ML19296C453

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Transcript of 800212 Briefing in Washington,Dc Re Status of Licensing Review.Pp 1-67.Draft Commission Paper & Suppl 1 to Ser,Parts I & Ii,Encl
ML19296C453
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Issue date: 02/12/1980
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we UNITED STATES N UCLE AR REG UL ATO RY COMMISSION In the matter of:

BRIEFING ON STATUS OF SEQUOYAH LICENSING REVIEW

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washington, o. c.

Date:

February 12, 1980 Pages:

1_ g7 INTERNATIONAL VERBAT1M REPCRTERS, INC.

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I ITED STATES OF AMERICA I

NUCLEAR REGULATORY COMMISSION 2

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In the Matter of:

7 BRIEFING ON STATUS OF SEQUOYAH I

3 LICENSING REVIEW

________________________________X 9

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f 11 77 Commission Conference Room

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g Room 1130 1717 H Street, N. W.

Washington, D.C.

Tuesday, February 12, 1980 II l

The Commission met, pursuant to notice, for 18 presentation of the above-entitled matter, at 10:00 19 o ' clock a.m., Victor Gilinsky, presiding.

20 BEFORE:

21 VICTOR GILINSKY, Commissioner 22 RICHARD T. KENNEDY, Commissioner l

JOSEPH HENDRIE, Commissioner 74 PETER A. BRADFORD, Commissioner 25 t

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COMMISSIONER GILINSKY:

We're here today to hear 2

from Mr. Denton on the subject of the application for an 4

l operating license for Sequoyah Nuclear Station 1 and the status 3

of that review.

l 6

I have asked that the Commission be given an update 7

on the situation at Three Mile Island where radioactive water leaked to the ameiling( Building yesterday.

I understand the g

9 briefing will be ready at around 11:15 or 11:30.

So, to prepare for that, I would like the Commission to vote to have 10 such a meeting on less than one week notice --

(A chorus of " ayes".)

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13 COMMISSIONER GILINSKY:

-- which we're required to do by the Sunshine Act.

We will break at that time if we la haven't completed this meeting to hear about the Three Mile 13 Island situation for five or ten minutes.

14 l

Please proceed.

17 l

MR. DENTON:

Thank you.

18 Before I begin, Mr. Christenbury of the Office of 19 the Executive Legal Director would like to brief you on some 20 legal aspects of this case.

21 MR. CHRISTENBURY:

Mr. Chairman, we have one matter 22 we want to advise the Commission on.

We received three let' ers requesting a hearing in this matter prior to the 21 issuance of an operating license.

We have reviewed these me

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three letters and we discussed it yesterday with the General i

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1 Counsel's office.

We have determined that these three letters

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2 do not constitute petitions to intervene which would trigger 3

the exparte rule which would prohibit the briefing today.

Basically, our conclusion is grounded upon as the 3

Commission will recall, the original notice of opportunity 3

l for hearing in this case was issued on March 25th of 1974, a 30-day time to file petitions.

The notice of opportunity 7

said that petitions that were late filedwould set forth a good cause for their late filing.

9 l

These three letters have come in now for almost 10 six years removed from the expiration of the notice time.

i 11 They are generally requesting a public hearing prior to the 12 issuance of an operating license.

They do not in our judgement 13 constitute a petition to intervene.

They do not address the 14 late cause requirements or purport to comply with our 15 regu'

.on.

16 So, in consulting with the General Counsel's office 17 we conclude that there is not a prohibition under the 18 exparte rule for our briefing here today.

We have corresponded 19 with these three individuals advising them of the procedures

  • 0 for late filing of applications for intervention.

COMMISSIONER GILINSKY:

General Counse% you agree 22 with that?

2 MR. BICKWIT:

I agree with all of what's been said.

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COMMISSIONER GILINSKY:

Commissioners,any Dssues?

3 Please proceed.

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I MR. DENTON:

We're nearly complete with our g.

2 review of Sequoyah application.

I had hoped to be able to 3

bring to the Commission in the first instance a complete 4

revie.w.

But we've not been able to do that.

5 The outstanding issues are in two general categories.

I One category concerns the degree of compliance today and our 6

7 review of that compliance with the near-term operating license g

issues that in the list the Commission approved last week.

9 Today we'll be prepared to identify item by item the degree 10 f compliance of this plant with that list of requirements i

that the Commission has approved.

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The other issue concerns the emergency plan in the

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State of Tennessee.

I had thought that we were further along in resolution of that than would turn out to be.

I received a letter yesterday from official of FEMA that indicate 5 that the plan in their opinion does not comply with the re-quirements for full power license and they have not yet 17 adopted standards for that that they think are adequate for 18 issuance of a low power license.

19 So I have directed my staff to work through the l

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steering group to get back to FEMA to see if we can come 21 I

to agreement on what the proper subset of requirements would 22 y

be for issuance of a low power license.

I tried to talk to L

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Mr. O'Connell yesterday, he was unavailable fcr a meeting.

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think because of the fact that this question may come up

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C ome back to the Commission on this issue of emergency 7

planning prior to any issuance of the operating license.

So, what I would propose today is to see if I can 3

j obtain your agreement on a list of outstanding issues to be resolved and we'll work towards resolving those issu2s that l

come from a near-term operating list.

I'll brief the Commission again on the status of the emergency planning 7

issues in the State of Tennessee when we've been able to 8

resolve that issue.

9 I have with me today the resident inspector of TVA 10 l

which is Bill Cottrel and the project manager Mr. Carl Stahle.

11 Denny Ross will make the presentation.

12 Would you prefer to stop at 10:15 or to resume 13 af ter the TMI--

14 COMMISSIONER BRADFORD: ; Eleven.

13 MR. DENTON:

Eleven fifteen.

Would you like to 16 l

resume or just make that the end of today's briefing?

t 17 COMMISSIONER GILINSKY:

Why don't we see how far 18 we've gotten and where we stand at that point.

10 MR. DENTON:

Mr. Ross has the presentation.

20 MR. ROSS:

Okay, let's start with slide one.

21 This is a briefing we have prepared to discuss in 22 general two types of safety matters.

One having an associa-22 tion with Three Mile Island and its aftermath.

The other 24 type is the general pre-TMI or sometimes called non-TMI l

3 matters that are ordinarily present in a review at this i_ v _,,. - -

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I point in time.

Let's go to slide two.

2 We have prepared to discuss five broad categories.

3 The introductions I'll get to in a minute.

It outlines 4

the types of things we talked about today and two general 3

categories of safety matters.

We have a brief plant descrip-tion.

Then we'll run down in part 3 the compliance at i

6 7

Sequoyah with the near-term OL list that the Commission saw last Thursday.

Part 4 is the other in TMI, the pre-TMI g

matters and the extent to which the plant complies.

9 On the bottom line on Part 4 is that there is no pre-TMI 10 matter that would preclude operation up to including 5 percent in our opinion and in the conclusion.

Next slide.

,,ss Three block categories in the introduction we talk about requiring here today, I think Bill already talked 14 about.

Let's skip the next slide and go to slide number six.

13 COMMISSIONER BRADFORD:

Could you talk a little 16 about the anima'. that you 're talking about issuing, that it's 17 t'

a 5 percent opera ting license.

What I'm interested in is what 18 level of effort goes into reviewing the 5 percent operating 19 licenses distinguished from a real live operating license 20 l

as we've known it before?

21 MR. DENTON:

A very large percentage goes into 22 fibers issuing the 5 percent.

There are few issues which i

l have not been resolved between we and the applicant to our

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satisfaction to operation beyond 5 percent.

So, the scope of I

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the license that we were proposing today is one which i

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I would permit operation only up to 5 percent of full power.

2 Even there as I mentioned in my memo to you, was considering 3

a phase approach to 5 percent power.

One which would 4

authorize fuel load and very low power physics testing and l

have in the test specs conditions that must be met before they e

an proceed even to do the 5 percent low power test.

6 COMMISSIONER BRADFORD:

Are you talking about 7

the Sequoyah operating license limitet to 5 percent operation or are there really two separate licenses involved here?

MR. DENTON:

I was talking about issuing a license l

that would valid up to 5 percent only and would have some 11 I

conditions that must be met before they could go beyond 12 zero power testing to the 5 percent.

COMMISSIONER BRADFORD:

What would you be issuing 14 at some time in the future?

13 MR. DENTON:

Then, another license to authorize full 16 power operation and that would be based on the Commission's 17 consideration on other items of the action plan and final 18 agreement between over what items had to be required for 19 full power operation.

20 l

COMMISSIONER GILINSKY:

Would that be an amendment 21 to the previous license.

MR. DENTON:

I think it would be a new license.

But, I'll refer to counsel first.

j MR. CHRISTENBURY:

I think in the past there 's been 3

an amendment to the operating license.

We have done this, i

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1 It's recognized in an adjudicatory proceedings under 5057 (c).

2 We have also applied the same principle in noncontested 3

proceedings.

There we have used the practice of having it 4

simply as an amendment to the operating license.

3 MR. BICKWIT:

I don't think there are any legal l

consequences associated with which route you choose.

In each case you have an opportunity to hearings --

7 MR. CHRISTENBURY:

In regard to notice I'm not certain.

9 MR. BICKWIT:

I don 't believe this is the practice 10 that we have traditionally followed.

11 COMMISSIONER GILINSKY:

We have issued such 12 licenses in the past.

13 MR. CHRISTENBURY:

That is correct.

14 MR. DENTON:

Yes.

Well, I think in the past we've 13 issued licenses for full power operation with conditions 16 I

l and restrictions that required operation at low power levels 17 l

are only permitted fuel load until certain conditions in the 18 license were met.

19 COMMISSIONER GILINSKY:

But, I thought at one 20 point we actually issued licenses which were limited to certain

  • 1 power levels.

I think we had some difficulty with --

II COMMISSIONER HENDRIE:

We granted a reduced 22 power for a while.

2' COMMISSIONER GILINSKY:

Well, I don't want to 25 hold up --

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MR. DENTON:

Apparently there have been instances 2

where we've issued licenses for less than full power for 2

technical reasons.

