ML19344D617
| ML19344D617 | |
| Person / Time | |
|---|---|
| Issue date: | 04/15/1980 |
| From: | NRC COMMISSION (OCM) |
| To: | |
| References | |
| REF-10CFR9.7 NUDOCS 8004250276 | |
| Download: ML19344D617 (79) | |
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l UNITED STATES NUCLEAR REG UL ATO RY COMMISSION In the m atte r of:
BRIEFING ON STATUS OF REVIEW OF ENVIRONMENTAL QUALIFICATION OF ELECTRICAL COMPONENTS AT OPERATING POWER REACTORS-Place: Bethesda,. Maryland Date:
April 15,1980 Pages:
1 - 78 INimMAnoNAL VesAmu Roonras. INC.
(j 40 SOUTM CAPITCL STREET. S. W. SUITE 107 WASHINGTON, D. C. 20002 2D1 6 8004250 f0-
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i UNITED STATES OF AMERICA I
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NUCLEAR REGULATORY COMMISSION 2
l l _________________________________x 4
l In the Matter of:
[
3 bBRIEFINGONSTATUSOFREVIEWOF 6
ENVIRONMENTAL QUALIFICATION OF l
! ELECTRICAL COMPONENTS AT 7
- OPERATING POWER REACTORS i
8
_________________________________x 9
to Room 550 East-West Towers i1 4350 East-West Highway
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l Bethesda, Md.
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Tuesday, April 15, 1980 l
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The Comission met pursuant to notice, for le e
presentation of the above-entitled matter at 10:08 a.m.,
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14 John F. Ahearne, Chairman of the Commission presiding.
l 17 l
BEFORE:
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RICHARD T. KENNEDY, Comissioner i
19 JOSEPH HENDRIE, Comissioner i
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PETER A. BRADFORD, Comissioner 0
VICTOR GILINSKY, Comissioner i
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_P _R _O _C _E _E _D _I N _G _S CHAIRMAN AHEARNE:
The Commission will come to 2
l order.
This morning we meet to hear a briefing on i
the status of the review of environmental qualification of 4
electrical components that operate in power reactors.
And that long title has buried in it some, I believe, quite i
interesting material.
7 Harold, I trcW:that you will have -- either you or minions en your behalf will have many things to tell us.
gg 11 MR. DENTON:
I need to review our physical
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COMMIS~SIONER KENNEDY:
It happens to all of us.
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13 CHAIRMAN AHEARNE:
Harold, we have a great deal l
I4 of trouble with material balances, and it probably applies I7 to people.
We just hadn't noticed it before.
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I3 MR. DENTON:
Ed, why don't you join us at the I9 l
table also.
0 COMMISSIONER HENDRIE:
It's the fifth floor, Harold.
l 21 MR. DENTON:
I knew there was something.
Let me give just a few words on the topic, and then turn it over :
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to Daryl Eisenhut, who will brief you on the status of our
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24 review of this topic.
-J This has been a troublesome issue for several i.,
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The early approach to equipment qualifications was t
j an attempt to set an umbrella standard, so that individual I
l pieces of equipment wouldn't hava to be looked at.
That 2
l standard wasn't even established until after a large 3
number of plants were built, and then an even newer standard 5
l was proposed -- so-called atroply 74.
The Staff didn't I
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propose to apply that standard till -- except to plants who
{arestillunderconstruction.
So we've had to go back and e! develop lower tier standards to do the comparison.
And 9
i j pieces of equipment that fall through this net -- and there i
l have been dozens of pieces of equipment out of all the p
f equipment in a containment that fall through the net that
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then have to be looked at individually.
And this is y
really -- causes the Staff difficulty, to review individual l
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y pieces of equipment.
Then you have to look at the perfor-y mance of that equipment,,how long it's intended to function.
17
- And it's the type of review that we don't -- it's the type la l
of detail that we as Staff don't normally get into.
1 19 It's looking at every nail, rather than looking at the j
i 20 criteria for nails sort of thing.
21 With that introduction, let me turn it over to l
Daryl to explain where we are in our review of plants that j
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- are in operation, and the relationship between the work i
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j for review, first pass-through of all the plants that are i
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i MR. EISENHUT:
Thank you.
Since this must be s
2 about our 34th meeting on the subject, I'll try to 2
l 4
summarize very briefly some of the background.
The first i
4
- slide, I have just a simple outline of what I'll be 3
going through, discussing the status of -- sort of the 4
i l safety status of our ongoing work, briefly highlighting I
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! the things we're finding, where we're going, and what 8
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i the schedules look like.
And then we'll discuss several l
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other subjects that don't really follow any pattern but 3,
l they're really some of the major significant aspects that's
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coming out of this, gg
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First, the work on environmental qualification g4 l has, of course, been underway for a number of years.
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13 was highlightad, I think, in '77, I think it's fair to say,
! by the UCS pet.'. tion that came in, that brought some extra 14 17 attention to i':.
For the last couple of years we've been 18 basically on an issue by issue approach.
We've been reviewing, 19 you will recall, a number of aspects -- improvements you l
l 20 might call them.
21 The next slide.
This is just a reminder of some
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I of the things we've done over the last few years, you 1
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remember; and I won't go through these in any detail.
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i They're all pretty self-explanatory.
It's fair to say we had a considerable number of debates, discussions, some i
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modifications in plants.
2 The key aspect is that every time one of these 1
I came up, we made a plant safety determination -- that is, i
4 whether the plant's all right or not, whether it requires l
t some modification.
It was always looked at as being somewhat of a short-term determination.
It was always in l the back of our mind that we were going to be going 3
I through the subject of environmental qualification, and 9
not item by item by item as they should arise, but rather l this overall umbrella approach.
And that's pretty much
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where we are today.
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The basic safety premise inithe past was that g
i l items would, in fact, survive the accident environment.
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y They would survive the accident environment through the a
short term.
That is, they would accomplish their mission t7 j quite often operating in a few seconds, although we had is questions about their ability to survive for a longer term.
19 j We felt that there is enough components to -- and enough i
20 redundency and diversity -- to allow plants to keep 11 operating.
However, we felt that we had to have a longer-I2 term program.
U Now, that longer-term program we've been working I'
on for a couple of years.
Basically it was broken down into i
two pieces.
One piece was, we started looking at the older i, %mri v
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! plants that are in the systematic evaluation program.
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11 plants.
And NRR was going to take a look at them and 2
decide what kind of a criteria should we be using for the 3
I evaluation in the long-term.
4 The basic requirements, you recall, come from 3
basically the GDC, General Design Criteria 1 and 4.
l 4
i
- GDC 1 just says that you have to have good quality things 7
i in your plant, say, sort of the overall 0-A requirement; a
l all structure systems and components must be good.
4 says that structure systems and components must be l
qualified for the environment; that they must function g
l following an accident in normal operation.
,7 g3 NOw, those are basically the two requirements.
5 9
j Now, that's not very specific.
It's also very difficult I
to review plants against those two requirements, and because' 13 I
of that we decided we needed to develop some more guidance.
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We designated one of our unresolved safety issues, given Is the nomenclature A-24, to be the subject of environmental i
19 l
qualification of electrical equipment.
l 20 Now, the requirement, you also recall, 323 71 was I l
the requirement that Mr. Denton referred to, was the 21 I
requirement that all plants up through some 20 more plants 4
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to go on line, become operational.
That is the standard 24 that they would have to use.
A lot of the older plants --
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in fact, most of the presently operated plants -- did not r
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! even have 323 71 at the time they went into operation.
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That's because the grandfathering of the requirement of 323 71. '
2 323 74-actually first goes into play, I believe it's
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the Commanche Peak plant, which is a number of years down 4
the road yet.
3 CHAIRMAN AHEARNE:
Darryl, both of those d
j standards are more, here's what you want to take into 7
} account, rather than very speci,fic, here's what you ought 3
i! to do.
9
,i MR. EISENHUT:
That certainly is correct.
And to i
l by and large, they're not a specific requirement that says g
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how you take things into account.
It's more -- for l
I j example, 74 says you take into account age, these kinds of g
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t.5 COMMISSIONER BRADFORD:
Nonetheless, the i
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' standards are significantly different.
I mean, there's a
,i big difference between 71 and 74.
17 la l
MR. EISENHUT: The standards are different.
l 19 There are a couple of aspects.
One is the margin that is i
20 required for testing from 71, 74.
That is, you require a 21
! longer -- a different kind of profile, temperature and IE i
pressure profile. Another one is aging requirements.
I think l
maybe that radiation is --
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- 4 MR. BOUCHER:
No, I don't think there's a signifi-i
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l MR. EISENHUT:
Ed Boucher.
It is fair to say 1
i that they're more of a general requirement.
So what we 2
i remarked upon is -- especially since we knew that the 3
1 plants -- most of the presently operated plants --
i 4
i were not required to meet environmental qualification l
l specifically at the time of the application.
We knew that 4
l when we went and looked, for example, there would not be 7
l good documentation.
So we wanted to develop specific l
1 enough guidance, or guidelines, so that when we went and j
1 ked we didn't just say, yes, we conclude there's no 10 l documentation.
We tried to go a little step further, and 11 r
we developed over the last year, I think that through 1979 q
13 we developed twp staff guidance documents.
l 14 i
One document is 824, as I mentioned, which was l
an interim guidance for plants coming down the line, 13 1
starting with Sequoia.
It lays out some guidelines of f
14 17 what it means to meet 323 71, and then what it would mean la to meet 323 74.
We also developed as a guideline document 19 l
referred as the DOR guidelines, which we sent out to all i
20 plants, which is a couple of steps more specific on what j
21 l
you look at, and what level you look at.
These two documents
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were basically what has been developed over the last year, U
t while we were actually doing very little in the way of l
s specific plant by plant evaluation component by component.
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We'd issued a ISO bulletin in 1979, which instructed i
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l licensees to begin looking ac themselves.
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l The 11 SEP plants did not receive that bulletin 4
l because we were going to pursue it in a slightly different 3
way; that is, we were going to work with them, lay out our requirements, and we were actually going to be more involved in the review process, so that that could be a vehicle 6
with which we could learn and develop some more specific 7
i l guidance o'urself, which would help as we go down the line in I
l the future.
9 to l
I think it's important that we go on now to the 11 following discussion.
It's important to remember that the
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k 12 DOR Guidelines are really a screening guideline.
They i
- address many parameters
- radiation, temperature, pressure, 13 i
14 vibration, all of the parameters you would look at to see 13 whether something's environmentally qualified.
14 They're a screening aid.
They're an aid for INE i
17
' to use when they're looking at plants to see whether they l
do a good job or not.
They're aimed to help us focus our 14 l review and to help us identify questionable components.
0 They will highlight the areas of deficiencies; for example, 21 i
1 if a component may not meet our guidelines for one
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l specific given parameter; for example, radiation.
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CHAIRMAN AHEARNE:
Darryl, could you take a j
24 minute and repeat for me the relationship between 824, 2
which I guess is in REG 5887 in=v ex me m GMrftim frugr, & e. SueTT ter I
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l MR. EISENHUT:
I think thas right.
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CHAIRMAN AHEARNE:
The INE bulletin, and the 2
l DOR Guidelines.
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MR. EISENHUT:
Okay.
The 824 document is a docu-ment laid out, called Interim Staff Guidance for doing the reviews coming down the road for plants that have to meet i
7 j
IEEE 323 71 or 74. It's a guidance document that went I
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through each of the major items.from those standards and l
9 l
said here's some kind of guidance, what you really need to l
to do to meet those ground rules.
It really doesn't say too l
much, I think it's fair to say, on the 71 standard.
On the 11 I
12 74 standard, which was a lot more specific, it gives some i
13 additional guidance.
So it's sort of an amplification of
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la 71 and 74.
13 CHAIRMAN AHEARNE:
So it is more -- first a's I
to restricted to those set of plants that have to meet 71 and I7 74.
Is that correct?
I8 MR. EISENHUT:
I think that's fair to say.
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CHAIRMAN AHEARNE:
Yes.
And second,it's not
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j in addition to, but it's an explanation --
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MR. EISENHUT:
-- of --
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I CHAIRMAN AHEARNE:
-- of how to do.
Okay.
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23 l
l MR. DENTON:
That last part has really been the t
- 4 difficulty with the 74 standard.
There are still differing,
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views on how do you comply with 74, ranging from it cannot be lurrWuneftenea '#suestias RupesfWes insk as sun # Tee 4&ss9T4 freuer. t e. marFE ter
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with these types of requirements.
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MR. EISENHUT:
Now, Ed Boucher, on my right, I
2 developed the DOR Guidelines, at least certainly the l principal focal point in getting it done.
So I'll let him I
go ahead and explain what it as we've developed, and why we've had to go beyond the 824 document.
i 7
CHAIRMAN AHEARNE:
Before he gets to that, 8
i i could you tell me, the INE bulletin was to all but the SEP 9
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plants.
10 MR. EISENHUT:
That's correct.
11 l
CHAIRMAN AHEARNE:
And it asked them to review l
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their plants against -- against what?
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e MR. JORDAN:
The original bulletin was telling 14 i
i them to review their plants against their exhisting 15 I
committments, the FSAR committments.
And then the 14 revisable, which was issued in January, is requesting them j
t,o to evaluate their plant components against the DOR guidelines and the NUREG 0588.
So we --
19 l
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CHAIRMAN AHEARNE:
Whichever is applicable?
