ML19323B638
| ML19323B638 | |
| Person / Time | |
|---|---|
| Issue date: | 05/06/1980 |
| From: | NRC COMMISSION (OCM) |
| To: | |
| Shared Package | |
| ML19323B639 | List: |
| References | |
| REF-10CFR9.7 NUDOCS 8005140009 | |
| Download: ML19323B638 (49) | |
Text
..
8005140009 c)g g p@r 1
e L
, u \\.
L3 1
UNITED STATES OF AMERICA 2
NUCLEAR REGULATORY COMMISSION 3
4 BRIEFING ON SYSTEMATIC EVALUATION PROGRAM 5
(Open to Public Attendance) 6 Commissioners' Conference Room 7
D.C. Office Nuclear Regulatory Commi--4.on 8
Tuesday, May 6.
J0 9
The meeting convened, pursuant to notice, at 2: 35 10 p.m.
11 12 Present:
13 CHAIRMAN John F. Ahearne COMMISSIONER Victor Gilinsky 14 COMMISSIONER Richard F. Kennedy COMMISSIONER Joseph Hendrie 15 COMMISSIONER Peter A. Bradford 16 Also present:
17 D. Crutchfield W. Dircks 18 D. Eisenhut H. Denton 19 E. Hanrahan Mr. Malsch 20 L. Bickwit J. Scinto 21 23 24 25 ALDERSON REPORTING COMPANY,INC.
Q Th @TR3% @ W. REPORTERS BUILDING. WASHINGTON, D.C. 20024 (202) 554-2345
I.
2 1
PR0CEEDINGS 2
CHAIRMAN AHEARNE:
I would like, if I could, to call 3 the Commission to the meeting again.
4 The purpose of this afternoon's second meeting is to 5 discuss the ever-evolving plan of the systematic evaluation 6 program.
I remember what it was.
It was just as I was going 7 back digging through all these old SECY papers dating back to 8 the Task Force Report of Nov. 1976 and SECY 76-545, decision 9 memo and SECY 77-561 and decision memo and an ACRS letter and 10 an answer to the ACRS letters.
11 MR. DIRCKS:
That is the historical possibility.
12 CHAIRMAN AHEARNE: No.- That has led me to realize
- that this is 13 something we'd like to hear more about, to at least understand 14 not only what is happening.
I guess my first question I would 15 have is, what is it?
16 Bill?
17 COMMISSIONER HENDRIE:
Since we have been -- every 18 time I turn around we have reorganized the SEP programs.
19 Harold has had major churnings out there, so one of the early 20 things I would like to hear is who has now got this ball so 21 that I know who to glare at.
22 MR. DENTON:
Darrdi Eisenhut.
23 COMMISSIONER HENDRIE:
And who works it for you, 24 Denny?
25 MR. EISENHUT:
The Branch Chief is the SEP program i
ALDERSON REPORTING COMPANY, INC, 1
a 3
1 branch.
It is now vacant.
Denny runs the Projects Branch, 2 which is sort of the routine branch.
3 COMMISSIONE.1 HENDRIE:
The project side of it.
4 MR. EISENHUT:
The Assistant Director of it is Gus 5 Lance.
6 COMMISSIONER HENDRIE:
Congratulations, Gus.
What 7 happened?
Did everybody run away from that branch?
It is 8 vacant because nobody will accompany it?
9 Never mind.
10 (Laughter) 11 COMMISSIONER HF.NDRIE:
Sorry.
12 CHAIRMAN AHEARNE:
Would you like to try again?.
13 MR. DIRCKS:
We have had briefing on this before and 14 I think it is worthwhile to go back and tell you where we have 15 been and where we are seeing some difficulties and where we 16 see some possible future attempt to cope with some of this.
17 As pointed out, Darrell has the ball.
He has had it 18 for awhile. "He is ready to talk about it.
19 Surprisingly, this fiscal year is pretty much on 20 schedule with what we set out to do.
We are about halfway 21 through the year and we have accomplished 55 percent of the 22 objectives, so it is functioning.
23 MR. DENTON: We're just Wg now to the payoff period of the 24 SEP -program. For years we only talked about. the plans. _These are reports cr:
25 specific grants.
The review has been completed and the ALDERSON REPORTING COMPANY, INC,
c a
i.* a f
1 decisions reach *ed as to the acceptability of those old plants 2 with regard to that area of review.
I think there over 200 3 issues now which are, in essence, resolved for these old 4 plants and an overview of mine is that, in some areas, we are 5 finding even though these old plants were designed before the 6 general design criteria they are able to. share conformance..
7 with today's requirements.
We managed to work these out in 8 detail so, in that sense, we looked better than perhaps we 9 thought they would.
10 COMMISSIONER HENDRIE:
I could have told you that.
11 There was an ancient principle that we were giants in those 12 d ay s.
13 (Laughter) 14 MR. DENTON:
At the same time, we have also 15 identified those areas where the Commission's requirements 16 have changed drastically and we know that we have got to focus 17 in on to make a commparability finding.
We can identify those 18 areas,'so we are trying to maintain the manpower in the i
19 program from here on out.
20 It went through a slump a year or so ago before we 21 assigned people, dedicated reviewers, but we are right now in 22 the pay-of f period to define those areas where the staff 23 really needs to concentrate and make those changes and one of 24 the fall-outs from this program, for example, was the show 25 cause order with regard to the effect and with that ALDERSON REPORTING COMPANY, INC, 300 7th STREET, S.W. REPORTERS BUILDING, WASHINGTON, D.C. 20024 (202) 554-2345
5 1 introduction, let me have Darrell give you a more planned 2 review.
3 MR. EISENHUT-I will just summarize a'nd go through.
4 I wasn't sure hou much detail.
There is no long track record.
5 I am not going to attempt to go back through the old track 6 record.
7 If I may have the first slide?
8 This is just a simple outline of the areas.
We 9 would like to go through a very brief introduction and 10 background so we know where,it is.
11 Going through its present status, we will just 12 mention some of the difficulties that Harold touched upon and 13 some of the things we are looking at t'o keep it going and
\\
14 really build the momentum into the program to reach. the hard 15 decisions.
16 The programming, you recall, has to do with the 17 overall safety confirmation of older plants.
Eleven of the 18 older plants are being reviewed.
19 These plants, in large part, pre-date a lot of the 20 modern plants that we have today -- modern plants where they 21 have a large loss and accident, large ECS systems, with a 22 somewhat rigorous, very elaborate set of safety requirements.
23 These plants go back, believe -- the first plant 24 went into operation in 1959 or 1960, about that time.
Seven 25 of these old plants still have provisional operating licenses.
F ALDERSON REPORTING COMPANY, INC, N M KnR3OKM Mfi$$
6 1 Remember, the thought was that a provisional license was a 2 license that was in effect for something l'ike 18 months.
3 After 18 months the thought was you looked at how the plant 4 performed.
If the plant performed well you convert it over to
~
5 a full-term license.
If the experience was not too good, you 6 would look at it from the standpoint that you need to keep it 7 going under a POL.
8 There was an automatic expansion feature of those 9 POLS -- that is, if the licensee requested --
10 COMMISSIONER HENDRIE:
A timely renewal.
11 MR. EISENHUT:
Yes.
A timely renewal.
12 It is similar to other areas we have that, if the 13 request is submitted, it continues.
The basic thrust of the 14 program was to compare these old plants against current --
15 against current safety standards.
16 COMMISSIONER HENDRIE:
It is not an NRC regulation 17 but it has its foundation -- where?
I's it not in the 15 Administrative Procedures Act?