4 COMMISSIONER HENDRIE:

There was also a time 3

when we issued licenses which were for full power, but, for less than the full life of the plant.

DOL will still 6

7 remain on the books.

COMMISSIONER BRADFORD:

I think we just started 8

putting a line through the other day.

9 I

MR. ROSS:

The pre-TMI monitors which will come 10 up at the end of our presentation reviewed with our existing 11 l

guidelines.

A lot of this review is in fact completed to Three Mile Island.

Our principal SER was '.ssued in March 1979 and the supplemental SER draf t that you have in la front of you discusses the unresolved items that were on the outstanding items they were lef t open las of March 1979.

16 Let's go on to the next slide.

17 COMMISSIONER GILINSKY:

Is this pian exempted from 18 any current requirements?

19 MR. ROSS:

We would have to --

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COMMISSIONER GILINSKY Other than the TMI matters.

21 MR. ROSS:

We need two exemptions in the area 22 that the Commission has seen on other plants, the appendix G and J.

With respect to the pressure vessel and the contain-ment air lock testing.

Is that what you're talking about?

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Well, I'm just out to a --

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MR. ROSS:

The number we --

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COMMISSIONER GILINSKY:

-- gendral question to see what exemptions are involved.

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MR. DENTON:

We would propose entering exemptions on these two areas.

They are the same two areas in which c

l we rec mmended a new granted exemption as in the past.

6 With their areas --

7 COMMISSIONER GILINSKY:

Can you describe the materials?

9 MR. ROSS:

It's the pressure vessel of the fracture 11 MR. DENTON:

It's areas in which we've indicated a 12 need to revise the regulations that we don't think they 're 13 serving the purpose that they would help to serve one time.

14 The Commission has passed a half dozen licenses are s'o granted 13 I

with similar exemptions.

16 COMMISSIONER GILINSKY:

Are these the only two 17 i

areas in which --

18 MR. ROSS: That's the only two that come to mind.

19 Probably --

20 MR. STAHLE:

It's GHNJ.

21 COMMISSIONER GILINSKY:

Will he mention those along 22 the way?

I MR. ROSS:

They 're in the SER and also in the 2#

presentation.

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COMMISSIONER GILINSKY:

Good.

3 MR. ROSS:

On the plant description just to get located.

Next slide.

I COMMISSIONER BRADFORD:

Denny, before you go off 3

l that point, you haven't, I take it, a bingham amendment 6

type of review of this plant.

7 MR. ROSS:

No.

8 COMMISSIONER BRADFORD:

Thac is we don 't in f act 9

know anymore than we would any other plant.

MR. ROSS:

Right.

That's correct.

11 The plants in south central Tennessee near 12 Chattanooga.

There's a little rectangle over the State 13 of Tennessee on your handout.

You can almost see it on the 14 map there.

There 's a little bit better view on the next 13 slide.

14 The plant is about 13 miles or so northeast of the 17 l

city of Chattanooga which is slightly over a 100,000 people.

18 The other population area is out 40 miles as you can see 19 on this map.

Chattanooga is the large town.

Next slide.

20 This is a two-unit station, Westinghouse for loop nuclear steam supply system.

Both units are located in an ice condenser type containment and both units use what is 12 known as an upper head injection feature in emergency core 24 cooling.

This is the first such plant that would be i

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there's any other new or novel features of the immediate site.

2 If you see, I would like to point out one thing 3

on the far left.

There is the Sequoyah Training Center and 4

it is simulator of the Sequoyah Station located there.

5 The next slide we'll take a quick look at the 6

cross section of the containment, showing the pressure vessel 7

in the bottom center, the steel containment, the outer shell of the ice condenser.

3 Nothing in particular to point out here.

9 On the next slide I want to point 10 out the reactor coolant system.

We've shown here on the left

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side the equivalent of three intact loops.

This is how one would do at a model or put coils.

We're going to start with developing loss of coolant analysis model.

The features here show the upper head injection connected to the top of 13 the reactor vessel head.

It shows the pressurizer.

It has 16 f

a cold leg accumulators much like in the other plant except 17 l

the pressure is slightly lower.

It has the low head pump 18 injection going into the cold leg also.

19 Let's skip the next slide and go to the one on the 20 upper head injection system.

Most of the upper head injection 21 components are located outside containment contrast to the C

ordinary emergency core cooling system accumulators for the inside.

The store gas bottle -- I say its a bottle, it's 24 a large vessel a couple of stories tall.

It's storing I

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1 eventually connecting to the reactor vessel head.

The 2

pressure is about 14 to 1,500 pounds.

2 When reactor coolant system pressure drops the 4

upper head injection system automatically reactuates.

There 3

are no moving parts.

It just injects again check valves.

l 6

That's a brief plant description.

Next slide.

7 What we'll do now is go down the Sequoyah compliance or in a

some areas the lack of full compliance with the near-term 9

operating license list.

10 Next slide.

There's several places where there's j

11 supplemental presentations, but, the format lists the item 12 n the left to when applicable either held off rith fuel

3 loads are at peaks full power.

On the right is the reference in the Sequoyah, the draft supplemental SER and a brief

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statement on the status.

COMMISSIONER GILINSKY:

Let me ask you, where does I

l this stand with respect to ACRS revie..'?

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l MR. ROSS:

We have two SERS letters.

I guess they're both in the SER, that's SER, we have one in the 19 MR..STAHLE:

Just one on the SER.

20 MR. ROSS:

Well, we h' ave the interim operation I

21 letter and then we have a regular letter --

22 MR. STAHI:E :

Yes.

MR. ROSS: -- both similar and it's in November 24 i

.or December of

'79.

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The ACRS concurred in the principle j

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of doing low power testing at this plant through December.

2 But with regard to the near-term list, since they had not 2

seen or specifically concurred in the near-term operating 4

list itself, they've not reviewed how Sequoyah complies with J

the near-term list either.

l 6

COMMISSIONER GILINSKY:

Does this go back to them?

7 MR. DENTON:

No, we have not planned to take it 3

back.

They had agreed with operation of Sequoyah up to 9

power levels of 5 percent in December.

10 COMMISSIONER GILINSKY:

They have gone over all the non-TMI items?

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MR. DENTON:

Over all the non-TMI items and over g

g the low power testing program that was proposed.

But, since they have not seen the NTOL list itself, they have not seen how Sequoyah supplies with it either.

MR. ROSS:

They did ask to be kept informed about the status of the low power testing and they understood that 17 l

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the staff would be following the detailed test planning and the procedures.

19 Carl, that's appendix what of the -- Well, the 20 letter's printed verbatim in that report that you have.

21 COMMISSIONER GILINSKY:

I received it late last

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night.

D MR. ROSS:

Yes, sir.

24 COMMIS;SIONER HENDRIE:

Appendix D for the seekers --

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MR. DENTON:

Let me make one initial comment l

about this list of near-term requirements.

I think there 's a good understanding between the staff and the applicant 4

as to what's outstanding and what's required is the licensee to implement that near-term OL requirement and perhaps to e

review it in those places 'where we don 't have a closed 6

7 resolution on it.

But, Denny's going to focus today only on those g

issues where we have not come to complete resolution and 9

review of those items in the near-term list.

COMMISSIONER HENDRIE:

The problem is we go through do you want to indicate in the fuel load designated items which ones you would tag as ZP's and which one is LP's.

13 MR. DENTON:

We'll differentiate between the ones 14 I think are for the ZP or for low power.

15 MR. ROSS:

The first item, Roman I, A.l.3 referred 16 l

to both a SRO a senior reactor operation and a RO in the 17 i

control room would be as Dr. Hendrie in your context would 18 be a fuel load requirement.

TVA has not --

19 COMMISSIONER HENDRI:

I presume it would be a r.ero l

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power requirement.

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MR. ROSS:

Yes.

But TVA is aware of the requirment 3

and has not yet submitted to it.

We had a little dialogue yesterday on the subject of is the control room well

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defined and what are the four corners of the control room l

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resolved with the TVA that would be for zero power.

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The second item 1A3.1 licensing examinations.

What I'd like to do is go to the next slide.

What we 4

see here with Sequoyah and with other plants that would come i

3 to our attention and the Commission 's attention this Spring l

is that we're under a transition period where the operators 6

that received licenses for plants to start up now.

Their 7

trainirg might be a year taken place in the last year or twa and would not be in the same upgraded status as operators say they take the exam a year from now.

We 're definitely in a transition period.

What we want to do is summarize the status of the operators that 12 just received their licenses at Sequoyah and then point out 13 how the next group will be treated and so on.

14 There were some tests given about a year ago at 13 Sequoyah.

Quite a few of the operating license branch 16 people were diverted in late March of '79 to work on Three 17 i

Mile Island.

There were many times which the tests weren't 18 just graded, because people had been diverted.

19 The criteria at that time for that initial group 20 I

was the criteria we had always had prior to TMI.

The second 21 group was examined last f all with the additional test material of course could not have been on the first test

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because it was before TMI.

j The passing grauc was, as you can see on point

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Point number three, the people who received the initial exmination received a supplementa exam under 4

i Three Mile Island matters.

Just recently, I think about a 3

week ago, the licensees were assignedfor the initial set at l

TVA, 18 seniors and 6 RO's.

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There work, point number five, is unde g for additlanal people to be licensed.

Now, this is not fully in compliance 3

with the upgrading of the operator trainee as listed in the 9

plan.

Let's say one more thing about the next slide, about the training of the people at the plant.

COMMISSIONER BRADFORD:

In what ways is it not in compliance?

MR. ROSS:

What I'd like to do so I get a complete answer, I'd like to get the Branch Chief, Paul Colluis, to 16 l

come up in front of the microphone and go through all the 17

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lists.

i 18 COMMISSIONER HENDRIE:

Paul, before you get 19 started, let me ask Bill Cottrel of residents.

But, I didn't 20 recognize you without your hard hat Phil or I'd said hello 21 l'

earlier.

How did they end up or have gotten to the present 22 stage with 18 senior operators and only 6 RO's?

Just lucky or they've got a good group and they're all going for the a

l top rating or what's the status?