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MR. JORDAN:
Well, against both, in the same p
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fashion that --
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CHAIRMAN AHEARNE:
Well, for example, since
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24 there are some plants for which -- you've already said a
that 0588 is for those plants required to meet 71 and 74.
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MR. JORDAN:
And I should make it clear that the t
issuance of the bulletin OlB is backfitting, if you will, 2
those licensees on operating plants outside of the SEP 2
l plants.
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CHAIRMAN AHEARNE:
2588.
MR. JORDAN:
20588, using the guidelines as the 6
means for evaluation.
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8 l
CHAIRMAN AHEARNE:
I see.
And is that equivalent l
9 to saying that alternates would then backfit being tg required to meet the 747 11 MR. JORDAN:
No, no.
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MR. EISENHUT:
No.
i 13 MR. JORDAN:
We're missing something here.
14 l
CHAIRMAN AHEARNE:
I'm missing something.
14 MR. JORDAN:
0588, it gives two tables as you j
i 14 go through it.
Each page is two columns.
One column is f
17 i
for -- here's what it means to meet the 71 standard.
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I8 l Here's what it means to meet the 74 standard.
I' Now, for the 71 standard, it doesn't give you t
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a lot of detail.
TheDORGuidelinessupplementthatcolumn.{
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21 So if you ask a licensee -- all of the operating plants, I
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think maybe 50 of them that are operating today do not have l 22 I
in their application a specific committment to meet the 24 IEEE 323 standard at all.
We are backfitting that standard i
to all operating plants.
We're backfitting the 71 version l
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1 CHAIRMAN AHEARNE:
The DOR Guidelines.
And i
that's what the January bulletin was saying, that the 3
i plants had to review against 588.
MR. JORDAN:
That's correct.
i 6
MR. EISENHUT:
Yes, the INE bulletin has been, 7
fortunately, a living document that's changed a number of l
g l
times.
It's really 7901, came out in January,
'79.
It's I
l been modified as time went on.
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CHAIRMAN AHEARNE:
All right.
11 MR. EISENHUT:
Why don't you give some specifics?
12 MR. BOUCHER:
Okay, before I say some specific 13
- words about what's in the guidelines, let me backtrack just 14 a little bit and try and give a general characterization 13 to the NUREG 588 document and how it compares on a higher te plane, a general sort of a plane, with the guidelines.
l 17 The 0588 document, I view it as a design tool.
I
! The kinds of things that are in there are the kind of 18 i
I' I considerations that one ought to put into a qualification
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when he's designing a component.
It gives a large list of i
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things that should be considered, with some soecific i
i guidance on acceptable ways in the design phast to consider l
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these things.
So it's a designer sort of a tool.
And for 24
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that reason it's very appropriate for our CP and OL g.
reviews, because that's where we're at in that prccess.
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We recognize on an ad hoc basis, when you attempt 1
to make judgments about things after they're already built, 2
you use different tools. Engineers might use different tools i
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i i in a situation like that, versus the tools they would a
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use if they were sitting down to design something.
And 2
l j that was the reason for creating the DOR Guidelines.
What l
4 l specific aspects of the design would you look at on an 7
ad hoc basis to make judgments about whether or not that 3
f design lools like it might be weak or questionable with regard to that component's ability to withstand severe,
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So that was the reason for creating the g
DOR Guidelines, because you needed a different tool for i
is a different sor,t of application.
la i
So the kinds of things you find in the DOR 13 Guidelines are statements like, you've checked the radiation.
I 14 qualifications profile to see that it is at least 2 X 10 17 res. And if it is 2 X 10 res, we believe that that l
gives one a sufficient level of confidence on an ad hoc 18 I
19 l
basis, on a cost benefit scale with regard to taking a l
1 20 piece of equipment out versus designing it from scratch, to (
f 21 say that there's reasonable insurance that it will withstand, 1
2 7
radiation.
If it's not designed to 2 X 10 res, when you're {
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t looking at it, if it hasn't been tested and hasn't been
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's qualified to that level, then one looks at the'caso specific U
application of that component to see if it will, in fact, i-Ti v
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specific guidance on how one makes a judgment about what dose it will see at a specific location. So you can see the
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DOR Guidelines were written for ad hoc decisions, post 4
design; whereas, the NUREG 588 were made for up front decisions, when you can look at a whole broader spectrum of 4
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i things.
I think that characterizes the general relationship 7
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j between these two documents.
I Now, as we go through the review process that 9
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- we've got on the program to make reviews on these operating 11 plants, we can see that these two documents come back togethe r
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t in the review process.
Once you've made a judgment using i
13 l the DOR Guidelipes that a component's qualification is I
i 14 i
in suspect, then you're forced to go into its detailed 13 design.
And when you go into its detailed design, then you l
I I4 begin to go back to those types of documents, those types j
17 of considerations that are appropriate at the design phase.
I 18 l
And you can see that we come back into the process with l
19 i
applying -- once we've sorted out, using the guidelines, l
20 j that the answer is no, you don't meet the guidelines, you're!
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into a detailed review sort of phase.
And then you see the,
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inputs to that decision, that judgment there, are the kinds I:
i of things one would consider in the design process, the 1
i 24 NUREG 588, and specific application type information, it's 23 location, the specific temperatures it will see.
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So you can see the process melds.
And then the I
l ultimate judgment, specific case requirements met, gives j
consideration to the NUREG 588 document.
l CHAIRMAN AHEARNE:
Now, by the subtitle you have A
i up there, I conclude that this is now applicable to all operating plants.
3 7
MR. BOUCHER:
That's correct.
i g
l CHAIRMAN AHEARNE:
Is.that correct?
9 MR. BOUCHER:
That's correct.
to CHAIRMAN AHEARNE:
SEP and non-SEP.
11 MR. BOUCHER: That's correct.
i 12 COMMISSIONER BRADFORD:
And when is it scheduled 13 for completion?,
14 l
MR. BOUCHER:
WE've established the goal for i
f 13 f
completion of this program by the end of this year.
- Now, i
I4 one has to recognize that we need to be more specific I7 l about what it is we expect to have at the end of this year.
18 l The very minimum that we've set for our goals at the end of I'
i this year is to identify all those cases where the DOR 1
- Guidelines are not met, and to make some judgment as to the I
- 1 l
overall safety significance of not meeting the guidelines
$2 there.
It's not clear that we will be able to get down to n
I the nitty-gritty all the way through the review process, 24 and identiry what the exact replacement component will be.
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that we'll get that far.
But at the very least, we expect i
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to have identified all those cases where the DOR Guidelines i
f are not met, and some judgment with regard to safety I
2 significance.
4 l
MR. DENTON:
Now, this date applies to all 3
plants, regardless of whether they're being done by INE, e
i l
or by DOR.
INE and DOR have split up the plants, but basically I
we hope to have tested all plants against the DOR 3
j Guidelines by the end of the year, and made an initial 9
judgment on those items that fell through the net, that to didn't meet it.
11
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l COMMISSIONER BRADFORD:
What is the corresponding 12 date then for a goal for actually having the qualified is eglipment in place in all plants ~/
14 i
l MR. EISENHUT:
I don't think we really have f
13 a goal for getting it all in, an actual date.
I think to I
to l
a large degree it's going to depend on what's found as a 17 l
result of the reviews.
Some utilities are coming in and la i
saying, rather than argue about a component, they want to 19 go and approach replacing it, and lay out a schedule for i
,0 4
replacing it.
Some utilities are going to end up testing a lot of equipment.
So, really, the target is to go throughi i
all the equipment from these plants by the end of 1980.
f i
1 v
MR. DIRCKS:
And this is component by component.
l 3
l a
This is a massive inventory.
I m m vome.msenmesmuna14 l
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18 l
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COMMISSIONER EENDRIE:
The end of '80 goal, as I
I understand it, is to scan the guidelines, identify places 7
} where the guidelines aren't met.
But you're not going to 2
l crawl down into details on components until some later time.
MR. EISENHUT:
Well, when you find a component that doesn't meet the guidelines, you, of course, have to 6
ask yourself what it means from a safety standpoint.
7 l
Now --
3 t
COMMISSIONER HENDRIE:
But that comes in that 4
9 i
i detailed review part.
I 10 l
MR. EISENHUT:
But some of that we're doing 11 l
right now.
When you find a component, for example, 12 j
that's really questionable, whether it will function in an 13 l
accident environment, you must ask what this means from 14 a safety standpoint.
So it's sort of a hybrid.
For plants, !
13 j non-SEP plants, we besically put the requirement on the l
licensee for him -- when it doesn't r*.eet the guidelines, is i
for him to decide and make a determi,ation whether or not i
I he has a safety basis for continuing to operate.
We'll 19 I
be auditing those.
We obviously can't check thousands 0
and thousands of components, nor do I think we should.
21 On the SEP program, which is running in parallel l
i now, but at the same time -- you ha re to understand, when l
h 4
we laid out the program, we laid it out in 1979, and it got u
considerably delayed by the Three Mile Island accident --
5 lasTguena h ',WeesT9as h last e
as WafThe enasTut. sTuser, & s. surft te,
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19 I
I o
o us sc I
the thought was that the Staff would be doing a lot more on the SEP reviews; therefore, learning a lot more from it, I
and perhaps able to define a lot more specific criteria to l
4 2
help everyone else do the rest of the plants.
COMMISSIONER BRADFORD:
Now, run that by me once 3
nore.
If the licensee finds unqualified equipment --
i 0
say, connectors, because that's something I can halfway f understand -- it's up to him to determine whether he has I
I an adequate basis for continued operation?
9 MR. DENTON:
In the first instance.
We check to
,! that.
But we make -- since there literally could be 11 l thousands of pieces of equipment that have to be compared, 19
~
i and dozens in any particular plant, he makes the first 13 l
l documentation ab to why, even though it doesn't meet the 14 j
blanket qualifications, it cnly performs -- it only has to 1.5 l
j perform during certain time interval or some other requirement, whether or not its failure to meet requirements is impor-17 tant to safety.
And then we check that after he's made the la initial determination.
19 l
t' I
COMMISSIONER BRADFORD:
How soon from the time 20 j
that the unqualified ecpipment is discovered does he owe i
you a report on that situation?
i i
I MR. JORDAN:
Okay. Assuming that it would cause j
g i
4 one of the systems in the tee specs to be made inoperable if' 3
this component were unqualified, then the licensee would B
lmftenas VWees11as h isst am smpfte Saa8Tm. #FWWF. E e. SNTE tW
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' have a 24-hour notification and a 14-day report to make.
I And so we would have his notification to act on, and also his report.
And then those are being reviewed on a real l
3 time basis as they come in.
For instance, I should identify from the revision 3
to the 7901 bulletin, we've now received six licensee --
6 I'm sorry, five reports and one pending -- on unqualified 7
I i
components that have additionally been identified from this l
first set of responses.
9 l-COMMISSIONER BRADFORD:
How many pieces of to I
l equipment are we talking about in a plant?
11 f
MR. DENTON:
Depends on how you classify, 12 you know, a piece of equipment.
But if you look at the 13 f individual serial numbers, the books I've seen -- do you I4 i
I want to guess?
You've been -- you've checked it.
IJ l
{
MR. BOUCHER:
You take all the equipment inside 14 and outside containment, it would run up into hundreds.
If you spoke specifically on inside containment, where the 14 i
biggest concern lies, where the hostile environments are most severe, I would say that probably you'll boil down l
3 i
to 30 or 40 at the low end of the scale, of critical 21 I
=
components, those which you really would believe should n
j be qualified, per plant.
I l
24 Now, of those, perhaps there might be some 2
duplicates in there too.
t e
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COMMISSIONER BRADFORD:
When you say 30 or 40, j
- would you be counting all connectors as one, or would you l
4 be counting connector by connector?
You're counting i
classes of equipment?
l MR. BOUCHER:
Classes of equipment.
3 i
COMMISS'IONER HENDRIE:
But individual pieces 6
\\
7 j
very much greater than that.
i g
l MR. EISENHUT:
That's.right. And that gets 9
you into difficulty if you find --
l COMMISSIONER HENDRIE:
No, a collector is one to 11 item.
It adds list.
12 MR. EISENEUT:
That's right.
i-1 13 COMMISSIONER HENDRIE:
But there may be 700 i
I4
~
connectors.
l 13 MR. EISENHUT:
Let's not focus too much on 14 connectors, because there are very few operating reactors i
U
{ with any connectors left.
II COMMISSIONER HENDRIE:
Well, as Peter says, I'
l we've been through that enough so commissioners understand I
.U connectors.
Even though we understand, it's no longer a 21 l
problem, it's a useful specimen to examine.
I COMMISSIONER BRADFORD:
Is it, in fact, the j
right magnitude and ratio to keep in mind, for one class 24 of equipment on that list of 40, there might be as many as l
2 I
lMM '$HfRIC l 0'C age amfpe SaMMb fRue?, L e, asfM :er I
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o nas no.
700 of them in the plant; so that you'd be talking about a list of 40, you've maybe talking about 28007 I
MR. DENTON:
I wouldn't think that was typical.
2 1
If you go to transmittors or something, there're not 700 transmittors.
I COMMISSIONER BRADFORD:
No, but there's components --
7 MR. DENTON:
But there are classes where it a
t l
would be that large.
9 MR. EISENHUT:
So you'd run into the thousands.
l 10 i
MR. DENTON:
So let's get back to the question 11 l you're asking.
