ML19290B830
| ML19290B830 | |
| Person / Time | |
|---|---|
| Issue date: | 12/05/1979 |
| From: | Bender M, Ebersole J, Etherington H Advisory Committee on Reactor Safeguards |
| To: | |
| References | |
| ACRS-T, NUDOCS 7912140208 | |
| Download: ML19290B830 (51) | |
Text
- I)I N)d A uit h (L NUCLE AR REGUL ATORY COMMISSION ADVISORY COMMITTEE ON REACTOR SAFEGUARDS IN THE MATTER OF
SUBCOMMITTEE MEETING on FIRE PROTECTION Place -Washington, D.
C.
Date - Wednesday, 5 December 1979 Pages 1-50 Telephone:
(202)347 3700 ACE - FEDERAL REPORTERS,INC.
D D
L OfficialReporters 444 North Capitol Street p
t Washington, D.C. 20001 NATIONWIDE COVERAGE. DAILY
>: i
i CR8494 1
1 PUBLIC UOTICE BY THE 2
UNITED STATES MUCLEAR REGULATORY CCMMISSION'S J
3 ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 4l Wednesday, 5 December 1979 i
5'
'i 6
The contents of this stenographic transcript of the 71 proceedings of the United States Nuclear Regulatory 8 l Commission's Advisory Committee on Reactor Safeguards (ACRS),
9 as reported herein, is an uncorrected record of the discussions 1
10!i recorded at the meeting held on the above date.
I t
11 ll No member of the ACRS Staff and no participant at this
'i I2 meeting accepts any responsibility for errors or inaccuracies 13i of statement or data contained in this transcript.
14 h
15;I 16' o
17 Y 18 19 1
1574 105 20 i
21l 22 23l 24 Ace-Federal Reporters, Inc,!
25j i
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CR8494 2
BWil: f r i
UNITED STATES OF AMERICA 2
NUCLEAR REGULATORY COMMISSION i
3l ADVISOMY COMMITTEE ON REACTOR SAFEGUARDS I
i Al l
l 5j SUBCOMMITTEE MEETING 1
61 on 7i FIRE PROTECTION j
8 i
I 9j Room 1167 i
1717 II Street, N.
W.
l 10 Washington, D.
C.
I 11 Wednesday, 5 December 1979 l
12 The ACRS Subcommittee on Fire Protection met, pursuant to 13 notico, at 2:10 p.m.,
MR. MYER BENDER, Chairman of the l
o 14 Subcommittee, presiding.
l!
15 l PRESENT:
16 '
MR. MYER BENDER, Chairman 17 MR. JESSE C.
EBERSOLE, Member 18 MR. IIAROLD ETIIERINGTON, Member 19 MR. JEREMIAII J.
RAY, Member 20 ALSO PRESENT:
21 D.
- Notley, R.
- Ferguson, D.
Ward, and E.
Sawyer.
22 i
t 23 24 j
Ace Federal Reporters, Inc.
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PROCEEDINGS 2
MR. BENDER:
I am sorry we are a li ttle late 3
getting started.
This meeting turned out to conflict with 4
another one that had to be carried on concurrently, and so b
Mr. Etherington and I cheated somewhat on your time.
I ho pe 6
we will be able to make it up without too much dif ficulty.
7 This is an open mee ting of the Advisory Committee on Reactor 6
Saf eguards Ad Hoc Subcommittee on Fire Protec tion.
Y I am Meyer Bender, the subcommittee chairman.
The 10 other ACRS members today are Mr. Jeremiah Ray, on my extreme li left; Mr. Harold Etherington and Mr. Je sse Ebersole.
12 The purpose of this mee ting is to discu ss the 13 pro posed fire protec tion rule, 10 CFR Part 50.55a.
This 14 meeting is Lying conduc ted in accordance with the provisions 15 of the Federal Advisory Commi ttee Ac t and the Government in lo the Sunshine Act.
17 Mr. John McKinley, on my right, is the designated 18 f ederal employee for the mee ting.
Also present, from the 19 ACRS staf f, on Mr. McKinley's right, is Mr. Peter Tam.
20 The rules for participation in today's meeting 21 have been announced as part of the notice of this meeting, 22 previously published in the Federal Register on November 20, 23 1979.
24 A transcript of the meeting is being ke pt, and it 25 is requested that each speaker first identify himself or 1574 107
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herself and speak with suf ficient clarity and volume so that 2
he or she can be readily heard.
3 We have received one written statement and one 4
request for time to make an oral statement, f rom Mr. Donald 5
Ward of Baltimore Gas & Electric.
Mr. Edward A.
Sawyer of o
Yankee Atomic Electric has also provided a written 7
statement.
8 A tentative schedule for this meeting was prepared V
on November 20, 1979.
Commen ts were received which caused a 10 revision of the sc hedul e.
Copies of the re vi se d sc he du l e,
11 dated Lecember 3rd, can be found near the doorways.
12 Let me ask firsts are there any questions f rom 13 the subcor.mi tt ee, of a general nature, that it would like to 14 raise at this time?
15 (No response.)
10 MR. BENDER:
Jerry?
17 MR. RAY:
No.
16 MR. BENDER:
Harold?
19 MR. ETHERINGTON:
No.
20 MR. BENDER:
Je sse?
21 MR. EBERSOLE:
No.
22 MR. BENDER:
I would like to clarify for the 23 benefit of the regulatory staf f as well as the audience the 24 committee's reason f or holding this meeting and possibly to 25 help bring out the poin ts tha t need to be brought out during 1574 108
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the discussion.
The fire pro tec tion question has been an 2
open question since the Browns Ferry fire, and there has 3
been anrequirements for fire protection, that are now 4
established in a branch position that is being used by the 5
staff for evaluation purposes.
6 There was a discussion once of pu tting t ha t 7
information in a Regula tory Guide, and as many people know, 8
I and some other members of the subcommittee objected to the 9
i ssuance of a Regulatory Guide at that time, because we felt 10 the practices were not well established, and it was not 11 clear that there was enough of an understanding about what 12 should be in a guide to justify pu tting one out then.
13 Tha t was some time ago.
We haven't reviewed the 14 status of the regulatory prac tice since then, and I am no t IS sure, today, that we know precisely wha t ought to he in a 10 Regulatory Guide.
A decision to go forward with a rule, 17 a ppa r en tl y, is being considered now by the regulatory staf f, 18 and in turn by the co mm i ssi on e r s.
The regulatory staff has 19 asked for the committee's opinion on the desirabili ty and 20 advisability of a rule.
21 The pur po se o f this meeting is to find out the 22 basis on which it is proposed tha t a rule be prepared.
My 23 personal reac tion is to say that not having very much 24 comfort with the idea of going ahead with a Regulatory Guide 25 1574 109
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yet, I am less than comfortable with the idea of pushing for 2
a rule which will embody, in a fixed condition, some 3
requirements that are still being looked at in a fairly 4
general way by the reviewing organization.
5 I think we really need to know what the rule will o
a ccom pli sh, and whether it really will serve the regula tory 7
purposes well to have a rule in force.
And so, I would like 6
if I coulo to call on the regulatory staf f to give us V
wha tever clarification they can o f f er.
10 MR. FER GUSlN :
I am Robert Ferguson, with the 11 Division of Operating Reac tors.
As you mentioned, since the 12 Browns Ferry fire, there have been que stions about the fire 13 protection programs in the operating plants.
In May of 14 1970, around tha t time, I first came to the program, and at 15 tt.at time the question was being raised as to, why isn't 16 some thing being done about the fire protection program in 17 operating plants?
16 The staf f pre pared guidelines based on their study IV of the Browns Ferry fire, which were a pplicable to new 20 plants.
Subsequent to that we visited three older plants, 21 ranging from Dresden-1, 2 and 3, Yankee Rowe, Browns Ferry, 22 to see what kinds of problems would be involved in applying 23 guides that were developea for new plants, to older plants.