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MR. COTTREL:

That's been exactly the case.

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of these individuals took the test back in January and March of last year took it at both the RO and SRO level.

3 COMMISSIONER HENDRIE:

I see.

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MR. COLLINS:

That's common practice.

In the cold y

examination was I've seen mostly senior operators rather l

than a mixture of operators and senior operators.

COMMISSIONER HENDRIE:

Good.

7 MR. DENTON:

The question was they don't comply literally with the near-term OL list because of the sequencing some operators had licensing.

Let's walk through what the 10 near-term OL list would require and how they use that.

11 MR. COLLINS:

The near-term -- the new criteria 12 l

that's goi.ng to be 1M0393 on licensees will be an aid to 13 l

send overall passing grade and at least 70 percent in each 14 category of the examination.

So, that is the difference.

13 l

The first group had 70 percent overall to pass, that was the 16 I

last January - March.

17 In addition, we made them take another exmination la with a passing grade of 90 in the TMI related subjects.

The 10 second group that took the examinations in September '79 20 were only required once again to get a 70 percent overall grade and 80 percent on TMI tube material.

However, a review m

of their results indicated that that second group did meet i

22 a new criteria and all the people had at least 90 percent Id in the overall grade and at least 70 percent in each i

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category.

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Though, we could find no deficient areas there 2

that even by the new criteria even though they did have to 3

meet i 4

This third group they were given their written 3

examinations last week.

They haven't been graded but just l

based on the September '79 experience I'd expect pretty 6

7 favorable results from that.

g COMMISSIONER BRADFORD:

If I remember point 5 on 9

the previous slide right though it says that the passing 10 grade is still 70 for the third group.

MR. COLLINS:

Yes.

l l.e COMMISSIONER BRADFORD:

Why would you do that?

MR. COLLINS:

Seventy percent overall and eighty percent on the TMI tube related materials.

COMMISSIONER BRADFORD~:

Okay, now if the NTOL base requirement is 80 why would you --

16 MR. COLLINS:

Eighty overall..

17 l

l COMMISSIONER BRADFORD:

Why would you be using 18 i

70 as a grade for a group tested as recently as last week?

  • 7 MR. COLLINS:

We haven't -- we really hadn't gotten 20 the requirement to go ahead or'the orders to go ahead with 21 the new criteria when we gave the new examination.

O COMMISSIONER GILINSKY:

Is that right?

I thought 2

we had decided that the passing grade had to apply to each 24 individual category of the exam:as well.

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l MR. COLLINS:

Seventy percent.

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That is what we proposed in the SECY paper that we 2

presented to you.

But, we've been waiting to implement that 3

alog with the rest of the action plan that we've done the a

last --

3 COMMISSIONER GILINSKY:

Glen is waiting for the I

whole action plan?

6 7

MR. COLLINS:

Yes.

g MR. DENTON:

The scores did chmac,'.

You may recall 9

it used to be 70 percent total to pass.

You can make any 10 grade of the categories provided the total.

So, Paul has l

incorporated 70 as a minimum in each category and 80 overall.

)

COMMISSIONER GILINSKY:

That's what I was asking about just now.

MR. DENTON:

So, that is a part of this.

COMMISSIONER KENNEDY:

That has been implemented?

[

MR. COLLINS:

Seventy percent, yes.

16 l

MR. DENTON:

Let's go back one -- let's go to the 17 l

bottom --

18 COMMISSIONER GILINSKY:

Let's be sure we're all 19 talking about the same thing.

I 20 MR. COLLINS:

On the last one, yes, 70 percent in 21 each category is the passing grade.

With the 80 percent 22 on the TMI tubing.

22 COMMISSIONER GILINSKY:

That's not what your slide 24 l

says, though.

It just says overall.

Okay, as long as we l

t i

me 1

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~

understand that, l

g l

9,.;

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21 pact nc.

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/

1 MR. DENTON:

I think taere's another aspect to, is 2

that we expanded the scope of the test.

The test was to a

include more material in the thermodynamics and heat transfer.

4 So, the first group who got their licenses in March last year 3

did not have that as part of their package.

But, they will l

be reexamined or they'll have to be requalified to the new 3

7 criteria when their term comes up --

MR. COLLINS:

Every year an annual examination.

g MR. DENTON:

So, the real question we wanted to bring to you is when operators are qualified all throughout the year do you want to bring them all up to the standard that you approved last Thursday or do you want to recognize that in some areas they won't all be in literal compliance?

13 If you go to the next slide, this is a unique 14 group of operators because they 've been in training for so 15 long.

I think Pau)

,'ou should talk about the last aspect too.

16 l

MR. COLLINS:

I do and I have supplementary infor-17 l

mation to this chart.

18 COMMISSIONER GILINSKY:

Could you tell us what 19 fraction of the operators who would operating this plant 20 have operated reactors before? -

Il MR. COLLINS:

Not -- no I can't say --

3 MR. ROSS:

We did point out and this came from i

22 our management review group a couple of weeks ago that at the supervisory level there was a shortage of people --

l 24 I

i in fact we didn't find any with pressurized water experience.

1!

j

Jn ; ' 5,9 P ACZ No.

22 f

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b/

1 We thought it important enough to get TVA to augment at least 2

through these testing program additional operating experience from Westinghouse.

They have agreed and they have assigned 4

additional people on a shift basis to guide and advise the 3

TVA people because of shortage of PWR operating experience.

l COMMISSIONER GILINSKY:

Could you find that out 3

for me?

7 MR. COLLINS:

Yes.

g MR. DENTON:

Let's walk throdgh their background what they do have.

It is the first PWR I guess in the TVA i

system.

MR. ROSS:

Yes.

12 j

MR. DENTON:

So, none of them have PWR experience, is i

l MR. ROSS:

Well, they have some imported and some is of s rather old.

Bill may have some additional Laformation 13 I

I on that.

16 l

MR. COTTREL:

We could address that but can we 17 i

address the items on --

18 l

MR. ROSS:

The management results.

19 MR. COTTREL:

That's one of the areas we specifically 20 I

looked at.

21 MR. COLLINS:

You have it for all the people?

~~

MR. COTTREL:

I'm not sure.

i

'~

MR. DENTON:

Let's go through the chart here 24 i

I started.

I 9C I

~~

MR. COLLINS:

Item 1 there all applicants have about i

i.,re

% vo am. Remmm. i e.

% o Aw 23 psas nc.

br f'

l 1

3000 hours0.0347 days <br />0.833 hours <br />0.00496 weeks <br />0.00114 months <br /> of classroom training prior to taking their l

2 examinations.

I verified that with TVA yesterday and that

,7 V

l 2

applies to all three groups.

They've added an excess of 4

1 classroom training.

l 3

In addition, what doesn't appear on that chart, l

all the operators that had 600 hours0.00694 days <br />0.167 hours <br />9.920635e-4 weeks <br />2.283e-4 months <br /> of simulated treining 6

7 which is just about double the number of hours we would normally see in our

t. pical coal training programs.

They g

also have 300 hours0.00347 days <br />0.0833 hours <br />4.960317e-4 weeks <br />1.1415e-4 months <br /> of observation training at operating 9

I plants which is about equal to what we require for the 10 normal coal training program.

The post TMI training amounts to 90 hours0.00104 days <br />0.025 hours <br />1.488095e-4 weeks <br />3.4245e-5 months <br /> of post CMI tube training including studies in thermodynamics 13 and the related instrument responses.

14 The final two items, the operator requalifications 13 I

i program has been in effect since March of '79 so that they 've 16 I

been staying current on things that are occurring.

Of course, 17 j

we have this additional training plan during the low power 18 special testing program which doesn 't appear on the chart 19 here.

20 COMMISSIONER GILINSKY:

How long would you expect 21 the low power program to continue.

~~

j MR. DENTON:

I think the fuel load zero power i

f test is about two months long and then probably two months

~

i a4

^

j of low power testing af ter that.

So I'd __

j i

me

~~

i MR. ROSS:

Four to six months, depending on what i

f Ca c ' :s s t 24 f

nax nc.

f j/

l I

I goes on wrong overall.

COMMISSIONER GILINSKY:

Okay.

3 MR. ROSS:

Any other questions on the operator 4

licensing?

COMMISSIONER HENDRIE:

It sounds to me like we better get them started they 're getting over trained.

MR. DENTON:

Just to close this one off, while 7

we 're not able to say they literally comply with last Thursday ', s requirement in every aspect, I think the staff has no Y

problem saying that when you look at their total qualifications i

and training, I don 't see that this would be a barrier to i

11 fuel load or low power testing.

Since they are being augmented 12 with some TWR experience in Westinghouse.

But, it is an 13 area which one could clear is not in literal compliance 14 starting today.

13 COMMISSIONER GILINSKY:

Did you say this is the 16 I

first plant to use upper head injections?

17 MR. DENTON:

Yes, it is.

18 t

COMMISSIONER GILINSKY:

Does that introduce any 19 wrinkles here in the training of --

l MR. ROSS:

Wel'- we'll discuss it later.

The only i

  • 1 l

thing diff erent is as f ar as TVA's concern no.

As far as the staff is concerned it's a wrinkle in that we have to go back to the small break LOCA analysis and guidelines 2#

and work with both TVA and with Westinghouse on different

(

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guidelines because the transient will run a little differently, I l

larTrummaticsim. Veema71es Repourrpts asic.

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I 9ut, all it means for TVA is they have to have a LOCA procedure f

and other precedures that might look like LOCA that takes 2

1 2

into account upper head injections.

4 COMMISSIONER GILINSKY:

In the training of these 3

operators is taking all this into account I assume?

?

6 MR. COLLINS:

The training simulator training is

l 7

f using the Sequoyah simulator that has the upper head injection system model.

y MR. DENTON:

This system represents an advance in 9

I g

j safety.

It just happens to be a first Westinghouse plant I

to have operators like this.

Would you like to add any observations?

l,a MR. ROSS:

Let's go to the next slide.

There are three items on the next slide.