Are we -- we were saying we hope to have 7
12 completed the initial screening of all operating plants --
13 and we'll set aside plants that are under review for just 14 i
a moment -- by the end of the year.
That's both SEP and 1.5 l
all others.
So between DOR and INE, they will have made I4 l
the initial pass-through to see what falls above and what i
17 falls below the DOR criteria.
And we'll make some initial i
18 i
I judgment as those deficiencies are revealed.
A final 19 i
l decision on whether that equipment really is qualified for j
,0 a
its' function, or whether it's got to be replaces, will come I
21 i
=
some months after that, probably as the result of back and I
n forth with the licensee, after an initial judgment is made.
i 4
And it is true that in many cases licensees are i
u
. opting to just replace it with new equipment rather than i-~ v
- x age mWTee esp *T4h. #Tuer, & e. starft te, l
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e am. o.
23 1
try to trace -- especially if it's a real old piece -- to 8
l I
try to show that it's really qualified for the base conditions if it hadn't been tested quite to that standard.
MR. EISENHUT:
That's right.
So there's not really a point where you just truncate it and say I'm done.
It's the kind of thing where first you worry l
6 t
7 about the 30 or 40 most significant, and there may be 3
l another 60 or 70 lesser significant that you work on next.
9 l And it's going to be a very long program for a plant who to may have these 100 different types of components which were 11 never really looked at from an environmental qualification 12 standpoint.
You think they're generally good quality, 13 but they weren't specifically looked at, and therefore, 14 i
don't have the paper pedigree behind them, because it i
13 just wasn't --
id MR. DENTON:
With regard to this area, perhaps in i
i 17 retrospect we should have done at it with certain minimum la
- standards for all equipment, and somewhat higher standards U
for other equipment.
And instead we adopted a standard l
g from which we readily permit deviations.
So it's not i
a minimum standard for any piece of equipment, if it can l
I
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be shown not to apply.
I think that's what's made our
{
administration of it so difficult, 24 s...
COMMISSIONER BRADFORD:
Darryl used the phrase
- .?.
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24 1
I 4
8 saas so.
~
l paper pedigree.
I take it that the pedigree will, in l
fact, be a requirement apart from the fact of qualification I
of this type of equipment in the future.
But it isn't for 2
the equipment that's already in place?
MR. EISENHUT:
For the really old plants it I
was not a requirement to have a documented bases for the documentation.
So that's what makes the job very 7
j difficult.
Do you go out -- plants very often have to go i
3 l
l' in and look and see physically what kind of a piece of 9
i equipment they actually have.
And there's not the long to record behind it supporting it.
In new plants, there 11 l
certainly would be, yes.
[
1:
MR. DENTON:
Maybe this is a good point to talk 13 I
I about the visits.to the six plants, and to summarize what 14 i
those results have indicated.
13 1
j MR. DIRCKS:
You might add, Darryl, at this la l
point, where once you've gone through this process --
17 we've talked about this -- and you establish that the 18 components qualify for a particular plant, from that. point, 19 j
i for that class of components, then you sort of lock it
,0 i
i up, and it becomes a part of the license, so to speak.
Is j
p i
g that how you're looking at it?
I l
i MR. DENTON:
Yes, we like :o do that.
3
- 4 MR. DIRCKS
And that's an enforcable type of n
thing.
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25 4
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l MR. EISENBUT: Clearly it's got to be -- once
+
I you have it done, you don't want to be doing this again o
I
! five years from now.
This is the related aspect.
2 There's always the related aspect.
And that is, once an item is qualified for use someplace -- one of the items in the last seven things we'll talk about, sort of l
a clearing house, keeping a list of all that equipment --
7 l
MR. DIRCKS:
Yes.
g l
l MR. EISENHUT:
Right now, the status of the SEP 9
plants -- now, I call them SEP plants, but we've added 10
- Indian Point and Zion to that set too -- we're reviewing both j of those together -- is that we've done a preliminary site 1
i review of really Palisades and Oyster Creek.
Because of 13 the results we were finding, I asked a team to go out for a very preliminary evaluation of Indian Point and Zion.
13 j
Although --
t CHAIRMAN AHEARNE:
Are you going to discuss the results?
i MR. EISENHUT:
Yes, I will.
Just a second.
19
! Although I recognized when sending them out that we were f
l still very early in the review process, they had not 21
=
gotten all their documentation together.
The basic finding !
l 3
that we've had -- found -- from those reviews is that, first,!
- 4 I think we're, running about six to eight items per plant;
- s that we've looked at the preliminary way, and those items
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! do not meet at least one of our screening guidelines, or t
they failed to meet our screening guidelines in at least 2
one aspect.
2 COMMISSIONER BRADFORD:
This is six to eight of i
4 30 or 40?
l 3
i MR. EISENHUT:
Yes.
So what we had to do --
6 CHAIRMAN AHEARNE:
How were they chosen?
7 l
\\
i MR. EISENHUT:
Completely at random, I believe.
I 3
l f
MR. BOUCHER:
Well, they weren't totally at 9
random.
Some cases they were, and other cases they I
weren't.
We looked at them and we -- we didn't want to 11 look at the same component over and over again, because --
s
,7 j
for valves in one plant and then another plant -- so that affected the sel'ction.
We tried to get a complete e
9 I
is spectrum all the way across the board.
i COMMISSIONER KENNEDY:
So that, in effect, in f
14 g-dealing with the six or eight plants, you have in fact looke I
is
! at the full range of components which you would want to I
i 19 l
look at in any given plant.
t i
1 20 MR. BOUCHER:
I couldn't give you complete assur-i 21 ance that we've looked at one of each that's going to appear i
in every plant.
But certainly that was the goal.
I think
)
i U
we've looked at pretty close to that.
1 U
MR. EISENHUT:
Which is certainly the major groupings.
But there's some in each plant of my six to
.{
as suwfie SM'PER. SfulWT. & e. Wert ter mE l
0 3
27 naz.wo.
eight where -- that's probably a rough average number.
I I
notices on Palisades we looked at probably a dozen.
But 2
I also noticed that on every plant we looked at ASCO 2
i r
1 e
CHAIRMAN AHEARNE:
That is the point that i
you're making; that you've looked at --
i MR. EISENHUT:
a wide spectrum.
7 CHA N AN AHEARNE:
-,a wide spectrum.
And all 8
i 9
l of them failed some aspect --
to l
MR. EISENHUT:
All of those have at least one l problem with our screening guideline.
That is correct.
it 12 MR. BOUCHER:
Some cases that problem is 13 relatively minor.
We wouldn't want to give the impression l that there's nothing out there that could meet the guide-la 13 lines.
In some cases the problem is relatively minor.
We l
i 14 expect that it will be resolved.
I could give you -- I could 37 put these slides up if you like, which is a summary of the I8 different components we've looked at at different plants.
I' The slide's too big, but you can see that you've got U
solenoid valves, you've got control cables, valve operators.i i
3 i
And there's duplication in some areas, in other areas there 4
i isn't.
Recombiners, I think we only looked at them at one l
t l
23 i
plant.
Switches, cables -- it's a broad spectrum of equipment 24 there at those three plants.
And then --
2 i
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28 l
o a
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I MR. EISENHUT:
Now, as you point 6ut in f Palisades, Palisades was the only plant we've done where I
2 we've done a full site visit, so the list there is somewhat i
3 longer.
It's one of the original plants that we looked at.
I Now, as we go through these, and as we identify 5
where these items come up, and where it does not meet our l
7 l
screening guidelines -- that is, the area where it's 8
either -- has a questionable deficiency, that it certainly t
9 I
i doesn't meet our guidelines in one aspect -- we have to look 10 at it from a safety determination standpoint.
So on these 11 plants on these items, when one of these arises we look at 12 it specifically on how it's used, and have to make a decision, is l
on whether or not it's important from a safety standpoint 14 that immediate action is required.
1 l'
i i
COMMISSIONER HENDRIE:
When you say some of the i
1 problems you found were not too major, I gather that some l
17 1
18 have been major.
Could you give a kind of description of kinds that were?
19 i
MR. BOUCHER:
Let's run through one example of I
g
-- a specific example of what we identified.
21 MR. EISENHUT:
We're just picking one example.
I i
We've done this approach basically on every one of these
(
24 items that we looked at in here.
It'll give you a feeling u
for how major anrexercise it really is.
i
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MR. BOUCHER:
Here's our old friend the ASCO solenoid valves, but this is a different twist on the 2
story.
The first column is a list of deviations that we found from the guidelines.
We regard the d;viations as fairly significant in that there's no test data at all I
for many of;.'the areas that we believe one ought to consider. j l
And further, if you do a materials analysis, you find I
7 i
i g
that the component.does in fact.have materials that you 9
l wouldn't want in a nuclear application inside containment.
10 So our judgment is that the thing just plain isn't qualified.
11 At the plant, when we identified that for the licensee,
\\
12 we told him that our judgment is that it isn't qualified.
13 And he said, well, that's our judgment too.
And we're i
14 going to replace it before we restart.
i 13 So that's a nice neat clean one there.
t id CHAIRMAN AHEARNE:
Well now, the model that 17 he's replacing it with --
l II l
MR. BOUCHER:
That's what I want to speak to l
I I'
next.
So that was our next question.
We said, well gee,
.U we'd like to see what you're going to replace it with.
How l
21 l
i good is that?
We know what you've got is not particularly
~
comforting, but let's see what we're going to get.
So j
n this is what we got.
This was a little bit disturbing to 24 us.
Right there.
And the disturbing fact is that the 2
i l6M YMN
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l licensee didn't have any qualification data for that I
i component, but he was able to identify it.
Well, it turns i
! out that I recognized that component, and many of our I
3
- participants on the Staff team did recognize it as one 4
i
- that had been qualified in another application.
So we 3
l
~ believe that the component is, in fact, qualified, and our estimate of the impact on the overall plant safety 7
l! is that there's no immediate impact; because it's our s
i l judgment that it is qualified, but that we still believe 9
that licensee ought to go out and get that data and sit down to and study it and see that he agreed with our conclusion on 11 a plant specific application. Maybe he has some twist to
(
his plant that validates that conclusion.
n l
l MR. EISENHUT:
Ycu know, he could conceivably la i
-- the component could have been qualified for one l'
i environment, and his environment could be harsher.
WE looked 14 i
t at it -- this is a case which we'll come back to in a i
17 I
little bit, because it's an example where the Staff knows i
the component's been qualified elsewhere.
That information g
t
.g has been propriatary, so it's been tucked away somewhere.
l 21 This licensee didn't know it, but this licensee comes before us and says that he's not sure this component's i
2 qualified.
- 4 COMMISSIONER BRADFORD:
Why is the fact that a 2
piece of equipment is qualified propriatary?
larTWumaftenne. '/Ignesftes NEPeurfWEE IMIL as sm, rte CapM4n. frIBWT. E e. marft ter I
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I, MR. EISENHUT:
Very simple.
Because money is I
i the reason.
It costs money to qualify it, because the only 7
way to qualify is to test it.
So if you had a nuclear 3
l plant, and wanted to go out and have ten new components you A
! wanted to put in, and you had to hire someone to run a test, 3
and pay $1 million, let us say, to run those tests, you 6
l want to keep that information on the hopes that you can sell 7
it back and recoup your money.
It's a very simple financial 3
incentive.
CHAIRMAN AHEARNE:
In other words, the company io
! who makes the component doesn't --
11 MR. EISENHUT:
It's a spectrum.
Some I think i
i 12 have.
i 13 i
l MR. BOUCHER:
In some cases the company who makes 14 l
the component pays for the test, and in some cases the 13 licensee does.
And they all have paid money for this 14
'I qualification, and they hold it propriatary.
We -- in i
17 fact, this is a bit of a problem between the utilities.
Is t We received a freedom of information request from one group 19
)
of utilities trying to get us to force the other group of j
20 j
utilities to release the information, which puts us in a very uncomfortable position.
And we have attained some i
y
'I information on a propriatary basis also.
It's a problem in g
the industry right now.
3 2
COMMISSIONER BRADFORD:
What is the component in
v me -wa
as an, rte CusT4n. #TisW'r. E e. Sufft ISP 8
_ _ e, & & mm
(
4 0
32 l
usa.ye l
l manufacturer doing while all this is going on?
If I I
l j manufactured solenoid valves, and knew them to be qualified,
- I would, far from having it held propriatary, I would start 2
running it in my advertisements.
CHAIRMAN AHEARNE:
But you can't.
You need it for the qualification.
You can't do that.
j i
i COMMISSIONER BRADFORD:
I wondered about that.
7 COMMISSIONER HENDRIE:. If the valve manufacturers g
9 run the qualification, then you typically don't have thit to l
kind of problem, because the utilities that bought the i
valves from him says, hey there, valve maker, are my I
12 valves good?
The guy says, sure they're good.
Let me l
13 j
show you -- give you a copy of the data sheets.
Or it's l
14 i
worse, the valve maker will say to the utility, look, i
i 13 you didn't buy those on the basis that you wanted data l
t i
i I4 sheets, and'I want another $2 nd a half per valve to W
l send you copies of data shec.s, but at least they're I8 availab1e.
The pinch is where utility A needs the infor-t I'
mation.
The valve maker doesn't have it.
Utility B or 20 i
somebody else has done the test.
They've spent money as 21 i
related here on it.