24 We f elt at t ha t time that an individual study had to be made 25 of each area of the operating plants in order to assure a i574 110
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reasonable fire protection program.
2 We also recognized there were alterna tive ways of 3
achieving fire protection, other than those outlined in the 4
guide, that would be more sui table, or some things in the S
guide would be more suitable to new construction.
And an o
alternative would have to be found f or an existing pl an t.
7 Where we felt tha t these kinds of relief should be 6
given, it was indicated in Appendix A around September of 9
1970 Since tha t time, all of the licensees have evaluated 10 their plants against those criteria in Appedix They have 11 made a fire hazards analysis of nost of the areas.
We have 12 issued an SER on all of these areas, on all of these 13 plants.
There are about 530 open items on the SERs that we 14 have issued.
Some of the se cone about because of some of Ib the analysis we originally requested in September of '76 10 tha t wa sn' t done at the time we issued an SER.
Others come 17 about because we feel some changes should be made, and the 16 utility has not agreed with us and wanted more time to IV evaluate it.
Other changes and other open items are simply 20 getting documenta tion, things like doing qualification te s ts 21 for seals and presenting the information, that sort of 22 thing.
23 When we initially started in '76, our goal wa s to 24 have all modif ica tions implemented by October 1980.
We are 25 f ind ing, since we i ssued our SERs, that there are sti ll 1574 III
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outstancing questions between us and certain licensees in 2
certain areas where we have to find a way of resolving these 3
differences.
4 The staff f eels that certain modifications are 5
ne ce ssa ry.
Some licensees in these areas f eel that they are o
not nece ssary.
There are usually two ways of doing this, 7
discussions with the licensee s, which have been held -- and b
I think we clearly unders tand each others' posi tions -- the Y
next step would be to accomplish these through the i ssuance 10 of orders by the NRR or by a rulemaking.
In December of 11 1976, we started f orward wi th an order on the single issue 12 o f a five-man fire brigade, of updating a specific pla n t 13 which has a three-man fire brigade to a five-man fire 14 brigade.
15 In considering use of an order in this area, NRR lo managment and the of fice of the legal director got toge the r 17 and decided that, really, we are establishing a base line of le minimum requirements of fire protection in these areas.
It lv was not some thing that was peculiar to a s pe cif ic plant, and 20 i t would be ce tter to
- sol ve these certain items in a 21 rulemaking proceaure, ra ther than an individual order to a 22 plan t.
23 On tha t basi s, we started forward with a rule and 24 we were asked by our managemen t to pu t in to this rule, along 2b with the rive-man fire brigaJe, any other issues that are 1574 112
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outstanding with a given licensee, where there would be the 2
probability that the licensee, if he tried to o ppose this 3
unilaterally, would reque st a hearing.
And therefore, we 4
have put all such items which we f eel are across the board b
i tems, and can be resolved in this way, into thi s pro posed o
rule.
7 There are still site-specific issues which we will o
still have to discuss on an individual basis.
Bu t we feel V
t ha t the requirements in the rule provide a firm framework 10 on which we can resolve t ho sa i ssue s individually.
ll In summary, I guess, the base line is to resolve 12 these differences.
We have the choice of an order and a 13 rule.
And at present, NRR and OELD feel a rulemaking 14 proceecing is the proper way to resolve these issues.
15 MR. EHERSOLE:
As I see the rulemaking, it seems lo to legalize f or all times the mininum standards tha t might 17 be permitted, and therefore to inhibi t what ought to be lo done, which is improve standards in this area.
IV MR. FERGUSON:
We are limiting thi s rule to be 20 applicable to only those plan ts operating as of July 1, 21 1976.
We uo not intend t hi s to be a ppli cabl e to any other 22 plant.
I agree wi th what you are saying.
One of the 23 problems is every time you write something down, t ha t tends 24 to become the way to do it from there on.
25 On the other hand, the problem I have is to get i574 ii3
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thi s over wi th.
We have places where we know wha t we wan t.
2 We have known wha t we want for a year or so.
Time is 3
running out with regard to this October 1980 date.
I don't 4
feel any of the decisions are ea r t h-s ha k i ng.
It is just 5
part of the decision-making process.
6 MR. EfHERINGTON:
Are there other cases where a 7
rule is being written applying only to operating plants?
o MR. FERGUSON:
Not as far as I know, sir.
Y MR. ETHERINGTON:
This is a departure, then?
10 MR. FER GUSON :
Yes, sir, there have been many such 11 departure s f rom normal practice in the fire evaluation.
12 When we first startea, we were encouraged to use as many 13 innovations as we could to speed things up, and to arrive at 14 a quick decision and allow the licensees to get on with the 15 Job of implementing the modifications as it felt nece ssary lo and tried to accompli sh the whole thing by Oc tober 1980.
17 As a result, we relied a lot on phone 10 conversations, meetings with licensees and that sort of lY thing. At the same time, to find that we had disagreemen ts 20 with some licensees, and then no real basis for -- and the 21 record for establishine an order, so i t slows us down in 22 t ha t regard.
23 Now we are tr ying this approach.
24 MR. R AY :
dp until now the controlling document, 25 as I understand, has been a guide.
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MR. FERGUSON:
Not even a guide.
Appendix A to a 2
branc h posi tion.
3 MR. RAY A branc h po si tion.
So this would really 4
be the first formalization?
b MR. FERGUSON:
Yes.
I might add that in the 6
proceeding before the Commi ssion on the UCS petition f or 7
reconsideration, the Com:ni ssion -- or one of the 6
co..mi ssioners -- asked us our views on making that guide a 9
rule in to to.
And our response was that, no, we did not 10 feel that was the way to go, bect se there were things in 11 there tha t we aidn't think should be in the rule; how e ve r,
12 t ha t we did f eel there were certain things that should be 13 made a rule.
And we were proc eeding with those individual 14 i tems.
Ib MR. B EN DER :
Why don't we go ahead and see -- you 16 are going to give us further discussion of what should be in 17 the rule ana why.
Is Mr. No tley going to do that?
16 MR. FERGUSON:
- Right, 19 MR. NOTLEY:
I am David Notley, a fire pro tec tion 20 engineer with tne Off ice of S tandards Development.
Bob has 21 given most of my presentation already, and quite well.
22 T han k s, Bob.
23 He is here wi th several members of the DDR staff, 24 and some consultants who have been ac tive in fire protection 25 o pe ra tion in evaluating plants.
Any que stions that come up i574 115
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t ha t I can' t answer, I will be giving to him.
2 Before I get started in the -- into my 3
presentation, I would like to call ou t two changes and ask 4
you to make them on your copies, pl e a se.
On the firs t page, b
the word " docketed" in the title should be changed to o
" operating."
The title will then read " Appendix R.
Fire 7
Protection Program for tiuclear Power Plants Operating Prior 6
to July 1,
1Y76."
9 The second c hange is on page nine, fourth line 10 from the bottom.
We did not intend the flame retardant 11 coa tings f or cable should replace fire protec tion sys tems, 12 or all fire su ppr e ssion. That line should properly read, 13
" acceptance of the coa ting in place of automatic fire 14 su ppre ssion systems. "
That is page nine, fourth line from ib the bo ttom, "a cce ptance of the coating in place of automa tic lo fire suppression sy stems. "
17 We have made a number of other changes, either to le more clearly state our intent or in a few instances to 19 correct errors.
I have marked copies that I have already 20 given to Peter fam to distribute to the conmittee at the end 21 of tnis; however, we want to talk to the copy that you 22 have, the working pa pe r B.
We would like the commi tt ee's 23 comments on that draft.
24 MR. EBERSOLE:
To be absolu tely certain about 26 this, you said " operating prior to July"?
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MR. NOTLEY:
Yes, sir.
