ML19345G666
| ML19345G666 | |
| Person / Time | |
|---|---|
| Issue date: | 04/07/1981 |
| From: | Advisory Committee on Reactor Safeguards |
| To: | |
| References | |
| RTR-REGGD-01.068, RTR-REGGD-01.142, RTR-REGGD-1.068, RTR-REGGD-1.142 ACRS-T-0842, NUDOCS 8104090542 | |
| Download: ML19345G666 (91) | |
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W. Anderson J. Costello 4
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FF0CEEDT N G S 2
MR. SIESS:
Th e ne e tin g will come to order.
This 3 is a meeting of the Advisory Committee on Reactor 4 Safeguards, Subcommittee on Regulatory Ac ti vi tie s.
5 I am Chester Siess, Subcommittee Chairman.
6 The other members of the Subcommittee that are 7 present now, starting from my left:
Er. Ray, Mr. Ward, Mr.
8 Mathis, and Mr. Sam Duraiswamy on my right is the Designated g Federal Employee.
10 This meeting is being conducted in accordince with 11 the provisions of the Federal Advisory Committee Act and the 12 Government in the Sunshine Act.
And we are keeping a 13 transcript.
So be sure to identif y yourself so tha t the 14 reporter will get your name.
15 The purpose of this meeting is to discuss two 16 proposed Regulatory Guides as follows:
Regulatory Guide 17 1.142, Revision 1,
en titled " Safety Related Concrete Structures for Nuclear Power Plants"; and Regulatory Guide 18 19 1.68.3, formerly Regulatory Guide 1.20, "Preoperational 20 Testing of Instrument and Control Air Systems."
We have received no written comments from members l
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l 22 of the public and no requests from anybody to make oral t
statements at the meeting.
So we vill proceed.
23 Which order would you like to take them?
24 i
MR. MORRISON:
The order that you read them in, 25 li ALDER $oN REPORTING roMPANVn INC, 400 VIRGINIA AVE. S.W. WASHINGTON. D.C. 20024 (202) 554 2345
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1.142 and 1.68.3, will be fine.
2 MR. SIESS:
All right.
I will get eine in 3 o rd e r.
4 We will take up 1.142 first.
Who is going to 5 present tha t ?
6 MR. MORRISON:
Gunther Arndt will take care of the 7 honors.
8 MR. SIESS:
Gunther will prasent it?
9 MR. MORRISON:
Correct.
10 MR. ARNDT I would like to make four points 11 before we get into any questions you might have on the guide 12 in its proposed final form.
First is that this is basically 13 an endorsement of the American Concrete Institute standard 349 in its basic 1976 issue, along with the 1979 14 15 supplement.
16 MR. SIESS:
Let me stop you right there.
Is th; 17
'79 supplement -- does it include all the previous 18 supplementc?
There was a '77 and a '78 supplement.
Are 19 they cumulative?-
MR. ARNDT I believe the answer is yes.
20 HR. SIESS:
It.is?
Yes, okay.
Because that is 21 22 not true in division one.
So '79 is cumulative.
MR. ARNDT But this is a parely American Concrete 23 Institute standard.
24 HR. SIESS:
I couldn't remember how we did it for 25
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312, because we only get them up here every two years, so 2 they can't be cumulative.
I had a question about that when 3 I read it.
4 Okay, thank you.
Go ahead.
5 ER. ARNDT:
The for-comment issue of the guide was 6 put out in April of'1978, and between that time and now is
'7 when the '79 supplement to the code came out, and some of 8 the changes that we have between the final issue and the 9 for-comment issue reflect the issuance cf this 1979 10 supplement.
Following the public comment period we received 12 11 12 comment letters from the public, and a number of these comments have been addressed, as well as some impact on the 13 code chan7ing from 1976 to
'79.
And our responses are 34 included in the enclosure as far as responses to public 15 16 comments.
And another point to make is that this guide, in a 17 f ashion similar to Regulatory Guide 1.136, we intend to 18 revise periodically to keep up and stay current with our gg sudorsement of tnis particular standard.
As such, we intend 20 to periodically put it out in final form without going 21 22 through the public comment interim issuance and without on a routine basis com'ing to the ACES for the prior 23 consultation.
24 However, if it turns out that some of the 25 s
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positions that we address in a revision of the guide appear 2 to be significant and of in terest to the ACES, we vill b rin g 3 them here before going out with the guide.
4 MR. SIESS:
Now, when you put out, say, one y e a r.-
5 if you get some comments on that you will consider this the 6 next time you go out ?
7 MR. ARNDT:
Correct.
It would revert somewhat to
.e guides originally were established 8 the procedure that t
9 under, under which they were in a constant state of 10 revision.
Whenever there was a significant enough comment ij or set of comments, it was tine to update the g uid e.
12 3R. SIESS:
Do you think you will be on a one-year 13 schedule?
MR. ARNDTs Approximatcly, yes.
34 15 MR. SIESS:
If you are, that will be about twice 16 as fast as you are doing it now.
MR. ARNDT:
That's the reason for dropping the 17 18 public comment phase.
MR. SIFSS:
You will still be getting the public 19 comment?
20 MR. ARNDT:
Right, but doing it in a single issue 21 format instead of a sequential format.
22 MR. SIESS:
You will issue sny comments on that 23 when you consider the next guide, and that's a one-year 24 25 cycle, and this was issued in
'78, you got the comment, and ALDERSoN REPORTING CoWPANY. INC, 400 VIRGINTA AVE., S.W WASH:NGToN. D.O. 20024 (202) 554 2345
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it's going out in
'80.
So you see, it will actcally be a 2 faster cycle, with sort of a continuous issue and a 3 con tinuous comment, so you will be able to res;ond to 4 comments even more rapidly than you do now.
5 ER. ARNDT:
Eight.
6 ER. SIESS So you won't get as cacy.
7 ER. ARNDT It doesn't address an abstract issue
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8 by itself.
It addresses a particular standard which is g revised periodically, and we would like to stay as current 10 with that as we can.
ER. SIESS:
I assume that vill be coing both 11 12 vays.
In other words, as 349 co:es around, to your way of 13 thinking, you vill be able to draw up positions.
ER. ARNDTs That's already reflected in what you 34 15 have.
ER. SIESS And as they add new stuff, you vill 16 have to possibly take positi.ons on it. as you did hare.
17 ER. ARNDT Correct.
18 ER. SIESSs Okay.
I think we had no problem with 19 that last month, I think it was, or whenever we met, two 20 21 months ago, when you proposed that correction of 1.136.
