ML19322C218
| ML19322C218 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 09/27/1979 |
| From: | Moseley N NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | |
| References | |
| TASK-TF, TASK-TMR NUDOCS 8001160635 | |
| Download: ML19322C218 (12) | |
Text
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134 UNITED STATES OF AMERICA 1
NUCLEAR REGULATORY COMMISSION 2
1
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I In the Matter of:
4 ii THREE MILE ISLAND Si SPECIAL INTERVIEWS 6
-X 7
NORMAN C. MOSELEY (continued) 8 Room 400 6935 Arlington Road 9
Bethesda, Maryland 10 Thursday, September 27, 1979 Il '
9:10 a.m.
12 BEFORE:
13 l For the Nuclear Reculatory Commission:
I4 WILLIAM J.
BALLAINE, ESQ.
ll GEORGE RIVENBARK
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licensco no:esserily recches what is ref errce to as
- ommercial operation for accounting oursoses?
3
.ione Inst I -
no, none tnat I know of.
It nas no s
meaning to us, as I have said.
3 as ignore that cate.
2 Are you aware of whether or not a plant can reach what is called " commercial operation" for accounting purposes 6
cefore it nas gone tnrou;n its start-up testing program?
/
A Sefore it has completed its start-up testing 10 -
program? Yes.
11 3
re you aware of tne earliest point at which 12 curing tne start up testing program a licensee can actually I
13 reach tnis point of what they call commercial operation?
l' A
I have not made any effort to determine which plant 13 made that oe laration.
I jus t haven' t --
15 2
As far as you know, that *:ino of information li isn't compiled by IAE or anyone in :ne.JRC.
13 A
It is not comoilec Dy 115.
1/
U You are not aware of it ceing comoiled oy anyone 22 else in the.G07 2.
A c! 3.
I celieve th? 3rcy Sook 7es en entry whi:n 22
- ontains tne date of commer:ial operation.
- he can take the 23 3rs/ Boot ano ;c tarou;n anc put cown :ne cate at wnich :neir 2;
license was received and then tne cate a: wnica :ne comm3 rcia '
25 operation was acnieved and suctract the nutoer ano cnen co" 4
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up wi tn sucn a Ostermination.
I have not oone it.
e 3
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- .or tne recore, way con't you exclain wnst the 4
3rs/ Sock is.
5 A
The Gray Book is a book that is puolished oy M?A montaly, which lists on the lef t page some historical data.
Also, on the left page, it lists some current inspection 5
inf ormati on.
And on the richt-hano page, it is a page tnat is relateo to the power performance of the -
power proouctio 13 of the facility during that month.
11 0
tio w, during each of the discrete power levels, the 12 licensee is required to perform certain tests. Is that righ:?
13 A
Yes.
14 2
Inere is some kind of audit of those tests by l-
'nso3ctors.
Is that a f air statement ?
1:
A inere is an inspection program that is specifically li addre ssed to the start-up testing program.
li 2
.in e r e is One insp3ction program tna specificelly is rela:es to power start-up?
2s A
It is a section of our inspection manus 1, our li m ocul e, cer:ain mocules that are aoplicaole durin: :nis 2
time period.
23 2
Ano is it fair to say tas: that is the only 2c
<tritten cirection to an inspector as to now to go acout 23 auciting tne testing of the licensee curing eacn of the 9
e
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213 I
cis: rete power levels ?
?
A Yes.
s 2
Do you know now it wa s dec i de d wne t type of cirecti i
to give the i nspector in auaiting the testing program of the 5
licensee during these various discrete power levels?
A Ine inspection program for start up testing, just as all tne other inspection programs, is a result of an 5
e volutionary process that began witn no written direction
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whetever to inspectors.
13 In the ceginning, inspectors inspectec to the FSAR ano, in 11
- fact, there were no tech specs cack in the early days 3o 12 the inspector took the F5AR and the license anc cecid d f e
or 13 himself what he tnought should be inspected and went o'itand 14 insaected it.
la As we crew, we celieve tnat that wasn't sufficiently la Cefinitive, that we needed to orovios more guidance ano ls J-irection to inciviouals wns inspectec.
15 30 tne people wno were inen in tne program contriout 1) eo their iceas as to what ought to be cone.
2;
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ais was written down anc cecame the first inspection
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.oro ecure.
...no our present menuel is tne evolutionary result 42 of :nis e f f:rt.
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G Do you believe that there are any phases of the
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1 2 'j startup testing that a licensee goes through during which i
!3i the licensee is more eager to complete testing and get on
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from one power level to another?
5; A
I expect that licensees are eager to complete i
6' power ascension from the very beginning, from the time they I
7I obtain the license.
The point of building the plant is to 8
make power, and the higher the power level the more money 9
they can get in revenue.