2 MR. EBERSOLE:
No t docketed.
There is a 3
tremendous difference.
4 MR. NOTLEY:
Yes, sir.
5 My presentation will consist of four parts.
Some 6
backgrouna material, a brief description of the staft's 7
understanoing of how fire protection requiremen ts fi t into e
the general scheme of things for NRC, the ac tion we hope Y
ACRS will take on this proposed rule and brief comments on 10 specific items of the rule.
11 (Slide.)
12 Bob has already covered almost all of this.
The 13 whole thing that started witn the Browns Ferry fire of March 14 22, 1975.
The special review group made two recommendations lo of in te re st to us, here.
One was that the Commission needed lo to develop some specific fire protection guidelines.
The 17 second was that af ter these guidelines -- af ter these fire lo pro tection requiremen ts were developed, that each plant 19 should be evalua ted, each plan t's fire protection program 20 should be evaluated against these guidelines.
21 The branch technical posi tion 9.5-1, guidelines 22 for fire protection f or nuclear power plants, was developed 23 for new plants, and the Appendix A to tha t branch position 24 was developed for plants that had been docke ted prior to J uly 1,
'76.
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(slida.)
2 The guidelines in A ppendix A, the ones that we are 3
interested in, have been public for about three years, and 4
they have been used -- all of the operating plants have been 5
evaluated against the provision of Appendix A.
Most of the 6
plants have accepted most of the guidance contained in the 7
A ppendix A.
6 Y
10 11 12 s
13 Y
I4 lb lo I/
Id l'y 20 21 22 23 24 25 1574 118
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MR. NOTLEY:
530 items still exist in the SERs, 2
and these are differences of opinion between the sta f f and 3
the individual licensees on interpretation of the guidance 4
in Appendix A.
I would like to stress that there is no new a
guidance that we are going to be tal k ing abou t in this a
i nte r pre ta ti on.
They are all things that have been public and been used for aoout three years, a
(311de.)
de feel that setting fire protection requirements 13 is indeed a matter for management.
By its nature, it is a 11 policy matter that has to be decided for us in NRC.
These 12 minimum fire protection recuirements need to be established 13 by the NRC.
de feel that thi s rule estaolishes these 14 minimum requirements for contested generic issues.
None of la thes3 issues, again, are new, and none of them are la plant-specific items that will have to oe taken case by IJ Oas?.
13 (311de.)
l>
as do hope that tne ACRS will oe aole to support 2]
the e ntire rule as written.
If there are some exceptions to 21 any o f it, we would like indications of those portions that 22 the Committee can support or cannot support.
23 (3lide.)
26 M1. BENDER:
Can I ask a couple of questions about 2a the rule?
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MR. NOTLEY:
Yes.
2 MR. BENDED First, a great d3al of this is 3
prescriptive.
If I understand correctly, almost all of it 4
has already been implemented in the plants to which the a
rules apply.
So what is the rule accomplishing?
6 MR. NOTLEY:
For those plants where we do have the difference of opinion.
e d
MR. BENDER:
Well, I guess -- I blow there is a proolem with the fire brigade.
That is a. difference of 10 opinion.
But is the rest of it a dif ference of opinion?
It 11 sounds to 13 like a lot of detail.
l>
M.1. FERGUSON:
Most of the things in here, there 13 is at least one utility or one licensee who disagrees with 14 i t, la MR. BENDER:
I think that is a poor reason for la having a rule, because one utility disagrees.
As a matter il of fact, I suspec t that if I went through and looked at it 13 in great det ail, I could find nits about every piece of it 1/
that no utility complied with.
One of the concerns about 23 making it a rule is that you will create just a horrendous 21
'< i nd of legal problem associa ted with tne fact that those 22 peo. ale who sant to challenge the regulatory f unc tion might, 23 in fact, went to pick on the detail of this thing as part of 24 the reason for the challenge.
2; I don't really have much conc?rn about the 1574 120
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rulemaking process itself if it is the kind of rule that is 2
not easily challenged, but this thing has so much detail in 3
it tnat I don't believe that it could stand scrutiny.
I 4
think that needs to be thought about some.
a Md. FERGUSON:
We hope it c an withstand scrutiny.
5 Certainly everything in here has bean scrutinized between us
/
and the licensees over the last two or three years.
Our 8
legal people are the ones wno are advising us that doing it t his way re qui re s -- is less of a legal proolem than doing Il it the other way.
11 M.f. B ENDER:
I realize that the lawyers are 12 anxious to do legal kinds of things, and they of ten take 13 taccs that make no technical sense.
I think this is a 1i fairly good example.
But I do recall another rulemaking la that involved an unbelievable amount of paper, and that is 13 the Appendix K whicn is used to evaluate f ue l.
It has the ie same kinJ of prescriptive requirements in it, and the amount 13 of time that was spent in the regulatory proce ss of 11 establishing a rule contrib1ted ver/ little to the safety of 23 the public.
21 I suspect this is going to do the same darn 22 thing.
Why can't you limit it to something that is less 23 aetailed anJ get the principle in it without going into all 21 of tne fact that you arguing with each licensee over soma 22 amount of detail in one part or another of this?
i574 121
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You can always have an order.
I think you said 2
that yourself -- requiring them to do something.
3 Md. FERGUSON:
Oh, right.
4 Md. BENDER:
It hardly meke s sense to have a a
rulemaking oecause one guy disagrees with something.
A o
rulemaking ought to be something that can be applied on a i
very general basis.
I wond3r whether your approach is d
right.
Md. FERGU30N:
I guess the problem is not 13 necessarily my approach.
11 Md. BENDER:
I am not talking to dob Ferguson 12 i n.1i v idua lly, you know.
13 Md. FERGU5ON:
I think we can find arguments on 11 either side of this -- all through the staff and prooably la through the legal department also.
The best I can say at la this time is, this apparently is the pr3sent way that NRR 1/
management and the legal people want to go.
11 MR. BENDER:
Does the Commi ttee have any comments?
11 Md. ETHERINGTON:
dill you have another rule for 2J new plants, Bob?
21 Md. FERGU5ON:
No.
At the present time, there is 22 no plan to nake a rule for new plants.
23 M?. ETHERINGTON:
This is only a rule because it 21 is a proolem?
2; Md. FERGUSON:
Right.
To c omplete the 1574 122
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implamentation of the modifications of the operating plants 2
by October, 1980.
3 MR. EBERSOLE:
Boo, I have trouble with tnis rule 4
in the detail.
2 M1, FERGUSON:
I guess the problem we have in a
detail and principle is that is where our arguments are, in e
the detail.
Everybody agree s in princiole.
d (Laughter.)
MR. EBER30LE:
It appears that the rule here still 13 doe 3n't really consider fira as a dasign basis event.
It 11 doesn't require safety grade suppression systems.
12 Md. FER3U50N:
Tha t's true.
13 M1. EBERSOLE:
In the context of safety grade iL systans.
It acknowledges that fire may occur, so you can't la forget what it will or will not do, i f f or no other reason la than transportability of comoustible systems from here to
!/
- thera, la fne manual systems are ourdened with the ultimate 19 safety proolem of maintainq safe shutdown heat removal as 2J well as the automatic systems.
The systems are non-seismic, 21 and I think that has been a very shallow investigation which 22 I certainly suggest be examined in greater depth.
23 I think you know with your bac k ground that the 21 likelihood of ma jor f aults and short circuits and other 2a 31ec trical -- electrically ignited as well a s propogated i574 123
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fires are likely to emerge from seismic events because of 2
loss of the battery trip systems, which is one of the early 3
victims of the earthquake, the non-safety groups.
But there 4
are s till a lot of intermixed circuitry of heavy capacity.
a Not3oly is the main coolant pump circuit which may f ail to a
clear.