Does anybody on the Committee have any objection 22 23 t9 that?
It seems to me, although they take us out of the loop, unless they rall it to your attention, it so haryens 24 in both of these I would probably know about it.
If it's 25
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sig nif icai.t, we vill call it to their attention.
Although 2 it d' take us out of the formal route, it tends to keep 3 things r ving, and I think the process becomes a better one 4
a' more up-to-date all along.
MR. ARNDT The last point I would like to =ake is 5
6 of an editorial nature.
It has quite recently come to our 7 attention that one of the standards that we reference in 8 this draft here is likely to be withdrawn.
It's ANSI Standard N-101.6, under radiation shielding.
It has not at 9
10 this point been firmly withdrawn by ANSI to my knowledge, but we have expectations it vill be.
11 12 And so we wanted to do some editorial shuf f112.g in 13 here.
The points that we make with respect to fundamentally 14 paying attention to the radiation shielding aspects of these structures will be retained.
Si= ply the reference to the 15 standard will be deleted, if and when it is withdrawn by the 16 tite this goes final.
17 MR. SIESS:
We commented a couple of years ago 18 that this shielding is sort of a crack that something had 39 f allen into here, two or three standards, and none are quite 20 applicable completely.
And you put something in here.
Is 21 22 anybor y verking on a sore directly rslated standard that woula deal with the radiation shielding as far as structural
.g elenents?
24 MR. ARNDT Well,. currently there is sone 25
.g ALDERSoN REPORTING COMPANY,1NC, 400 V;RGiNIA AVE. S.W. WASHINGTON. D.C. 20C24 (202) 554 2345
9 1 discussion with 349 to do this.
I'm not sure at this point 2 just how far that has gone.
I do know there is another 3 standard which was originally developed as an analysis and 4 design standard, which is also referenced in here, N-403, in S the American Nuclear Standard N-403.
6 T. '. SIESS:
Who's developing that?
7 ER. ARNDT:
ANS.
8 MR. SIESS:
Okay.
9 ER. ABNDT But this is incorporating some of the 10 material provisions of the ANSI N-101.5 sta nda rd and 11 probably will do th? job from the point of view of designing 12 how much shielding you need.
And that is being endensed in 13 a separate action by a separate regulatory guide that is 14 already out for comment.
15 Cur intention here is simply to remind people in 16 the design of these particular concrete structures which 349 37 applies to that radiation shielding is still an ites to pay attention to.
18 3R. SIESSs But there are a number of interfaces.
l 39 I remember in 1.136 you vorried about filling up those 20
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21 pipes.
There must be some questions about if somebody wants i
22 to use heavy concrete, can they use it for structural concrete.
Maybe there's not enough data to tell them now.
23 f
MR. ARNDT This is something that would not be 24 covered by - ANSI N-40 3, but which we ha ve been talking with 25
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349 about covering in sone manner, whether we could get an 2 appendix into 349.
3 ER. SIESS:
I assume under 349 you couldn't use a 4 heavy structural concrete, could you '
5 ER. ARNDTs It's not addressed.
6 ER. SIISS:
It's not forbidden, either.
It 's just 7 nobody would do it because they wo uldn ' t know what values to 8 use.
9 ER. AREDT:
I tnink from an econo =ics point of to view, looking at it from a purely structural function, it would be considered.
11 12 ER. SIESSs I would visualize where somebody has 13 got to combine shielding and structures and they have a 14 space problem and want.t to go to heavy concrete.
Can they 15 do it?
I would be a little suspicious right now-cf how to 16 design it.
I don't know whether I know the properties of 17 heavy concrete and shearing tension and ductility and a fav 18 other things enough ta make a design that would meet 3u9.
M R.
'4 A R D s it would be up to the applicant to 39 demonstrate that.
20 ER. SIESS:
It would be nice if 349 would look at 21 that.
Eaybe it's not enough of a problem for them to spend 22 their time on it.
But you know, the treatment is a warning 23 here, and it refers to about.three other places.
By the 24 time a guy goes through'all of those, somev:.tre somebody 25
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vill be telling him what he is looking for.
2 MR. APNDT It's a good point and we app?,eciate 3 your support on this.
4 MR. SIESS:
He can go in all these places and 5 probably find some questions if he knows what the ansvers 6 are.
But we want to be sure he asks the right questions.
7 Ckay.
8 MR. ARNDT Thank you.
That's all the key points 9 I have.
If you have any specific questions.
10 MR. SIESS:
Yes, I want to go through this a little bit.
But first of all, you have added fiv* positions 11 12 that were not in the one that vent out for comment.
13 MR. ARNDT Right.
MR. SIESS:
And the thing that intrigued me was 14 15 there was no discussion of any of those discussions in Part 16 B.
So I don 't know why they are added.
Maybe the people 37 tha t wrote 349 know why.
And although I am a consulting 18 member of the Committee, 349, I don't know why, because I didn't read maybe my own work.
19 But you have discussed in the discussion section 20 most of the other positions.
You have done it in a rather 21 l
interesting manner.
You have discussed first C.5, 2, 3, 6
E 21 23 and.7.
C.4 I think didn't need discussion, maybe.
Maybe it does or maybe it d oesn 't.
But I wasn't quite sure why they 24 were in that peculiar order.
25 ALDERSoN REPo (TING COMPANY. INC.
400 /lAGINIA AVE., S.W, WASHINGTON. D.C. 20C24 (202) 554-2345
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I'm not going to give up on this format thing.
I 2 think you go back far enough to remember our arguments that 3 it's awfully hard to trace some things through B and C.
I 4 had to go through and mark.
It was very clear beginning at S the top of page 3 what regulatory positions you were going, 6 except in the case of C.5 at the top of 3.
io you see 7 regulatory position 5 7 8.
The rest of them are not identified by regulatory g positions, although there is clearly a paragraph or two on 10 each regulatory position.
When you get over to 6 they arr identified.
11 12 MR. ARNDT4 I understand.
I think regulatory 13 g uide 136 presented a model value, like the discussion laid 14 out on a one for one basis, although I think you indicated a 15 preference that we reverse the order.
MR. SIESS:
The fact that they are out of order I 16 think is unnecessary, and the fact it starts off so pretty.
17 It says, regulator'y position 5.
And then the next one, 18 which discusses the one beginning at the top of page 4,
you 39 just have to go figure out which one it's discussing.
And 20 it could say that.