So I think there are always consi-10,j derable economic pressures to complete the power ascension 11 !
- program, i,
Is it your impression t' at they are as eager gettin, 12 i 4
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through the first stage of the program as they are getting it, N.
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through the last stage to full power?
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A My impression is that the motivation is not much
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1 16 4 different.
ile 17 !!
O I take it you are aware that the term " commercial 13 -
operation" does have tax significance to a licensee; is that:
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right, or at least you believe it?
'?
20 A
I believe that, yes.
p 21 1 g
Do you know whether anybody in the NRC has ever 22 !l given consideration to whether or not the licensee is more 23 '
eager to complete testing, such testing that leads to the 24 point that they can declare con =ercial operations, than they
- 8 493Orttfl. t a0. "
i 25 " would be after they have received that tag?
i 1
A I am suro com ona in ths NRC at som3 point in timo i
2 may have thought of this and maybe even perceived that a ft i2 ll particular licensee may have been unduly influenced by the --
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maybe d.e change of the tax year or whatever is important in 5
making that decision.
So yes.
6 0
Is that speculation on your part?
i 7
A tut.is speculation.
It has not been a particular l
8 issue, to the best of my knowledge.
9i 0
I guess that is what I am wondering:
whether you 10 ever recall seeing anything in writing raising that issue or 11 suggesting that certain steps be taken because of some 12 perceived issue like that?
13 A
I have had discussions with licensees when I was 14 j an inspector and when I was a branch chief and regional 15 j director about concerns that they were in too big a hurry, 16,
without regard to the commercial operation date.
And one has l
17 to cencede that that may be a motivation for licensees at a 13 particular moment in time.
!?
But what I am trying to say is that these motivations to 2 0,, hurry are already there, with or without that.
21 g
To your knowledge, is there any difference in the
!I 22 I way in which the inspection program works as respects the n
23 ' various discrete power levels?
24 A
No.
l rr4aonen.ine.[
25 >
c
. As far as you know, the kinds of things that an i
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1, inspsetor is supposed to do, the extent to which tha incpactor 2[
is involved, is the same during each of the power levels of 3
a power ascension program for licensing?
i 4i A
The amount of inspection effort is in relationship 5
to the amount of testing.
The same amount of testing is not 6
required in each discrete power level.
So at whatever power i
i 7
level more testing is done, then more incpection is done.
i i
8 g
So the inspection would be related to the number of 9
tests that have to be conducted during power level?
10 A
Right.
II g
With respect to the testing, are there written 12 rules or instructions or guides for the inspector as to 13 whether or not a particular test conducted by the licensee 14 during a power level is sufficient?
i 15 A
There are modules for this, the power ascension 16 !
testing program.
It is -- it does not define which specific UI! test will always be inspected.
It provides a list of these 1:
M b frcm which the inspector chooses to observe and review U
test programs.
M' q
And the modules, again, are found where?
21,l A
In the IE manual.
i 1
22 h 0
And that is the extent of the writing, as far as you 239 know?
2' I was trying to answer the specific question --
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with respect to this question cf setting out whether l-0 F
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'l!! -- what type of review should be made of a particular test?
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2y A
I am not real sure what your question is trying to c
3; get at.
But I believe the answer is that the guidance to the l
4 inspector and the direction to the inspector as to what to j
5, inspect is included in the manual.
There are no other sources l
l 6
of instruction, with the exception that perhaps individual l
l 7' regions may have adopted some informal directives that certain l
't 8
things might be done.
On a national basis there are no other i
9l directives.
I I
10 g
Does the manual also indicate what the standards is Il for whether a licensee -- the licensee's test result is satis- -
t 12 factory?
i i s
t 13 A
The inspection procedures are more general than l
4 14 cookbook.
They provice in one section -- they provide i.
15 [ guidance to the inspector, which is in the way or provicing i
16 ;
some acceptance criteria.
But they aren't go-no go type i
h i
il I7 guidance er directives.
I I's i; G
The only criteria there are, again, are in the 7
manual, at least at the national level?
20 A
The criteria for the acceptability of a test is q
21,. really the design of the system.
So an inspector has to go 1
22 h back to the safety analysis report an/
w%termine, for instance, 23 I what a pump is required 06 delivrx 5) i p: pressure, in order 24 to determine whether this pump, when tested, selivered the
,7 AeDorters, Inc.
1 l
25, amount of flow at the specified pressure.
So the detailed e
i e
j 1.{ ccccptanca critoria coma more from what is being tacttd and t
2 what was the design intent and rcquiremant, which is an FSAR 3'
requirement, rather than from the inspection manual.