They'd like to sell that information I
i
~
l to utility A or the valve maker and recover some of their l
2 costs.
24 COMMISSIONER BRADFORD:
And it's basically those l
l I
lasTWieneftElsene. ',guesfits h IM".
l aus WIWThe CAAp4n. ST45WF. & e. Saf?S !st 8
_A&M
33 O
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test results that are at issue.
i l
I MR. HENDRIE:
Yes.
Verified copies of the test 2
data are typically the hard nut information that stand i
3 l
behind a qualification. Or similarly, if there are analytical results that come along, why, the copies of 3
that.
i 6
l CHAIRMAN AHEARNE:
Is this significant problem or an irritation?
I l
MR. EISENHUT:
I think it's got the potential 9
to be a significant problem.
I think -- from two aspects --
10 COMMISSIONER HENDRIE:
And we've had it before.
11 l
I can remember in a few densification days, where the Staff l
(
12 is sitting at the middle and getting propriatary informa-13 i
tion on this fuel manufacturing processes, and how it 14 i
I all turns out from five or six people.
And here comes a l
15 I
i poor plant operator.
We say, you've got a fuel densification 14 17 l
18 l
i 19 l
i 20 21 k
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I COMM. HENDRIE:
Because of information we've 2/1 gotten from somebody else on a proprietary basis that is 2
fuel is, you know, maybe it's fine.
But he can't show that 4
because he can't get that data.
And there were some con-r I
siderable agonies there and -- and --
4 COMM. BRADFORD:
Is it that he can't get it, or f
I is it that he can't 'et it without paying for it?
g S
I COMM. HENDRIE:
In those cases -- in most of 9
j those cases it was he couldn't get it because these people 10 were, you know, they're life-and-death competitors for that 11 fuel business.
And Westinghouse is not about to supply 12 information that will let GE's fuel pass muster.
12 l
l MR. EISENHUT:
The problem is even worse than 14 I
that because the second guy may not even know that the l
component was ever qualified.
He may not even know that 14 the information does exist.
Because its existence by itself 3
I,<
l is in fact --
l 18 i
i MR. DIRCKS:
I think you're going.to --
g MR. EISENHUT:
-- means it's either qualified.
i
.O l
you're going to touch on some MR. DIRCKS:
21 i
22 of this on recommendations at the end; maybe a clearinghousej i
22 or maybe hear something for the industry to pickup --
i l
24 MR. EISENHUT:
Yes.
sort of the -- the punch line there, 13 MR. DIRCKS:
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MR. EISENHUT:
Yes.
Maybe we can just cover l
I it now since we're 90 percent of the way done.
I think it gets down to the basic question, 4
one of the things that we see as a problem, and a major 2
problem,is this proprietary information aspects.
From 6
~
i two basic aspects; one is, it helps us make a safety 7
l decision if we know that information.
In this case the 3
team of people has been working on it for a couple years 9
and they certainly are familiar with this.
And the other to l
thing is, our team of people that's assisting the staff 11 i under contract comes from Franklin Research Institute.
(
Franklin happens to be one of the big qualifiers of 13 i
l electrical equipment.
i i
So, it helps us make safety decisions.
It also g
can help us avoid an unnecessary plant shutdown, both for --i g
37, whether we would require it or whether the utilities tg themselves would be shuting the plant down.
19 MR. DENTON:
You mean the availability of a l
I 20 data base would.
21 MR. EISENHUT:
The availability, that's correct.
i 22 MR. BOUCHER:
And let's say that -- that part of la it does exist.
We had in fact pooled all the major -- well, 2A the two major testing labs, and they provided information 2
to us under proprietary agreement for us to use in making in
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the short-term safety decisions, but we have no right to l
I 2
! release it to other people.
2 j
COMM. BRADFORD:
Who are those two labs?-
4 MR. BOUCHER:
Wiley Labs and Franklin.
Under 3
l subcontract to noe of the national labs.
i, i
6 MR. EISENHUT:
So, the way it can really help j
I l our terms is it really helps our people doing this effort l
5
- by giving them a better understanding of the types and kinds i
of things that are qualified.
You really can't look to component by component.
It just gives you a better back-11 i
ground knowledge of the general nature of what will survive la i
an environment and what will not survive an environment.
I l
13 f
COMM. HENDRIE:
Well, it's a very considerable is l
help to the exercise of your engineering judgment on 12 s
whether a particular component for which there is not a 14 clean and -- and verified pedigree is in fact in the real 17 l
world servicable if something happens.
That's often the is l
case.
If you don't have the pedrigee, but the instrument 19 l
turns out to be all right.
And having a body of test 20 data on all kinds of things as background for your judg-21 i
ment of a particular component is a lot better than just l
i sort of squinting at the ceiling and --
23 MR. EISENHUT:
It certainly helps with the process.
,a s
MR. HENDRIE:
-- and making a guess.
j
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l MR. DENTON:
It seems to me a case where the 2
economic back and forth were disincentives to a -- a l
3 I
safety and -- or an administrative -- a convenient
- administrative process.
3 COMM. BRADFORD:
I can see how this problem i
0 would arise frequently with regard to the pre-1971 standard 7
material; that is, the -- where the only requirement was S
l that 'it be of high industrial quality.
i 9
But for equipment that was supposed to be quali-10 i
fled at least to the '71 standard, is there -- is there not 11 l
even supposed to be assurance supplied from the manu-i 12 facturer to the utility which would be available to us, 13 1
I that in fact this equipment did meet the '71 standards?
14 i
i i
MR. DENTON:
What you're saying would certainly i
t.!
i follow, except I think it's 58 of the operating plants do to not have to meet the --
17 COMM. BRADFORD:
The '7 -- even the '71 standard.
MR. DENTON:
'71.
So, you can see the magni-19 I
l tude of the problem we have is not -- it's not --
.O l
COMM. BRADFORD:
Yes.
1 4
l MR. DENTON:
'67.
~,
i 2
CHAIRMAN AHEARNE:
Very small --
24 COMM. HENDRIE:
You have to realize that the '71 i
u standard is, you know, was adopted in '71.
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COMM. BRADFORD:
For plants which --
I COMM. HENDRIE:
And you ask now which plants I
would have in their designs then specified the '71 standard i
4 as the basis for equipment purchase?
Typically those will 3
be plants which have not filed -- gotten as far as filing 6
a CP application by '71.
So, maybe plants that are I
j violating itin '72 have now picked it up.
But earlier --
I I
f but you know there aren't that any plants that had --
in '72.
10 i
MR. BOUCHER:
That was a trial U-standard 11 also.
People who tend to lose track of it.
That was I
12 l
not issued as an official Triple A standard.
It was 13 trial use.
The official standard was the '74 versions.
i 14 i
l So, there was a
.,,a1 use period in there.
So, the staff 12
- was a little bit uncomfortable with applying it as a to licensing requirement.
The utilities were uncomfortable 17 with embracing it.
It just took some time to get comfort-able with it.
19 A VOICE:
I think what they're --
l 1
i COMM. HENDRIE:
I don't know that we 're comfortable g
with the '74 standard; are we?
i 7
MR. BOUCHER:
Certainly more comfortable than 3
l l
24 we were with the '71 I think.
~
COMM. HENDRIE :
Well, it's a higher standard, but n
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ltherearetheseargumentsaboutwhetherit'sdurable 2
' in all respect.
3 A VOICE:
I think that's right.
4 f
MR. DIRCKS:
I think what you' re talking about e*
here, and we 've talked about, is some sort of a clearing-i g
house, whether the industry could get together and do it.
I 7
It would be tremendously advantageous for an industry group tp I
l have this sort of thing because they are the major bene-9 i
ficiaries and would be the users and at least know what 10 equipment is qualified and what could -- could they use --
11 lead off.
12 f'
MR. EISENHUT:
That's right.
l 13 i
i As Bill mentioned, on the short term what we're 14 I
i trying to do is we have-- we're having our own computer l'
listing that I&E's putting together, keeping track on 14 all the equipment that comes out qualified.
On the longer 1,
term we're going to be looking at it as it's principally 3,
l a burden on the industry.
The industry should be the one 3,
i doing this.
And it's one of our other items in a moment 20 l
i 21 l
we'll mention.
We'll just touch upon it now.
And that is, i
the industry is just going to have to pay more attention l
n to environmental qualification.
They're going to have to i
l i
i 24 put more attention on it both plant by plant, and plant f
specific evaluations, and they're going to have to think i
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2/7 I
2 You can't keep going on with this item by item 2
l by item year af ter year af ter year.
And we're going to l
- be looking at ways --looking to ways to get that message clearly to -- to the industry.
i n
i i
CHAIRMAN AHEARNE:
Now, you're not going to skip 7
over, I trust, your --
3 I
l MR. EISENHUT:
No, I.'m not.
7 i
CHAIRMAN AHEARNE:
-- assessment of base for I
to continued operation.
11 MR. EISENHUT:
The basis for continued operation --
12 let's put it up.
We give you an idea on -- on an ASCO 13 l
l solenoid.
14 l
CHAIRMAN AHEARNE:
I gather you're jumping ahead i
12 i
when -- do you have a summary of deviations and the guide-I4 lines?
17 l
MR. EISENHUT:
Yes.
13 I
CHAIRMAN AHEARNE:
I gather you're -- that --
19 i
from that you're seeing a variety of problems that aren't
,0 4
just that.
i 21 MR. BOUCHER:
Well, I guess when one makes the j
g i
23 statement that we haven't found any equipment that meets 24 all the guidelines, it's clear that we've found at least i
23 some equinment that just about every piece of the guidelines
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2 I think they breakdown into these probably four 2
i i major categories--certainly it should be no mystery that 4
' there was an aging consideration given in these early plants.
And that --
6 I
COMM. BRADFORD:
Because it wasn't a requirement.
7 MR. BOUCHER:
It wasn't a requirement.
s I
l There are a couple of things that are a little 9
bit surprising, and is that -- that is that the component i
10 I
installed in the plant, it -- it's not surprising that it's g
not identical to the component that, perhaps, was tested g.,
\\
i and -- and cited as a basis for qualifying -- for qualifica-33 tion.
But it is a little bit surprising that in many g
i i
33 cases it is not even very close.
So, that's a significant l
i y
aspect.
l i
17 And the guidelines require that if you're going is to rely on similarity it has to be very sLmilar.
i 19 l
COMM. BRADFORD:
Well, let me ask a little bit 20 more about that.
21 That means that if the paper describing the 22 plant shows that Brand A is in place, you -- and then you i
I3 went and looked you might actually find Brand X?
j
?
t MR. BOUCRER:
Yes.
s COMM: BRADFORD:
Is that not a violation of
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I MR. BOUCHER:
What the -- the paper -- let me 2
put in the perspective which the papers cite it, i
4 The paper is cited as a test which demonstrates 3
by similarities that the component as installed in the i
0
, plant is qualified.
And what we would expect to find, 7
j and this is the licensee's judgment, that it is similar I
3 enough to demonstrate that the qual -- that the component 9
I have in my plant is qualified.
Well, what we find is 10 there's a large disparity between the licensee's judgment as to what is similar enough and what we would regard as 12
(
being similar enough.
And we find that in years -- in l
is i
l recent years the staff's view of similarity has declined 14 i
as a valid qualification tool.
13 Does that clarify the --
14 MR. DENTON:
I don't think it's -- I think 17 you need to separate misrepresentation of parts in --
18 MR. BOUCHER:
That's right.
I don't think --
19 the plant from --
MR. DENTON:
,40 MR. BOUCHER:
No.
21 from is a technical opinion j
MR. DENTON:.
thatacertaintestappliestowhat'sintheplantandour--l 7
I
- 4 MR. BOUCHER
That's right.
i 3
MR. DENTON:
-- judgment that it's not close enough i
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l MR. DIRCKS:
Well, I think that's getting back 2
i to the issue we had before about the enforcability of the 4
j thing.
We're going through in almost now and saying if you have component X, Model so and so, Serial Number such 6
i
- and such you're qualified.
And the question is once we've 7
l gone through this exercise how do you lock it u p and prevent 3
I substitutions from going in and out.
And I think that's 7
the point that you want to talk about in a few minutes.
I 10 j
l Is that right, or do you at least raise that as 11 i
an issue or once you go through this horrible, agonizing
(
II i
exercise and you determine that that plant is qualified, j
can you end the process then until you're qualified with i
these components?
And then two weeks later what you don't l
want is a component being pulled out and another model 94 97, being thrown in there.
COMM. BRADFORD:
Yes.
I would guess that cer-
- g i
pp tainly you don't want that, but that's also likely to be i
- g a little less of a problem than the situation, perhaps, 21 when the plant is being built and it just isn't convenient I2 to install what you thought you were going to install, so I
22 you put something else in I4 MR. DIRCKS:
Well, I suppose what's being built l
1
~J now then if you -- if you could determine -- you say you put-inrussianmun.Vemmanu meneewn lac.
l as sen,no enauT4a. FruMF. L s. marTT 18F l
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44 casa sa 1
I qualifying equipment in and -- and you'd -- they'd have 2/12 l
a pretty good idea of what's qualified and what's not on 2
i 3
I it.
COMM. BRADFORD:
But I'm looking at the plants t
l that are already out there.
Certainly if you get down to I
the level of specificity which I gather you'd -- there 0
are a lot of cases you don' t have where they actually --
7 a portion of"the serial number of the piece of equipment,
~
and it turns out to be completely different.