Again let me remind that this is from the near-term OL list is part one which you had a 15 label at the top in requirements not yet issued. On Roman one 16 l

B11, B12 is C5 and we talk about as a unit because they all 17 i

have to do with the management and technical competence of 18 TVA to run the plant during normal and abnormal events.

19 While I'm running through the list, if Paul 20 Kellogg would come up I'd like to describe how the staff 21 interacted.

The plans said that there should be for the

~

plants in the near future an interoffice meaning between I&E i

'~

and NRR team to visit each plant pending development of 24 criteria.

We 're coming along pretty well on the criteria, me I

i I

~

but it's not developed.

So, we do have this os a ad hoc l

c. '

Aq 26 l

e l'

(

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basis an interoffice team.

2 The inspection and enforcement furnishes in i

2 addition to team members a team leader and for Segnoyah 4

Mr. Paul Kellogg of Region 2.

As soon as he says his 3

first sentence you'll realize that he's from Region 2 The report of the team is --

6 7

COMMISSIONER HENDRIE:

You notice Denny's been 3

trying hard to loose his over the years.

MR. ROSS:

What Mr. Kellogg will do, we'll give 9

an oral summary of his report which is in draft form and he 10 would be called up here has not yet been assigned to review.

g The items that we looked at if we could go to the next slide is six items shift manning, organization and management criteria, safety engineering group, resident I

inspectors, licensee dissemination of operating experience 15 and communications.

As of the NRR participants were the 16 f

project manager, Mr. Stahle is sitting L're and several 17 3

others Larry Crocker who's heading up the team looking 18 at this subject of NRR in general, Jim Snell who's an 19 alternate project manager and worked on this extensively 20 l

as part of his special inquiry,' and then a *_eam f rom 1&E.

21 I

What they found is shown in summary form on the 22 next slide.

There are seven items, we have discussed these 22 items with TVA.

We don 't expect any undue dif ficulty in 24 resolving them and I think the most efficient thing to do f

i 98 l

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is just to have Mr. Kellogg briefly run down each item and 4

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1 flush it out a little bit.

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18 19 20 21 O

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,gg se, 3-1 MR. KELLOGG:

Item Number One, on the senior 2

personnel, we looked at the shift watch engineer who would 3

be the senior licensed indivdual in the control room and f

we also looked at the operation supervisor who was the I

the gentleman that they report to and they found that one i

6 of the major portien of it that the last time they had 7

been to an operating pressurize water reactor plant for l

3 observation of the systems in operation of the fuel and 9

power was at about 1975.

10 We recognized that they had extensively used I

the simulator and the time that they had been stationed at 12 the site to augment this but our feeling was that we felt j3 that until the staff actually has experience in operating

g the plant with fuel in it, at temperature and pressure, that they needed to augment that staff with operations 33 l

personnel who are protected.

g COMMISSIONER GILINSKY:

Did they have other nuclear experience?

MR. KELLOGG:

Yes, sir.

They did have on the most part a lot of them had been involved in the Browns 20 I'erry, but that is before they had a reactor versus pressure 21 reactor.

=

We felt that there had been a lot of changes 23 in the way things were operated recently as a result of 24 l

i l

Three Mile Island and it was the team's feeling that they 25 l

i needed r. lot at that level of watch standard.

i i-% v ammon i=

l 29 c'

I

    • cr uc.

I COMMISSIONER GILINSKY:

And you felt that that could be done during this period of low power testing?

I f

2 MR. KELLOGG:

Yes, sir.

We discussed it with TVA f

and had basically arrived at an agreemen; with them that 4

3 they would have an individual who has current operations experience on shift any time that there is fuel movement, I

7 fueling operation or when a reactor is above what we call j

3 mode three or is a temperature.

COMMISSIONER GILINSKY:

Then the man sounds like 9

a road scholar.

10 MR. KELLOGG:

Okay, plant organization.

j; Our finding there was that TVA had reoganized beyond 37 the organization that had been submitted in the application g

FSAR and that they had not updated NRR with the new people, their new reporting lines and responsbility and their new functions.

16 So, we left an item with them that they either needed to revise back to their old or to submit for review 18 to the new organization and they have gone back now to the 19 old organization.

20 COMMISSIONER GILINSKY:

Does that clarify the item?

21 MR. KELLOGG:

That will clarify the item, yes.

O The problem is that NRR --

2 COMMISSIONER HENDRIE:

Does that improve the 24 org mization of the plant staff?

I am delighted to have clarifier.tions, buc I just assume be clear about the best i-% v

% i c

30 ncz no.

1 organization or the second best organization.

2 l

MR. KELLOGG:

As it turns out, Co=missioner, 2

there are really three organizations involved.

J There is the one that they are in, the one they 5

had submitted, and the one they want to go to and they are l

back at the one they submitted and they are going to reorganize 6

7 to the one they wanted to go to and I feel that that is the best organization.

g COMMISSIONER GILINSKY:

When will that get done?

9 MR. E LOGG:

Dere was no commitment made as far 10 l

as when it would be reorganized.

g COMMISSIONER GILINSKY:

I see, so that would just take place.

Are we involved in that?

MR. KELLOGG:

We would be involved in it from the 14 review of a technical specification amendment after the license was issued because section 6.1 of the technical specification 16 l

contains the onsight portion of the organization.

17 j

COMMISSIONER GILINSKY:

So they would submit that 18 l

to us and we would do that.

19 l

MR. KELLOGG:

The training and the emergency response 20

~

teams we found that currently the staff who report to and 21 you have to recognize that TVA is their own architect, O

engineer, constructor, designer, that the staff that reports i

~

to the site in the event of emergencies is more of an is engineering discipline.

l

~

In other words, they are interested in a system or

(

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l 31 l

c' escx nc 1

a component in their normal function.

2 i

They do not have a training program which would bring these staff members up to have knowledge of system s

interaction, or system transient actions, and the guidance c

~

that we have we do not have we went on to inspect with 0

indicated that this is one of the items that they should I

have which was an ongoing training program to insure that a

the technical people who would be responding to an emergency 9

to the site are aware of the conditions as the site is 10 modified and have this system in transient training.

i 11 l

This is contained in NUREG guide 3.1 and addresses 12 it which is still in draft form.

13 COMMISSIONER GIL'.NSKY:

I guess I am not clear, la who is getting this training now?

13 MR. KELLOGG:

Okay, this would be the staff 16 members from the corporate office primarily the divisions of reactor engineering which for instance would be mechanical, 17 l

jg electrical engineers who would augment the plant staff in an accident condition.

39 They would be bringing in technical expertiese.

20 COMMISSIONER GILINSKY:

And when would this 1

4 training take place?

MR. KELLOGG:

TVA has indicated that they would j

start the training program as soon as they can come up with 24 j

some criteria for it and it will be fully in place by the 2

l time the get the full power.

It is not an tumediate hold item i

mm ve = % i.e.

l

o' l

rsaz nc, 29 rep starts 1

if your will.

The people that, that are currently involved 2

with the plan are the staff that would be reporting there in an emergency.

The problem is that there is no, no re-4 qualification; there is no ongoing training program of this staff to ensure that they remain f amiliar and that they get e

l some systems interaction training.

6 7

MR. KENNEDY:

Total satisfaction of this require-ment, in your judgment, is not necessary before issuance of 3

zero power and low power.

9 MR. KELLOGG:

That's what I was about the say.

SPEAKER:

That is correct.

11 COMMISSIONER GILINSKY:

But you will pursue it, I assumer.

13 MR. KELLOGG:

Yes, sir.

14 COMMISSIONER GILINSKY:

The outside safety review 13 group.

TVA has committed to, to the NRC to have a on-site l

review group who is primarily a surveillance group who 17 i

i reports back off-site, if you have any problem getting this 18 zero power initial criticality with the augmented test la program.

20 They do not have what the action plan lines are as 21 a safety engineering group on-site.

They do have various

~*

functions in the corporation that provide an independent assessment of the operation of the station, but it is located

  • L l

in the corporate offices and is not on-site as the action se plan calls for an on-site crew.

I

~

i lOM YNN hN

f 8

0 paGZ Na, 3 3 I

COMMISSIONER GILINSKY:

What precisely is this group 2

supposed to do?

I MR. KELLOGG:

The group as it's described in the, in 4

the acceptance criteria and the action plan basically is an independent safety review group who is on-site.

They review e

l P ant operations, plant operations experience; and they make l

6 7

recommendations off-site, at least at the current time, to someone above the plant manager.

They're not associated with 3

the operations or the maintenance of the plan.

9 COMMISSIONER GILINSKY:

Do you see them playing i

some special role during this low power testing period?

MR. KELLOGG:

Well, they committed to, to an independent group.

The difference is that the proposed 13 charter for this on-site group is much broader than, then the 14 commitment that they have made to 'the NRC for the group that they are going to have in place.

16 Also, it is TVA's feeling and position that the 17 j

assigning of this on-site bimember group is really detri-18 mental to their overall effectiveness and independent review 19 function.

20 COMMISSIONER GILINSKY:

Do you regard their 21 proposal as satisfactory.

22 MR. KELLOGG:

I do for, for this period.

Yes, sir.

l MR. ROSS:

They did agree, TVA agreed to reconsider I#

their position, the independence here of the low-power tests. ;

,a They seemingly have enough of a commitment for that part, andI

-~

i I

lOM NDM IN

ncz nc.

34 1

maybe further action through the action plan or further 2

persuading will produce a different resolution before we are 2

ready to go full power.

4 At any rate, they agreed to reconsider.

i 3

MR. DENTON:

I, I think we need to rethink what we 6

want this group to do for a big Federal bureaucracy such as 7

TVA, that when in my concept it was most useful for smaller mpanies -- and I was concerned about reporting channels --

8 I think one thing I found in this organization:

there's a 9

lot of reporting channels from the plant, as you might expect, for, for, for a big company such as TVA is.

And this is satisfactory low-power license.

TVA has other alternatives that they think would, 10 would actually function better if it" fit into their 14 management scheme.

We, we could consider those during the 13 time between now and the issuance of a license for core 16 l

power.

17 I

COMMISSIONER BRADFORD:

Harold, let me stop you 18 there just on one phase.