It would be so simple.
21 But ycu didn ' t discuss tae new ones at all.
Would 22 you like to first run through the added positions and cive 23 me some idea of why.they are in there, since 349 didn't ask
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24 to to present sad comment on these?
7 is the first one.
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ZR. ARNDT:
I think ' o some extent we have not 2 provided some discussion on the new editions, which result 3 la;gely from reviewing the '79 supplement, because either we 4 expect them to be adopted by ACI-35', such as the numbers 10 5 and 11 on local exceedance of section strengths, or it did 6 not seem necessary really to say much in the discussion y beyond what we had in the position that generic criteria of 8 Appendix A on thermal considerations that are in the code g now are acceptable.
10 MR. SIESS:
I see.
MR. ARNDTs So we didn't feel --
11 12 MR. SIESSs 7 says how you treat -- yce say if 13 liquid is a f unction of groundwater variation, you treat it 34 as an age rather than a water, which I think is reasonable.
It seems to me we go through the same arguments in 318 right 15 16 now trying to get that straightened out.
Was that something
.that came out of the supplement or was that 17 MR. ARNDT This was something th a t predates the 18 supplement.
39 I
MR. SIESS:
Tha t's what I thought.
20 l
21 ER. ARNDTs We have some correspondence between us and ACI 318 Committee on this point, where we questioned how 22 you would handle the saturated or partly sa turated soil.
It 23 is not a pure hydrostatic lesd, it is not a pure dry lateral 24 soil load either.
And we prefer to take the position that 25 k...
ALDER $oN REPORTING COMPANY. INC.
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this would be covered under H rather than F, under the soil 2 rather than under the liquid.
And it gives a higher load 3 factor.
4 And in the correspondence we felt that we received 5 a sympathetic consideration.
6 3R. SIESS:
You said ACI 318.
You neant 349, 7 didn't you?
MR. ARNDTa Now, I have here something that is to 8
g John Breen, Chairman of ACI.
ER. SIESS:
I tnink this is reasonable, on the 10 11 grounds that pure hydrostatic pressure, a tcnk load or 12 something, has less uncertainty than water in tne soil, 13 unless you want to assume it's all the way up to here, which is not necessarily a reasonable assumption, although it is y
15 certainly conservative.
So I have no argument with it.
I was just 16 37 vondering why it hadn't been discussed.
I still think, if 18 you think that's going to be adopted real soon, with appropriate commentary on 349, I guess it doesn't bother 19 me.
But one reason for-having your discussion, we just want 20 the commentary in the code, is to get on record why you
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21 wanted something done.
22 It's f or your own information and for the 23 licensing review people's information, because they might 24 come across a situation where it isn't absolutely clear 25
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ALDERSoN REPORTING COMPANY. INC.
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whether it applies.
But if they know why it's there they 2 can make a much better judgment.
And so basically 3 explaining reasons is as much for your benefit as for 4 anybody else's.
That's why 349 is supposed to have a 5 commentary.
6 Now, 8 is clearly a disagreenent with 349.
They v a n't differential settlement in just a through 11, which is 7
all the non-normal load conditions, and this sa ys, put it in 8
g every load combination including the dead, live and normal 10 forces.
And there was no Itason given for that anywhere.
And that is not a new one that happens to be -- tha t is the 11 12 old number 10.
13 ER. ARNDT Right.
I'm a f raid I an not able to shed a lot of background or anything really in the way of 14 15 background on this point.
MR. SIESS:
It's addressed in the response to the 16 17 resolution, I think.
HR. ARNDT There are various places in the 18 package, either the value impact statement or a discussion 1g on the comments received.
20 ER. SIESSs There was an argument about it l
21 somewhere.
let me see if it's the value impact state 7ent.
22 No.
23 Incidentally, the added ones are not addressed in 24 the value. impact statement either.
I mean, they just aren't 25
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addressed, period.
And I did not cross-reference -- now I 2 can tell that 's old 10.
Do you have a comment en that from 3 EBASCO?
4 And the argument is that it is all right -- it is S not all righ t to lump differential settlement in with creep 6 and shrinkage.
End tr.cre are some very strange statements 7 in there about 318 that I didn't quite understand.
3 Differential settlement -- I don't see how it's that much g different from creep and shrinkage.
They are all three 10 deformations that occur.
That at least stresses the need to 11 restrain the structures.
They are all self-limiting in that 12 they are deformation stresses.
They are not added to load 13 stresses once you get into an inelastic rance, which is what 14 you would in extreme cases.
15 They are additive in the non-extreme cases, which 16 is the three you want to add it to, one, two and three.
But 17 why add just differential settlement, but not creep and 18 shrinkage?
The distinction isn't reasonable te me.
There's gg a deformation encased by the structure by some means, whether it's creep, shrinkage or deformation, that's induced 20 21 by the structure.
So I'm villing to let it go.
But you didn't get a 22 heck of a lot of argument from anybody on it.
349 didn't 23 24 pick it up.
But the reasoning is not clear.
I wish I could argue clearly one way or another, but we're going through 25
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ALCERSON REPoRTsNG COMPANY,INC.
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the sane question for 318, but separating out differential 2 settlemont.
3 318 says they could be considered when they have 4 an effect on the strength and nobody quite knows what that 5 means.
6 MR. ANDESSON:
You do provide guidance for how to 7 handle creep and shrinkage.
They are anticipated to be a really self-limiting.
We can't put a linit on the g settlement.
We really can 't anticipate on the settlement.
10 MR. SIESS You sure have some applicants that try 11 to predict it, but I admit they don't predict it all that 12 vell.
The differential settlement is part of the predicted 13 settlement, usually.
14 Well, I can't find it righ t now, but there is some 15 point about you could get stresses due to differential 16 settlement that would affect the response of the structure 17 to the accident ~ loads.
And that sounded real good the first time I read it, but the more ! thought about it the more I 18 vondered how anybody knew that.
I couldn't quite figure out 3g how I could impair the strength of the structure by 20 21 something that happened two years before th a t.
So the point you made about the ability to predict 22 and'the uncertainty -- but that should really add onto what 23 kind of load factor you put on, not whether you include it.
24 Also, there is a different uncertainty on differential 25
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settlement.
You might take that back to Hans and ask him to 2 think about it.
3 But I gather that 340, I think the letter there i
4 said that they were working or it, and it is not an easy 5 question.
6 All right, now.
9 is a new one and I guess you 7 cannot argue with it.