Then, you're 9
j not talking about similarities, you're talking about an 10 error or a deviation of a different sort.
I 11 i
But if you just talking about the Brand A versus
(
12 Brand X, are you saying that if the licensee had said that 13 Brand A was going to be in there and Brand A was qualified, 14 it would be enough to -- for them to say in their judg-I 13 ment that the qualification testing done for a component 14 i
l made by one manufacturer could be carried over to a --
17 j
to a different component made by -- or to the same compo-i 18 l
l nent made by another manufacturer using -- it -
19 MR. DENTON:
Maybe what we'll have to --
20 COMM. BRADFORD:
Maybe I'm misunderstanding the 21 qualification process, but some how that seems like quite 22 i
a jump.
23 MR. BOUCEER:
Let's take an example like cable.
2A i
A poly -- a significant feature of a cable is its l
2 i
l l
imum m ven.ma awaerem :=
as some summ. sriseur. s, s. marft ter l
_. s e mm
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/13 ir aulation system.
And maybe DuPont provides polyethylene 2
i insulation to several different cable manufacturers.
I 3
don't know that to be a fact.
I don't know whether poly-4 ethyelene's DuPont's trading name or not.
I I
But in any case a polyethylene insulation on 6
one cable has the same resistance to radiation as it does 7
l on another cable, and if it is relatively the same thick-8 l
ness of insulation, which it is likely to be, because 9
of the international cable standards on -- on what to
. insulation is required for a given voltage level; you can 11 l
extrapolate from a test en one polyethylene insulation k.
12 l
system to give you some information, some judgment 13 I
I material, the data to use for another piece of cable by 14 a dif ferent manuf acturer with the same insulation.
15 f
The things that are a bit different --the things 16 l
that give us trouble are cases where a licensee cites 17 l
a qualification test report for a valve operator that is I
la done with one manufactrer's motor as the driving force 19 to attempt to justify qualification for a similar j
20 operator -- valve operator, but with a different motor 21 l
l in it because the insulation system's from one motor 22 to the other might be different and the materials might 23 l
be different.
And we believe it's possible to get some l
24 useful information in that kind of extrapolation.
But it's i-= v m i, as amarw s.mm. erwarr. s m,r =
_. _ s t==
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i necessary to examine in great detail the similarities and 2
the dissimilarities.
And we find that that hasn't been I
3 done yet in these cases.
And we're a bit surprised that f
when one attempts to use the similarity argument that he A
3 doesn't have right behind it a detailed analysis that i
4 supports that similarity or --
I I
l MR.' EISENHUT:
In fact, just to give you an idea 8
of how real a problem we had on the polyethylene cables 9
last year was we had one where it was a cross-length to polyethylene which is a little different structure II than another one.
And in fact they behaved differently.
j k
12 One turned out to be qualified and another one i
13 replace the cable.
la l
l So, it's the -- you've really got to look at it I
in a lot of detail.
But, yes, there's certainly room to 14 make engineering judgment materials compressant from
- 7, I
one component to another component.
la l
j In fact, that's part of your bases by -- I 19 j
think even in fact our requirements state the --
20 l
MR. BOUCHER:
The guidelines permit similarity 21 l
l arguments as long as they're done in sufficient detail l
22 l
that permits test or --
23 MR. EISENHUT:
That permits test or --
24 i
and so does I-Triple E Standard l
MR.BOUCHER:
l 25 l
l t
Iswsumafissena.Venanfies musarrent Iser.
as sumarse ometen. srnurr, s. e. surre re, T
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t 2/15 permit similarity.
2 COMM. BRADFORD:
It's a lot of theory.
I'd 3
want to see extended operator training and licenseeing.
4 These two gentlemen went to the same school, one passed, i
i 3
i t
one didn't.
I 6
MR. DENTON:
They have to be out of the same mold.
l 7
I l
MR. EISENHUT:
So, you caal see these are the i
S l
other kinds of considerations.
I don't know how much 9
you want to go through these.
Aging considertions, of to course, they wouldn't have.
11 Test sequence may not be quite along the same
(
l t
(_
12 lines that you'd expect and inadequated documentation.
13 It's fair to say also,even though not on here, 14 l
there is a number of columns we found case-by-case, 13 for example, insulation problems.
But insulation problems 14 l
are really not a problem that we're looking at here.
17 l
It's coincidental that we ran into them.
I8 i
l MR. BOUCHER:
Did you say " installation" or 19 l
1
" insulation."
20 MR. EISENHUT:
Installation.
21 l
I MR. DENTON:
If you find a couple that are n
i installed differently than in the plant than the way it 23 was tested, and that installation gives one question 24 about the validity of the test.
l 13 l
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COMM. BRADFORD:
Well, couldn't it be worse f
2 than that?
I mean, suppose it wasn't properly installed 3
but it only works if it has --
4 MR. EISENHUT:
Certainly.
That's right.
l f
There could be a box that wasn't sealed up properly, 3
i 0
i therefore it's deficient.in
-- that's right.
So, it I
would be quite major insulation deficiency.
3 The general ' conclusion..was that most equipment failed to meet at least one aspect of our guidelines.
10 But we went through it just as we showed you on Palasades 11 1
the component we went through.
We have gone through k
12 I
item by item where we have deficiencies, and we have 13 concluded that no immediate plant : shutdowns are required 14 I
for different kinds of reasons in each case.
- Although, t~e l
j we feel that we ought to continue with a high priority i
14 effort to get the issue resolved.
17 CHAIRMAN AHEARNE:
Now, in that case, just as 18 you have pointed out that one of the problems you found 19 with the licensees was documentation, if one were to ask l
2e take a particular plant that you've gone through, have 21 l
l you documented here the weaknesses you've found and here 22 are the reasons why it's adequate to continue --
23 I
MR. EISENHUT:
Well, we haven't progressed far 24 enough to -- for it to be done, Even Palis. des we're not j
2
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49 caos so.
I j
complete.
We're just past the first step.
Palisades 2
i j
review is going to run for a couple of months.
At the end of that review you will have a documentation of --
4 i
l CHAIRMAN AHEARNE:
Well, now, my point is that you 5
just said that you went through item by item and reached 6
l the conclusion that no immediate plant shutdown required, 7
et cetera.
And --
8 MR. EISENHUT:
How did we document that?
9 CHAIRMAN AHEARNE:
Yes.
Answer that question.
i 10 MR. EISENHUT:
I guess it's a varying degree.
11 i
l MR. BOUCHER:
It is a varying degree, and we
(
12 haven't done it in the same sense that we've written SER 13 for each of these plants, and the SER writing process is 14 at the very end of this trail that we've gone through.
Is t
l And in order to make a safety judgment you can see that you 14 have -- there's an. awful lot that goes into one of these 17 j
judgments.
That's the bottom line so to speak.
MR. EISENHUT:
No, it varies from case to case.
19 I
l CHAIRMAN AHEARNE:
I wasn't saying necessarily 20 that a formal product to put into a formal system, I'm 21 l
j just asking --
22 l
I MR. EISENHUT:
It varies from case to case.and 23 f
generally not.
For example, we probably would not have I
I written down the Palisades' items so explicitly if we l
25 i
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hadn't gone through some of the --
2 t
CHAIRMAN AHEARNE:
Put it on a slide, i
3 MR. EISENHUT:
-- put it on a slide.
Because 4
it's just not really profitable on these kinds of items.
I l
It takes a considerable period -- amount of item and 6
l staff resource's to go through and write down each item.
7 i
When you're dealing -- on Palisades it was twelve to S
l fifteen items alone.
9 CHAIRMAN AHEARNE:
Did any items reach the level 10 l
of threshold significance that you required them to make 11 1,
('
j an immediate change?
12 i
i MR. BOUCHER:
Immediate changes?
13 MR. EISENHUT:
I could probably tell what la a
these are.
15 MR. BOUCHER:
There were some items.
We were 14 I
particularly troubled with these solenoid valves again, i
17 j
and we've made some changes on that.
And there was a case.
In some cases there have been procedural changes l
to where there's not as much reliance on that component 20 i
as there was.
The operators have been instructed about the questionable intelligence they might get from a given i
instruments, and they are instructed to check other instru-23 I
l ments.
3 3
There have been some immediate reactions in many l
in nen ven.nu me wom sac i
unen. came. sr==r. s. n. new ie
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- l 51 n
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I j
cases.
Most of the time the licensee present this to us 2
i l
j when we arrive.
In other words, he's already judged that I
something more needs to be done in this area.
Certainly a
l before we leave we come to agreements like that.
s CHAIRMAN AHEARNE:
Do you write down those i
6 agreements?
I 7
i MR. BOUCHER:
There are trip reports that are l
prepared that we get requests for additional information 9
from our contractor. fit's just not organized in te same 10 l
I j
way that an SER is.
If I was --
there is though.
I 11 i
MR. DENTON.
But it will all be by the end
'/
12 j
of the process. 'In other words it's a -- I think 13 partially the f act that it's ongoing in some area.
14 CHAIRMAN AHEARNE:
This is probably a dumb 15 question.
If it's going to be written down at the end 14 1
I of the process, how do you recall over this period of 17 a year what was agreed to back at the beginning of the la l
year if you haven't documented it?
19 l
A VOICE:
It's not a dumb question.
In fact, 20 l
it's a good question.
21 I
i MR. BOUCHER:
The question is it's written 22 down, but it's not published.
And certainly it's written i
23 down in our review process.
Our contractor keeps brief l
24 j
i logs of --
23 l
larruunamanna.Vessesme Reperfem 18edL aus summe e.aarren, sfusesr. t n. surrs ter c_ s s==
52 Q
O l
TAGE No.
i i
I l
MR. DENTON:
Logs and so forth.
2 MR. EISENHUT:
At this point, what we'd like to i
3 I
l do since I&E is doing a considerable number of these reviews 4
1 l
also in a slightly different -- using the same guidelines 5
I in a slightly different fashion.
Ed Jord.an will sort of 4
j summarize what I&E has done before we come back -- we'll i
7 l
come back to the last line.
8 MR. JORDAN:
We've gone over some of these in 9
the processes discussion.
What I would like to focus on i
10 I think is the very bottom section where the revised 11 bulletin was issued.
The lessons that we learned in k
12 I
the previous bulletin were that we had to make our ques-13 l
tions very clear.to the licensees.
We had to do a little 14 i
,i more in the way of explaining what it is we needed.
The is bulletin that we issued was much more detailed than the
!d t
earlier. bulletin.
We asked for the information in a 17 specific format.
We provided examples of the typess of 18 l
i l
data that we needed and the way in which we wanted that
{
II l
l
- data, j
20 Then, the task group members provided a work-21 i
shop meeting in each of the regional offices for all of 22 l
l the licensees who were ' included in this review process 23 j
during February, subsequent to their receipt of the bulletin.
24 l
l s
l And then based on the issues that were identified l i
larvWunaftsunaa.Veumarine Rupeurrena Isac me sawTte sammen, arisser. t w. masvu ter
- _ a c amm
I
'2
'l i
- aas so.
~
53' I
l during those meetings, we provided a -- a set of supplemental 2
information to those licensees, answers to the principal i
3 l
questions that they raised during that meeting.
CHAIRMAN AHEARNE:
When you say all the licensees that wera covered, that -- is --
I 0
MR. JORDON:
The 52 operating licensees.
7 The specific things that the revised bulletin 8
required were in two sets of information.
The first 9
i set, or the first three items, their response was requesting to 45 days from the bulletin issuance which occurred the last 11 l
of February, and we wanted a master list of the, first 12 l
of all, the systems and then the components within each 13 l
of the systems that are relied on to mitigate design la i
basis events.
And this is for LOCA hydrogen line break 15 I
and both inside and outside containment environments.
16 We requested them to provide written evidence of 17 l
the qualifications of these components and service profiles la l
based on the FSAR design.
And I'll explain where we are 19 i
as far as those responses are in a moment.
20 Then, the second set of data is the 90-day l
21 l
response, which is presently due.
And we requested the 22 l
i licensees to review their components against the 23 DOR guidelines that were provided to the licensees and 24 i
against the new Reg 0588 to evaluate the maximum flood y
in ri v
=am ie wmm. wasse. s.
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l 54 Q
9 i
CASE No.
~
I level, which is one of the parameters in the DOR guidelines.
l
,! And reminded them that any equipment that was inoperable 2
i 2
l should be reported as an LER.
4 And this bulletin went out as a 50.54F type i
,f bulletin so that the responses were under oath or affirma-3 4
tion compared to the normal bulletins which had not been I
in the past.
8 Now, the -- I mentioned that we had set up a task group to do this work.
I realize this isn't the 10 Academy Awards, but they get very little glory for the II amount of work they're putting in.
Vince Thomas of my
(-
12 l
staff and Al Bennett are the headquarters representatives.
And they're both sitting behind here.
i Al Phinkle from Region 1, Ray Hardwick from 13 l
Region 2, Jack Hughes from Region 3, Dan Mcdonald from l
14 i
Region 4, and John Eland from Region 5 have been the 17 i
l principal reviewers through this process.
And they contributed la to developing the revised bulletin, to the inspection pro-19 cedures for performance of this task.
20 l
We broke the task down into some five increments I
21 l
for scheduling to have milestones that we could work with.
22 I
And we're now into the task -- combined task two and three, 22 l
and those have sort of merged now.