I don't tnink -- oy the way, Reg Guide 1.75 which 4
3 you also had a hand in is not conside red as a re f e ren ce
- document, D'I t it is intimately related to this thing.
It is 1) the electrical standard for separation which is, I think, 11 clos 11y related to the fire proolem i tself.
12 I see again the same old thing, then -- that 13 turning it over to fire experts results in prooably about 75 14 perc?nt of this document beinq devoted to de tec tion and la suppression rather than prevantion in desion by altering 1) des i7n by iavoking, as it says here, alternate shutdown 1/
syst2ms when you can't really satisfy yours31f that you have 13 a saf e, protec tive arrangem3nt.
l>
I don't see any criteria for determinina when safe 2J shutdown Cannot ce determined by protective and suppression 21 syst>ms.
I don't know how you make the judament otner than 22 a p3rsonal one oy going in and looking.
I am reading now 23 from it "Wnen safe shutdown cannot be a ssured by ca rriers 24 and detec tion and suppression systems, then alternate 22 shutJown Cap aDili ties are required."
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I don't know how you'd make that judgment in the 2
absence of c riteria.
I think particularly of Fort 3
St. Vrain.
'deren't their problems there aoout this matter i
solv 3d by r3 distribution of critical circuitry, or are you o
familiar with it?
3 Md. FERGU5ON:
Yes.
/
Md. EBERSOLE:
How much of that has been done, for 3
example?
Is Reg Guide
- 1. /5 still applicable where you have 9
asbes tos sheets between critical circuits, a few inches lJ apart?
Therefore, you are subject to something like a 11 Molotov cocktail consequenca if you bridge the barrier, il which might be eff ective against an electrically originated 13 fire but not against a fuel fire.
14 fne burden would f all on tne suppression system la ana Jetection systea.
Aell, I have gotten into details.
la M3. F ERG USON :
To some extent, your comments are I,
very applicaole f rom the standpoint of taking this without 13 the oackground of the analysis whicn has already been done.
1)
In other words, tne licensees haven't done any fire hazards 23 analysis to try and use this rule to give a fire protection.
21 They won' t Jo it.
22 It has to De read in the context of -- in 23 particular your questions about seoaration and that sort of 24 thing -- with the cuidance we set out in September of 19/0, 2;
requ? sting that a fire hazarJs analysis ce made in which 1574 125
8494 02 08 22 mgc BWH I
they identified each of the fire areas of the plant, what is 2
in it, and if a fire took out that area, wha t would be the 3
effec t of tnat fire on safe shutdown.
4 It is in the contaxt of those kinds of analyses a
that we say that i f you c an' t show oy that kind of analysis that you have an e ff ec tive saf e shutdown, then you should a
e provide this alternative system.
d MR. EBERSOLE:
Will the rule expedite ge tting that
/
analysis, which I take i t yo u haven' t got?
13 Md. ?ERGU50N:
de have gotten that on a number of 11 plants.
It is all taken care of.
The re a re a few plants 12 whi:n are still doing it ana a f ew that are reluctant to do 13 it.
There are a few that believe you should not be aole to 14 withstand a fire with loss of offsite power.
You should be la able to count on off site power Dein7 availaole.
la I agree with you.
Tha t's s till where we have it, 1/
and you hav3 to make a cecis ion.
It is still a judgment, 13 Carl, on what is the separation or arrangement of fire l>
protection features in a particular area -- what you decide 2J is reasonaale and what is not.
24 And there are even dif f erences of opinion among 2_
the s taf f members.
You can get anywhere f ro m -- if you 23 don't have a fire barrier around one division in that araa, 24 throughout the whola area, to -- as long as you have five 23 feet separation and so on.
1574 126
3494 02 09 23 mgc BWH I
MR. EBERSOLE:
That would still be true under the gg 2
rula.
Ther3 might ce differences.
3 Md. ?ERGUSON:
Unde r the rule, it is down to the 4
discretion of the staf f reviewers essentiall/.
It says it a
hasn' t been determined.
It says it means that if we aren't a
assured it c an be done, i t would have to be done.
/
'id. EBERSOLE:
There are words in here that say 8
all you hava to do is last for /2 hours.
I don't see how that could oe a practical thing.
You have to last IJ ind3 f initelf on hot or cold standby, one or the other.
Il M3. FERGUSON:
But if you lose your cold shutdown 12 and all you have is not shutdown, it means you have to be 13 acl3 to go to hot snutdown and stay there for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.
I+
M1. EBER30LE:
I don't understand the cutof f point la at L2 hours.
It is still a big proolem.
15
'U. FERGUSON:
Th?n you have to have the aoility 1/
to go to cold shutdown af ter /2 hours.
13 lt. ESER5DLE:
You are saying you allow only /2 li hours of hot shutaown?
Then you will require cold shutdown?
2J M1. F ERGUS ON :
Ri7ht.
The damage is limited sucn 2i that it can be repaired --
'U.
EBERSOLE:
I didn't read it tnat way.
23
- 12. FERGU50N:
'de have two problems, okay?
Some 21 pers]n with a boiler says, "I don't hav? to stay at hot 2;
shutdown for 12 h7urst I will b7 at cold sh'Itdown in 10 1574 127
8494 02 10 24 mgcBWH I
hours."
That is perf ectly acceptaole.
He has gotten to 2
cold shutdown.
3 Somebody in a PWR will say, "I
am going to go to 4
hot shutdown, and I can stay there indefinitely."
de are a
- saying, "No, you can't stay there in de f i ni te ly.
You can 3
s tay there for /2 hours, but within that time you have to have your systems oack so you can get to cold shutdown e
d within /2 hours. "
MR. EBER50LE:
You are trying to shotgun the thing 10 for both the dWR and PAR?
11
'H.
FERGUSON:
Right.
12 MR. EBER50LE:
Which is always to'igh for anything.
13 Md. FER3U50N:
That's correct.
And you can even 14 o r e a.< it down that fine, because you have, particularly in la the dWR, you have di f f erent considerations -- whether it has la isolation condensers.
Il Vd. EBERSOLE:
That is because of the requirement 13 that they in ject energy to a sump, and they have to pump l>
water to coal it which the ?dRs don't have to do.
2J
'U. BENDER:
Anything else, Jesse?
21 1?. EBERSOLE:
That's all I have to say.
22 Md. BENDEls It is not clear how we should respond 2J to this request.
Let me as'<
something aoout horking Paper 2 26 and the decision c riteria wnich seem to be the kind of thing 22 that we mignt want to comment on.
1574 128
8494 02 11 25 mgcBWH I
You have listed several decision criteria -- one 2
of them:
" Joes the alternative resolve
- r.. o contentions 3
existing between the staf f and the licensees?"
The i
presumption is that if the alternati ve doesn't, th3 rule a
will.
3 I guess I would have to -- if that is a decision
/
c ri t a ria, I would have to say an order would resolv3 the 8
cont 9ntions, would it not?
Md. ?ER3U30N:
An order which states the staff's lJ position to resolve contentions, the licensee wcould request 11 a hearing, and we would be involved with a hearing and all la the ramifications of that, and the resolution would be when 13 th3 Licensing Board made a decision and may eventually be 14 appealed and come right back to the Comnission again.
la
'U. BENJER:
I can't really come around to a view I..)
that says th at a rulemaking is made in order to avoid il hearings.
fnere is somethina wrong 'vith that.
13 Md. FE7GU30N:
It is not made to avoid hearinas-1/
It is made to consolidate hearings, i f tnere is going to bs 2J a h3aring, to consolidate tnem into one, rather than to hava 21 20 or 30 separate ones on individual points.
22 Md. BENDER :
That is exactly the concern I am 23 raising rigat now.
You pointeJ out that there are 21 individual issues between one applicant, maybe concerned 22 a bo.i t ona piece of this rule, and anothar applicant i574 129
8494 02 12 26 mgcBWH I
conce rned aoout another.