19 MR. EISENHUT:
Yes, it is.
j 20 MR. MALSCH:
The activities are contingent until the 21 application is acted on.
22 MR. EISENHUT:
The basic' thrust of the program was 23 to compare these plants against current safety standards.
I 24 use " standards" in the overall, larger sense, not as if you 1
25 were building the plant today, but look at it against today's ALDERSoN REPORTING COMPANY, INC, M
.7 1 real thrust of what the safety requirements are trying to do 2 today.
3 Today's requirements standards, guides, are the 4 yardstick we are looking at.
The review was not to be a five 1
5 by five, line by line, review but rather, as each review 6 progressed to some point, you either decide that you have j
7 found a major deficiency that must be fixed now.or you find 8 there could be a deficiency that could wait until the end of 9 the program, re-orchestrate them together, hence an integrated 10 assessment.
11 CHAIRMAN AHEARNE:
Can I ask you a question on that, 12 Darrell?
13 One of the difficulties in trying to read a lot of 14 background quickly, if sometimes there are some ide'as that 15 weave in and out, it is a little difficult to conclude which 16 stayed and which didn't.
But at various stages, I found in 17 one case the objective was going to be to look at the design 18 basis events and then on the basis of those, see which systems 19 were critical and then analyze those.
20 There was another flavor at some point that would 21 decide on some other way, which systems are important to 22 safety and look at those.
23 Is there any simple way of describing the process 24 that you have just said?
25 MR. EISENHUT:
Yes, there is.
The basic program was ALDERSON REPORTING COMPANY,INC, Q3 7tti @TR3R @.W. REPORTERS BUILDING. WASHINGTON, D.C. 20024 (202) 554-2345
8 1 laid out first.
The thought was that it was a systematic 2 program.
3 We started with something like 800 topics not 4 designed as basic events, per se, but 800 topics.
There were i
5 a collection of topics from the ACRS, many different elements 6 of the organization, from the public, from utilities.
Those l
7 were put together in a set of topics.
8 Where we culled those, we could, either for lesser 9 safety significance because they were the development of new 10 requirements, because they didn't affect.those family of 11 plants -- we culled it down to 137 topics.
Those 137 topics 12 had two parts to them.
One part was there were about 50 items 13 which were already undergoing ~ review by some other people --
14 fire protection, for example.
15 Those 50 we just said, the review will continue as 16 it needs to and we will, to the extent possible, integrate it 17 with those other 80 or so but the other 8C, what we will do is 18 t 7at we will first look at it topic by topic by topic and you 19 would reach an interim feeling of the measure of goodness of 20 the plant.
But you would not act on fixing up a crane in the 21 building, necessarily -- that may not be the world's best 22 example, but you would not fix up one particular component 23 until after you had gone through the topics.
24 You looked at the design basis events.
You looked 25 at really the design basis events and said, well, so what?
So ALDERSON REPORTING COMPANY, INC,
i 9
1 what is the net effect, if the containment could only take 40 2 pounds of pressure instead of 60 pounds.
You really look at 3 the design basis events and you look at this.
This is sort of 4 the integration aspect and by looking at what is important t7 5 the design basis of either the terms of the likelihood of the 6 event or the consequences, given the event occurs.
7 So it is really both of those tuo things.
We have 8 heen going through, topic by topic, first and you have some 9 co' peting things when you lay out to do that.
On firsthand, m
10 it is always nice to have as many topics resolved as possible.
11 If there are 130-some topics on each plant times 12 these other plants, you see there are about 1500 plant topics 13 to be done in the first place.
14 One thing would lead you to do the other things 15 first, because I can knock off the first thousand.
Well, that 16 is good.
It shows we have progressed.
17 But on the other hand, you note the more difficult 18 topics -- that is the topics, for example, associated with Ig seismic design are not going to bear any fruit for two years 20 or so.
21 MR. DENTON:
Let me interrupt for a few minutes, 22 Darrell.
We have gone at it topic by topic but I still think 23 there are issues of conceptualization as to what this program 24 is intended to do that remain to be decided.
We never could 25 decide quite how to approach it, and we kicked it off.
ALDERSON REPORTING COMPANY,INC, w
K@ M
f c
/v 10 1
That is how we got into sweeping through this large 2 number of issues we were going to sort of defer what was
- 3 clearly down the road.
How we have actually combined systems, 4 designed basic accidents, or whatever.
And the program has 5 suffered a bit from lack of general consensus on how do you I
6 approach plants that were designed and built 20 years ago to 7 all different codes and standards of the day.
8 Today, I think, you will find at the end of the 9 slide, at the end of the presentation, I should think it to should go from here more to the risk assessment idea than we 11 were proposing to do when this first started.
12 MR. EISENHUT:
It is really the two things combined.
13 If-I could have the next slide, this is really -- it 1-4 is a slide that is two or three years old.
This was basically 15 the objectives of the program as laid out by the Commission 16 following the first briefings back in 1977.
17 The program that you will see, as we will mention
.18 when we get towards the end, deviates from this slightly, but i
19 these are more the general statements.
20 The last one is the one that we will be addressing 21 somewhat in a moment.
22 If I could have the '4 ext slide, which just catches 23 up with what I've been saying, this just gives you a status of 24 how it is today'.
This is basically the topic, the plant topic 25 review list, and how far it has proceeded.
ALDERSON REPORTING COMPANY, INC,
'),
)
11 1
The resolution of certain of these topics has 2 already -- it has been a hybri.d up to this point, as it goes.
3 To the extent possible we have been using risk 4 assessment and we have been trying to use it more as we go 5 into this program.
6 There are two problems.
One is, of course, a 7 shortage of that type of expertise to be doing it on a large 8 scale here.
But secondly, you must make the comparison 9 against the requirements in the regulation because some of 10 these plants are going to have an opportunity for hearing, and 11 this review formed the legal basis that is necessary for that 12 hearing record.
13 CHAIRMAN AHEARNE:
Careful about "on this legal 1-4 basis."
We have just been deserted by our lawyers.
15 MR. SCINTO:
Not all of them.
I 16 COMMISSIONER HENDRIE:
I'm glad you stuck, Joe.
The 17 General Counsel left as soon as the subject was broached here.
18 Let me represent some sort of commentary.
Is CHAIRMAN AHEARNE:
Now the Commissioner lawyer is 20 leaving.
21 (Laughter) 22 CHAIRMAN AHEARNE:
Are you having any trouble 23 getting information from these licensees?
24 MR. EISENHUT:
Yes.
This goes back to the last item 25 of the objectives I mentioned in the first place.
The basic ALDFASON REPORTING COMPANY, INC,
li, 12 1 thrust was we were not going to go out and lay a big i
2 requirement on the licensees and say, answer these 137 topics.
3 The first thought was the staff was one of the key 4 items, even from the Commission's guidance memos, to go back 5 first and look at all the paperwork that was there existing 6 and that is a real problem in these old plants because you 7 have an initial final safety analysis report with maybe 50 8 amendments, maybe 300 letters with additional technical 9 information and you must put all of this together and really 10 try to decide what the situation is.
l 11 Even then you don't have a lot of technical 12 information.
So the first cut is, you put the staff to work 13 going through all of the available information, seeing what is 4 there before you go to the licensee and say this is the 1-15 additional information that I need.
16 It is a.very difficult job, because of the 17 availability of information.
That is one of the key 18 ingredients.
19 CHAIRMAN AHEARNE:
And have the' licensees been 20 giving you much trouble in getting this?
21 MR. EISENHUT:
The licensees viewed this -- I think 22 it is fair to say they viewed this as an NRC program.