When you say something's satis-19 factory for a low-power license, help me put that in a 20 framework.

21 What percentage of the, the risk inherent in any plant is, is present when you're at 5-percent power?

Of the very, very small percentage -- and you don't i

og l

build up any core inventories; and you don't operate at any l

L oc extended periods of time at 5 percent -- I think the risks I

~

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4 g

pact Na 35 e

1 are, are really miniscule in terms of core-power operations.

I COMMISSIONER GILINSKY:

Well, you're stressing the low power with a, with a fresh core.

4 MR. KELLOGG:

Yes.

3 And therefore, for the kinds of transients that 6

might occur or events that might occur, the residual heat in

'he core is so low that --

c 7

(Pause.)

3 So it, it's much different than just one-twentieth.

9 I don't know how to quantify it, but I think it's very small.

g I

i COMMISSIONER BRADFCRD:

The intensity, it's lower than one-twentieth.

12 MR. KELLOGG:

Yes, with a fresh core and --

13 COMMISSIONER HENDRIE:

It's way lower, maybe a 14 part in a thousand of the full power reading.

In fact, you'd have to work pretty hard to, to get any, enough fission 16 products out of the iuel to make any difference even to, to 17 l

plant people.

18 You haven't got the driving forces.

You can't 19 overheat them, because the only way you can generate any 20 l

energy in them is to have the chain reaction going on; to 21 I

have the chain reaction going on, it has to be critical; and

~

to be critical, it has to have water around the fuel rods.

So you can't get into the, the classic problem of 24 l

undercooling.

Either you've got enough water to cool it, in 2

i I

i-m vimm. manrem, i c.

f l

0 pact sc.

36 l

1 which case you can have the chain reaction; but if you don't have the water and can't cool it, you don ' t have the chain reaction.

So --

MR. DENTON:

Having said it's a very small risk, I

that assumes that procedures and the limits on which they li 6

operate really do constrain the core to low-power operation.

i 7

COMMISSIONER HENDRIE:

Right.

I mean --

l 1

MR. DENTON:

When we look at these test programs, 9

we, we will be sure that instrument subpoints and procedures i

10 are such that the core is not permitted to operate at level.

I 11 But in, even if you, something above 5 percent were 17 to occur, there would be no inventory of fission products a

such as would result from extended operation of the core 34 power.

(Pause.)

3 COMMISSIONER GILINSKY:

Well, the fact is, I mean, g

it is critical, and the fuel is there, and the reactivity is l

i there; and it could go up to higher power levels if one 18 i

doesn't make sure it stays at a lower power level.

I COMMISSIONER HENDRIE:

And furthermore, your point, 20 you're obviously not carrying 'out a low-power test series 21 just as an end in itself and then you're going to go away and

':2 l

never operate at full power.

You're on your way to trying to 22 meet all the necessary cunditions to get this plant to full 24 power.

And that, for whatever the very much reduced, really l 5

i I,

inro = vomm-stoonras i c.

e nsz se.

37 I

nerp igible public-hazard levels associated with full power, I

vnu don't want to run a careless or inadequate operation there, 3

because you are on your way, presumably, on up eventually.

f And you want this period to be an adequate basis and a 4

3 properly run basis, and everybody do just the things they l

6 ought to do, just as though the plant were at full power.

7 MR. DENTON:

We cover the low-power test program as j

3 the next item after this, 9

COMMISSIONER BRADFORD:

I was just after some 10 context for the phrase that you would tolerate this during 11 the low-power testing but not afterwards.

MR. KELLOGG:

Okay.

With respect to the qualifica-77 tions of the Schick technical advisers, we had some open 13 items at the time the inspection was completed.

It basically consisted of eight individuals that TVA has removed from l

their reactor engineering department and sent to be STAS; and f

l l

they have completed the training on all those individuals 17 l

with the exception of two.

18 And there some problems with respect to dual 19 functionality., because they had come from reactor engineering; 20 they stand the STA shift duty ' There was a problem with the, 21 their feeling they were still working for reactor engineering.

22 l

TVA is placing another instruction out that defines when they're STAS, they're not working for reactor engineer-24 i

i i

ing group; they are in fact those STAS, and those duties and j

f I

25 i

0 pact Na 38 I

functions are, are assigned.

So that problem is really pretty l

well gone away.

2 With respect to the d

Westinghouse technical support for the special test program, i

3 our only finding there.was in TVA's Lastructions for the 6

conduct of the test program and test results review, they 7

had to define Westinghouse's role.

8 Westinghouse is going to be there.

They are going 9

to be providing an input.

And this was not covered in their 10 procedures.

I 11 They have since revised those procedures to incorporate Westinghouse's position in the test program.

COMMISSIONER GILINSKY:

Let's see.

I thought we

3
g were going to have tt ' vendors go over pro
Edures with j

utilities.

Has this taken place here?

MR. KELLOGG:

Yes, sir.

g I

l MR. ROSS:

What's the next item?

17 l

i (Several voices.)

18 But it's the next item on our list.

19 MR. KELLOGG:

Okay, the last item is the 20 clarification of demands for r'esponse organization.

21 In their normal organization and operating 22 l

instructions, they have lines of communications and, and who 22 reports to whom, and who's authorized to do what.

24 I

i In the emergency situation we were given such I

15 I

l i

m% vo ri nummia i c.

3 39 encc na 1

information that these lines of communication were contained I

in several documents we 've looked at.

We felt that they were 3

not clearly defined as to how those roles change.

f As an example, the, in the normal operation and 4

l 3

l facility the people who come to the site to perform modifica-6 tions reportage to an outage manager, who reports to the 7

plant manager.

In the case of an emergency the plant 3

manager becomes the on-site director, and those off-site 9

people report directly to him.

I 10 That was not well defined in the documentation that 11 we looked at.

TVA tells us that we have redefined these emergency response roles and that we can come back and look at the implementation.

So there's revising and reinspecting

7 their instructions in this area to make sure that the roles
j are clearly defined in the emergency response.

l (Pause.)

I i

MR. ROSS:

The bottom line on this item is that we 17 l

will need some additional documentation from TVA.

The 18 detailed from INE will be given to the TVA as soon as it's 19 signed, and we decided that it probably can be resolved 20 without any difficulty, at lea'st the requirement for --

21 COMMISSIONER BRADFORD:

Well, when you to perform O

this inspection, what were you inspecting against?

Was, what 23 was your list of things to look for?

24 l

i MR. KELLOGG:

There were several.

I have a draft U

I ImTsuonah Votaanes Rzpeurfums, im".

l O

l pacz so.

40 I

of acceptance criteria for utility management organization 2

and technical competence, which was issued by a group in, in 3

a nuclear reactor regulation.

A And that document references to several ANSI 3

standards, particularly 3.1, which is management and training i

6 of, for operations, which are --

7 Standard and the draf t criteria are all in, in I

8 draft form.

So we were using those, and we were also using 9

the team's jud ment, as well as the past commitments that TVA 7

10 had made in their application.

I 11 COMMISSIONER BRADFORD:

Now, in these areas, as 12 time goes by -- and you'll want to inspect again -- what kind 13 of a backdrop does that give you for actual enforcement if 14 l

you were to find something you thought was inadequate.

I 13 l

I take it that's not a penalty.

That's not a 16 framework within which one could very easily impose a penalty.

17 i

MR. BICKWIT:

You could not impose a penalty against t

18 the draft acceptance criteria or against the guidelines.

You p9 could impose a penalty against any of these commitments that l

20 l

TVA has made to NRR as a result of the short-term lessons and 1

21 what the long-term lessons were.

l These various things where the Commission writes to l

23 the utility, and they write back and say, "This is what I'm I

y going to do."

That's enforceable against that.

1 1

If you put it in the license.

I 23 l

4 h

I

e pact No.

41 1

MR. DENTON:

If it's in the license, it's clearly enforceable.

If it's, if it's a commitment, then --

3 MR. BICKWIT:

If it's a commitment without being placed in the license, I don't see that the civil penalty is I

strict.

l 0

MR. DENTON:

Well, I think what's happened:

in 7

l those cases the compliance attempts are obtained from clients 8

what we understand the mission to be.

9 i

And if that fails, then they can take it before the 10 plant.

I 11 i

MR. KELLOGG:

That's correct.

We use what they 12 call a deviation.

These -- the action plan calls us to 13 develop the criteria; and as Paul said, we adopted several l

14 l

versions.

15 We believe they about to the place where we can 16 release these criteria, albeit draft, to industry for interim t

17 use and comment, much as we issued the emergency preparedness 13 criteria for inner release and comment.

l 19 (Pause.)

I I

20 Okay.

Let's go to the next slide.

l 21 COMMISSIONER GILINSKY:

Can I interrupt you?

What 77 is the status of Unit 2?

l i

MR. ROSS:

It's supposed to be finished within a

3 l

l year.

24 l

We're here to discuss Unit 1 also.

7 is,rpeenaTicoana. Veemartie MarcseTous Imr.

42 o

pact No.

I COMMISSIONEP GILINSKY:

No, no, I understand, What 2

I'm concerned about is, is a site in which you have an 1

3 operating plant and another one under construction.

4 MR. ROSS:

Separation was explicitly discussed.

i i

3 They've done a lot of work recently to ensure separation, a 6

lot of security provisions.

7 Bill can discuss it.

8 We, on our site visit down there a few weeks ago, 9

we frequently ran into fences and, and gates and what-not 10 the ensure separation.

11 MR. DENTON:

This, this is not a, I think it was 12 first considered on grounds that the 2-3, one of the first l

multiple plant sides in a quite a history drawn up on how you 1:;

ta j

separate and isolate one half from the other.

l 13 COMMISSIONER GILINSKY:

You 're satisfied that this 16 has been done.

I MR. DENTON:

I, I know of no outside problems.

17 I

18 l

MR. STAHLE:

It is complete.

79 MR. POSS:

Okay, the next set is the special test i

l 20 program.

73 1

Go to the next slide, Bill.