But it is s eldom -- except for the 2
f iva-man rule that there is more than one applicant raising 3
questions aoout part of this rulemaking.
Am I saying it 4
wrong?
5 H)w many things are general in the rulema'<ing that 3
sever al applicants want to raise qua stions about?
I can't I
find very many in here, and you haven't culled out any, 1
e xc e.a t, I nate, the five-ma7 rule is in question.
Wnat about the rest of it?
IJ MR. EBERSOLE:
That's what I '< e p t looking for.
li M.f. FERGU3ON:
I nave here a matrix of the 12 plants.
These are oeing reviewed by a carticular team, and 13 these are tne i te ms in the second pnase.
And all the se a re 14 fair indications of where they are open on a particular la plant.
13 Ml. BENDER:
Being open doesn't necessarily mean 1i that they are taking issue with the rule.
It is the Id interpretation of how the rule will be applied that may be l>
the open question.
2)
M1. FERGUSON:
That doesn't necessarily mean they 21 are t aking issue with any of this rule, a specific item in 22 the rule.
ae are s t i l l --
23 MR. BENDER:
You are trying to understand 21 yourself.
2; MR. FERGUSON:
No.
It is something where we say,
\\514
\\30
8494 02 13 27 mgcBaH I
according to the guidelines, if you meet our guidelines, you 2
need this kind of a modification, and the licensee is 3
saying, we Jon't need that kind of modification.
4 Md. BENDER:
Having the rule is not ooing to avoid a
those discussions, is it?
6 Md. FERGUSON:
It is, if it becomes a policy that
/
you -- that a nuclear plant, an opera ting nuclear plant, 8
n eeds this kind of protec tion.
The problem gets to be -- to take a simple example of a cable screading room -- is it or 10 is it not tae policy of the staff to have an automatic 11 suppression system in the cable spreading room?
12 Let's take a cabla spreading room which has 13 notning in it but cables.
fou can' t make an argument based 11 on the fire ootential.
They are usually in restricted la areas.
We will keep everything out of there.
We will never la have a fire there, and that sort of thing.
14 It is a question of, if you do have a big fire li there, what the consecuences are to the plant.
I think it l>
is strictly a policy decision of whether you do or you do 27 not have tha t kind of pro tec tion.
21 Md. EBERSOLE:
The answer to your question about 22 what hapoens to the plant g3ts back to another interface 23 thina.
How does GDC-19 apply in that plant?
Was it true 21 that the auxiliar shutdown system was, in truth, isolatable 22 and independent of the cable spreading room?
Or was it
)514 \\3\\
28 8494 02 14 mgcBdH I
dependent since all of the leads were simply tapped out of 2
those rooms ?
It gets to be plant-specific again.
3 If you had a plant like Brown's Fe rry was supposea 4
to have oeen which had independent competence to shut down a
with the control room totally burnea out and the spreading 6
room burned out, then you mi ght we ll relinquish the fire
/
protection on the spreading room anJ Control room.
8
)
13 11 12 13 14 la c) 14 13 1574 132 23 21 22 23 24 22
29 CR 8494 WHITLOCK t-3 mte 1 l
There is a hash of interpretations of how GDC-19 is 2
applied.
Some do it, others don't.
So it leaves a plant-r 3
specific requirement on the fire protection problem.
Do you 4
follow me?
5 MR. FERGUSON:
Yes.
And I think that is -- we have 6
that kind of a problem in here, where somebody has given us, 7
let's say, a dedicated system which is completely independent 8
of such an area, so we know that there is no dependence on that.
9 Then we generally relax the fire protection requirements.
10 MR. EBERSOLE:
Then it becomes easier to use the II suppression concept.
I2 MR. FERGUSON:
The problem we have in operating 13 plants is each one is unique.
There is no such thing as l
l Id saying, how does any general design criteria apply.
You can i
15 get either answer, it does or it doesn't, or, yes, we agree l
16 with it.
But you don't know how -- just the specifics, or the l i
way one plant complies with it is not the same as the way f
17 i
18 another plant complies with it.
l9 MR. EBERSOLE:
In using this requirement for the f
i 20 alternate shutdown system, I can recall from memory l
21 Fort St. Vrain had to do extensive work.
I think some of the 22 Duke plants.
Were there others that have used the construction' 23 of alternate shutdown capability; do you happen to know 24 offhand?
I
. eeersi neporters. inc.
l 25 MR. FERGUSON:
There are two different things.
We 1574 133
mte 2 1
are making a distinction between alternate shutdown capability 2
and dedicated shutdown capability, dedicated meaning they 3
have put in pipes, pumps, and perhaps a power supply and that 4
sort of thing, along with all of the wiring, a completely 5
separate system.
6 Duke at the Oconee plants and Fort St. Vrain are the 7
only two --
8 MR. EBERSOLE:
Those are the only ones I have heard 9
of.
10 MR. FERGUSON:
But there are other plants who have II done what we call an alternate shutdown system, in which they 12 sometimes have part of the capability independent, and there 13 have been some wiring changes to increase that capability Id because they do have it.
It is essentially the existing 15 systems that were there with some modifications of wiring, 16 additional : switch gear, control panels, whatever, in some I7 cases gathering together things that ware originally spread 18 out over the plant and that sort of thing.
MR. EBERSOLE:
I see.
20 MR. BENDER:
Vic?
2I MR. BENAROYA:
I think what Bob is trying to say is l
22 that for new plants the reason we don't want a rule is because 23 of what Jesse has been saying.
It is too much plant dependent.
24 And we do like to encourage dedicated shutdown systems.
This A<
edet al Reporters, Inc.
l 25 is applicable only for plants where the evaluation has been 1574 134
31 mte 3 1
completed, and there are very specific items that need to be 2
fixed.
That is why it is the easiest way of implementing it.
3 MR. BENDER: Let me get back to the question of 4
decision criteria.
The second item down here, it says:
Does 5
the alternative provide adequate fire protection for operating 6
nuclear plants with r egard to licensee requirements and 7
decisions?
8 I think the question also has to be asked:
Does 9
the rulemaking provide adequate fire protection for operating 10 nuclear plants with regard to licensee requirements and II decisions?
I raise that question in the following context:
i2 If, within the next one to five years, I should find something 13 else that I would like to have done in the way of fire protec-14 tion, does the rulemaking make it difficult for me to ask for 15 additional things?
16 MR. FERGUSON:
I would say it would make it easier.
17 MR. BENDER:
Why?
18 MR. FERGUSON:
Because if you have a rule and you I9 amend that rule, you can do it across the board on a fixed 20 schedule, in a relatively short period of time --
21 MR. BENDER:
How long will it take this rule to be 22 established?
23 MR. FERGUSON:
You want me to predict the future?
24 MR. BENDER:
Sure.
I think that that is relevant A<
Metal Reporters. Inc.
25 to the question.
1574 135
32 mte 4 1
MR. FERGUSON:
This is a question that has to do with 2
the whole rulemaking procedure.
I can say I think it is fair 3
to say that some rules have been published very expeditiously, 4
and others have taken years to get out.
This is really the 5
Commission's decision.
6 I would say, in light of their order to the staff 7
in the UCS matter completing the implementation of modifica-8 tion by October 1980, that the Commission would want to publish 9
and have that made an effective rule rather expeditiously.
10 But I can't really predict what the Commission is going to do.
11 MR. BENDER:
I would have to argue that the rulemaking 12 process itself has never been expeditious.
I am open to the 13 belief that it could be changed.
14 MR. FERGUSON:
I also feel, on something like that, 15 I think an expeditious rulemaking procedure, which clearly 16 states the staff's requirements and is given a reasonable 17 implementation date is much more desirable from the utility 18 standpoint of knowing where they stand in the beginning than i
19 it is to go through some letter asking for comments and what 20 do you think about this, and just keep goofing around with it.
l l
21 '
MR. ETHERINGTON:
Nothing could be clearer than 22 Appendix K, which Mr. Bender mentioned.