They 23 viewed this because, as an NRC program, back from the 24 inception when it was announced, the staff said this is 25 basically an NRC program.
The principal burden initially in ALDERSON REPORTING COMPANY,INC, L
13 1 the program will be on the NRC, not on the licensees.
2 It is the fifth objective in that initial slide that 3 has caused considerable difficulty in getting up to speed.
4 They are getting up to speed on selecting topics where we made 5 it very clear in the beginning that if left to the staff, 6 these were some areas that we were going to have real problems 7 with.
8 It is fair to say in the last few months, over the 9 last perhaps year, the licensees have been instructed to work 10 in certain areas.
11 5 MR. DENTON:
And all of the lessons learned that 12 have swept through since TMI have all applied to these plants.
13 They have been swept up and making all of the order changes 144 and everything else at the same time while trying to reassess 15 old issues.
16 MR. EISENHUT:
This program we are talking about 17 today is over and above everything we have put on all plants 18 and we didn't spare these plants, so they have' got a lot of 19 work.
20 CHAIRMAN AHEARNE:
In the information to go out, is 21 it primarily for them to collect information that they have, 22 or do they have to dig out and give it to you and you do the 23 analysis, or have you shifted over to asking the licensee to 24 do the analysis?
25 MR. EISENHUT:
We sent out guidance letters where we ALDERSON REPORTING COMPANY,INC,
14 1 broke all the topics and all the plants into three categories, 2 I believe.
I believe it was three categories.
3
- One is where we say.we think we
- hhve enough informatio 4 that after we look at it, the problen is going to go away. We have those 5 where we thought the licensee would have to do some supporting 6 work and those where the licensee would have to do a 7 considerable amount of effort.
8 So we wrote a letter to him and said, these are.the 9 items.
I think we had actually four subgroups, but it was 10 essentially on those lines.
11 So on some we ha've shifted it to licensees.
Yor 12 will see one of our bottom line recommendations is that we are 13 looking again to see whether we can shif t more to licensees in 14 the program at this point.
i 15 These are some topics where the SEP is actually 16 doing some of the frontrunning work.
17 The environmental qualification we talked about, the 18 eleven SEP plants are the first plants being reviewed and they 19 are the lead for all of the other plants.
Safe shutdown 20 re"iews -- this is going back and seeing what you really need 21 to shut down a plant.
22 This is what I mentioned earlier.
23 The seismic program is probably the single biggest 24 program in SEP because from inception we identified this as 25 pcrt aps the single biggest problem area.
ALDERSON REPORTING COMPANY,INC,
/A 15 1
CHAIRMAN AHEARNE:
It this because the NRC's 2 regulations have developed much more in that area?
3 MR. EISENHl'T:
That is because four of the plants 4 really didn't have the sites reviewed.
Two of them didn't 5 eyen refer to a seismic design basis.
Two were designed to thia unified 6 building code and the other plants were designed to the 7 very beginnings of what was later developed into a highly 8 refined NRC program.
3 The site specifi,c spectra program here is actually a 10 program that is a state of the art program.
It is using some 11 15 to 20 seismic c,onsultants throughout the country and a 12 panel forum to come together with a new approach that is 1; actually a refinement on Appendix A.
14 It is a program which is giving us some quite 15 definitive guidelines on plants in the eastern part of the 16 United States.
This does not address -- it; addressed ten of 17 the eleven plants.
It does not address plants west of the i
l 18 Rockies.
It is the eastern plants, that are generally in a I
19 lower seismic region, generally nothing over a.2 or
.21.
20 In fact, this program will likely have an impact 21 back into the process on new plants, if this methodology is 22 fully adopted and it turns out to be one of the ways.
We 23 really try to define the sort of deterministic, imperial 24 approach of Appendix A.
25 MR. DENTON:
As Darrell mentioned through technical ALDERSON REPORTING COMPANY,INC, fB 72 EFJTE E1W. RMRiisR@ @MlSelNR WA@HIN@T@N, D.C. 20024 (202) 554-2345
~
5.
16 1 assistance, you might name the contractors here.
2 MR. EISENHUT:
Yes.
The two principal ones are the 3 TERA Corporation and tne Lawrence Livermore Lab.
And there is 4 a whole slew of consultants including, or course, New Mark Hall.
5 MR. CRUTCHFIELD:
People like --
6 MR. EISENHUT:
This is quite unique because the 7 program that was laid out by the TERA Corporation and 8 Livermore, because it was going to a number of something like
~
9 10 to 20 experts around the country and asking the what you 10 really would think about the seismic design of these older 11 plants.
They actually sent this approach and got woven into 12 the overall technical group of experts, even people who were 13 intervenors in some of the hearings.
14 So they tried to get a consensus of not just those 15 people who have been supporting plants, but those people who 16 were actually experts in the fields of -- who ha.] actually 1'7 opposition in public hearings.
18 So it is a very well-founded program.
19 It is clearly one of the biggest.
20 MR. DENTON:
I would just echo, it looks like a very 21 successful program so far.
It involves site visits, actual 22 examination of the way the plants are constructed with a very 23 large group of individuals.
24 COMMISSIONER BRADFORD:
Darrell, you said that two 25 of the plants, I think -- correct me if I misparaphrase it --
ALDERSON REPORTING COMPANY, INC, I
J 17 1 but were essentially built without a seismic design -- without 2 seismic design considerations.
3 MR. EISENHUT:
That is right.
They were built, in 4 fact, prior to the NRC's having a seismic design requirement.
5 Two others were built in accordance with the NFI' building 6 code.
Therefore, they were not built to any dynamic analysis 7 approdch either.
8 COMMISSIONER BRADFORD:
What are you finding when 9 you look at those four plants now?
10 MR. EISENHUT:
When we look at those plants, up to 11 this point in time the basic approach was to develop a, a 12 methodology; second, develop what kind of acceleration you 13 would expect, whether it is peak ground acceleration; and 14 then, third, the spectral shape that needs to be used in 15 analysis.
16 For each of these plants we have now, the methodology 17 has been pretty well developed and has been generating a draft 18 acceleration and spectral shape for for each of these plants.
19 We are going to a meeting with each of these licensees next 20 week and that will be the first time we will be laying upon 21 them the results of our work, saying this is the new 22 acceleration in the spectrum that our analyses have seen.-
23 MR. DENTON:
There are two things to keep in mind 24 about these.
Livermore did these for their own reactor.
They 25 used Appendix A, and that reactor was designed early on in the ALDERSON REPORTING COMPANY,INC,
18 1 manner in Project A.
So they used Appendix A and they went to 2 their most elaborate mechanical engineering codes for plastic 3 deformation and concluded that they only needed to make one 4 change.
5 A serial test reactor, to meet present day 6 standards, but it was a very elaborate analytical job and the 7 same approach is being applied here.
We don't really know the 8 outcome until you do all the calculations and see what 9 changes.
10 The other thing to keep in mind is they are low 11 power plants.
They tend to be located in remote areas so in 12 terms of their consequent side of the risk equation they are 13 at the bottom parts of the comparison.
14 But we won't know until these results are further 15 along.
16 COMMISSIONER BRADFORD:
When do you expect to have 17 the analysis you have done matched up with what you know is in 18 those four plants?
19 MR. EISENHUT:
So you can make a determination?
20 Probably later on this year.
21 Let me clarify what I said before.
Two of these 22 plants did not have a seismic design input at all.
Two others 23 were designed to a static, unified building code, which is a 24 very small acceleration.
25 The fifth plant, San Onofre, had a static design l
ALDERSON REPORTING COMPANY,INC, L
a 19 1
1 also.
These five plants, I should point out, have been doing 2 considerable work.