77 Yes, sir?

i i

COMMISSIONER HENDRIE:

On the, the items 3, 4, and 7

i 24 l

5 back in the tabulation, either the ones we've just been across, do I mark those " low power" or "zero power"?

3 l

infomam vevaarim Ptemernes, lac.

I me 30WTM CAMTth STREET. S. w. SufTE 167

=

c pacz No.

43

- l MR. ROSS:

The, I believe Mr. Kellogg said that 2

three, the continuing thing, would be actually --

COMMISSIONER HENDRIE:

It may even be full power.

MR. ROSS:

Right, right.

It's a 40-year commitment.

3 And maybe some of -.because he was worried more about recall I

6 of these people.

7 I think the commitment provided probably can be 8

done very quickly.

But as far as safety's concerned, I don't 9

see that it's needed before the special test program.

So I 10 would put "FP" for " Full Power" for that one.

i 11 Item 4, they have the function now.

The question 12 is, do they need it for the 40-year license?

Do they need a 13 on-site permit commitment for the on-site safety review?

14 I

That's what we agreed to l

reconsider at the end of the special test program.

So that 15 I

i 14 I

also is listed as " full power."

17 I think, I think 5, we wante'd fixed before OL 13 issuance, as I recall -- which would, which would give it a 19 "ZP" label.

I 20 COMMISSIONER HENDRIE:

Okay, it's, it's a mixed I

21 group.

22 Let's go on.

I

3 (Pau se. )

l MR. ROSS:

On the special test program --

74 I

I, i

i MR. DENTON:

Do you want to hit the procedures?

Gol

.3 l

I f

44 w

o pacz NC 1

back one slide and --

2 MR. ROSS:

Okay.

The, the subject of the vendor 3

review procedures, which is under 1C7 -- and I don't want to jump slides; but if you, if you thumb through your set, 1C8 is.

I e

the NRR review.

We selected notes of procedures.

l I

6 And 1G is the training --

I No, don't go to the next slide.

That's all right.

8 Let's stay with -- all related subjects.

9 So I thought we'd talk about the proposed test 10 l

program as a class, because these are interrelated.

1 11 There was a question a minute ago about the l

12 I

review of procedures.

Westinghouse is in fact in the process 13 of reviewing some of TVA's procedures, and so are we.

We i

14 i

received draft of at least one.

There're some factors aboit 15 it that we didn't particularly like, so we asked for a few 16 more; and we're shipping those off to them.

I believe that we will look at some -- we will look 17 ta at some selected procedures that have had the benefit both of 19 TVA and Westinghouse comments as a precondition of going from 20 zero to the special test program.

21 These are in addition to the special test procedures which also will be examined by us.

The type of procedure i

23 that we'll probably look at; the emergency procedures would be in addition to --

24 I

3 There'd be loss of people under loss of AC power I

i iwnm m vsinari= w ie.

o nor so.

45 steam generator --

I Maybe a few others.

3 MR. DENTON:

I think the answer to your question before, my understanding of Westinghouse, is looking at all I

the emergency procedures for full power.

6 MR. ROSS:

That's correct.

7 MR. DENTON:

And that will be required before any 8

operation above the low power.

9 MR. ROSS:

Yes, sir.

That 's subitem A of 1C.

10 On the proposed tests, we focus in, as you can on 11 I

the slide here, starting with natural circulation, and items 1

12 2,

3, 4,

5 use the acronym "NC" for " Natural Circulation" in l

13 a number of different modes.

14 COMMISSIONER GILINSKY:

Could you also indicate how 15 these tests differ or go beyond what would normally take l

16 place, or what has taken place in the past, and when l

17 l

breakers start up.

i 18 l

MR. ROSS:

Bob Bayer, who is the branch chief and 19 division project officer, was given the job to coordinate for l

20 NRR the review of this subject.

So, Bob, would you respond l

gg to that?

3 MR. BAYER:

These groups of tests are completely i

n in addition to the normal tests they do under reg guide 1.68.

24 These are series of tests that are not normally performed 3

during the start-up.

y l

i-= v-m. - i c.

46 g

o pacz No.

i MR. DENTON:

The whole group?

2 MR. BAYER:

Yes, sir.

3 (Pau se. )

MR. DENTON:

And the other unique feature I recall e

was we were going to have these tests done on them by every i

0 i

shift.

7 MR. ROSS:

Yes, that's coming up on some of our 8

succeeding slides.

9 So, in addition to the natural circulation tests, 10 which took its code through 1 through 5, and we're looking at 11 the PWR who's a -- a system goes by different names.

The 12 chemcial volume control system, where you can take fluid out 13 of the primary system, bring it out of the containment, 14 l

lowering the pressure, cooling it, and make it -- pump it i

15

[

back into the system through makeup pumps.

16 i

This is the way, among other things, you can control 17 the inventory and you control the boron.

That system has a, la a -- since you had a letdown cooler or something that goes 19 by that name, a certain cooling capacity; and that's what 20 item 6 is.

21 Item 7 is the simulated loss of AC.

22 Item 8 is starting the plant from stagnate condi-i

3 tions, that is, not having your primary pumps and bringing the plant up to power and seeing how well natural circulation 24 i

i starts more or less from a blue-strapper and perhaps a black

,3 i

t U

i te?

9 e

ncz No.

47 I

start.

I A plant -- force circulation.

2 MR. BAYER:

Actually, 9A is going to be one of the f

first ones that performed to get, calibrate the instrumenta-4 I

tion.

6 These are not, these are in the order TVA numbered 7

them, M t not the order they'll be done -- not quite the 8

order.

9 MR. ROSS:

Now, I'd like point out there're five l

criceria on the next slide for tha low-power test program.

10 11 Earl just mentioned training, which is number 2.

12 The test should provide meaningful information.

We'd expect 13 to be able to, to trovide the test data to go along with the 14 j

analysis on plant performance -- in particular, natural 13 j

circulation.

So, in effect, this would be a verification l

16 programs f

Point number 2 is the training.

And I believe that 17 l

18 many of these tests will be done for each of the five 19 operating shifts.

But each shift can see --

I 20 COMMISSIONER GILINSKY:

I don't understand.

This gj is in addition to the, to another series of tests which they 3

would otherwise be required to perform.

MR. ROSS:

The application, the FSAR has a section g

3 i

15, chapter 14, on -- called " Initial Tests and Operation."

t 3

l And the reg guide is 168 -- reg 1, I believe.

It's 1.68 I

i

-- v ne, w

4

=

o pacz No.

49 1

anyway, where they cc mit to do certain tests for start-up.

And, as Bob said, we're talking about now supplemental tests.

3 The concept, for example, in point number 2 is a

l supplemental training.

i e

l COMMISSIONER GILINSKY:

And what proportion in some 6

sense is this what would otherwise have been required?

I MR. ROSS:

I guess 4 to 6 weeks more of plant 8

operating --

9 MR. BAYER:

Well, I think they 're planning six 10 weeks for the low-power test.

That's probably on the 11 optimistic side.

12 MR. ROSS:

Say more than two.nonths.

13 COMMISSIONER GILINSKY:

So it's about 15 percent 14

'more than would otherwise be done.

15 MR. ROSS:

Well, we're just talking about a zero to 16 5 percent -- there's still some testing that we have not yet 17 discussed of that 5 percent.

And that would be two categories 18 also:

one, what's always been required; and then there may be 19 some supplemental tests like this that will come up as a 20 result of needing more training, as well.

21 (Pause.)

MR. DENTON:

Well, I think the more normal testing n

programs are, are designed to assure that the, that the plant 21 con.Tiguration and fuel installation and -- is as, as 25 projected.

I i-- v- - %

i in

M c

PAGE NC.

40 These tests are designed to put the plant through 2

unusual paces, such as natural circulation, and verify I

analytical results.

So it's a different focus than the a

l normal start-up program, which sort of verifies operability i

e

~

a.id correct installation of components and hardware, and 6

functionability of the plant -- these go more toward verifying 7

operation under accident conditions or simulated accident I

conditions.

9 COMMISSIONER BRADFORD:

Harold, would you recommend 10 start-up testing like this for all plants in the future?

II MR. DENTON:

I think this is in the action plan.

1 We recently met --

13 COMMISSIONER BRADFORD:

The same program basically?

i I4 f

MR. DENTON:

Well, I,

I, I don ' t think the action 15 plan defined the type of program; but I think the concept of, I

16 of additional start-up testing to verify performance, l

17 especially if the reactor design were changed or -- and it 18 also has a training advantage, even it's the same design.

19 Let me ask someone from the steering group exactly I

i 20 how the action plan --

l l

21 SPEAKER:

The steering group has disappeared.

l 22 MR. DENTON:

Anyone like to volunteer?

3 SPEAKER

Any action plan, Harold, calls for the

4 development of criteria that would be applied during low poweq.

3 But the long-term criteria might not turn out to be identical l tursse, am vuesame Rap:serens. le I

ao scarrw caema, svnurt. s. w. surra ses

=

o pact No.

50 1

to what is being proposed at this time.

2 l

MR. DENTON:

Thanks.

3 We do engage in something like this, flowing from 4

i the actual plants for all, all --

I t

MR. ROSS:

Commissioner Bradford, we did meet with I

6 an owners' group comprised of representatives from three f

Westinghouse near-term OLs.

I 8

COMMISSIONER BRADFORD:

I was going to ask about 9

the other.

I l

10 MR. ROSS:

And this would be Westinghouse, plus i'

11 REPCO Public Service, and Pacific Gas and Electric.

12 And the purpose was to develop an integrated plan, 13 a master plan, for which this should be done at each facility 14 l

aad which tests could be done once, in terms of gathering in 15 l

our safety information.

16 So we are trying to coordinate these ef forts with i

i 17 the other Westinghouse near-term OLs.

18 l

That's the only class of plants we have for the 19 next few months, is Westinghouse.

20 Item 3, tests should not impose undue risks.

This i

21 illustrates the one area of the low-power test program that is still not complete, because a safety document is undar i

23 I

preparation by Westinghouse -- and we'll talk about that in a 24 minute.

l And additional criteria is:

the risk should be lowq 3

levisunam Vaaaa tes Rupaseres le

=

o pacz NC.