I think there is a 23 feeling that Appendix K has prevented the staff from making 24 quite extensive changes.
Do you agree with that?
A<
deral Reporters, Inc.
25 MR. FERGUSON:
I am not directly familiar with 1574 1?A0'
33 mte 5 I
Appendix K.
If it boxes the staff in, then the staff ought 2
to change the box so they aren't boxed in.
3 I don't think it is fair to say that if there is 4
something that in fact needs to be done, just because there 5
is a rule established some time ago, that it can't be changed 6
expeditiously.
I think that is a copout for just not doing i
7 things.
8 Maybe there is not enough manpower available to do 9
it expeditiously.
But we usually don't -- are not utopped by 10 guidelines.
There is no reason why we should be stopped by II rules, except that there should be a procedure of saying what 12 the rules are at any particular time and having reasonable 13 implementation dates, that those rules have to be changed.
I#
MR. BENDER:
Let me stop here and ask whether 15 Mr. Ward of Baltimore Gas and Electric is here and wants to 16 make a statement.
I7 MR. WARD:
Yes, sir.
You have the floor, Mr. Ward.
I9 MR. WARD:
Thank you, sir.
20 l I am Don Ward, chief civil engineer of Baltimore 21 Gas and Electric Company.
Our major comments on the 22 November 16, 1979, proposed draft of Appendix R, fire pro-23 tection program for nuclear power plants docketed prior to l
24 I
July 1, 1976, are as follows:
A_
ecieral Reporters, Inc.
25 Number one, we believe that the rule should be 1574 137 1
34 mte 6 1
clarified to require operating plants to install --
2 MR. EBERSOLE :
Pardon me.
I want to make an obser-3 vation right away.
You said " docketed."
4 MR. WARD:
That is the way Appendix A reads and 5
that is the way we would like this to continue to read.
6 MR. EBERSOLE :
All right.
7 MR. BENDER:
Go ahead.
8 MR. WARD:
It should be clarified to require operat-9 ing plants to install barriers or fixed automatic fire sup-10 pression systems in fire hazard areas.
It is our belief that 11 a cost-benefit study will show that barriers or automatic 12 fire suppression systems, backed up by manual fire fighting l'
13 efforts, would be adequate, would provide the defense in 14 depth.
15 It is extremely difficult, if not impossible, to i
16 backfit a full system of barriers in an operating plant.
This 17 difficulty is due to controls on plant access, especially in 18 the radiation areas, and working around all of the installed structuresandequipmentandpipingandinstrumentationandthe!
19 20 wiring that we have, cable trays, conduits, and so forth.
21 This comment applies several places in the draft, 22 and it would apply on pages 4, in the defense in depth 23 section, on page 5, page 6, page 9, and page 21.
24 In this same context, we believe that Section II.D.
l At Metal Re@rters, inc.
l 25 should be clarified to require automatic fire suppression 1574 138
35 mte 7
I only if more than one division is involved in the fire.
2 Our third comment:
Sections II.E. and F involve 3
significant changes from the previous guidance, the guidance 4
that we have received.
We believe that putting these 5
sections in the rule would require program changes for all 6
operating plants at a significant cost for marginal benefit.
7 Section II.G. requires eight-hour emergency lights 8
in plants where one and a half hour lights were originally 9
provided.
The change-out does not appear to be justified by 10 cost benefit.
We have committed to the change-out.
II MR. BENDER:
Mr. Ward, you have used the term 12
" cost-benefit" a number of times, and since I don't know that l
13 the industry has ever stated its criteria for cost and benefitsJ 14 it might be wise for you to tell us what you mean by that.
15 MR. WARD:
I believe that the rules say that changes 16 are made if the benefits outweigh the costs.
We have some 17 probabilistic ways of approaching the benefits.
We have some i
18 probabilistic ways of approaching the costs.
l 19 l
I had understood that NRC had on the staff some 20 people who were working heavily in the cost-benefit area with 21 regards to TMI and I assume also on fire protection.
22 MR. BENDER:
I am sure they do.
But I think that 23 you are making the cost-benefit judgment.
So I think the 24 onus is on you to say what the cost-benefit judgments are that A
ederal Reporters, Inc.
25 you are making that are going to show these.
Are you telling i
1574 139 l
36 mte 8 I
me that the staff is going to determine whether your costs and 2
benefits are properly balanced, or are you going to do it?
3 MR. WARD:
I believe before it goes in the rule it 4
ought to be the onus on the staff, sir.
5 MR. BENDER:
That is an interesting point, and I 6
think the issue is fairly well stated.
Would you be likely 7
to challenge a rule in which the staff did not do that?
O MR. WARD:
On that ground?
No, sir.
Just on 9
cost-benefit?
No, sir.
We wouldn't go to court over something 10 like that.
11 MR. BENDER:
Let me ask -- go ahead and finish your 12 statement.
I will come back and ask a couple of other 13 questions.
14 MR. WARD:
Okay.
We have committed to this change-out 15 of the emergency lighting.
We did some negotiating and talked 16 about providing some portable lamps, and we said we would do 17 it.
Preliminary estimates are on the order of $65,000 on what ;
i 18 is one of the very small changes.
19 And our fifth comment:
If Section II.J.5 is to 20 be imposed, a numerical value should be given.
This is on 21 the pressure differential for the fire test.
Please note that 22 ASTM E-119 and other testing standards do not require pressure 23 differential, much less any numerical value.
We suspect that 24 imposition of this requirement would void the applicability A
ederal Reporters, Inc.
of all fire tests performed to date.
1574 140 1
37 mte 9 I
MR. BENDER:
What is the alternative?
2 MR. WARD:
Testing without a pressure differential, 3
the way most of the fire tests have been performed today.
d MR. BENDER:
I will ask the same question I asked 5
before:
Can you do a risk on a cost-benefit analysis to 6
justify the omission of it?
The fact that it isn't done on 7
something else doesn't necessarily tell me that it shouldn t 8
be done in this case.
9 MR. WARD:
We do it on electrical penetrations, and 10 I believe you have to throw out the piping penetrations, the 11 three-hour walls, the three-hour doors, and so forth, that 12 have been done without it.
You have to go back and retest 13 before you had any three-hour ratings.
MR.
BENDER:
Go ahead.
Are there other points you 15 want on the record?
16 MR. WARD:
No.
MR. ETHERINGTON:
Mr. Ward, I presume if this rule 18 is published, you would make similar comments on it, wouldn't i
19 you?
It is being published for comment.
l 20 MR. WARD:
Yes, sir.
We just hit a few of the high 21 points.
2 MR. ETHERINGTON:
Has the staff been aware of these l
r 23 points before the rule was formulated?
MR. WARD:
I believe we talked about all of these.
As deral Reporters, Inc.
25 For instance, on the pressure differential, we have asked i574 141
38 1
mte 10 1
for the numerical value.
2 MR. ETHERINGTON:
You would have some concern that 3
you would not be given satisfaction in making your comments 4
in the ordinary way.
5 MR. WARD:
Pardon me, sir?
6 MR. ETHERINGTON:
You have some concern that you 7
would not get these changes introduced in the rule in the --
8 the rule is out for comment.
I l
9 MR. WARD:
We got it just about a week ago, sir.
10 MR. ETHERINGTON:
It will be out for comment.
11 MR. FERGUSON:
It will be out for comment.
I 12 l M t.
ETHERINGTON:
You can make these comments to the i
13 staff.
14 MR. WARD:
Yes, sir.
15 MR. ETHERINGTON:
Do you have some concern that 16 you will not be able to r esolve it to your satisf action?
17 MR. WARD:
Sir, I think our basic concern was that 18 we got the notice of this meeting about a week ago.