3 San Onofre has spent tens of millions of dollars 4 already redesigning work, trying to upgrade their plant.
So a 5 group of these plants -- they recognized this from the very l
6 beginning and they are doing considerable work.
7 We think some plants will have structural 8 modifications.
Some will have mechanical equipment 9 modifications and almost every one will have electrical to equipment modifications in order to assure that they can 11 resist an earthquake.
12 COMMISSIONER HENDRIE:
In the early days, Peter, 13 where there was not any sort of organized seismic design 14 basis, even if your spec for the design jobs that mention it, 15 the structural people pretty generally would throw in some 16 static horizontal forces, a la the Unified Building Code, 17 which would cover seismic and some wind bloating, amplified 18 wind bloatings, and things like that.
19 And'because of the generally conservative design 20 practice in structurer, that turns out often not to be too 21 bad.
22 I can remember when the first Brookhaven Graphite 23 Reactor was designed in late -- I guess it was 1945 or the 24 beginning of '46.
They sought advice and received a letter 25 from a very eminent and ancient Jesuit seismologist up at ALDERSCN REPORTING COMPANY, INC,
20 1 Fordham who, among other things in his letter said, "I can 2 assure you on the highest authority that there is very little 3 seismic activity to be concerned about on Long Island."
I 4 said, by George, you can't do any better than that.
5 (Laughter) 6-COMMISSIONER HENDRIE:
Nevertheless, there was a 7 twentieth of a G unified building code put into the 8 structures.
But when you aet thingslikebquipment i
9 qualification, at the present time you have a seismic design 10 basis and you have got a piece of mechanical or electrical 11 equipment that is important to safety.
12 You have to go put it on a shaker table and shake it 13 with a prescribed spectrum and see if it holds up.
14 There was nothing like that contemplated in those 15 days, so the mechanical gear, the electric gear, it was 16 whatever good quality industrial instrumentation and 17 mechanical equipment was designed to in those days.
It didn't 18 have that kind -- it certainly didn't have seismic --
19 COMMISSIONER BRADFORD:
In the case of the two that 20 didn't have the seismic factored in, is that like saying they 21 were built, in effect, on the assumption there would be no 22 earthquake?
23 MR. EISENHUT:
No.
At the time they were built, 24 which means, if you look at some of these plants, they were 25 designed back in the late 50s.
That wasn't one of the ALDERSON REPORTING COMPANY, INC,
21 1 considerations.
2 MR. DENTON:
I think it means you can't find that 3 the AEC gave any attention to this and they were probably 4 built at that time.
Good practice for hazardous structures, l
5 suc as dams, intended to follow that kind of industrial 6 practice.
7 But the AEC didn't get into the review at all.
8 The same way with floods.
9 COMMISSIONER BRADFORD:
What is puzzling me, I would 10 have thought that somewhere you would be able to find that 11 they used some kind of acceleration factor regardless of where 12 they got it.
13 MR. EISENHUT:
Two of tne plants even predated that.
l 14 The others were like the.02 G that Dr. Hendrie just 15 mentioned.
i 16 COMMISSIONER HENDRIE:
I expect that in order to 17 find that, you see in those days there wsa not the 18 requirements for the sort of documentation of what you put 19 into your design that there is now.
Now we have requirements, i
20 Now you have to keep documents and show that you met all the 21 requirements, and so on.
22 In those days, the chances are that the project 23 owners, the people who are buying the plant, simply didn't 1
24 even ask their engineers, what was your basis?
They went to 25 an engineer and said, I want a building.
And the engineer sat ALDERSON REPORTING COMPANY,INC,
22 1 down as a competent professional in the field in the context 2 of the practice at the time.
I dare say that the structural 3 people cranked some things in there to provide themselves 4 elbow room.
But I doubt very much it is documented.
5 The only way you would ever know is to go back and 6 find the chief designer of this or that and the other thing 7 and ask him if he could remember what he put in there.
8-MR. DENTON:
The intent of this program was --
9 COMMISSIONER HENDRIE:
That doesn.'t mean that the 10 steel and the concrete may not be pretty good, but you don't 11 have a paper trail that you can follow along.
12 COMMISSIONER BRADFORD:
The business of verifying 13 that against what the program is coming out with obviously 14 will be quite a challenge.
15 MR. DENTON:
I think this program is going at it the 16 othe. way.
It is really what is there and how they have their 17 supports and piping arranged in estimating and comparing that 18 with what Appendix A required.
19 MR. EISENHUT:
It is really doing both of those.
20 You want to look at the existing plant, the existing concrete 21 and you want to estimate what it will take.
But if it can 22 take X amount, you have to look at the regulations and say 23 what would the NRC's present current approach require?
Not to 24 state that it would require something much greater.
25 So it is a very difficult job, particularly in this ALDERSON REPORTING COMPANY,INC,
23 1 area and there is quite a large gap.
2 MR. DENTON:
Even the mechanical codes have changed.
3 It used to be SEY, SP3 I think this is why we have such an 4 elaborate array of consulting assistants in this area.
If 5 there is anything to do with seismic reviews, even any modern 6 plant is complicated and doing over a plant that wasn't built 7 with that in mind is even more difficult.
8 MR. EISENHUT:
Just one other thing on this program.
9 There are other things coming out.
In passing on the seismic to program, for example, when the teams have been going to sites 11 and requiring a look at the design of the plant, you get some 12 spin-off effects.
13 For example, af ter looking at some plants they found 1-4 with the DC power supply that the batteries in the plant were 15 sitting on battery racks.
In these old plants, they didn't 16 think of bolting down the batteries.
They didn't think of I'7 bolting down some vital equipment, of putting restraints to 18 hold down.
Some pretty simple things that you know are going 19 to have to be done, regardless of how this program comes out.
20 Those kinds of things.
We have issued information 21 notice to all operating plants, not just the SEP plants, but 22 we have said, you ought to look at these things and you ought l
23 to consider -- we went to everyone.
24 These are the kinds of things that have spin-off 25 ef fects.
ALDERSON REPORTING COMPANY,INC, 300 7th STREET, S.W. REPORTERS BUILDING, WASHINGTON. D.C. 20024 (202) 554 2345
I 1
CHAIRMAN AHEARNE:
You will be sending out some sort 2 of a bulletin which will'say, batteries ought to bolted down?
3 MR. EISENHUT:
Things like batteries are, in fact, 4 bolted down so there is a good chance they won't fall aff the 5 racks with an earthquake.
We felt at one plant there was a 6 good chance that they would.
7 CHAIRMAN AHEARNE:
Let's take that one plant.
Is 8 that telling it that it should, or is it saying ---
9 I'm not clear what you are really telling us.
10 MR. EISENHUT:
The item that went out is saying that 11 you should look.
We have asked them to follow up to be sure 12 that they'are looking, letting them follow up and do the job.
13 On plants that we found that there really is a 14 problem we are pretty much telling them, but it is an informal 15 telling them at this juncture, though.
16 We haven't issued an order, or anything like that.
17 It says, put on bolts and bolt down your equipment.
We are 18 trying to wait until we see the overall program, but we sent 19 them a formal letter which said this item 'we don't think you 20 should wait until the end of the program.
21 MR. AHEARNE:
You have formally told them, for 22 example, that they have to bolt on batteries?
23 MR. CRUTCHFIELD:
We have asked them-to survey their 24 f acility.
They have come back to us in many areas and said, 25 we seem to think we are satisfactory.
We have a great number s
ALDERScN REPORTING COMPANY, INC, l9:M 7%E53
25 1 of bolts there.
I have notes on the bolts, and things like 2 that.