You say you will do it case by case 8 basis of
-g MR. ARNDT:
It is still largely under go investigation, I believe.
MR. SIESS:
That's the load for pool dynamics, and 33 12 349 didn't cover those anyway.
That will be a NUREG coming 13 or something.
HR. ARNDT:
I'm not sure what the end result will 34 15 be.
FR. SIESS:
That's Hark I and Mark II.
16 Now, Tan, you have taken exception to the 17 l
18 ductility ratios that are in Appendix C.
Incidentally, this l
gg isn't your thought.
I guess it's in 349.
But this term l
" Permissible ductility ratio" bothers me.
It's really l
20 21 permissible in design, right -- in analysis, I mean.
You
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22 cannot assume a higher ductility f actor than is in the analysis.
23 I mean, if I want to make a structure that's more 24 ductile than this, fine.
Nobody's telling me I cannot have 25 r
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a beam that's got a ductility ratio higher than 3, am I 2 right?
3 MR. TAN My name is Tan, from the Structures 4 Engineering Branch.
5 HR. SIESS:
Well, do you agree with me?
These are 6 the maximum that you can assume in the analysis.
7 MR. TAN:
You can use it.
8 ER. SIESSa But you see, it always bothers me and 9 it's got to bother somebody tha t 's used to 318, because the 10 limits on ductility on 318 cre lower limits on ductility.
You limit the steel ratio tc some value in order to put a 11 12 lower limit on ductility, at.d then when I look at 349 13 putting an upper limit on dactility for use in analysis, not 14 for use in design, you see And it just confuses me.
15 Now, this is clettrly you said some of these 16 were going to be picked ur by 349, but is this one of those?
17 MR. ARNDTs If you go to the next to the last page 18 19 in the package, page 13, regula tcry position -- it's labeled 20 here 12 and 13 at this point.
MR. SIESS:
Which page?
21 MR. ARNDT Page 13, local excedances.
22 HR. SIESS:
Wait a minute.
I have got mine broken 23 down.
My package is no longer intact.
24 HR. ARNDT:
It's page 13 of the resolution of the 25 ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W WASHINGTON. D.C. 20024 (202) 554 2345
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comments memorandum.
2 MR. SIESS:
Tha t's old position C.12 and 13.
3 MR. ARNDT And there it is indicated tha t on the 4 local excedance of section strength, ACI 349 was agreeing 5 with the concerns indicated here and tha t they should be 6 clarified in the code section 9.3 or in the commentary to 7 the code.
8 MR. SIESS:
Now, the differences you have made I 9 don't object to.
10 MR. ARNDT The differences I think were largely 11 saying that the values given for a ductility ratio of 3, for 12 example, would be all right localized, but not over the 13 general structural area.
MR. SIESS:
Now I know what a ductility ratio of 3 34 15 seans in flexure, and I assume this is flexure, because C.3 16 and 4 in the code is flexure.
I know what a ductility ratio is when I analy=e the structure and I've got a local 17 r tation of a joint, a ductility of 3 presumably in the 18 rotation.
I would make that assumption.
19 I really. don 't know what you mean by a ductility 20 j
21 ratio of the structure as a whole. Say I've got a lateral load.
Is this in terms of the deflection of the top story 22 at yield or the deflection of the top story at ultimate?
23 MR. ARNDT:
I think I will defer to C.P.
Tan.
24 MR. TAN:
Yes, I think that's true.
It's the 25 i
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building, the whole building considered.
When you said of 2 each member --
3 dR. SIESS:
All right.
So I have to use a 4 different measure.
It would have to be the deflection of 5 tne building, right?
And the ratio of ultimate over yield, g right, or some limit over yield?
But the yield for the i
g structure, would tha t be where there is no yield within the structure or could the structure have yielded locally --
10 11 sec, this structure won't begi' to show any real inelastic 12 action until it gets a fair amount of yield, local yield.
13 As long as there are parts of it that are still elastic, the 14 thing will still look pretty elastic.
15 MR. TAN:
Yes.
16 MR. SIESS:
It won't be linearly elastic.
But has 17 anybody checked that?
MR. TAN Ycu have designed where the yield in the 18 whole structure is.
3g MR. SIESS4 What do you mean by that?
I don' t 20 know what that means.
Say I have a three-story, one-bay 21 building.
I would have to get what, six plastic hinges 22 before the whole structure would yield.
23 MP. TAN:
Yes.
24
'ER. SIESS:
And you would call that yield?
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MR. TAN 4 Yes.
2 MR. SIESS:
The beginning of the last plastic 3 hinge, and they you would have to figure -- and you would 4 vant tha t one.
Okay, I guess I can see how to get at it.
5 But suppose somebody isn't around to ask you the question.
6 That's why I'd like to see some discussion on sone of these, 7 because the si=ple structure I just proposed is one thing.
8 If the thing has shear valls in it, I'm not sure what the g devil it is.
10 MR. ARNDT All right, that's a good point.
MR. SIESS4 And agai now, on ites B under 10, that 11 12 section 7367, you just want more ductility than they've got, 13 just an honest difference of opinion.
You want 1.3 on --
14 MR. ARNDT*
We want to lower it fro: 1.3 to 1.0 15 for the ca;e of shear carried by concrete alone, and we want 16 to lower it from 1.6b to 1.3 where we have a conbination of 37 concrete and reinforcement carrying the shear.
We are not 18 taking any exception to the 3.0 ductility ratio where the 39 shear is carried completely by the reinforcing.
MR. SIESS:
I an inclined to agree with you, 20 21 because if it's shear carried by the concrete alone I don't 22 know how you can get a ductility higher than one.
I haven't a
seen a beam yet I would call anything higher than one when 23 24 it's all carried by the concrete.
And I think the other one is probably consistent.
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But again, I wish there were some discussion.
2 Now, on 11, all you have done there is extended t
3 the list and the supplemen - to list the number of dynamic 4 loading cases, and you have said in your summary you can use 5 it for them, is that r,'ght?
6 ER. ARNDT Right.
7 MP. SIESS:
This is not a replacement list.
It's 8 also acceptable.
So nobody should have any objectice to g that one, I don't think.
10 MR. ARNDT:
That's right.
MR. SIESSs It is not acceptable for seismic, 11 12 though.
13 MR. ARNDTs They make no mention of that.
ER. SIESS:
And then 12 you mentioned earlier.
It 14 15 doesn't seem to me there is any problem with that one, is either.
I guess it is more or less self-explanatory.