And that merging was 24 i
based on the licensee's responses in some cases merging l
15 i.
twnsensmanne,Veseams Ruperrent lac
-- : _ _, & c em
l
.55 i
l as well.
Some licensees have requested delays because of l
l other work and because of their plant status and -- and so 3
we are in the process of both Tasks two and three doing 4
i j
inspections at plants based on their status.
All of the 5
refueling plants, of course, get first priority.
So, 1
6 that's where the inspection effort has been initiated thus 7
far.
8 The 45-day responses have been screened and 9
I this is to ascertain the state of the licensees responses 10 and whether he understands fully what we are looking for and 11 i
is responding in an adequate fashion.
I(/
12 I
And then we're beginning to get the 90-day 13 responses.
As I;have said, those are due right now.
14 Projecting, we anticipate being able to complete is l
the evaluatian of the responses and the major part of the
!d I
l inspections by September -- the end of September.
And in 17 l
conjunction with the schedule that licenseing has 18 identified earlier, we anticipate being complete down to 19 l
a reasonably low level with the reviews and identifications 20 j
of discrepancies by the end of December.
21 We did make a projection in terms of followup Z
l i
of implementation.
And our basis for it was that the 23 l
l procurement time and going through at least one refueling 24 cycle at plants to allow replacement of marginal components. l
,J terruunafManas.Veseaffas Atreurfunt 18ec i
aEG M CapvTW, STWWF. L sr. mMTT TGF l
_ - 8. 4. m
~
l 56 4
0 C ASE NO.
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l I
So, that would run a total of some 29 months l
2 from the first of this year.
3 CHAIRMAN AHEARNE:
Ed, your estimate of how l
i 4
i long it's going to take for Task 3, you haven't yet really I
3 i
got the 90-day responses in?
4 MR. JORDAN:
That's correct.
But we've begun 7
doing the ins'pections because of plant status which contribute to the completing of those reviews.
So, we're --
9 and I'll describe in a little more detail what those 10 inspections consist of.
11 CHAIRMAN AHEARNE:
Do you think that's a 12 realistic estimate when you'll be completed with the 90-13 day response?
14 MR. JORDAN:
We will have worked through most 13 of the licensees by then.
Some of them because of the 16 date of their responses will spill over into this latter 17 phase.
But it's a phase effort and -- so we will have 18 narrowed down the total effort by that time to relatively 19 few licensees.
20 To date some 12 facilities have been inspected 21 and the -- the object primarily is to have performed an 22 l
l audit of at least one safe-celated system, and this is Z3
(,
a hand-over-hand review.
Perhaps. I shouldn't call it
,4 s
l an audit because it's a --
23 Infammanomas.Venenme Muromfant leer.
i as smurte cameren, stuurr. t e. ms,ru is, l
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i I
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1, r:msa No.
j l
I l
CHAIRMAN AHERNE:
What is a hand-over-hand?
i 2
MR. JORDAN:
I say hand-over-hand because the 3
inspectors are in the containment envircnment, and they're i
i i
crawling through that system examining the cables, taking
=
l the descriptions from the cables and components directly.
i 6
So, that becomes a part of their data base for reviews of I
I l
the licensees' submittal subsequently.
So, in many cases I
a we're looking at the components before we receive the licensee's submittal.
We'll compare our findings with i
what the licensee submits.
If, for instance, his sub-10 t
11 i
mittal is quite representative and our findings sub-i 12 stantiate it, then we would not have to do more inspection i
13 l
i effort of the actual components of the plant.
Otherwise l
14 i
l we would have to go back in and do more work, and force If l
him to do additional work.
14 l
CHAIRMAN AHEARNE: Now, you say you audit one i
I l'7 plant's system, that's --
i l
18 i
MR. JORDAN:
And the object is to rotate systems l
l 19 l
through the variety of plants.so we have covered the 20 entire plant.
21 CHAIRMAN AHEARNE:
Any -- any plant system would f
l I2 i
have many components.
23 I
MR. JORDAN:
That's correct.
So, we would be
('~
I 24 looking at 15 or 30 components, depending on systems.
i 15 i
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I j
That kind of a magnitude.
And the object is to get 2
physically into the right plant area for that system.
i l
And this also causes delays in the inplant part of the 4
inspection because we are not going to require shutdown i
l 4
l for the inspection.
We're phasing with their outages.
CHAIRMAN AHEARNE:
Now, what do you mean "one I
7 l
unqualified limit switch"?
i a
liR. JORDAN:
Okay.
The inspector in, let's 9
i say, crawling through the plant found the limit switch io on a main steam ostellation valve that was unqualified 11 and brought it to the licensee's attention.
i 12 CEAIRMAN AHEARNE:
But are you saying that in i
n 13 i
l all of these facilities that's the only thing, or is 14 l
that a example of the kinds of things --
13 MR. JORDAN:
That's the only thing that was to j
specifically found that was immediately obvious.
And i
17 so what we have now is a data bank from these plants that la I
will compare with the licensee's qualification data 19 i
and with his findings.
20 So, this was a limit switch that was known from 21 l
i previous work to be unqualified.
j 22 j
MR. THOMAS:
Similar to the Haskell valve situa-El I
tion.
24 COMM. BRADFORD:
Was known from previous work.
l 2
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me sauvee ens = Ten, senerr. s, e. metre ter I
i
- n e
59 csas na.
l i
It had been tested elsewhere and --
2 MR. JORDAN:
Yes.
Yes, we had -- we had issued l
3 l
other bulletins and other activities that identified that 4
this particular switch is not correct?
3 l
CHAIRMAN AHEARNE:
But I gathered that in this 4
l particular inspection that it was more a data gathering 7
than an actual comparison at the time.
And this just 3
I happened to be that that particular inspector knew, or 9
that team, knew that component was not qualified?
10 MR. JORDAN:
That's correct.
II l
COMM. KENNEDY:
Did the licensee know it?
II MR. JORDAN:
When it was brought to his attention I3 he realized it.
I I#
COMM. KENNEDY:
But you said you had issued 13 I
j bulletins on the subject.
f f
MR. JORDAN:
Yes.
i l
l COMM. KENNEDY:
He didn't get one?
18 MR. JORDAN:
To go into the detail, that 19 particular licensee believed that that was a switch that I
- o l
was performing only an indication function and was not 21 l'
necessary.
We had previously conveyed to licensees that 22 l
l that indication function was necessary and should be Z!
l qualified.
So, he didn't get the message.
l 24 I
COMM. KENNEDY:
He didn't know that either.
I 23 at M S prM b #RIE T. E e. ENTEfor
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m i
COMM. BRADFORD:
Which plant was that?
2 MR. JORDAN:
What plant?
2 MR. THOMAS:
It was Hatch-2.
4 COMM. BRADFORD:
Again, my -- it's a standard l
question--at what point did something become'a violation?
l Here they've not -- not only is it unqualified but they've i
4 j
had a bulletin to the effect that this type of equipment 7
should be qualified.
Surely, it isn't a defense to say that they don't understand what the function of the limit 8
switch is?
9 MR. JORDAN:
Somehow I thought you'd ask that to question.
11 l
{
COMM. BRADFORD:
Well, what's the answer?
12 l
MR. JORDAN:
Enforcement has to be considered 13 in each of these where we -- we made a clear story to the i
14 licensees and where it is quite certain that the component 13 i
is required to be qualified.
We have not made a determinatior 16 t
i at this point on this particular instance whether enforce-17 ment action is warranted.
But it will be considered.
18
{
The inspection -- I'm not sure of the date of 19 20 the inspection, but as a part of the inspection writeup,
\\
21 that's the basis for the consideration of the enforcement action.
22 l
I 23 And understand that we are pressing very hard to t
i 1
l y'
make these trips at the plants while they're in the right 3
condition to get into them.
inv ex i
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i t
l Could I have the next one?
i 2
There's -- excuse me.
Let me switch.
There's I
2 l
one unqualified equipment reported.
I think I gave you
)
l the -- it out of sequence -- horizontal, yes.
1 3
i I mentioned earlier in discussion that there 6
were some six instances where we had come across un-I identified -- I'm sorry, unqualified equipment.
And five 8
of these are things that the licensees identified and reported as a part of the licensee event report.
And l
i 10 the sixth is one of those in the top item of valve position II indicating limit switch.
12 s
And once again, I think, as the licenseeing 13 reviews'have found, these are all types of components i
14 that have been previously identified by licensees and 1
by the commission as having qualification problems.
And i
I4 I think perhaps you -- the one that may f all out a little 17 i
1 l
different is the -- there was a motor-operated valve that 18 was a misapplication and was brought when the licensee 19 1
l found it.
It was obvious to them that there was a 1
20 problem, and he's replacing it.
21 f
i COMM. BRADFORD:
Misapplication means that 22 l
l there shouldn't have been a motor-operated valve in that --
D j
j MR. JORDAN:
No.
That the motor operator was a i
j
~ 24 x-misapplication for the environment.
So, that there was --
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A VOICE:
You mean the wrong motor?
2 MR. JORDAN:
Yes.
Used the wrong environment.
3 Should have been used -- qualified for some other environ-4 I
ment.
i 5
I CHAIRMAN AHEARNE:
Or a different way of
?,
d putting it, not qualified for environment.
7 MR. JORDAN:
Right.
Another way of putting it.
3 Okay.
Now, the screening of response.
9 t
The other part of the manpower is in the screening 10 l
of responses.
And as it was earlier indicated, the 11 I
numbers of items is very~large in terms of components
(-
12 and in the parameters associated with each component.
13 The -- to put it in general terms, the mac.ter list of la i
equipment, the licensees have generally provided.
13 l
And the biggest flaw in what they've provided thus far 14 l
is in the qualification documentation.
They were in most 17 l
cases incomplete'.
And the licensees have stated they la are still trying to dig up that material.
But certainly 19 we know that there's going to be some quantities of it l
that are not available, don't exist.
21 The licensees in some cases have anticipated 22 l
delays in the 90-day responses, which is really the 13 l
detail in their evaluations.
They are due, as I indicated l
earlier, April 13.
Presently due.
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Those that have foreseen their inability to 2
meet that date have requested in the main, delays out to 3
June.
We have some eight units that have requested 4
i j
delays until August.
And five additional units that are 3
requesting delays beyond August.
6 l
We are examining those requests on a case-by-7 l
}
case basis in terms of how much work they've actually 8
l accomplished thus far.
This is in terms of the manhours l
I 9
i of work.
10 l
CHAIRMAN AHEARNE:
In general, what are their 11 i
l reasons for the very long delays?
b 12 j
MR. JORDAN:
13 They're saying that the workloads l
that they have either because of a Fplant condition or 14 I
because of TKT related response and other bulletins that is l
are using up their manpower.
We had, for instance, la interaction of a bulletin 79.27 with this bulletin.
A 17 number of the licensees identified that as being a problem.
The same type of electrical people involved in both o 19 j
l these.
And --
20 CHAIRMAN AHEARNE:
But that intersection of 21 I
I 22 i
bulletins would occur for:many plants; wouldn't it?
l MR. JORDAN:
But may impact some licensees worse 23 i
t
(
i v 24 than others because of either common in triple S or common A&E's.
There seem to be an incredible variety of ine n
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i 1
l l
64 a
n russ so..
l 1
l stories in that respect.
2 l
CHAIRMAN AHEARNE:
Do you really mean incredible?
l I
MR. JORDAN:
- Large, s
l The -- but I wouldn't plav down the amount of 4
[
~
work that's involved.
There are many man years of effort 6
required from each licensee for each of these.
i 7
CHAIRMAN AHEARNE:
No, I wasn't questioning the g
amount of effort required.
I was just curious that there 9
were such a wide spread of ability to --
l 10 l
MR. JORDAN:
And that's why we're having to i
11 i'
look at those that are falling, certainly, outside of this June date on a case-by-case basis.
And we're planning --
13 considering when we have reached the level of, I'll say, 14 I
acceptance of their given date that we will issue a 12 confirmatory order much as we did bulletin 79.27.
So, 14 that we've locked up that time frame.
17 And I guess the last thing that I put in here 18 is something we touched on earlier, is the -- some sort of 19 l
I computer file for data.
We've tasked MPA, and they have 2o l
begun work on a computer file for data for each plant so 21 l
that we would have a listing of every system and each of I
the components and each of the qualifications for each 23 I
(.
of the components.
And the ability then to compare components,
,t a
Plant A and Plant B for the existance of the same component
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I for whether it's qualified in one as compared to the other.
2 And to be able to make searchs across and also keep track l
3 l
of the status; as of some date some total percentage of f
4 the components have been reviewed and are acceptable or 3
rejected.
And perhaps that could be a contribution to i
4 j
some sort of an industry data bank subsequent.
I f
MR.' DENTON:
The situation seems to cry out for 8
an underwriter's laboratory sort of situation within the 9
l utility system whereby they maintain lists of equipment i
10 l
which is qualified for certain types of environments and i
11 I
makes it very easy for us rather than putting the burden i
12 somehow back on us to keep the list and the acceptance.
13 CHAIRMAN AHEARNE:
True.
l 14 i
l MR. JORDAN:
And that's all I had, l
t~e MR. EISENHUT:
Just in the way of wrapping up, to I
there were several issues that we mentioned, that we would i
g, be touching upon.
I think the first is just the overall recognition that this is an important issue.
