same results no matter what the configura-2 tion.
3 That is one way to interpret the standard.
4 MR. HINTZE:
Your relative selection shouldn' t 5
change, provided everybody changes the same way; yu 6
MR. SULLIVAN:
There have been variation.
this 7
test, for example, tray loading, dif ferent flamability up 8
to 210,000 Btu per hour and so forth.
l 9
As I recall the test results, the answers came out 10 the same, that is, cable A was better than B in ont test, l
11 l
and it was also better.. than B in the other test; but both of i
12 them may have burned.
13 But there is let's say a plateau in here, a l#
parameter.
Of course, you can carry it to extremes.
15 MR. BENDER:
Well, I guess what I am trying to 16 I
do is get myself in a position where there is more than one way of skinning a cat.
I can use a little les ser quality of I7 I
I8 cable with some difference in configura tion and get the same 19 i
results.
29 MR. HINTZE:
We are not really allowing that here.
I i
2I MR. BENDER:
I understand now.
I 22 MR. HINTZE:
We are having the minimum.
23 l
MR. BENDER:
I will wait until industry makes 24 their comment and we'll see how they respond.
l esi Reporters, Inc.
MR. HINTZE:
Yes, sir.
jrb95 95 I
DR. SIESS: Industry has been doing it this way, 2
because tha t's what the standard is.
3 Any other comments on this?
4 MR. ETHERINGTON:
I have just one on wording on 5
page 4, item 13, the burners will be mounted parallel to the 6
plane of the horizon.
Could you say it as mounted 7
horizontally?
8 DR. SIESS:
Tha t's what they had.
9 MR. ETHERINGTON:
I mean, the horizon isn' t t
10 I something you go outside to look at.
Mounted horizontally l
II would co it.
I2 MR. HINTZE:
No, it wouldn't.
13 (Laughter.)
i I#
Because if we said " vertical" to the plane of the 15 horizon, okay, we run it at exactly 90 degrees; is that vertical?
Some would say it is.
16 l
I7 DR. SIESS:
In the first place, you are not going
{
l 18 to get anything exactly 90 degrees.
MR. ETHERINGTON:
No, but you are not mentioning l
I9 l
90 degrees, it is mounted parallel to the plane of the horizon.!
20 I
I 2I DR. SIESS:
And that's horizontal.
How do you l
22 see the difference?
23 (Laughter.)
2d MR. HINTZE:
We've been around on this before; I l
cs
_.2eral Reporters, Inc.
25 remember it.
jrb96 96 I
MR. HINTZE:
Maybe we could just say horizontal.
2 DR. SIESS:
They are words, but they are absolute 3
synonyms in any nomenclature I've ever heard.
4 MR. KERR:
Vertical with respect to horizontal, 5
of course.
6 MR. HINTZE:
If you don't object to it, I'd like to 7
keep it.
l 8
DR. SIESS:
We don't object.
9 I have one other comment:
discussion of public 10 I l
comments.
This is very carefully numbered " comment 1, comment l II 12 2",
and there's absolutely no way to correlate those with the 13 public comments.
If somebody would just take those comments Id I
and put a "1" in the margin or something, so you could find l
15 them?
l l
16 I am not even sure they are all taken care of.
I l
I7 could not correlate at all.
For comment 1 there's no reference 18 whatsoever to show what comment it refers to.
19 MR. HINTZE:
We will try to straighten that out.
20 DR. SIESS:
Hearing no objection, this will be i
l 21 approved for further public comment.
22 For next month, gentlemen, we have a proposed 23 agenda, a proposed revision to Reg Guide 1.94, Quality 24 Assurance Requirements for Installation,-
pection and l
Ace _ Jeral Reporters, Inc.
25 Testing of Structural Concrete, Structural Steels, Soils and l
jrb97 97 I
Foundations During the Construction Phase of Nuclear Power 2
Plants.
3 Is that an ANCI N45?
4 MR. MORRISON:
Yes.
N45, 315; it's the revisions l
I 5
to that standard, and the main purpose of the revision is 6
to bring in the soils and foundations.
I 7
DR. SIESS:
All right.
l 8
Then Regulatory Guide 1.9 -- gee, that's an old 9
one.
Selection, Design and Qualification of Diesel Generator,
6 10 I Units Used in Onsite Electrical Power Systems for Nuclear l
Power Plants -- that's post comment; right?
{
I2 MR. HINTZE:
Yes, sir.
I 13 MR. MORRISON:
The original guide did not endorse I
I#
a standard, this does.
15 DR. SIESS:
We must have seen that.
8 0
DR. KERR:
Yes.
1 I7 DR. SIESS:
Regulatory Guide lEJBSC-521-4, Guide IO for Licensing Applica tions in LWR Reload Fuel, pre-comment.
I9 Does that endorse anything?
I suspect not.
20 MR. MORRISON:
No.
i l
2I DR. SIESS:
What's EJB?
l 22 MR. MORRISON:
Somebody's initials.
23 (Laughter.)
2#
DR. SIESS:
I thought it was a branch.
l eral Rooorters, Inc.
25 Okay.
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i 98 jrb98 I
Any other comments?
2 (No response.)
3 The meeting is adjourned.
4 (Whereupon, a t 11: 22 a.m., the hearing was 5
adjourned.)
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