In other areas, they think they are weak.
3 Right'now, what we are doing is assessing what we 4 have received back on all eleven plants.
Then we will be 5 going out with instructions as to what action they are to 6 take.
7 MR. EISENHUT:
On the batteries, for example, the 8 first site they were found --
9 MR. CRUTCHFIELD:
I think the batteries have been 10 taken care of.
11 MR. EISENHUT:
So it is an informal exchange.
We 12 try to get licensees where every time they find something, say 13 we ought to can it.
14 CHAIRMAN AHEARNE:
There will be --
15 MR. EISENHUT:
There will be a formal way at the end 16 of the program.
17 CHAIRMAN AHEARNE:
You will be sending letters back 18 out to the SEP facilities saying here are the things you have 19 found in that review that ought to be fixed.
20 MR. EISENHUT:
Yes, that is our intent and they will 21 all be on a nice, neat document at the end of the program.
l 22 I won't go through the rest of these.
I will just 23 mention the last one.
That was control room habitability.
I l
24 That was an item that was identified under the SEP program i
25 that, coincidentally, came out as one of the action items ALDERSON REPORTING COMPANY,INC,
26 1 under the post issues also.
This was an issue on the SEP 2 program that was identified even prior to that.
3 This is just the tightness of the control room.
4 Can I have the next slide?
5 Program difficulties.
I would just mention a couple 6 of these.
7 It is a difficult program, as you can imagine.
When 8 you find a deviation is actually when your work really begins 9 and you have to really assess those deviations.
The designs to are different than current plants.
That is, some of these 11 eleven plants are really unique.
K
-f ewers quite of ten are 12 not familiar with these kinds of plants.
13 So the person who has been doing a lot of review 14 work on this modern vintage plant has a really difficult time 15 going back.
It is a learning process,for that plant.
16 I have already mentioned that licensees are not 17 aggresively pursuing the program and Harold mentioned that 18 they had considerable amount of competing activities over the 19 years.
20 CHAIRMAN AHEARNE:
Darrell, you say, as you 21 mentioned before, it is viewed as an NRC program.
Are we 22 doing anything to dissuade them of that view?
23 MR. EISENHUT:
On the next slide, I might address l
l 24 that.
25 CHAIRMAN AHEARNE:
Wait.
Peter had a question.
ALDERSON REPORTING COMPANY,INC,
27 1
COMMISSIONER BRADFORD:
You mentioned this problem 2 of reviewers having to accustom themselves to these older 3 plants.
In the course of your reorganization and just general 4 turnover, you must have had a fairly high turnover of people 5 involved in the program as well.
6 MR. EISENHUT:
Yes.
We had a considerable-number of 7 people who previously were assigned to the program who will 8 not be -- but you will see were addressing this third bullet 9 up there.
10 MR. DENTON:
To one extent, Commissioner, that wa's 11 deliberate.
I was concerned that we were building up a group 12 of people who were wiling to say that the plants that met less 13 than today's standards were okay for some technical reason and 14 another group in the same technical discipline who were 15 insisting that today's standards be applied.
16 We tended to put all of those technical people l'7 together. in the very specialty branches and I want to have a 18 corporate memory in those branches that we have a plant of 19 varying designs.
And I thought by building up two technical 20 groups, one of whom could approve the system one way and 21 another group who could view the system another way, we would 22 eventually lead to major conflicts between those.
23 So I hope, by putting them together, they will be 24 able to rationalize more fully.
25 CHAIRMAN AHEARNE:
Are you saying, Harold, that you ALDERSON REPORTING COMPANY, INC,
28 1 are no longer going to have a separate group of people looking 2 at SEP plants?
3 MR. DENTON:
We have about half the people who are 4 looking at SEP plants are still together.
The other half we 5 put back into a technical home where it may not be the same 6 reviewer.
7 CHAIRMAN AHEARNE:
So you are saying, instead of 8 having all the people working on SEP on one group, you are 9 having some of the people still working in SEP in that group 10 and, in addition, you will be pulling people out of these
.11 other centers to work on SEP?
12 MR. DENTON:
Yes.
13 For an example, to pick an example, in the 14 structural seismic area, there is still one person warking for 15 Denny in the seismic design area, but he is getting assistance 16 in geology and seismology from that branch, for example.
So l'7 rather than have a geologist just assigned to SEP plants, we 18 debated back and forth which way to handle that, whether to 19 dedicate people or to go the other way.
And I guess we have 20 gone about halfway towards putting everybody back in the 21 technical home.
22 COMMISSIONER BRADFORD:
What is the relationship ZI between the SEP Branch and what I guess is the SPE Branch, the 24 Safety Program Evalation?
The latter is developing criteria 25 across the board?
i ALDERSoN REPORTING COMPANY, INC, mmm ms:uom
29 1
MR. EISENHUT:
the Safety Prograa Evaluation Branch 2 is a branch that is more looking at the overall business.
It 3 looks at any new requirement.
4 For example, it is the built-in process to insure 5 that new requirements, whether they be on an old plant or a 6 new plant, et cetera.
7 MR. DENTON:
I didn't pick up and jump to the other 8 division.
We do have a program now in the Division of Safety 9 Technology that I. hope will perform the functions at the 10 branch level that the ratchet committee used to perform, that 11 whenever any division initiates a new requirement or thinks up 12 a new way to improve his particular discipli.:e, we go over to 13 that branch under Roger Mattson, and that will be looked at 1-4 for impacts in other areas, and total risk improvements and 15 Mattson would endorse it.
16 It is a permanent ratchet committee that interacts l'7 with standards and ACRs and then comes back and does it.
That 18 is different than the small branch of dedicated professionals 19 who are still working with SEP plants.
20 COMMISSIONER BRADFORD:
Right.
21 What I am trying to get at, though, is at some point 22 the question has to arise once they have made a decision that 23 something ought to be back here, whether that decision would 24 apply to the SEP plants as well.
25 Are the SEP plants treated any different with regard l
l ALDERSON REPORTING COMPANY,INC,
30 1 to decisions of that type than other, older units.
2 MR. CRUTCHFIELD:
I think, in general, we have tried 3 to historically take the R3C, category 2 and 3 positions, 4 which were backfitted on a case by case basis and forced back, 5 if you will.
We factored them into these eleven facilities.
6 I would foresee that we continue on that proposal 7 with respect to continuation of the SEP.
New postures and 8 sositions that come out of this group will them be fed back 9 into the SEP group with applicability to these older 10 f acilities.
11 COMMISSIONER BRADFORD:
What then becomes of my 12 reasoning that one doesn't want to impose too man ad hoc 13 changes on the SEP plants as you go along because they are 14 going to have to be sort of major, far-reaching changes.
1C MR. DENTON:
I think that consideration is still 16 there in certain areas and some of these backfitting issues 17 will probably be addressed through bunkered systems where they 18 will be solved in one complete redesign and many of the 19 isolated problems.
20 If you take one like the show technical advisor, 21 that is an easy one.
They can put that one in.
So there are 22 a number of plants, I think, that are considering bunkered 23 systems that will have to cesign a whole new tray of safety l
24 systems to encompass all the new requirements.
25 MR. EISENHUT:
So far, we have laid on all these new l
l ALDERSON REPoRTMG COMPANY, INC,
)
31 1 operating plants, including these eleven, all TMI issues.
We 2 haven't given SEP relief on any of them.