MR. ARNDT Right.
17 MR. SIESS:
You had a fair amount of argument 18 incidentally, in response to the public comments you did 19 some additions to Part B.
In other words, you gave the 20 reasons or some of the reasons that people were objecting 21 to.
In fact, that's what some of them asked for.
I think 22 23 you just didn't go quite far enough.
ER. ARF :
Okay.
24 MR. SIESS:
Regulatory position 5, about how often 25 s
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you sample concrete.
I'm getting a little tired of that 2 one.
But I guess you got their attention.
3 Who wrote N-45-2.57 4
MR. ARNDT4 I don't remember.
It's been around 5 for a number of years.
It crew from what it originally 6 covered to cover more in the way of materials -- concrete, 7 steel, soil, and various standards seem to either address or 8 potentially be able to address the material covered in g
N-45.245.
10 For example, ASME section division 2 has what are 11 considered comparable requirements for concrete containment 12 OA.
The potential seems to be tc, I personally feel, to tak'e this particular standard and disseminate its various 13 14 parts on quality control of materials to the respective 15 design standards that are involved in sections ACI 349, 16 American Institute of Steel Construction nuclear 37 s pe cifica tion s..
The American Society of Civil Engineers has a standard Don earth structures now.
And we could 18 19 perhaps avoid some duplication by appropriste incorporation.
20 21 ER. SIESS:
But this particular question isn't a 22 OA question, it's a OC question.
How often you sample is not a OA; it 's routine q'2ality control.
23 MR. MORRISON:
By our definition it's part of OA, 24 so it is a OA question.
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MR. SIESS:
ANSI calls for 100 yards.
349 0111s 2 for 50s 318, do you remember?
I thought I had it down 3 somewhere.
4 ER. ARNDT:
I don't remember 318.
I think *50.
5 And was 302 the construction standard -- 301 calls for 100.
6 MR. SIESS:
I have two thoughts about this one.
7 You gave them a little.
You didn't give them very much, 8 because they could go from 100 to 200 with good control on 9 the concrete.
I just was a little bit amused that the staff 10 argument for staying with 100 is because it's an ANSI 11 N-45-2.5.
And I just sort of wondered why you preferred one 12 standard over another.
I mean, you must have had another 13 reason, because you've got two equally valid sta nda rd s.
And 14 th;s says *00 cubic yards and on the other one it says 150.
15 Now, the innate regulatory conservatism would say 16 naturally take the lower one in this case.
But you know, 37 they're both just opinions.
You must have some opinion as 18 to why you chose one or the other.
You could take a higher 19 one and cite it as an argument, you know.
MR. ABNDT I might put a little history on it 20 21 with respect to'150 cubic yards versus 100 cubic yards.
We 22 started out with 100 cubic yards and then in discussions, we should raise that to 150 cubic yards on the basis that the 23 concrete being placed was more mass concrete poured than the 24 25 conventional, let's call it more slender concrete pours that ALDERSoN REPORTING COMPANY. INC, 400 VIRGINIA AVE, S.W, WASHINGTON. D.C. 20024 (202) 554 2345
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ACI 318 and 301 address.
2 We were not convinced that this particula r i
3 argument to go from 100 to 150 cubic yards was really valid, 4 in that if you take the quality of concrete that you're 5 looking at per cubic yard placed, we were not looking at a 6 traditional sense of mass concrete pour quality level per 7 cabic yard.
We were looking at an equivalent on a per cubic 8 yard basis of a quality level the same as what is poured in g the column of a building of this type.
10 In other words, it is fairly critical to us what 11 the quality level is on a per cubic yard basis in comparison 12 with conventional construction.
And it is not really 13 analogeus to say tha t the quality level we are looking for in these large concrete pours is the same as in a great big 34 15 massive pour somewhere else, a dam or some very large 16 foundation somewhere.
We cannot tolerate very much in the way of voids 17 in three and a half and f our-foot walls, not from the 18 strength point of view, but from the shielding point of gg view.
So we decided to, unless there is some strong 20 21 evidence, to stay with this.
And then when the arguments 22 case, that if we can show a better q uality control r<nd that we are maintaining the level of quality by some means, this 23 seemed to be a reasonable argument.
24 And we said, all righ t, we vill go along with this 25
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philosophy, but we are not going to open-end it.
And the 2 dif ference between ACI 349 and the dif ference between what's 3 in the regulatory guide here aside from the 100 or the 150 4 cubic yards is that we also put an end on the degree to S which you can expand the program.
6 HR. SIESSs That's another argument for the 7 shielding to be separated out.
You've got a lot of walls 8 there that aren't separated for shielding.
So if you're g thinking simply structures, you could say for a conventional 10 building like this one back here, you're really concerned 11 about the quality of maybe an eighth of a cubic foot of 12 concrete.
If you've got that concrete in there in the wrong 13 place in the building, you can have a failure.
With the massive kind of stuff we are putting into 14 15 structures for nuclear, you might be maybe a cubic foot or 16 two or three cubic feet before you would have a weak spot that would bother you.
This is a probabilistic type thing.
17 18 I am sure that the 100 cubic yards and the 150 in another 19 isn't based on intuitively any kind of probabilistic consideration.
It's based partly on experience, partly on 20 21 wha t's practical, partly on how much -- you know, what it 22 takes to keep people honest and sort of control the 23 process.
Anyone really worried about quality control in 24 25 concrete, you control the quality back at the plant, but not
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by test cylinders that you test 90 deys later.
I am 2 amenable to what you've got, because I think it tightens 3 things up.
4 But it seems to me that the industry, if the3 5 don't like it, could present some statistical data to 6 support their arguments, certainly on the structural part, 7 just on the control part, the uniformity part, the 8 consistency, the uncertainties.
g And one of the letters mentions the nr>Jer of 10 samples they actually take on the study, that statistic and the kind of control they get.
I think if somebody wanted to 11 12 come in with some decent quantitative data, 349, 318, 301, 13 could all look at it and come up with some much better criteria than we've got now, one test per day but not less 34 15 than 150 cubic yards, et cetera.
Because otherwise, it is just one opinion against 16 another, the kind of reasoning you were going through, which 17 18 gives a relative value.
But maybe 50 cubic yards is better, 19 maybe 500.
I don't know and I don't think anybody does.
But that 's something I think they ought to be looking at.
20 MR. MORRISON:
Your question about who wrote 21 N-45-2.5, you mean the individual standards committee?