H 4 lI G
To your knowledge, are there any minimum or maximum I
5l time limits with respect to the completion of a power ascension I
6' program?
i a
7j A
There is nothing that is predefined as a requirement.!
i 8
We have expressed dissatisfaction with licensees in the past t
9:
if they didn' t proceed with their startup testing program in 10 what was perceived to be an orderly manner.
By that I mean, II I if he went and did his testing at 50 percent and then stayed l
12 '
at 50 percent, he obviously -- he must complete the testing 13 i by license.
Each time he goes to a new power level, he must i,
14 H complete those tests.
i l
15 l But there is nothing by the licensing that would prevent i
16 him from going to 50 percent and stopping and operate for a ti I7 while.
But we don't feel very happy about that kind of a 13 d thing.
U BY MR. RIVEN 3 ARK:
U G
But there is a time limit, is there not, on the 2I licensee itself that is issued, such that if one takes longer 1
22 1 -- and we are talking years now -- if one takes longer than 23 '
the license will have expired and you would so many years,
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have to get an extension of that license in order to continue es Reporters, Inc.
25 ' either to construct the plant --
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'I A
We are talking about startup testing.
Theoparating.j 1h' 2h license has been issued.
The operating licenses are typically !
I a
2]' issued for 40 years now.
5 BY MR. BALLAINE:
i 5i 0
You caly have 40 years to complete your startup I
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testing?
I 7j A
Provisional operating licenses were issued for a I
l i
i 6I couple of years, but that hasn't been done recently.
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O Do you think there should be some fixed minimum or 10 l maximum time periods for -- at least for parts or all of the I
1 1
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power ascension program?
l i
12 A
I really don't see a great deal of value in such t.
13 / limits.
One can' t predict problems that a licensee would have, '
r I
i I
and a limit which said, completc all of your startup testing 14 i p
I 15 in three months, just to take an arbitrary number, would add i
i I additional pressure, if you had a problem, to try to rush i
16 ;d I
17 :! throuch that problem, in addition to the economic pressures in f i
i gi I3 order to meet that deadline, which is a license requirement.
I I think it might be, under certain conditions, more detrimental 2
than it would be heloful.
I 21
.G But I take it that you believe than there can be l
I 22
.roblems with the licensee remaining at one power ascension i
23I level for a long period of time; is that right?
l i
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[A A
- Yes,
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t00mrt, Inc.
C What is the nature of the problem with that
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I I; happening?
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Because in the startuo testinc crocram 1
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I there are some things that aren't tested at all until yo i
f.
u reach power 4
level X.
So if you are operating at some power l l
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than that, evel less even though you have completed all of the te F
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I, l that are required for that power lev l l
sts i
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d that have not be there are still tests f
done.
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4 Give me a dramatic example?
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A
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Loss of off-site cower.
It may l
oniv be run at 10 j 75 percent.
I don't know' what the actual is, but let's t k i
llO that as an example ae
'J 12 4
1 What method does the NRC have to ensure th
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13 9 adequate safety of the public i e
{
n a situation where the plant
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14 has stopped at -
seems to be stuck at a parti n
cular stage of 15 ;
16 power ascension before testing something like off o
o 16 '
-site power?
A
- Well, i
the method that has been used in the I7 '
past is i
the one that I have described earlierwhere we meet with the 18 licensee and express our concern and find out what his plans are and when he is going to complete this If we became concerned sufficient to raise a health and safety issue 21
, we would issue an order.
22 '!
4 Are you aware of any such order having be 22 '
en issued?
i I am not aware of any such order C
Are you aware cf any situations in which som b d
- m. ine. o
-d=
eoy from the NRC has me i
and' expressed concern to the licensee I
c 1
we>*e,&,
.see m.g e
.~==.p r.W****'em-s
- f Ip about the stage of
- the speed wi h.
221 s
' !y t
h; through the power asc~ension program? which he is 3h 9
A Yes, that has happened in the v
4 past.
such We have had 3
0 0
Can you think of meetings that 6L i
involved in?
you yourself were
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Yes.
1 8
G 1
l Over the past five years 9I 10 {!
That I personally participated i, how man I
A n
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I suspect there may have been n, maybe one or two.
11 more than that.
i i
O And any others that you are a i
12 I3 l your division had over that time period? ware of that peo 1
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[
Iq A
I am generally aware that the 1', (4 have happened before.
se types of things l
l 4
But I don't have a feeling of 15 0 average rate is.
n what the s
16 D h.
4 Other than issuance of an ord 7 ]c any means other than expressing coner, does the NRC have u
i i
encourage a licensee or -
to do s cern whereby they can
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g omething about the with which they are proceeding th
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t speed r.
'i rough the power ascension program?
A I don't know of anything other th 4
,r them and an order.
an meeting with 23 "
4 Do you think that is adequate?
- koorters, inc.
i Sure.
25
?
Mr. Moseley, I want i
to show you what has alread-e i
k 9
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