3 One of the things they would like to request is 4 rather than put in some of those post-TMI fixes, they would 5 like to consider looking at the SEP, looking at an integrated, 6 brisk assessment, and then deciding on what needs to be fixed 7 in their plant and maybe going to something like a dedicated 8 shutdown system where rather than fix up systems A, B,C,D,F 9 they would give us a brand new one and add on one brand new 10 system with its own source of water, its own power supplies, 11 capable to do the job which could help out all of the systems.
12 MR. DENTON:
I think the answer is, we have not bent 13 the system.
We have backfitted some things that they would 14 have preferred could have been dealt with in a larger context 15 and some things we have agreed in the larger context.
It is 16 almost case by case specific.
17 If you look at each plant, there is a different 18 ensemble of issues to be solved.
There is one plant that is 19 proposing -- and maybe you should turn to that next slide --
20 to do an integrated risk assessment.
21 CHAIRMAN AHEARNE:
What happened to NRR manpower?
i 22 MR. DENTON:
We have problems with that one.
23 CHAIRMAN AHEARNE:
Back one slide, please.
24 MR. EISENHUT:
Budget assumptions are 32 man years 25 of ef fort devoted to the SEP program.
That has been effect l
ALDERSON REPORTING COMPANY, INC,
. RR Kiric WMSFE!a l
32 1 since 1978,' FY 1978.
In FY '78 there was considerably less 2 than 32.
It started picking up a little bit in FY '79, as you 3 can see on the slide.
4 FY 80, there is -- it looks like it dropped off in 5 FY 80.
But there is a mistake in the computation on FY 80 6 becaut.,e 13 did not include an overhead factor and really what 7 it is, it is in fact the information we have for FY 80 is that 8 it is right on the money.
We are expending it at almost 9 precisely the rate at which it should be.
10 In fact --
11 CHAIRMAN AHEARNE:
Are you saying 16 for the first 12 half?
1 13 MR. EISENHUT:
It would be equivalent to 16 within a
(
14 fraction.
That is reflected because, as Harold mentioned, 15 about last July was when we made the decision to, in fact, 16 take the individuals and dedicate them to the program.
17 MR. DENTON:
That is when we dedicated the resolved 18 safety issues.
Since that time it has been getting about the 19 right manpower.
20 CHAIRMAN AHEARNE:
The logical next question is, you 21 are saying when you concentrate all in one place on getting 22 the right manpower, but your cecision is not to put it all in l
l l
23 one place.
24 Continue.
25 MR. DENTON:
The manpower now is assigned to the SEP ALDERSON REPORTING COMPANY, INC,
~33 1 but it is not all reporting to the same branch chief.
2 CHAIRMAN AHEARNE:
I think what Darrell has just 3 pointed out is that when they are all in the same branch it is 4 clear tha't is what they will work on.
When they go to other 5 branches, which is now part of their job, apparently -- what 6 are you planning in FY 817 7
MR. DENTON:
In FY 81 I think it is the same level 8 of effort.
The original effort was to complete this.
9 MR. EISENHUT:
It is essentially the same.
I think 10 the real answer --
11 MR. DENTON:
It was to continue the same level of 12 effort until we complete all of these same eleven.
13 CHAIRMAN AREARNE:
How many are in this branch?
14 MR. CRUTCHFIELD:
The SEP branch has ten 15 professionals, two section leaders and a branch chief.
16 MR. EISENHUT:
So it is essentially 13 out of 32.
17 There is a standard conversion factor of 1.4.
18 MR..DENTON:
If we really wanted to do it the other 19 way, then we would take these people who are assigned here and 20 put them all under Denny and have a 32-person branch.
21 CHAIRMAN AHEARNE:
I was just trying to make sure I 22 understood it.
23 MR. EISENHUT:
The real difference here is we tried 24 it in FY 78 to get it the way we were proposing, but there is 3 a difference.
In FY 78, we said that we would have people ALDERSON REPORTING COMPANY, INC, 300 7th STREET. S.W. REPORTERS BUILDING WASHINGTON, D.C. 20024 CO2) 554-345
34 1 assigned and we gave the branch chief some flexibility on who 2 that assigning could be.
3 The thing we didn't do was, we didn't move up in the 4 division's organization and hold the division management 5 accountable.
6 For example, we are going to have a pretty firm 7 tracking system to see that the manpower is coming out of the 8 system if it doesn't get out of these other divisions, the 9 di. vision's management and the accountant.
10 MR. DENTON:
What I really hope will happen, if you 11 take degrees like mechanical engineering, I would hope that 12 branch chief would realize he is responsibl'e for operating 13 amendments, day to day fire drills, SEP-resolved safety 14 issues.
15 We have given him resources to do all of these tasks 16 that we have said we are going to do.
And he has to juggle --
17 maybe decide who is the right person to do which task.
But 18 his net line-up each month will be to put that much effort 19 into eac'h one.
So he should be a little more efficient than 20 if we had dedicated it out and had no flexibility.
21 But obviously we have got to watch each branch to be 22 sure that it doesn't all get gobbled up and tomorrow is a fire 23 drill exercise.
24 And we have put in place a reporting system that 25 should do that.
l l
i ALDERSON REPORTING COMPANY, INO,
35
~
1 CHAIRMAN AHEARNE:
That reporting system is one --
2 MR. DENTON:
We are starting but like we did the SEP 3 program.
The caseload is to look at each'two week period to 4 see if we are actually getting that much work on operating 5 reactors out of each branch as we budgeted and we are going to 6 do the same thing for our unresolved safety issues, SEP and so 7 forth.
8 We get all the data in these manpower reporting 9 systems.
It is just a matter of breaking it out now in the to right order.
11
,MR. DIRCKS:
You might pass that around.
12 MR. DENTON:
That is aggregated data.
You need to 13 check it branch by branch.
14 CHAIRMAN AHEARNE:
All right.
15 Now, since you had also mentioned that you have a 16 fairly sizable contract effort in this, how is your money 17 breaking out?
18 MR. EISENHUT:
Basically it is about $1 million.
it 19 is going to continue to be administered out of the systematic 20 evaluation program branch itself where there. are ten 21 professionals.
2 22 CHAIRMAN AHEARNE:
Is the '81 money also being 23 resolved?
24 MR. CRUTCHFIELD:
It is in three similar ones.
It 25 is a bit rough.
i l
l ALDERSON REPORTING COMPANY,INC, fWINEflYet MA2HQIFT@No @.@. M4 (202) 554-2345
-l 36 1
CHAIRMAN AHEARNE:
So that is decreasing the level 2 of effort?
3 Al1 right.
4 MR. EISENHUT:
If I could go back to the last slide, 5 just to wrap it up, we state here that we consider this to be 6 a high priority program.
We are shooting for completion in 7 April of '82.
We are, as we mentioned, considering having i
8 committed full-time reviewers, these other bodies that are 9 setting the branches wherever they are setting.
We need to 1
10 know who they are.
They would be committed with their 11 management and their counsel.
12 We will be looking at plants as we go down the line,.
13 We will have 80 or so draf t safety assessments.
You will have 14 to integrate that together.
15 There will be two things that are integrated as 16 project power manager, although we don't have him on board 17 today.
That is one thing we will be recruiting for, filling 18 some positions.
19 MR. DENTON:
I think we will find it necessary that 20 once we get a good number for each plant to have a person who 21 is full-time then trying to integrate the places where that 22 doesn't perform without having an individual discipline do it, 23 because if they do it it would violate one of our original 24 charters to try to do it all at one time.
25 The project manager assigned in the old plant, for ALDERSON REPORTING COMPANY,INC, sv;\\sy w
37 1 example, in any of the eleven, has a full-time job anyway 2 dealing with the ongoing amendments and the ongoing action 3 plan items and so forth.