When 22 it first came out, it was under the old N-45, under the 23 N-45-2 Subcommittee, and under that it was 2.2u5.
ASME was 24 the secretariat.
But now it comes under the Nuclear Quality 25 r
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Assurance Standards Committee.
2 HE. SIESS:
Because I didn't know now many 3 concrete people, whether they got their data out of some 4 concrete code or what.
Probably teok it out of 301.
But 5 that's an area that people can argue about all they want, 6 and I don't think anybody knows the answer.
I'm not sure 7 100 is going to be any better than 150.
In fact, if' 8 somebody argued that I bet they could produce data from the 9 job that would show that.
HR. ABNDT:
I agree with you and I presume one 10 could make as good an argument f or one number as the other.
11 12 And in the meantime, we are amenable to saying that if you 13 can demonstrate that you have a very good QA-QC program in 14 this area, we are willing to go along with you to some degree and give you a tradeoff if you have a better control 15 16 System you can test less frequently.
MR. SIESS:
All this is showing is that they have 17 a control system independent of the sampling.
The sampling 18 is just a verification of how good their controls are, 19 because you're sampling one truck out of 15, and if you get 20 one back truckload you could be in real trouble.
That's not 21 a cubic. foot -- I don't know how big these trucks are, but 22 this stuff is mixed and I don't know what sire mixers 23 they're using, but I'm sure they are big ones.
24 You might take a message back to 349.
Maybe I can 25 L
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get it to them more directly.
2 Let's see, you get into another argument --
l 3 incid e n ta lly, I know you consider the temperature loading.
4 I think I don 't have muen of a problem with that.
There is 5 a conf goint sade in here that it's the load effect that has the load uncertainty, not the load.
a
~
7 And this whole discussion of load factors, as you 8 probably know -- well, let 's take the one where you pref er 9 318 t.o 349, which is to a certain degree flattering, on the 10 earthquake loading.
You want the 10 percent increase.
I would be flattered that you accept the 10 percent increase 11 12 out of 318, except that I haven't got the slightest idea why 13 it is in 318.
I have been in 318 for 20 years and I can't 14 15 remember why it's in there and I can't find any record of 16 it.
I have been back through my files, and I think there is 17 a very valid argument by the 349 people that the earthquake 18 that 318 buildings are designed for is a completely dif ferent earthquake than the nuclear buildings are dasiined 19 f0E' 20 i
21 To argue about 10 percent in the load factor, the i
number you multiply E by, when E is probably different by 22 200 percent, you know, it seems just a little bit silly to
- 3 me.
You cannot ignore the fact that it's 1.7 E.
It's 1.7 l
24 t
times some number that is handed down on stone tablets.
And 25
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those E's are quite different for what 318 is talking about 2 than it is for reg guide numbers.
3 MR. ARNDT.
I think you also pointed out to us 4 previously that there is an inconsistency between the 5 nuclear concrete design for 349 and 359.
6 ER. SIESS:
And you're working on that, I 7 noticed.
8 ER. ARNDT We have started to pay some attention 9 to that and hope to address this.
I think there are some 10 programs already which are investigating the various load 11 f actors in part of our research ef fort.
12 ER. SIESS:
There is a research program on load 13 factors and I think everybody should keep an open mind on 14 it.
And as you know, the ANSI A58 load committee is 15 proposing load factors and they won't look anything like the 16 ones you see in ACI-318.
And on seismic they are quite 17 different.
Again, c ;. s y are based on ATC seismic hacards 18 probabilistically, with a hell of a big empirical 19 justification, because otherwise everything looks like it 20 ought to fall down, and they don't.
So none of those numbers are very meaningful from 21 l
l a probabilistic basis, and anything in 318 that is any good 22 is good simply because we've been using it for a long enough 23 time that we know not many buildings fall down.
You can't 24 use 318 even to justif y 349, because you design f er 25 m
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dif ferent kinds of structures and consequences and 2 earthquakes.
3 I really think that 10 percent argument lacks 4 strong justification.
But I'm not going to object to it.
5 And of course, the rest of the stuff under 6, the other load 6 factors, they will come out, I think, essentially in the 7 research.
I think it would be a good idea if the research 8 people were alerted to these particular arguments so they 9 could get some input.
10 I know what they are doing.
There is a tendency 11 for research, by the time it goes through them and through a 12 contractor, and he goes off on a two-year program, to get 13 very comprehensive when there are some nice specific -- he's here.
14 i
15 MR. COSTELLO :
I'm a little miffed, but I'm here.
ER. SIESS:
No, you know what I'm talking about, 16 Jim.-
There are some very specific questions that they ought 17 18 to know.
They might know them, but let's keep -- what I am 19 getting at, I guess, is Dr. Okrent has complained a couple of-times about the SSMBP program that has been going on nov 20 l
for three years and you still haven't got the answers.
21 I
And I would say it would be awfully nice if on the 22 load combination program we got maybe a little bit of ar.
23 answer on some of these things within a year or so, to show l
24 the guys that we are going in the right direction.
I had my 25
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1 research hat on that time.
2 But of course, the ones you are disagreeing with 3 349 on may not be the most important ones.
An awful lot of 4 theirs came from 318 and that doesn't give me a hell of a 5 lot ;
confidence in them, either.
6 Let me run through my notes here on your 7 resolution of public comments.
Gee, I hate to raise th a t 8 question about number one.
That one seemed very familiar.
9 Position C.1 says that the ice condenser barrier and the 10 dryvell/wetwell barrier in the Mark II -- it didn't address 11 the Mark II'*..
Does that mean that the Mark III dryvell is 12 no'. considered a containment?
13 MR. ARNDT:
Your terminology gets somewhat
$4 fine-tuned at this point.
15 MR. SIESS:
Oh, it does say the Mark III.
I'm 16 sorry, I missed it.
17 MR. ARNDT:
Marx III is mentioned in the 18 discussion on page u.
But the dryvell is not considered a containment per se in the context that we have been using it 39 20 here today.
1 MR. SIESS:
It's not a leak-resisting element.
It 21 22 must contain the pressure long enough to make a bypass.
I know what we went through on the-Mark III as to how much the 23 leakage area should be and so forth.
24 MR. ARNDT:
There.are certain allowable bypass 25
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leakage for each one of those barrier designs.
2 MB. SIESS:
But now what is the position?
The 3 position says that you will follow standard review plan 4
3.8.3, and it says it will be reviewed on the same basis as 5 the containment.