We wanted I
i 19,
to make sure that there was something besides just the rule i
l i
20 l!
laid there, without you all having the benefit of any comments 21 that someone from the industry might make.
i 22 Certainly, if it comes out for public comment, we l
l 23 would certainly intend to comment on it.
24 MR. EBERSOLE:
Mr. Ward, how many units, nuclear As aferal Reporters, Inc.
25 units, do you represent?
\\514 \\42 l
l
39 mte 11 I
MR. WARD:
Just two, just the two at Calvert Cliffs.
l 2
MR. EBERSOLE:
In applying General Design Criteria 19,'
3 what interpretation did you use about the requirements for l
4 wiring in conjunction with the alternate shutdown system?
i 5,
MR. WARD:
I don't know, sir.
6l MR. EBERSOLE:
There are two ways.
You can extend 7
the wiring to the alternate shutdown system from the terminal 8
boards in the control room, and thereby create a distant 9
control point, still dependent upon the control room.
Or you 10 can i.idependently wire the distant point to be totally inde-II !
pendent of the control room.
These are the two broad cate-l 12 gories.
13 You recognize the first is the least conservative.
I4 MR. WARD:
Yes, sir.
i 15 MR. EBERSOLE:
When was your plant built?
16 MR. WARD:
We went operational in '75 and
'77, which 17 is one of the problems with the docketing versus operating.
18 MR. EBERSOLE:
You were with the majority and you 19,
extended your remote control centers from control boards in l
l 20 the control room?
i 2I MR. WARD:
Either in the control room or the cable 22 spreading room.
i 23 MR. EBERSOLE:
That makes your distant control point i
24 dependent on the viability of the cable spreading room.
n ederal Reporters, Inc.
25 MR. WARD:
Yes, sir.
One of the points we have l
l 1574 143
40 mte 12 1
always thought we had going for us in that was we very early 2
made a determination to use the silicone-rubber-asbestos 3
cable, which we believe offers a superior power resistance.
I 4
MR. EBERSOLE :
In the spreading room, you are 5
dependent on barriers to the criteria of 1.75?
6, MR. WARD:
That is my understanding, yes.
And our 7
proposal is to add a suppression system.
8 MR. EBERSOLE:
A suppression system, being non-seismic 9
and non-safety grade, et cetera, says that -- well, it brings 10 this question up.
I can see within the rule an exit, if Il somebody who is in authority is dissatisfied, he can invoke 12 that the arrangement is unsatisfactory in a case like this, 13 and require the auxiliary shutdown circuitry.
I see a degree 14 of freedom in the rule that lets me escape from anything in 15 the rule I might not like.
Is that right, Bob?
16 MR. FERGUSON:
Right.
17 MR. EBERSOLE:
I can ?.ead the rule both ways.
I l
18 can see bad things, but I can fall back and say I can get out 19 '
of that by declaring that this general arrangenent is not i
I 20 1 satisfactory; therefore, I would have to have alternate i
I 21 shutdown circuitry.
l l
l 22 There is a great deal of freedom in the rule, isn't l
23 there?
l 24 MR. FERGUSON:
Yes.
ederal Reporters, Inc.
i 25 MR. EBERSOLE :
The nature of the rule, as against l
1574 144
41 mte 13 1
present practice, doesn't change that.
The judgment will still 2
be the same.
3 MR. FERGUSON:
No.
But the issue, where we are 4
trying to resolve it, is whether these grey areas between is 5
the suppression in a given area good enough or is it not.
6!
MR. EBERSOLE:
Yes.
I 7
MR. FERGUSON:
It is easy to take either side of the 8
coin.
9 MR. EBERSOLE :
In.that connection, you stated the 10 cost-benefit studies.
Have you made such an evaluation for 11 this particular case in the spreading room and control room?
12 MR. WARD:
No, sir.
We started down the line on 13 some of the costs.
14 MR. EBERSOLE:
Of course, that is one of the worst 15 places to look at.
I would suggest that you make one of these 16 evaluations and show it to us.
Include in it the alternate 17 prospect of putting in independent wiring, which is within i
18 the rule, you see, as against the terrible problem of creating l l
i 19 l barriers in these places.
l l
i i
20 l I can share your views on the barriers.
21 MR. WARD:
The cable spreading room, we think that 22 we are going to be in good shape with the barriers, because i
23 we have already done some barriering for separation.
I guess 24 the only remaining question is, are we required to assume A
ederal Reporters, Inc.
25 total burnout of the room.
i i574 145 i
42 mte 14 1
MR. EBERSOLE :
Or crossing the divisions.
You don't 2
get to get total burnout.
Just cross the redundant divisions 3
with fire damage; in other words, defeat the separating 4
configurations afforded by 1.75, which are quite nominal, 5
like a few inches or feet, with an asbestos board between them, 6
I believe.
7 MR. WARD:
But that is one of the places where we 8
believe we are in good shape on the barriers, and with the 9
addition of the suppression system, we do not believe that e-3 10 we would have alternate shutdown for that particular area.
11 We have some other areas where we don't have 12 three-hour barriers.
We have extensive walls that are thick l
l 13 enough to be three-hour barriers.
But all of the penetrations i 14 aren't sealed with three-hour seals.
We aren't sure that there 15 is a piping penetration seal that is rated at three hours.
16 MR. BENDER:
Let's try to straighten out your plant l
17 here today.
18 (Laughter.)
l9 MR. WARD:
The only way I can talk is off examples.
I 20 MR. BENDER:
Yes.
I think we have got enough 21 information to understand what your concerns are.
l 1
22 MR. FERGUSON:
Mr. Ward mentioned he only received 23 a copy of this within a week; maybe some of the other people 1
the same way.
I would like to point out, that is another 24 A
ederal Reporters, Inc.
25 innovation on this, that normally proposed rules do not go l
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out until after the staff h as finished their review, the A
2 ACRS has finished theirs, and the Commission has finished 7
3 theirs.
4 This is another thing that is unusual about this.
5 And we recognize the interest among the licensees.
We had 6
the project managers call each licensee a month or so ago 7
and advise them of this meeting and roughly the time that the 8
rule would be available.
In some cases the project manager 9
sent the utility a copy of the proposed rule, and in other 10 cases it may have been delayed.
Il MR. BENDER:
Well, the Subcommittee is in a position 12 of having to make some recommendation to the full Committee 13 concerning this.
14 Harold, do you have any thoughts?
15 MR. ETHERINGTON:
There is another letter here.
16 MR. BENDER:
From Yankee Atomic.
It sort of 17 addresses the --
18 MR. ETHERINGTON:
It is addressed to the Committee.
l 19 l MR. ESERSOLE:
There are a lot of details.
I don't l
20 l think we can go over this in the time period we have here.
21 l MR. BENDER:
My suggestion would be that we recog-22 nize that it exists.
Do you think we ought to go through it?
23 MR. ETHERINGTON:
No, I don't think so.
I just 24 wanted to recognize it, that's all.
ederal Reporters, Inc.
s 25 MR. BENDER:
I think what we just expressed as an i
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opinion, it seems to me we ought to let the rule go out for 9
2 comment in order to hear what the industry, what the industry's 3
viewpoint is.
At the same time, I think we should point out 4
to the Committee that this is a very unusual application of 5
rulemaking.
It seems to be a little out of the normal from I
6 'i the way in which rules are developed, and as a matter of 7
precedent there ought to be some serious thought given to this 8
wisdom.
9 Does anybody have any objection to making that kind 10 of a point to the Committee?
11 MR. ETHERINGTON:
A good point.
12 MR. EBERSOLE :
Yes.
13 MR. BENDER:
Bob, are there other things which you 14 would like us to talk about here today?
15 MR. FERGUSON:
No.
There are two things about the 16 rule that I wanted to bring to your attention and make sure 17 you clearly understood.