Even though 19 we've been resolving it issue by issue as we go along, I
- o l
it is an important issue that the -- both the staff is 21 l
going to have to continue work on, and in fact, the industry 22 l
is going to have expend considerable resources, l
M t
l
(
I think it's fair to say the industry over the last year, certain segmenta of the industry, have not U
i i
v
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as ag.pte C.*rfe. STUIEEF.1 e. SuffT IWF i
e L 2. mm l
a 66 n
cnas so.
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l I
progressed very fast on this is.-ne; partially, I think 2
because of even out -- the staff's own discussions of the 3
last year or so where the staff made the determination 4
that there was no immediate need.
These plants now continue i
1 5
to operate.
People are now playing those words back to I
6 us arguing that they didn't realize this was an important I
7 issue.
So, w'e will be -- or continuing the highlight the 8
fact that this is an important issue that the industry 9
I i
is going to have to work on very systematically over the l
1o j
next months and in fact few years.
11 The staff in fact has recognized the importance b
12 of this issue and has in the new NRR organization -- under 13 oux division of engineering.
That branch is going to 14 I
be responsible for doing the reviews; continuing on with 13 i
seeing that safety evaluation reports are issued.
It's 14 l
going to evaluate the many, many topical reports that are 17 i
I in.
It will interface with the division of project is management to do the interaction with the licensee, 19 sending out the requirements to the licensees, and will i
i 20 l
l be making the safety decisions concerning continued 21 l
continued operation.
i 22 i
l There's an interface, of course, with systems 23
(
considerations.
There's an interface with human factors.
24 l
The -- quite often it is not an environmental qualification i
l
(
15 l
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- 67 I
j issued by itself.
It's a safety -- overall safety aspect f
of the plant from a systems standpoint.
2 3
I&E will, of course, continue to be doing the 52 plant reviews and will be inspecting and enforcing I
the requirements that are developed.
0 Now, the last thing I am going to highlight on I
the chart is over at the right-hand side.
You will see I
8 I
a division of safety technology which is the -- I think 9
j it's been characterized as sort of the conscience of NRR.
I to It's a norm -- it's sitting normally outside of the 11 day-to-day licensing process.
They are not involved in 12 l
the day-to-day decisions.
But th,ey are the keeper of the is i
masterpiece.
I la i
l CHAIRMAN AHEARNE:
That's a new division?
15 l
MR. EISENHUT:
Yes.
14 Yes, it's Roger Mattson's division of the new 17 l
organization.
That division will be responsible for 18 l
developing new requirements.
It -- in fact, it has 19 I
l the subcase, which is the unresolved safety issue piece, 20 i; which was the source of the A-24 interim criteria document--
21 NUREG 588.
22 l
It's fair to say, I think, that for the present 23 time that effort is essentially complete.
What they will 24 j
i be doing in this area is continuing to evaluate how these l
25 1,
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68
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I interim positions are being implemented and revised and 2
l continue to develop the criteria as need be.
3 There are also the overall coordination with the standards and research.
And you'll see in a second there is a, of course, a significant piece of agency resources 6
l and research being devoted to this effort.
7 I
l And that's basically the structure. We're trying S
to have a very streamlined organization with a -- recognizing 9
the importance of the issue, we've created a, I think l
to it's equipment qualification branch, which looks at i
I 11 environment qualifications, sysmic qualification of
(
12 j
equipment, and pump and valve testing.
13 l
l CHAIRMAN AHEARNE:
So, the title environmental 14 l
i qualifications title.
13 MR. EISENHUT:
I think that's too narrow.
Id I think it's equipment qualification system.
Unless 17 it got --
18 l
CHAIRMAN AHEARNE:
Well, if you guys don't know --
19 MR. DENTON:
Well, we haven't officially named l
20 l
I them yet.
21 MR. EISENHUT:
It was supposed to have been 22 l
i equipment qualification unless we gletched to somewhere.
23 l
The --
l 24 i
i A VOICE:
The chart design in --
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1 MR. EISENHUT:
The last piece -- let's see if 2
we can burn out the bulb here.
2 The -- this is just the last slide in the l
handout.
We've touched upcn most of these with the 2
i l
exception of two.
We touched upon the need for a more 3
6 specific enforceable guidance.
And we said there the 7
possibility of a potentially a new rule.
i 8
We"re not sure it's c new rule or what form it's i
I going to take.
However, at the present time the only 30 real enforceable piece is general design criteria 4.
II And I think it's f air to say that I&E finds that obviously
(
I
you can't really enforce -- it's very difficult to tell I3 people to meet that without having some additional guidance.
14 So, one of the things we're going to be developing 13 over the next few months will be really looking at it and 14 i
deciding what form should it take?
Should it be something i
I7 l
l like the DOR guidelines?
Should it be something like 14 NUREG 5887 Should it be something like an appendix to 19 the -- appendix to Part 507 We really haven't decided, 20 i
and we're going to be looking at those various options.
21 I think the one thing we're all clear on is you i
l I2 i
need more than a GDC-4.
D i
Ith.s also fair to say that there's considerable 24 concern that maybe you just can't write very specific, j
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45 M N N. & e. SNTE tWF AALM
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definitive guidance.
And I guess I tend to agree with that.
i 2
That you're just not going to be able to write very specific i
2 i
j guidance to cover all aspects.
4 I
l However, clecly there ought to be more than --
3 I
be able to write more enforceable guidance than the three i
4 sentences in GDC-4.
l 7
I i
l So, that will be another area that we will working I'
5 on.
l 9
The last item that we have not specifically touched 10 l
upon is confirmatory research and testing.
You will recall 11 that research has laid out a program to confirm the qualifi-12 cation of components.
Over the last couple of years they i
I
'3 have developed a program --
i 14 l
CHAIRMAN AHEARNE:
Demonstrated many things, 1.5 not that.
16 i
MR. EISENHUT:
They have demonstrated many things.
17 i
They have -- is there someone from research here?
I8 Supposed to be here?
Someone from research was supposed 19 to be here to address this.
I was kind of hoping --
20 l
I CHAIRMAN AHEARNE:
It was probably decided that 21 it wasn't something --
I2 1
MR. EISENHUT:
Wasn't the appropriate meeting 22 l
(
to come to, yes.
24 I
The intent of that program was to take a piece l
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s 1
l of equipment, you will recall, that was qualified elsewhere 2
and requalify it.
Todate they have retested the connector 1
3 I
j from Brown's Ferry.
Do youremember?
I think it --
t h
1 l
CHAIRMAN AHEARNE:
The real connector.
MR. EISENHUT:
The real connector that was I
4 floating around the table here, it seems like a couple 7
of years ago, that they have in fact run a test on.
1 l
1 It's also fair to say in their defense that they i
9 i
have developed quite an elaborate experimental rig at to Sandia which will be capable of doing all kinds of good 11 tests.
And we're hopeful that we will be working with 12 l
them to layout -- to try to see if we can't layout a 13
{
very definitive program.
14 MR. DENTON:
Can you sort of as a result of 15 that test - - it met the standards.which I recall TVA 14 said it met.
l i
17 l
MR. EISENHUT:
Yes.
That's all it was really I
la tested to.
They tried to duplicate the test that TVA had 19 i
ran.
They essentially duplicated the test and the compo-to nent passed just as the test that TVA ran.
So, it confirmed 21 the TVA test.
22 COMM. BRADFORD:
I -- let's see.
It sounds as
\\
j though there's something more.
What are you not saying m
24 about the TVA test?
l IS istrumentionnai.Veename Rupturrena lac so sawm carna, svuurr. t e. surre ist
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I rwas.we.. 2 I
i MR. EISENHUT:
The TVA test was the test that I
2 was -- a test for a profile, as I recall, that was basically l
the profile that they laid out in their FASR.
3 And I I
think -- I'm not trying to say anymore about it than --
I COMM. KENNEDY:
Well, that -- let me just -- that 's i
I l
reasonable; isn't it?
t i
MR. EISENHUT:
That is reasonable.
I COMM. KENNEDY:
Yes.
MR. EISENHUT:
Except you have to ask yourself 10 how reasonable it is because a lot of the older applica-i l
11 tions did not really layout the right kind of profile
(-
12 you would want today.
13 UR'...DENTON: I:
But I think the right answer --
14 l
l COMM. KENNEDY:
But that's a different question.
13 I
MR. DENTON:
It's unanswered whether it meets id i
I the '74 standard, for example.
It goes back to what 17 i
does it take to show compliance for the '74 standards.
It is l
meant what the applicant claimed it meant.
19 l
COMM. KENNEDY:
But as I recall it didn't --
20 i
i MR. DENTON:
And what we have accepted as being 21 sufficient.
22 I
i CHAIRMAN AHEARNE:
Yes.
But I think we 23 I
l originally described it as going to do more than that.
t i
MR. DENTON:
And I am -- that's why we need
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I someone from research, I think, to get into that little bit i
a' extra area.
I COMM. BRADFORD:
Well, let me just mention that 4
i in the April '78 decision, I guest, on the ECS petition, I
the commission did specifically request a paper laying 4
I l
out the alternatives for a -- conducting independent verifi-7 cation testing.
+
8 I
CHAIRMAN AHEARNE:
And we even put some money in 9
the budget.
I 10 e
j COMM. BRADFOID:
We even put some money in the i
11 i
budget.
And from time to time --
(.
12 CHAIRMAN AHEARNE:
On the belief that the paper 13 would be coming.
14 COMM. BRADFORD:
That's right.
We push a 15 i
button or something that doesn't seem to be connected to 14 l
anything at the other end abc n
- hat paper.
But --
17 j
i A VOICE:
That's why research isn't here.
18 l
COMM. BRADFORD:
That paper indicates it's never 19 i
come up.
20 MR. JORDAN:
I think -- maybe I can help out 21 t
a little bit.
The division of operating -- I'm sorry, 22 I
the division of construction of reactors for I&E is 23 i
l
(
praicalgating such a paper, and their representative is 24 j
here today, Wayne Ryland, and Bill Rutherford who can give l
1 t
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74
.O c
j CASE No.
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I i
I l
you a little more as to its status.
And a'
MR. KUTHERFORD:
The Sandia study is complete 3
l and as a result of that study it is presented in a paper that we expect to have it out by the end of this month t
provided we can get a consensus within the staff.
6 In addition to the presentation of. the Sandia i
j results, there are three alternatives that we studied.
We 8
have identified as a program and will continue effort on 9
i the problem of qualifications starting with the management to l
1 people --
11 The progran specifies an independent verification l
e testing based on what we find, what has come out of the 13 l
l operating -- division.
I 14 i
The other aspect of the proposed program is 13 j
indepth inspection as the work is under progress.
That is I
id g,
-l the qualification of it while it's in progress as opposed to redcing it after the fact.
18 l
COMM. BRADFORD:
Why don't we just leave it that 19 j
we look forward to the paper, Bill, and put it in your 20 i
tracking system.
21 l
MR. RUTHERFORD:
Yes. Right.
22 i
CHAIRMAN AHEARNE:
I think you've directed the 23
/
question.
We'll look forward to the paper, k-24 sergeant at arms.
l COMM. KENNEDY:
j l
le s rio V eie. m mura c o m re.c me SIN 19e CAMT4I. STue?. & w. SittT ter j
'n gm.n 15 i
(
l I
l MR. DENTON:
Tish concludes our plan presentation.
l CHAIRMAN AHEARNE:
Harold, could you tell me why the industry seems to be reluctant to put together that 4
I underwriter laboratory type approach?
i Are they reluctant are --
6 MR. DIRCKS:
I don't think we've ever -- well, I
l pushed them In this direction.
i 8
CHAIRMAN AHEARNE:
Have we ever made -- really 9
made a proposal to them?
10 MR. DIRCKS:
We started a big push in this i
11 I
area pre-TMI days.
And it has -- I'm not -- I've I
s 12 not surfaced it since we made the six-plant audit and l'
13 l
the I&E results.
And it's probably appropriate to bring 14 it up again.
i 13 l
MR. EISENHUT:
I think the -- if they take id I
l a look at the direction of this program, then youcan see 17 the economic incentive to move along this path, and it is l
would be helpful when we talked to them.
And they have l
19 organized themselves into many operations since TMI and t
2a maybe one of these 21 i
CHAIRMAN AHEARNE:
It really seems to be a y
logical --
23
(-
i MR. EISENHUT:
I think so.
24 CHAIRMAN AHEARNE:
And as you say, it would be lwressaariosine. Vuemarine Rupasrrena tw amm.cu mn. m une.s.
wrrsin l
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TR I
i
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l I
j much more appropriate for them to begin than for us to be plunging into this.
f MR. EISENHUT:
I think the incentive will be 4
I l
a lot clearer since the last time we talked.
S l
i COMM. BRADFORD:
Let's see. I sometimes drift 6
away from it.
Did I miss a slide or something somewhere I
7 summtrizing your visit to Indian Point?
8 MR. EISENHUT:
No, you didn ' t -- you d. idn ' t --
9 you didn't miss it.
We just didn't go it through it to plant by plant.
11 i
COMM. BRADFORD:
I thought, though, that John 12 l
asked; and if he hadn't I would have, specifically about 13 l
Indian Point.
14 MR. EISENHUT:
Okay.
The general conclusion 15 on all of them came out basically the same.
We do have -- we have the Indian Point.
Oh, we had a listing 17 i
of the -- yes, we do -- yes, we went through the lists.ng, la i
you remember, plant by plant of the items that were found at 19 l
Indian Point.