And the language in the SRP really was not 6 absolutely clear what "the = ore basis meant."
7 MR. COSTELLO:
Professor Siess, in the design of 8 the drywell, we say because of the shape -- it's cylindrical 9 in shape, so we say the ASME division two code should be 10 referenced.
HR. SIESS4 Yes.
But there is nothing in division 11 12 two as far as the concrete design that really relates to 13 leak tightness, because any concrete containment has got a steel liner for leak tightness.
Now, the Mark III drywell 14 and the Hark II divider and the ice condenser divider z.re 15 16 unlined concrete walls, which can leak a certain amount of 37 the so-called bypass, would have to leak little enough that 18 the water will go through the suppression thing or the ice 19 chamber.
And you remember, we got into this argument on the 20 Mark III about what kind of testing, so when it says on th,e 21 same basis as the containment, there is no basis in the 22 containment design for leak rate, and I am not quite sure 23 24 why.
349 does ha ve crack control provisions.
I don't 25
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know how good they are.
But I think I would rather see some crack control provisions or crack calculation provisions 2
3 where somebody could compute that bypass leakage, because 4 somebody vent through those calculations on the Mark III 5 when we were arguing it out, than to simply say, do it like o
6 a division two, which doesn't have anything shown on it.
i-7 Division two has got a steel liner.
8 ER. ARNDT We do say in our discussion also that 9 in order to include these particular barrier structures to under the code, the following additional provisions are needed in the code.
And as you mentioned, one of them is 11 12 the provision for crack control under service loads.
13 ER. SIESS:
All of these are good.
ER. ARNDT And then to deal with the transition 14 15 area, and then, thirdly, to have some provision for s
16 preoperational and in-service testing of these barrier 37 structures.
I understand that at least one plant's tech specs do require that there 1 a preoperational test of the 18 br ;rier at full calculated accident pressure, and the-19 2r. subsequent 1f, whenever there is a refueling outage, retest 21 it again -a t a much lower pressure just short of where it would double through the suppres.sion pool.
22 EB. SIESS:
As I recall, all the Mark I7's are 23 going to be subjected to a full differential pressure by 24 sealing off the downcomers.
I ferget what was decide 1 on 25 ALDERSoN REPORTING COMPANY,INO, 400 VIRGINIA AVE, S.W. WASHINGTON O C. 2CC24 (232) $S4-2345
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the Mark III's.
2 But my point is that by saying in C.1 that you 3 von't use 349, but tha t you will use division two, I don't 4 think you vill find any more in division tio than you have s
5 in 349.
Division two is all oriented tosards strength with 6
~
7 the steel liner for leak tightness, and you would do a lot 8 better to work for some crack criteria in 349.
9 HR. ARNDT:
There is one significant~ difference to between the two approaches, and that is much grea ter controls, quality assurance or l'ispection control, I 11 12 believe, in division two, throur,n the process.
13 MR. SIESS:
That's fine, but if y ou 're not controlling the righ t thing it's not going to help you.
14 l-ER. ARNDT:
It's another level of control on a i
15 division two type of structure as compared with the AC-349.
16 l
ER. SIESS:
There is nothing in division two I can 17 think of that is gc'.ng to control the cracks.
l 18 MR. TAN:
On the service load, including that 19 l
under test pressure load, you realize the deficiency --
20 HR. SIESS:
Oh, yes.-
You say 3u9 would be better 21 22 if you had that.
But in th e meantime, we're throwing 3u9 away and referring to something that doesn ' t have anything 23 l
24 on crack control, either.
BR.~COSTELLO:
I think I can recall some of the 25 f
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1 history back to the previous issue of this guide.
As I 2 recall, the re was some thought about suggesting ACI 3%0 type t
3 of crack control.
4 MB. SIESS:
That's hydraulic strength?
5 HR. COSTELLO:
Yes.
6 HR. SIESS:
Sure.
7 ER. COSTELL0s But that was thought to be too 8 difficult to effect a bridge of sorts.
But the point..you g mentioned was well recognired.
10 MR. SIESS:
Basically what 350 says is, eep the 11 stresses down.
That's the way to do it.
You've got to put 12 a liner in.,
13 MR. COSTELLO:
Now, the history, as I recall, was 14 that the i tent of the 359 reference was to knock the ball 15 back into ite 359 court.
The argument that went on in the 16 359 Committee was, the staff says 349 does not have pressure 17 retention requirements built into its crack control 18 requirements.
The 349 Committee would respond But the divider barrier is not pressure retention.
And apparently 39 it hasn 't gotten anywhere since then.
20 ER. SIESS:
I think you have done a good job of 21 22 handing the ball back to 349, and I think they will pick it 23 up and do something with it.
But in the meantime, I think you are leaving the staff in limbo.
And I'm not sure 24 division one is any better way than -- offhand, I night 25 i
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accept the suggestion to go to ACI 350, which is hydraulic 2 stressors, which keeps the stresses down to about 20,000, I 3 think -- 16, which is fine, which is what those people have 4 been doing for years, either that or put a liner in.
5 ER. ARNDT:
That might be a point for us to 6 consider.
MR. SIESS:
But I wish 349 had been present today, 8 - and they ought to go to the next meeting.
g Incidentally, in the resolution of public comments 10 you have a couple of pages or so based on the old position 11 C.9, thet's the new C.6, which is very interesting, except 12 that it only addresses 6A, B or C -- the only thing it 13 addresses in there is the comments on C.16, mainly John Stevenson's comments that you made it more conservative.
14 15 But again, I think that about as far as -- there has to be some work done in getting these people together, 16 17 349, 359.
And I think Jim Costello has got some good proof l
for his load combination thinc.
18 ER. ARNDT I don't think the presentation in the 19 comment resolution was structured organizationally to 20 21 respond A, B, C and D.
ER. SIESS:.But you had comments on A, B, C and D, 22 and they don't really get responded to.
23 MR. ARNDT They are sort of responded to on a 24 load ba sis, rather than a --
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MR. SIESS:
Well, they don't address the E or the 2 EO items.
The B A item didn 't really get addressed.
3 Well, I will sunmarire my position.
The 349 4 docurent is in a state of flux.
It's constantly being 5 changed and constantly being improved, I think.
You have 6 taken exception to a number of things in here.
In some
~
7 cases I don't really believe your exception has got any a better basis than they have for theirs.
g On the other hand, where you do differ with them to it is in the direction of conservatism, and I have not got 11 any evidence that it is excessive conservatis=.