That is that the fire protection for 18 shutdown equipment is different than fire protection for I
19 equipment that would be used solely for LOCA applications.
l 20 In our evaluation, our whole evaluation as reflected in the l
l 21 i
rule, for instance, containment sprays are necessary for j
22 l
post-LOCA type things.
23 Instrument ssociated with following an accident is 24 associated.ith post-LOCA.
We have not necessarily provided j
s emi nemrtert mc 25 l
for separation of those things.
In other words, there are I
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fires where you could lose all of that and be on a minimum 2
shutdown.
3i The other thing is what we have established is the 4
minimum.
We say in a specific area, if you burn out, you are 5
down to this one system, this minimum way of maintaining hot 6
shutdown.
7 Those are the three things that need careful considera-8 tion.
9 MR. EBERSOLE:
If I take the core spray pumps, the 10 post-LOCA pumps, and you have a certain kind of fire protection II for that, and then you have an auxiliary feedwater system for I2 the PWR, a different protection which is not post-LOCA, which I3 is the higher degree -- on which is the higher degree of Id protection --
15 MR. FERGUSON:
Let us assume that we have two i
16 auxiliary feedwater pumps.
We would make sure that those I7 were separated and only one of such would be involved in any 18 particular fire.
And then you have redundant core spray l9 pumps.
20 However, you -- and they are in the same area, and 21 may be lost in the same fire.
However, there is another way 22 of making up to the primary system, other than the core spray.
23 As long as you have the makeup capability necessary to maintain 24 hot shutdown and go to cold shutdown from somewhere, you may a1eral Reporters. Inc.
25 lose those two safety systems.
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MR. BENAROYA:
I am not considering LOCA and fire 2
at the same time.
3 MR. EBERSOLE:
Is that the essence of what you are 4
saying?
5 MR. BENAROYA:
That is what you are saying.
6l MR. FERGUSON:
That's true.
But sometimes the point 7
is missed that you have different protection, bec'ause there 8
are requirements within the GDC, for instance, that you will 9
have a core spray system that can do certain things with 10 regard to a single failure.
11 A fire is not a single failure, not the kinds of 12 fires we are proposing.
13 MR. EBERSOLE:
It may not need to be said, but I 14 will say it anyway.
By and large, the shutdown requirements 15 without the LOCA are far more an important in aspect to fire 16 protection.
17 MR. FERGUSON:
Yes.
l i
18 MR. EBERSOLE:
One general question here.
There are 19 numerous li ttle things in the interior of this document.
Is 20 it the intention to go into these little things in this kind i
21 of a meeting?
i 22 For instance, you refer to a requirement that we have '
23 the pressurizer level in PWRs as a guaranteed indication, which 24 we now know not to be enough from TMI, and numerous other e
wersi neporteri. inc.
I 25 little things like this.
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I MR. FERGUSON:
The pressurizer indicator is just 2
an example --
3 MR. EBERSOLE:
It shall be capable of maintaining 4
the reactor coolant level above the top of the core for BWRs --
5 it doesn't say what margin -- and the pressurizer for PWRs.
It 6
is an extrapolation of the old assumption that if you have the 1
7 pressurizer level, then you are in high cotton, which you are.
8 MR. FERGUSON:
It is an indication of where the 9
level should be.
We haven't identified --
10 MR. EBERSOLE:
No longer is it adequate just to have II pressurizer level.
It is implied that that is all you need.
12 But you need more.
13 MR. BENDER:
Jesse, why don't you pass along the I#
comments you have?
15 MR. EBERSOLE:
I would be happy to do that.
16 MR. BENDER:
The staff will get comments on this I7 thing anyhow.
And judging by the two cents that we have seen 18 so far, the number of comments are going to be large,
I think.
That is predictable.
l 20 MR. EBERSOLE:
As always.
2I MR. BENDER:
There is no sense in dealing with a few 22 right now.
I think we have to take Mr. Ward's comments 23 seriously about the cost-benefit analysis.
I am a little l
24 surprised that he is unwilling to do it.
But I think the wer nepo,ms, inc.
j staff does in fact have an obligation to look at the 1574 151
48 mte 20 I
cost-benefits of the requirement.
2 I wonder if the regulatory staff has any intent to 3
try to make some judgments about --
4 MR. FERGUSON:
When the reg guide was initially 5
brought out, when the cost-benefit was made at that time of 6
applying the guidelines across the board, then I think at that 7
time we estimated to operating plants it was something like 8
between 2 and $4 million.
9 I believe somebody in industry was also asked to 10 make an estimate.
II MR. BENAROYA:
We did, $10 million.
12 '
MR. FERGUSON:
To an operating plant?
13 MR. BENAROYA:
No, to a new plant.
Id MR. BENDER:
Ue didn't do anything for the operating i
15 plants.
And the arguments that were made had to do with l
l l
16 plants that were partially constructed, and for those plants l
17 I think it was pointed out that the $10 million was quite a l
18 low number.
Is that correct?
l9 MR. BENAROYA:
That is correct.
I 20 MR. FERGUSON:
Probably with inflation, it is lower i
21 than that, comparatively.
l i
22 MR. BENDER:
I am only trying to point out that if 23 you are seriously considering a rule, then I think all the 24 things that go with evaluating a rule have to be considered.
ederal Reporters, Inc.
l I
25 You can't just decide that, because it is nice for the lawyers 1574 152
mte 21 49 1
to have a rule, that you can afford to ignore all of those 2
things that are associated with it.
Cost-benefit happens to 3
be one of them.
4 MR. EBERSOLE:
Mike, I can't see the staff doing a 5l cost-benefit on Mr. Ward's plants.
I only can see Mr. Ward 6
doing that, because it is so plant-specific.
For that matter, 7
it may be financial systems-specific.
8 MR. BENDER:
They have tc do it in some way.
T 9
don't know if they need to do it to Mr. Ward's plants speci-10 fically.
I think they need to do it in some context of the Il gross picture.
12 MR. FERGUSON:
The problem of doing a cost-benefit --
13 I have no problem doing it ourselves -- but to get down to Id what is a real cost, unless you have a utility cost figure 15 that you are going by -- I think anybody besides the utility 16 to tell them how much it is going to cost to do the job is 17 going to be somewhat in error.
18 MR. BENDER:
I think the numbers on Brown's Ferry l9,
are fairly well known, aren't they?
20 MR. FERGUSON:
I don't know how much they apply to l
21 any specific plant.
Each plant has its real specific l
l i
22 problems for any particular item.
1 23 One thing that has come up during our evaluation is l
^
24 a few of these have been already appealed through the normal
,o aere neportm, inc.
j 25 appeals channel within NRR in doing individual evaluations, i
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and from time to time the cost argument came up.
At that dme, 2
the Director of Operating Reactors asked the utility to 3
provide the cost figures for the particular modification.
And j
4 in all cases the utility, after considering the cost, found 5
it really wasn't that much and they couldn't really make a 6!
case.
7 I am not sure that is the case every time.
But that 8l has been the experience on particular items.
I 9
MR. BENDER:
Let's leave the issue this way, then.
I 10 We will recommend to the Committee -- I think probably we don't Il need to have more than just an acknowledgment from the 12 Committee that you are sending out the rule for comment.
We 13 will point out to the Committee some of the concerns about 14 this, the peculiarity of this rule.
15 But I suspect the actual viewpoint of the Committee 16 as a whole would await industry comments, as we have # th 17 other kinds of things.
You might expect a more formal kind 18 of response at that time.
I9 Does that sound all right?
l 20 MR. ETHERINGTON:
That sounds good.
l l
2I MR. BENDER:
Thank you.
l l
22 If there are no other comments, we will adjourn the 1
23 meeting.
I l
4 24 (Whereupon, at 3:25 p.m..,
the meeting was adjourned.)
. Werai neporters inc.
l s-25 I
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