51 1

And in certain requirements, point number 5, 2

shouldn't be precluded by the, by the radiation levels.

3 Criterion 1 --

next slide.

3

-- we, we've talked about in terms of gathering 6

data for the use of verified plant operation.

And in 7

particular, I think, the one about the boron mixing during 8

actual circulation will be useful.

9 We do point out that we do not propose -- TVA did I

10 not propose, nor did the staf f -- two-phase testing; that is, i

11 having evaporation in the primary and condensation in the 12 l

primary system, during the whole process.

13 We had asked research, NRC Research Office, to 1.1 l

perform such tests at various facilities.

And those, those 13 efforts are underway.

16 Criterion 2 is the training, where tests will be i

l 17 repeated each crew will see some of these tests.

In addition, 13 l

some operating auxiliary control.

l 19 Criterion 3 is, we're not finished yet.

20 Well, in order to assure no undue risk, TVA will 1

21 submit a safety analysis.

And this should have, this is what there's a ZP or zero power; until TVA sends in the, the

3 safety analysis and we reviewed it, we would not propose to
4 go on past zero power.

i i

3 CDMMISSICNER GILINSKY
Now what is this safety analysis?

_ _ v.,_,

lll me sca,m c.asmL sTuesr?. t w. surra to,

g MGE No. _12.

I This is specifically --

2 MR. ROSS:

To the low-power tests, n*

CDMESSIOtER GILINSKY:

Tied to the lower-power tests?

A I

l MR. ROSS:

At certain points and restric-i l

tions on operation.

And what I would propose when ultimately 6

we're ready to issue a low-power license is that we break it 7

into two parts:

one, the fuel load; and two, power testing.

8 In addition, the start of the low-power tests on 9

the staff 's review approval of the exact details and pro-l 10 cedures under which these tests will be conducted.

I 11 COMMISSIONER GILINSKY:

And when do you expect this l

safety analysis?

12 MR. ROSS:

3 They promised to provide it to u

us at 1r st 30 days before they planned to do any testing.

I l

i

3 think that should probably be sufficient time for us to review g

it and to improve it.

i i,s COMMISSIONER GILINSKY:

Let's see.

You talked of a

}

four-to-six-month testing program before going full power.

MR. ROSS:

Roughly split in half.

COMMISSIONER GILINSKY:

So half zero power and half 20 low power?

So they would have to submit that 21 two months af ter -

one or two months af ter going to zero power.

22 i

MR. ROSS:

Well, TVA hopes to get 22 I

I through their zero-power tests in about six weeks, 24 I think.

COMMISSIONER GILINSKY:

t u

l It would be done in late f

l M

, p useTes,fm ET. L W.

SLAM MI

=

c ncz sc.

53 1

March or early April.

l l

MR. ROSS:

Well, we don't have a specific 3

schedule right now.

I think it somewhat depends on whether 4

or not they get their low-power license.

5 CDtNISSICtER GILINSKY:

It's not imminent, anyway; it's 6

not next week.

7 l

MR. ROSS:

Well, your, your schedule is a 1

8 good approximation that two months for the low, very low 9

power testing -- and this will have to a rconth earlier than End Tape 3 10 that er we would in a critical pass.

11 i

l 12 i

13 14 l

l l

is i

16 i

9 IS i

l 19 I

l 20 g

i 21 D

23 i

i i

lWTtypseaticosak Vegan 11es W 14

. NDP c 'ndo f

54 pacz sc.

TAPE 4 I

COMMISSIONER GILINSKY:

Would you write a SER 2

on that safety analysis?

I 2

MR. ROSS:

Most likely, depending on the format 4

of the license, we will have to issue a license amendment.

3 COMMISSIONER GILINSKY:

So, one is really talking 6

about two license amendments.

There are two steps going 7

to operating license, critical zero power and then five a

percent and then full power.

9 MR. ROSS:

With each license amendment there would 10 be safety evaluation report.

So, yes at the time we issued f

that license amendment we issued an SER to evaluate it the I

TVA input.

12 Both we and TVA agree with test area four that the 73 f

test for proposal a low risk and for criterion five, TVA believes that possible future requirements would not be concluded by the official. product activity and vessle activation that woul~d occur from low power operations.

17 MR. DENTON:

Maybe this is a goou point to stop 18 l

and ask you if you would like to be briefed.now on the TMI i

occurrence ;esterday or would you like to continue to l

20 this to some set time?

21 I

O COMMISSIONER GILINSKY:

Well, I believe they said 22 they would be ready around 11:30.

I just spoke with 22 l

Mr. Chilk and I would propose that we just continue this --

24 I

MR. ROSS:

This completes our discussion on the 2

1 i

i r

v

~%=

I

c' 55 ncz sc.

4-2 1

special testimony.

2 So, if there is nothing else, Mr. Bayer will push 3

on.

4 COMMISSIONER GILINSKY:

Fine.

i i

MR. ROSS:

All.right, the next slide.

6 This slide has the matters that are all part of 7

the special test program.

3 So, let's go onto the next slide.

9 This starts Part Two of the NTOL list and if you 10 will notice the heading at the top is Requirements already 11 issued.

Most of these, and the origin of most of these is

7 g

from the Short Term Lessons Learned reports NUREG 0578, and most of these items were listed to be closed, I will do 3,

a little bit lof bookkeeping and I guess if the Commission g

wants to interrupt when we get to one of these disucuss what we can.

17 Item One, the shift technical advisory we just discussed from Paul Kellogg the status is we need a 19 I

commitment frem TVA.

20 l

Item Two is closed.

Il Item Three was also discussed from Mr. Kellogg with respect to the onsight group.

Item Four which was Roman ICI, the short-term 24 i

accident analysis procedure and revision.

What we are doing j

me

~

there is looking at the differential effects due to upper l

- = v - = m m.m>=.i.e I

l e*

56 pacz sc.

4-3 1

head injection.

2 l

This would not preclude zero power but we would 2

like to get this matter settled before going onto low a

power testing program.

3 The reason is, the upper head injection system would 6

be armed at five percent power and would like to know if 7

the operator has a procedure for using it.

COMMISSIONER GILINSKY:

Now, why does one require g

re-analysis here?

9 MR. ROSS:

We work with the owner's group all 10 last year for Westinghouse plants and non-UHI plants on 11 l

procedures and guidelines for small break LOCAs.

There had to be a different document to differentiate 13 with the upper head injection.

14 The re-analysis applies not to anything TVA did but to what Westinghouse did under the owner's group with 16 l

the non-UNI plants.

17 j

COMMISSIONER GILINSKY:

But didn't they do something 18 for the UHI plants?

19 MR. ROSS:

Well, they have a UHI Appendix K analysis 20 in the application.

What we are talking about here is a 21 realistic appraisal on how the plant would perform so the

~a guidelines could be prepared, and procedures prepared based 7

m

~

on realistic analysis.

What is yet undone here is we have to -- Westinghouse 25 has to do kind of a realistic analysis of how this plant l

l 1

{

i.nw m vo am. Roomm. 9.c

o' paar sc 57 4

I would behave with upper head injection.

From that they 2

developed guidelines and from that procedures were written.

2 That work is not yet done.

4 COMMISSIONER GILINSKY:

And when is that going to 5

be done?

MR. ROSS:

Well, we were going to meet this morning 6

7 with -- our review should be finished this month and the g

guidelines should be out run after that, COMMISSIONER GILINSKY:

What is the relation 9

f this to TMI list?

10 MR. ROSS:

This type of thing which we decided late

)

l last Spring to focus in on the operator response to small t

break LOCAs.

13 That is where this comes in, Item A, small break LOCAs.

13 COMMISSIONER GILINSKY:

I see.

So, it is the 14 analogue for the upper head injection plants of the small 17 break LOCA --

18 MR. ROSS:

That is right.

19 COMMISSIONER GILINSKY:

and they want to see 20 i

some review of procedures that we conducted on the other 21 plants.

MR. ROSS:

The only thing you have to do is --

you see some transients like a steam line break or steam 24 generator tube rupture drop the pressure low enough to turn on the UHI.

So, you have to make sure that it is all taken i

i

-- v r,- - i.

t a

psaz nc.

5B 4-5 I

into account.

I MR. DENTON:

So, the focus within the owner's 3

group for the bulk of last year was on plants that did not 4

have UHI's because they were the ones that were in operation I

and UHI was a low priority item for them to get to include 1

6 these calculations.

7 COMMISSIONER GILINSKY:

Now, do you consider this 3

an item that must be completed before the plant goes to low 9

power testing?

I' 10 MR. ROSS:

Yes, I think it should be because it 33 l

will hold up zero power and the reason is the upper head i

injection vavles and the pressure will be armed and the 12 plant and the operator should have procedures on what to la.

do and if it comes on during the transient, inadvertently.

COMMISSIONER GILINSKY:

And you are in the process of working this out?

MR. ROSS:

Yes sir, and I do not see any trouble meeting this schedule at all.

18 The ICC acronym in Part B is for inadequate core 19 l

coolin;; and that again we have some work done by Westinghouse at least to be extrapulated and filled in for the upper 21 head injection plan.

The other transients comes later and it is on the D

same schedule as an operating reactor and is more applicable 24 for above five percent.

i I

l

.5 i

i l

m% vo ri-am mm. n.c

O 59 ncz No.

4-6 Item Five is complete.

If you would go to the next slide.

2 Item Six through Ten are either complete or full power and this slide for bookkeeping and I do not propose I

to discuss them unless there is some Commission question 6

or concern.

7 COMMISSIONER BRADFORD:

What does complete mean 8

in those cases?

9 MR. ROSS:

That they have documented compliance 10 with the requirement and in this case, in this list, the i

11 requirement is well defined because it is several months 12 old and operating plants have already received it.

COMMISSIONER BRADFORD:

And what is it that they 13

g l

received, the bulletin?

I

3 j

MR. ROSS:

Well--

MR. DENTON:

We sent letters defining the short g

f term lessons learned requirements.