4 So I see the need, as we make headway on the 5 particular SEP plant, to assign one project manager with a 6 full-time job to take these inputs as we get them to show 7 PJ.eas and continue with that plant until he.has. documented th 8 entire plant.
9 So that would be like eventually eleven more people 10 that we have budgeted for during that time phase when it has a 11 high pay-off.
12 MR. EISENHUT:
We are also considering different 13 alternatives to the program.
That is putting more burden back 14 on licensees very specifically, in specific areas, not just a 15 broad brush program -- especially where we are getting it down 16 to the point where it is becoming more finetuned in the major 17 problem areas.
18 CHAIRMAN AHEARNE:
Is that in any way responsive to 19 the ACRS or is it more gee, I believe it is now time to do 20 that?
21 MR. EISENHUT:
Even before we had the ACRS letter we 22 were thinking of doing that, over the last year.
You are very 23 f amiliar with other problems.
In 1979, the licensees were 24 extremely busy with seismic matters and then there was the 25 wave of post-TMI matters.
ALDERSoN REPORTING COMPANY, INC, fMIUB11Xil WA@HIN?T@N, D.@. 20024 J202) 554-2345
38 1
MR. DENTON:
I think it is really the change in the 2 percep tsa of burden of proof.
Before TMI, it was kind of on 3 the staff to prove that there were some defects in the design.
4 MR. EISENNUT:
It has also proceeded far enough 5 along to where you are able to do that.
Now we don't just 6 send out and say, review these 1500 topics.
7 I think we would be able to point them in the 8 direction we want to point them to.
These are the things 9 where the biggest safety pay-off is, and I think that is the 10 difference.
11 COMMISSIONER GILINSKY:
When this program is 12 completed, will these plants then be roughly on a par, at 13 least in terms of documentation, with the other plants in our 14 system?
Where,will that put them?
15 In other words, after that point, will we be able to 16 deal with all the plants uniformly?
Or will we still have 17 t o --
18 MR. EISENHUT:
There will be still scme in the 19 middle.
Remember, when we started this, we thought we need to l
20 get these eleven up to the par where they are either on the 21 par or there is a documented record.
Either they meet a ZZ requirement or they don't meet it, and if they don't meet it, 23 here is why, so you don't continually go through quest, ion 24 after question af ter question concerning the safety adequacy 25 of all plants.
l ALDERSON REPORTING COMPANY, INC,
39 1
When these eleven plants are done, plant number 15, 2 of course, still has some questions about it and plant number 3 20 because it wasn't a stepwise process.
It was of an 4 evolving nature.
5 COMMISSIONER GILINSKY:
Where do you see us going 6 after this? -
7 MR. EISENHUT:
I think what we will have to do, we 8 will have to look at -- this is called Phase II.
We will have 9 to look at it and assess where it is.
10 Personally I can't see going through, even though 11 there are a lot of merits to a systematic evaluation program, 12 perhaps the POL to FTO record that was needed helped drive it.
13 I really can't see going through 137 issues on all of the rest 14 of the 70 operating plants because I think the safety 15 play-of f, the real physical improvement in plants, just isn't 16 worth it.
17 We may have a lot of difficulty with people asking 18 questions, but I think we will just have to figure a way 19 around that, that if you go through these eleven plants on 20 some of the topics and you find that what is there is 21 adequate, it is likely that the rest of the operating plants 22 are also adequate in that area.
23 MR. DENTON:
We will postpone a decision on where to 24 go from here until the results become clear and it might be in 25 some areas we would decide that if they were adequately l
ALDERSON REPORTING COMPANY,INC,
40 1 addressed, unknowing to the AEC in the earliest plants, they 2 probably were addressed that way from there on.
3 Bu-t if be find areas where they were not, we will 4 have to keep plugging away on the later plants until we find 5 where the trend changed.
6 But I think in general there is a lot of sentiment 7 today for a national reliability, a national risk assessment 8 approach where eventually we would have to be able to specify 9 the type of risk assessments that would be valid and useful 10 results, and really focus the results plant by plant in order 11 of the highest pay-off areas for improvements.
12 CHAIRMAN AHEARNE:
Following that, will you mesh 13 with the other program?
14 MR. DENTON:
The IREP program was intended to 15 disclose how best to approach the entire population.
16 CHAIRMAN AHEARNE:
But it still eats its way through 17 plants.
18 MR. DENTON:
The original IREP program was going to 19 be six plants.
Hopefully that will teach us what to ask for
~
20 for all plants.
21 CHAIRMAN AHEARNE:
But for example, would you see f.n 22 some of the states, returning this approach back to the SEP 23 plants?
24 MR. DENTON:
Yes.
I hope some day we would be able 25 to do something in the risk assessment line on all plants.
l ALDERSON REPORTING COMPANY, INC,
s.
41
.1 MR. EISENHUT:
They sort of croso cut two different 2 directions.
3 COMMISSIONER GILINSKY:
Let me go back to a remark i
4 you made earlier, that if these plants are basically okay or 5 don't dspart too far in safety terms, we can expect that 6 probably the other plants are okay, too.
7 MR. DENTON:
I wouldn't want to stretch that too 8 far.
It depends on, I guess, the design and the vendor and 9 the ASME.
10 COMMISSIONER GILINSKY:
I understand that, but just 11 as a very general proposition you were making the point 12 earlier. that, in terms of possible consequences, these are the 13 low end of the scale.
They are small plants, if nothing else.
/
14 Now, as you go up in the CP number, the plants both 15 are more increasingly conformed to current standards but they 16 also get bigger.
l 17 The question is, is their conformance to current 18 standards, say, getting bigger?
19 MR. DENTON:
If we have done our job properly --
20 MR. EISENHUT:
They should at least offset.
We want 21 to keep a uniform approach.
1 22 COMMISSIONER GILINSKY:
Is it immediately obvious?
23 MR. EISENHUT:
No.
I don't think you could go so 24 far as to say that it ought to be immediately obvious, because 25 it is a very complicated' process.
ALDERSON REPORTING COMPANY, INC,
42 1
MR. DENTON:
The other thing you have to look at 2 with these old plants, too, are the operating history.
That 3 is a factor that really wasn't revved in strongly in the 4 original part of the SEP program.
5 You have to ask them that.
Be sure that they look 6 at it.
Not just the design per se, but we have 20 years of 7 history on some of these plants.
8 MR. EISENHUT:
One of the principles early in the 9 SEP -- this is in fact the way probability got there in the 10 first place, even thoug'.1 you migth not be able to show that 11 something is very reliable.
You have 20 years of data in that 12 particular plant.
13 In fact, that has been factored in to a number of 14 the items.
15 CHAIRMAN AHEARNE:
Since a lot of.those plants go 16 back many of those years before the AEC or the NRC were asking I'7 for live data to be supplied, don't you have to get a lot of 18 that information out of licensee records?
19 MR. EISENHUT:
You have to get it from the 20 licensees, yes.
21 CHAIRMAN AHEARNE:
Have we done that?
22 MR. EISENHUT:
Yes.
23 Where we have the question we ask the licensee -- we 24 made it very clear in our opening letters.
That is one 25 vehicle operating experience of the facility, so utilities can ALDERSON REPORTING COMPANY,INC,
s 43 1 go back and they have those vehicles.
It is optional to them.
2 CHAIRMAN AHEARNE:
But we haven't actually asked?
3 MR. EISENHUT:
We have, in some areas.
4 MR. DENTON:
Pre-TMI there was the idea not to 5 burden them with this.
There was this exploratory on our 6 part.
7 I would like to ask them if they are going to do 8 that for us.
9 CHAIRMAN AHEARNE:
Our point was we are obviously 10 agreeing that you have an old plant.