I think -- first, here's the overview of 20 the -- listing of components that we had questions about 21 it at Indian Point two and.three.
We went through these O
item by item in the same sort of way we did at Palisades.
(,
If you'd like, we certainly are prepared to go j
I I
l through some of those.
We can give you an idea of, for l
l
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l example, the pressure transmitters or the --
I t
I f
COMM. BRADFORD:
These are the components reviewed 3
in the same generalization about --
MR. EISENHUT:
Yes.
I COMM. BRADFORD:
-- that would apply to other 4
plants would apply to these as well.
I MR.' EISENHUT:
And we came to the same conclusions, 8
I yes.
They fell through the screen.
Ju'st to show you, this is the kind of thing we go through one by one.
10 These kinds of components.
You make a decision on the --
L I
It i
this is the Westinghouse electrical penetration, which
<w
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12 i
i l
is one of the items on the list.
1 13 And the -- we made a technical argument that l
3 14 i
i
.it looks like the basic materials and structure of the 13 i'
component leads you to the technical opinion that we'll i
14 survive.
17 l
COMM. BRADFORD:
Are both of these units among j
18 I
the 58 that --
19 l
MR. EISENHUT:
No.
The -- the NRR is doing 20 l
the eleven SEP plants plus Indian Point two and three and 21 Zior one and two.
22 COMM. BRADFORD:
I'm sorry.
Are they both among 23
('
the 58 that do not come under 32371?
I 24 MR. BOUCHER:
My recollection is yes.
I'm 23 i
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caos.wo.
rO i
I l
looking to see if I.:an verify that.
I MR. EISEFHUT:
I would suspect since there's --
i 3
MR4 BOUCHER:
Yes, the --
A i
MR. EISENHUT:
-- about a -- only about a dozen i
s e
i that do come under it.
So, it would probably be the i
6 j
dozen latest.
t 7
i
~
t MR. BOUCHER:
The answer is yes.
CHAIRMAN AHEARNE:
Thank you all very much.
9 It's obviously most important and you're putting a lot 10 of effort into it.
It was a very informative presentation.
11 Thank you all.
C 12 (Whereupon at 11:46 a.m., the meeting was g
ajourned) 14 l
13 id i
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^
STATUS OF OPERATING REACTOR REVIEWS e RESPONSES TO IEB 79-01 AND 79-01A INADEQUATE NRC QUESTIONS NOT CLEAR LICENSEE REPLIES DIFFICULT TO REVIEW LICENSEE REPLIES INCOMPLETE e SCOPE OF REVIEW EXPANDED MORE RESTRICTIVE GUIDELINES HELB FLOOD AGING e REVISED BULLETIN ISSUED JANUARY 14, 1980 NRC/ LICENSEE " WORKSHOP" MEETINGS HELD FEBRUARY l-12, 1980 t
" SUPPLEMENTAL INFORMATION" ISSUED ON FEBRUARY 20 0
b
REVISED BULLETIN 79-018 l
e REQUIRES:
1.
MASTER LIST OF ALL EQUIPMENT RELIED UPON TO t
MITIGATE DESIGN BASIS EVENTS 2.
WRITTEN EVIDENCE OF QUALIFICATION i
3.
SERVICE PROFILES 4.
LICENSEE EVALUATION AGAINST GUIDELINES 5.
EVALUATE MAXIMUM FLOOD LEVEL 6.
REPORTS INOPERABLE SYSTEMS AS LER 7.
REPORT UNDER 50.54f (a) 1, 2, 3 45 DAYS IFEBRUARY 28,1980)
P (b) 4, 5 90 DAYS (APRIL 13,1980) 1 f
1 I
l
REVIEW SCHEDULE TASK ELAPSED TIME (MONTHS)
TASK 1 INITIAL PREPARATIONS, REGIONAL 1.5 MEETINGS WITH LICENSEES
[
(JANUARY 14 - MARCH 1)
TASK 2 EVALUATION OF 45 DAY RESPONSES 1.5 (MARCH 1 - APRIL 15)
TASK 3 EVALUATION OF 90 DAY RESPONSES 5
(APRIL 15 - SEPTEMBER 30)
TASK 4 RESOLUTION OF DEFICIENCIES 3
(OCT0RER - DECEMBER 1980) i l
TASK 5 FOLLOWUP OF IMPLEMENTATION 18_
TOTAL 29 MONTHS h
1
,e-,_
0 ON-SITE INSPECTIONS o FACILITIES INSPECTED DRESDEN 3 FORT CALHOUN DUANE ARNOLD OCONEE 2 & 3 QUAD CITIES 2 RANCHO SECO HATCH 2 ST. LUCIE MONTICELLO TROJAN PILGRIM DIABLO CANYON i
e AUDIT OF ONE PLANT SYSTEM PER PLANT ONE UNQUALIFIED LIMIT SWITCH IDENTIFIED FINDINGS CONTRIBUTE TO DATA BASE FOR I
DETAILED EVALUATION l
I i
f
~
f l
p
SCREENING 0F RESPONSES t
e MASTER LISTS OF EQUIPMENT GENERALLY PROVIDED IN 45 DAY 2 REPORT QUALIFICATION DOCUMENTATION INCOMPLETE e LICENSEES ANTICIPATING DELAYS IN 90-DAY RESPONSES DUE APRIL 13
-- MOST COMMITTED BY JUNE 1 t
EIGHT UNITS DELAY UNTIL AUGUST 1 FIVE UNITS DELAY BEYOND AUGUST 1 e REVIEW REQUESTS FOR EXTENSI0NS i
WORK COMPLETED
-- ESTIMATE OF REMAINING EXTENUATING CIRCUMSTANCES,
e PLAN CONFIRMATORY" ORDERS ON NEGOTIATED DELAYED RESPONSES e MPA DEVELOPING COMPUTER FILE FOR DATA i
I
g
~
UNQUALIFIED EQUIPMENT REPORTED COMPONENT NUMBER OF PLANTS CORRECTIVE ACTION VALVE POSITION INDICATING 3
TO BE REPLACED LIMIT SWITCHES i
CABLE SPLICES 1
REPLACED MOTOR OPERATED VALVE 1
TO BE REPLACED PRESSURE SWITCH 1,
TO BE REPLACED 9
_,..m
.x,,....
7
__ =
~
/
_ COMPONENTS REVIEWED Zion Indian Point 2 Indian Point 3 ASCO Solenoid Valves ASCO Solenoid Valves ASCO Solenoid (alves Power and Control Cables Power, Control, Inst. Cables Power, Control, Inst. Cables Limi torque Valve P rators Limitorque Valve Operators Limitorque Valve Operators Electrical Penetrations Electrical Penetrations Electrical Penetrations J
9 Pressure Transmitters Pressure Transmitters Pressure. Transmitters Fan Cooler Motors Hydrogen Recombiner Terminal Blocks Cable Splices Motor-RHR & Fan Cooler Motor-RHR and Fan Cooler NAMC0 Limit Switches NAMC0 Limit Switches l i
.i cn_
/
COMPONENTS REVIEWED tconT.)
Y PALISADES OYSTER CREEK ASCO Solenoid Valves ASCO Solenoid Valves Power and Control Cables Power, Control, Instrument Cables Limitorque Valve Operator Limitorque Valve Operators instrusent Cable Electrical Penetrations Electrical Penetrations Junction Boxes and Terminal Blocks Pressure Transmitters Electromatic Relief Valves Terminal Blocks Hydrogen Recombiner Connectors Junction Box Fan Cooler Motors Miscellaneous Equipment Outside Containment 4
INDIAN ~ POINT 3 WESTINGHOUSE ELECTRICAL PENETRATIONS
?
Deviations from Component Quali fication impact on Overall DDR Guidelines Plant Safety e
No test data e
Critical design features e
No immediate safety for radiation (insulator, seals) similar concern pending to devices such as trans-licensee verifi-e No test data formers and incore neutron cation of qualifi-for chemical detectors which endure cation spray long-term high tempera-ture, high gamma environ-No aging consi-ment, thus believed e
deration acceptable until licenses can further justify e
Test sample configurations differ from installed uni ts
-.-,--._.,.,.m-.,,_,..,-m.-
_,,r
-v.--
2.,-,
,,,_.-e
N PALISADES ASCO SOLEN 01D VALVES MODEL LM 831614 Deviations from Componen t Qualification impact on Overall DDR Guidelines Plant Safety J
e No test data for e
Not qualified for e
No impact - Lic.
radiation long term LOCA will replace before service restart wi th ASCO a
iio test data for Model NP 831654E chomical spray e
10 test data for submergence e
Negative materials analysis
/
j P All SADES ASCO SOLEN 01D VALVES MODEL HP 831654E Deviations from Component Qualification impact on Overall DDR Buidelines Plant Safety
/
No data provided e
Based on test results e
No immediate safety e
to document previously reviewed for concern pending lic.
qualification NP series. valves and staff verification of discussions with vendor, applicabilityoftesQ e
Lic. replies on component is believed to be data which is avail-
- able, vendor compliance adequately qualified for with the purchase the present spec.
ENVIRONMENTAL QUALIFICATION BRIEFING OUTLINE I,
' BRIEF BACKGROUND II.
ONGOING REVIEW DELAYED BY IMI SCHEDULES SAFETY STATUS 1
III.
SIGNIFICANT ASPECTS IMPORTANCE OF ISSUE ONGOING ORGANIZATIONAL RESPONSIBILITY NEED FOR MORE' SPECIFIC ENFORCEABLE GUIDANCE CUALIFIED EQUIPMENT CLEARINGHOUSE BURDEN ON INDUSTRY NEED FOR CONFIRMATORY RESEARCH J
9
'f
't
t IMPROVEMENTS ALREADY COMPLETE OR UNDERWAY e
Connectors Replaced r
e Terminal Blocks Replaced e
Solenoid Valves Replaced Improved Instrumentation On Order (e.g.,
e Transmitters) i 1
Requali fication Programs (e.g., Cables, Splices) e Valve Operator Replacements On Order e
e Licensee Awareness Of Potential Failures P
r
4 OPEPATIi43 PEACTORS E/0 REVIEW PROCESS (SEP & IE BULLETIN 79-0D LICENSEERESPONSE DDR SCREENitG REVIEW GUIDELINES
=
E SITE VISIT c
YES
- GUID, ihT?
iiUREG tio 0588 DETAILED REVIEW ADPLICATION SPECIFIC INFO.
g
/
N
/
N REPLACE fio YES OuALIFIED OR SPECIFIC REQtALIFY REQUIREMENTS OR
\\*
/
ftT?
\\ExwT /
- BASIS FOR C0!!TlfiUED OPEPATI0il !UST BE PROVIDED
.BY TliE LICalSEE li! TliE liftRIfi a
BNIR0tfEMAL QUALIFICATION ORGANIZATION DSI DliF 4
AS NEEDED I
~~
(EtNIRON. QUAL.
s BRNICH) e REVIEW 52 ORS e lifTERACT WITH e CLARIFY NEW EO REQUIRE-e A-24 GUIDANCE PER DDR GUIDELINES LICENSEES,APPLI-MENTS (IrlTERIM CRIT.
ConPtnTe) e INSP. & ENF.
U e EVAL. OF CRIT.
REQUIREKRTS e SERS (15 ORS PER DDR e h n Umm IW N UATION REGARDING E0 GUIDELINES) e CRIT. DEVELOPENT e SAFETY DECISI0flS e SERS (IE IDENTIFIED REGARDING Oh PROBLEMS) e OVERALL COORD.
YU E SOS S RES eToelCALREPORTEVALUATIONS e IffTERFACE WITH RES, STDS ON EQ STN4DARDS e
s
STATUS OF SEP REVIEWS 1
e Palisades Full Week Site Visit Complete i
e Oyster Creek Full Week Site Visit Partially Complete - Balance Scheduled For Week of 4/28/80 Quick Look Two Day Visits Complete for Four s
Plants Indian Point 2 - H/0 Indian Point 3 - Site 4
Zion 1 & 2
- Site
SUMMARY
OF DEVI ATIONS FROM THE DDR SUIDELINES Component Installed in Plant Not Identical To e
Component Tested - Model, Size, Materials inadequate Test Sequence - Not All Service Condi tions Addressed No Aging Considerations e
incomplete Documentation of Tests Performed s
m I-t GENERAL ASSESSMENT OF SEP RESULTS TO DATE j
Although Most Equipment Failed To Meet At l
Least One Aspect Of The 00R Guidelines, No Immediate Plant Shutdowns Required While The Process Of Up Grading Equipment j
Ouali fication Continues.
n 4
k 6
s k
b I
i r
w
t BASES FOR CONTINUED OPERATION O
e Equipment Will Perform Short Term Ini tiation Functions Even if it Fails in The Long Term.
s The Probabil.ity Of A Major Accident Which Would Produce An Extreme Environment is Low.
Def ense-in-Depth Design Concept Of ten Provides Alternatives For Equipment Whose Qualification
!s Questionable.
l l
f-e A
4
1 i
f OTHER SIGNIFICANT ASPECTS i
Staff Recognition Of importance Of Issue e
New Environmental-Qualification Branch in l
s NRR I
Need For More Specific Enforceable Guidance.-
e Po tential New Rule 1
Qualified Equipment Clearinghouse - NRC And l
e Industry l
Need For Confirmatory Research And Testing e
e Increased Industry Emphasis i
4 l
l i
l
[
f
-