L.,

COMMISSIONER BRADFORD:

So, again how enforceable is that when inspecting later on?

MR. DENTON:

I think it falls in.

20 MR. COTTREL: It would" fall into the same category 21 before we have a commitment back from TVA and we can in fact enforce a deviation from the commitment.

23 COMMISSIONER BRADFORD:

Well, let's see what does 24 deviation mean?

25 1

3 MR. COTTREL:

Well, deviation is one of the j

L i - m v - m. e %

a c-Pacz Nc.

60 4-7 1

classifications of enforcement action that was --

2 COMMISSIONER BRADFORD:

Yes, but can you penalize it?

MR. COTTREL:

Not by a civil commission.

A l

MR. BICKWIT:

No, you first would have to issue i

t an order that violated that commitment and then you could l

6 enforce the order through a civil penalty.

i I

However, if you incorporate the commitment and the 8

license in the first place, then you can issue your civil 9

pentalty withe-going and that is the next step.

10 COMM1.3IONER BRADFORD:

At the moment, though as l

I understand it, the enforcement framework behind most of 11 12 these things have allowed one brief deviation if you will.

13 That is the worst that can happen is that you can get cited ja for a deviation which carries no penalty.

g MR. COTTREL:

I would say that the worst that 76 can happen would be we would have an immediate order issue i

7 for shutting down the test program and require management conference and resolution prior to the restart.

33 COMMISSIONER BRADFORD:

Okay, but there is nothing g

between shutting down and being cited for deviation?

MR. COTTREL:

Nothing formal.

MR. ROSS:

Okay, let's go to the next slide.

_a A minor item on Item Twelve, which is Roman Numeral 22 II D5 we need some documentation on the relief valve position 24 indicator as it is qualified and how it is calibrated, 3

I l

l that is relatively minor.

inn ~ % vi- = % =

c-pact NC 61 4-8 1

We know what we want and so does TVA.

Another 2

bookkeeping on Item Thirteen.

I We say essentially complete TVA needs to clear up 4

i a misconception of what the power supply is for the auxiliary 3

feedwater as a flow indicator.

l Again, there was a problem with the safety heater 6

concern.

7 On the next slide, I would like point out the 3

second, it says the second number 17, because the first one should be number sixteen.

There is some interim procedures for monitoring iodine and particulate effluents.

12 We have the procedures, we need to review them.

13 It is a short list of work and we ought to get it done 14 before 15 l

COMMISSIONER GILINSKY:

And there is instrumentation 16 in place to do that?

17 l

MR. ROSS:

Let me see, is Bill Kreger in here?

18 l

MR. KREGER:

Yes, Dann), Phil Stoddart in reviewing, 19 he is here too with Mr. Turner.

20 l

COMHISSIONER GILINSKY-We had a 90 day requirement 21 or something like that to install instruments to provide at least a rough measurement of radioactive releases --

l MR. DENTON:

It was in the short-term lessons learned 2'

j for the end of the year, prior to fuel loading, so it is

~

prior to fuel loading for this class.

l f

j i.m== vo-w me,omm. i c.

c ew.r uc.

62 i

COMMISSIONER GILINSKY:

I see, but that is complied 2

with or will be complied with.

MR. KREGER:

Yes, as far as the major instrumentation, but what we are looking at now is the interim procedures 4

for analyses of particular item samples and effluence using e

l existing instrumentation.

6 7

COMMISSIONER GILINSKY:

But using that existing instrumentation, will they have the capability to at least make rough estDnates of radioactive releases should they take place?

I MR. KREGER:

That is cor ect.

11 COMMISSIONER GILINSKY:

Thank you.

12 MR. ROSS:

The Item Eighteen, inadequate core cooling 13 as noted previously, we are still looking at the effects of upper head injection.

15 l

Other than that, I have eighteen as complete.

16 I

l The next slide on emergency preparedness --

l 17 I

MR. DENTON:

Do you want to take this or wait 18 COMMISSIONER GILINSKY:

I would like to hear --

19 how long will that take about?

20 MR. DENTON:

We could describe these in just a few 21 minutes.

COMMISSIONER GILINSKY:

I think that would be useful 22 to do that.

That way we could wind up at the start of your i

l section four of your slides and take this up, continue this er 1

when we meet again.

l Y

Y

6.

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4-10 MR. ROSS:

Mr. Miller?

2 MR. MILLER:

What we have is a situation wherein 3

we have two letters from FEMA, dated January 2nd and February 4

11th which refer to new criteria which we have developed 3

jointly and have supplied to the Commission for their 6

information.

7 l

The criteria is just now being put on the street.

8 It'was given to the Regional Advisory Committee I

9 of FEMA just this last week, and it is being given to all 10 of the States and all of the licensees this week.

11 The FEMA letters that are referred to essentially 12 state that the State of Tennessee should be using this new 13 criteria.

The new criteria for the most part, and the new criteria --

33 COMMISSIONER HENDRIE:

Jim, these criteria are

3 interim upgrade of the old 7511 --

3, t

i MR. MILLER:

111.

COMMISSIONER HENDRIE:

That is right.

MR. MILLER:

And incorporation of the EPA, NRC l

task force report NUREG 0396 which establishes the 10 to 50 mile limits.

21 COMMISSIONER HENDRIE:

I thought the thrust was you continue to use the previous set with regard to qualifi-22 cation of State plans and so on for some period until the 21 new criteria could be worked into the system.

25 MR. DENTON:

That was the approach we had gone down, i

i-m v ri mm-rom >=

Smv c M47 pact Mc.

64 4-11 I

and I think --

2 COMMISSIONER HENDRIE:

I was also the approach of 2

various pieces of proposed legislation, I must say.

f MR. DENTON:

In the enclosure to my paper is a 4

3 brief description of what we had done in a working level, l

Jim had proposed to use the Appendix E guide, the 11101 6

7 guidance and the esential planning elements in the NUREG g

75111 document and then look at the efficiencies from the full power plants and see if they affect the public risk 9

at low power but apparently that is not the understanding 10 within FEMA.

11 COMMISSIONER GILINSKY:

Let me see.

What concerns me a little bit is their letter seems to, at least gives me the impression that we have not been in close touch with them and beyond what you will be doing I would like, I 15 do not know if the Executive Director is here, is Ray Smith 16 here?

I would like you to get in touch with counterparts 17 j

at FEMA to make sure that we are working together and under-18 stand and respect their responsibilities and if there are 19 any problems, we will get back together and settle them.

20 I

But, specifically --

21 MR. SMITH:

We are planning to do that.

22 COMMISSIONER GILINSKY:

Right away.

MR. BICKWIT:

Mr. Chairman, I would just like to 24 l

point out, as a legal matter, this decision is the NRC's j

,e

~~

decision, not FEMA's.

j

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65 COMMISSIONER GILINSKY:

I understand that.

I l

l understand that, but nevertheless we have to work together 3

here and they also say we refer to things they never heard 4

of --

3 MR. DENTON:

I will let Jim describe what out 6

interaction has been.

7 COMMISSIONER GILINSKY:

We ought to straighten that 3

all out.

9 MR. MILLER:

In the draft SER, we refer to the i

10 items that Harold mentioned, the existing Appendix E, and

)

75111 as the criteria that we used to judge the plant, but it was really an approach that we used until such time that new criteria became available, that it what they were referring

7 to.

COMMISSIONER GILINSKY:

Well, in any case, let us g

get back together with them --

MR. DENTON:

This is a critical issue.

I understand 17 that it would take 30 to 45 days of conserted effort on all parties for the State to comply with the latest FEMA position 19 for full planning, for full-scale planning and full power.

20 This is a different. criteria.

'I do not know how long it 21 will take us us to develop some subset of those criteria, but it is mutually considered acceptable for low power testing.

24 COMMISSIONER GILINSKY:

Well, let's at least get i

23 I

to the point where we and they are clear on what we want to l

l i

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66 4-13 1

do and what the other agency has in mind and if there are 2

differences, at least we can get very clear on what those are, and then, take it from there.

4 MR. DENTON:

I agree.

MR. HANRAHAN: -There is a distinction here that is I

6 important as to low power versus full power.

Clearly there I

is a distinction in the plant which relates to public 8

risk which was discussed earlier and was never made any 9

distinction about that before emergency preparedness and it 1C might be well to make that distinction --

i 11 COMMISSIONER GILINSKY:

Well, it was not clearly --

12 MR. HANRAHAN:

It becomes a continuing problem 13 with emergency preparedness going against operating licensess 14 and we are only talking about zero or low power situations.

1.5 COMMISSIONER GILINSKY:

Well, it was not clear 14 whether they they thought there ought not to be a distinction 17 or whether they felt.we had not made clear what the distinction 1

was.

In any case, let's get back together with them and jg clarify that.

39 MR. DENTON:

I think we have not formally communicated 20 through the steering group I guess is the case we have g

communications had been at the working level of the individuals.

COMMISSIONER GILINSKY:

And let's do that right away.

24 l

MR DENTON:

All right.

15 I

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i wwmc ne 67 4-14 1

COMMISSIONER GILINSKY:

Well, I think that pretty a

well completes your list.

The other items are relatively --

MR. ROSS:

There are two safety matters we should 4

I hear of TMI and one is the instructor's report, and the i

5 other item we should bring to your decision is Part Four l

Item One review of the program design review of the Part 6

7 Four, one of the two requirements of the special inquiry group, that is the two items left with TMI.

3 COMMISSIONER GILINSKY:

I do not want to do those hurriedly, and I do want to hear the briefing on the TMI-2 leak of yesterday.

i I propose that you get together with FEMA as we spoke about.

13 The Commissioners will have a little while to la review the document that we got last night and chew on l

13 what we heard today and let us schedule a meeting as soon 14 as possible on this matter.

17 I should have said at the outset that the Chairman la l

was ill and he would have otherwise have been here and he 19 is very much interested in this matter, and in particular the resolution of the emergency planning question.

Well, thank you very much then and I would like j

to prvceed to the briefing on the TMI-2 question.

I m

~

Thank you very much.

24 (Whereupon the meeting j

i i

3 was recessed at 11:40) l l

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