It is going to have a 11 lot of data available.
I doubted that it was -- it wasn't 12 sent to us.
You'd have to ask them for it, because they may 13 not even have kept it.
14 MR. EISENHUT:
Most design information is not sent 15 to us either.
That is why when someone starts working in one l
16 of these plants, it takes the first six months to basically r7 get acclimated with the plant and get aware of the 18 information.
19 MR. DENTON:
That is why I like the idea of a 20 prescient manager on this plant, to do this integration so you 21 are not just looking at technical isolation, bits and pieces 22 of the entire plant, but someone who.can say, considering all 23 of this together, and what I know about the design, 24 the operating industry, the site, where does this whole plant 25 stand and what needs to be changed should be changed first.
ALDERSON REPORTING COMPANY,INC,
@ SC @TRR @.W. RsPORTERS BUILDING, WASHINGTON, D.C. 20024 (202) 554 2345
44 1
I don't think we vill get it if we just have one 2 project manager per plant, because he is really burdened down 3 with ongoing activities.'
4 MR. EISENHUT:
That concludes our presentation.
5 CHAIRMAN AHEARNE:
Joe, do you have anything?
6 Peter?
7 COMMISSIONER BRADFORD:
One of the things that 8 concerned me is about the program, as we have been wrestling 9 with the fire protection and environmental question 10 separately, was the way in which it seemed that the SEP plants 11 for other reasons than one might have thought would be the
]
12 areas of greatest concern, have turned out to be the plants 13 which were hardest to bring into compliance.
14 The point was made that they had been told that 15 these would not be applied to them until the end of the line.
16 Is that a problem in other areas as well?
17 MR. EISENHUT:
Let me make sure that I clarified 18 that.
19 We didn't tell the licensees they did not have to 20 fix fire protection into the program.
21 COMMISSIONER BRADFORD:
Go ahead.
It MR. EISENHUT:
We had 70 operating plants that 23 needed to have a fire protection review.
Rather than do the 24 eleven SEP plants first of the 70, we made the last 70 but 25 still part of the program only because we had laying next to ALDERSON REPORTING COMPANY, INC, N
45 1 it an SEP schedule where we wanted to get the maximum benefit 2 of the fire protection reviews and the SEP seismic reviews, 3 safe shutdown reviews, and call for them to come together at 4 the same point in time.
5 So if you had brought first the fire protection 6 reviews first, we would wans to go ahead and fix those plants.
7 We wanted to have the two converge together.
8 We did not give the SEP plants relief on fire 9 protection matters in any other way.
10 COMMISSIONER BRADFORD:
I understand.
I am not even i
11 sayng that was an irrational way to go about it.
12 The business of trying to get all the problems fixed 13 up in a halfway coordinated manner, but the concern that one 14 comes across there does leave it in the oldest plants we have 15 we have some of the longest running deadlines as far as coming 16 into compliance.
17 And I just wondered whether they were -- I suppose 18 seismic is another area.
19 MR. EISENHUT:
The only item that I can remember 20 which we actually put last in the program was in fact fire 21 protection because we thought -- and in fact, there is a Zt benefit there that you end up with a better fire benefit 23 program than in the past because, just based on fire 24 protection, none of these plans, we would expect, would be 25 required to have a dedicated shutdown system.
Just fire
)
1 ALDERSON REPORTING COMPANY, INC, CMLKGR4CKR)P3F2"3
e.
46 l
1 protection would not drive them there.
2 We faced ourselves the question, does the situation 3 look bad enough with respect to fire protection required, and 4 the answer is no.
But when you take that in connection with a 5 lot of other considerations, the answer may well be that you 6 are looking for something better in the long term.
7 So we really didn't forego -- if you find the major 8 problem, if you remember back from the objectives, one of them 9 was that you had to have, built into the program, a system 10 that if you find a major design deficiency or a major problem, 11 you go ahead and fix it.
Environmental qualifications is a 12 good example.
13 The utilities, all eleven, all argued very 14 strenuously that they thought this was contrary to the SEP 15 philosophy.
Our answer was we think it is important enough to 16 be contrary to the SEP philosophy.
17 The Lacross liquefaction was another, so there were 18 a number of them where we decided to put the fix in place 19 before the completion of the SEP program.
20 COMMISSIONER BRADFORD:
What is the role of the 21 resident inspectors in the SEP scheme of things?
22 MR. CRUTCHFIELD:
We have been utilizing them to 23 help us in utilizing capability of the licensee -- how good he 24 is performing and using him to help us locate where 25 information is.
We may be overlooking that, so we can keep in l
I l
ALDERSoN REPORTING COMPANY, INC,
47 1 touch with him through the project management side as to what 2 is going on at the facility that could impact the SEP efforts.
3 CHAIRMAN AHEARNE:
Any more questions?
4 Joe, Bill, do you have anything else?
l 5
MR. DIRCKS:
We could have another crack at this 6 program --
7 COMMISSIONER BRADFORD:
I have another question.
8 In terms of a sense of priorities, where does this 9 fit in in the current NRR.
If you had $5 to allocate $1 10 apiece in five areas, would the SEP program be --
11 MR. DENTON:
It is both casework and OL and cps so 12 it is up there with operating amendments and unresolved safety 13 issues.
14 MR. DIRCKS:
It wasn't touched during the scouring 15 of the resources for the action plan financing which is 16 something, because resources is almost everything.
17 So, to that extent, it was held apart and given that 18 priority that we wouldn't even touch it.
19 CHAIRMAN AHEARNE:
I guess in running back over some 20 of these whole things I have found the notes I have made from 21 August 3rd of 1978 which clearly predates it, that -- and at 22 that stage, there are -- and what you have said was that SEP 23 was identified as second in priority for NRR.
24 MR. EISENHUT:
That is right.
25 CHAIRMAN AHEARNE:
The first was other problems.
~,
ALDERSON REPORTING COMPANY, INC, 8T#a EEDVid EM RMRViTIS ml@lNGo WASHINGTON, D.C. 20024 (202) 554 2345
)
48 1
So I guess my only concern would be that as one of 2 the problems with each of the shifts of the organizational 3 type structure I am sure carries along with it a good 4 rationale of why that is the right thing to do.
5 There was a notice in here in July of last year 6 which had a different organizational structure with a good 7 reason why it was the right thing to do.
Now there is a good 8 reason why this is the right thing to do, and I am not taking 9 any disagreement with that.
to But, of course, one of the problems with the 11 constant shif ting organizatien is that people are trying to 12 run the program.
13 They have difficulty keeping track of what it is 14 they are trying to run.
15 As you have pointed out, these are the eleven oldest 16 plants and are the most difficult to review, but they are 17 obviously ones that the Commission in the past, and you in the 18 past, have indicated they are ones that must be done with very 19 high priority.
20 I hope that in another six months, or in a year, you 21 will actually reach that conclusion of the effort rather than 22 another set of changes.
23 _
I recognize that it is very difficult.
24 Thank you for the information.
25 (Whereupon, at 3: 45 the meeting was adjourned.)
ALDERSON REPORTING CMPANY,INC,
<., o g.
r This is to certify that the attached proceedings before the 9
liUCLEAR REGULATORY COMMISSION in the matter of: Discussion and Vote on Briefing System and Evaluation Program Date of Proceeding: !!ay 6,19 80 Docket Number:
Place of Proceeding:
Washington, D. C.
were held as herein appears, and that this is the original transcript thereof for the file of the Commission.
Marilyn Shockey Official Reporter (Typed)
Official Rep rter (Signatu
'W