So I guess 12 I cannot argue too strongly.
I don't know the answer, 13 either, and your opinion is probably as good as mine or theirs, and yours tends to be clearly more conservative.
14 There are a number of positions that are 15 16 supportive, and there are a number which I think give a reasonably clear message to 349' of things that need to be 17 verked on.
That is a pretty good working committee, and I 18 19 have some hopes that as time goes on and we come out with these once a year there vill be some improvement.
20 l-21 I think just the fact that this guide exists nov
.s a pretty good step forward in getting some industryvide i
22 standards for a large portion of the structural work that 23 was pretty much left in limbo before.
24 So I will give everybody else a chance to ask 25 l
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1 luestions about things that they don't understand.
Max, do 2 :rou have one?
3 MR. CARBON:
Yes, I wanted to ask one about c regulatory position C.8, the testing of embedded piping.
5 Almost all of th e industrial comments were pointed at that.
6 Not all of them, but every commenter seemed to have one 7 comment th e r e.
And in the clarifica tie discussion you 8 point out that the ACI 349 Committee '.4s revised this 9 section and that you agree.
10 This implies there is no longer any difference of opinion between you and industry, but it does not say that.
11 12 Is that so?
Is the kind of revision the ACI group is coming 13 through with -- is this likely to be resolved such that industry will be reasonably satisfied also?
14 MR. ARNDT:
Yes.
This is an item, one of a couple
(
15 l
in here, where we reached a point of agreement with the 16 issuance of the 1979 supplement.
And the point that you 17 addressed here was in our f or-comment issue of the guide.
18 We have since struck it.
19 It is not in this particular package in the 20 21 regulatory position any longer, and we have responded to the public comments saying, we commented on what we had in the 22 public comment issue.
Subsequently th e
'79' supplement came 23 out with what ve-think is an acceptable position, and we 24 have since bought it.
We therefore dropped it as an item as 25 N.
ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W. WASHINGTON, D.C. 20024 (202) 554 2345
u1 1
a regulatory position and put something else in its place i
2 that we had a concern with.
t 3
MR. SIESSa 349 has industry represented.
4 MR. CARBON:
Well,-I know, but there are diff erent 5 segments of industry.
And sometimes just the word o
6 " industry" is too broad.
7 HR. SIESS 349 is a consensus group.
It's
~
8 supposed to speak for industry.
I was glad to see you get g that result, because I hadn't been able to do it in 318.
10 349 had picked it up from 318, and we had required testing 11 pipe to rome higher pressure than ASME vould allow, or vice 12 versa, I forget which.
And they were completely 13 incompatible.
You could not meet the ASEE pipe code and the 14 ACI code simultaneously.
15 And I asked the people at 318 if they could figure 16 out shere tr ' came from and nobody could.
It is still on 17 my desk, but at least your end of it is resolved.
You say 18 follow the pipe code and in the absence of that follow the concrete code.
So I thought <that was pretty good.
19 20 Any other questions about this, then?
( No response. )
23 ER. SIESS:
Well, I will suggest that we appr ove 22 O
it with whatever minor changes they have to make if ANSI 23 101.6, or whatever it is, is dropped, and that you keep 24 working on it.
And let me suggest that since we have a 25
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ALDER $oN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON. 0.C. 20024 (202) 554 2345
42 1
member of the Subcommittee that is supposed to be 2 knowledgeable on this subject, that as you make your changes 3 in the future, that you kee; him informed.
ER. ARNDT:
We agree that we vill do so.
4 5
MR. SIESS:
And if I spot anything that looks 6 really controversial, maybe we might want to say we want to look at it or we vill comment after it is or.t or something.
7 8
ER. ARNDT:
Certainly.
9 HR. SIESSt So we won't be just leaving it 10 completely up to you as to when to call something to our attention.
And if you would pass copies on to Sam, he vill 11 12 get them to me and I'll take a look at it.
13 MR. ARNDT:
We vill do that.
We vill also take the opportuni+;, Jubsequent to this meeting, to incorporate 14 15 a few of
- points that you made today which would aid in 16 the clarity of this.
ER. SIESS:
If you feel like rearranging Part 3a 17 little bit, which would be nothing but just rearranging 18 j
incidentally, the paragraph at the bottom of page 3 does not 19 apply to any position.
It doesn't say it doesn't belong in 20 i
Part B, but if I was rearranging them I would put it l
21 somewhere else, not between the two positions.
22 ER. ARNDT:
Its purpose was to highlight something 23 informationally rather than to take a position.
24 ER. SIESS:
It comments on 3u9, which is quite 25 9
w ALCEA$oN REPORTING CoMDANY,INC, 400 VIRGIN 1A AVE., S.W. WASHINGTON, D.C, 20024 (202) 554-2345
43 1
appropriate.
But it's not a position.
2 MR. ARNDTs We can sequence it better.
3 ME. SIESS:
I saw another one where people were t
4 awfully confused on things that were discussed in the 5 discussion, but not included in the position.
And I think 6 tha t is a question of policy f or you guys to settle on.
But 7 this was one reason I had proposed before that the 8 discussion was a commentary on the positions, in which case g the discussion would include anything that wasn't in the 10 position.
11 Okay.
We will recommend concurrence on this one.
12 Just go ahead with it.
Okay.
I'll put all my paper
~
13 together and we'll go on to the next iten.
MR. ARNDT:
Thank you.
14 15 MR. SIESS:
Do you want your copies of the 3ng 16 supplement back?
37 MR. ARNDT4 No.
If you don't want them, we can 18 use them, yes.
MR. SIESS:
The staff used to always ask for them 19 20 back.
I didn't have the supplement at home.
I was glad you 21 sent it.
22 Oh, there is one place in here you refer to 318.71 23 or something.
It's either in the resolution --
MR. ARNDT I don't recall-if it was a typo or a 24 resolution.
25 ALDERSON REPORTING COMPANY,INC, 400 VRG:NIA AVE S.W WASHINGTON. D.C. 20024 (202) 554-2345
un 1
MR. SIESS:
It's in a discussion of Appendix A of 2 318.
Let me see if I can find out.
'J e ll, I don't think 3 it's in the guide.
But let me check real quick.
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1 No, I don't see where it is right now, but it 2
referred to Appendix A as ' 71 and quoted from the introduction, 3
in the first section of it, and it's identical in Appendix A 4
of '77, 5
I You might check.
You have a reference for '71 for R
6 some reason, one of your references is 3/18/71.
R oS y
MR. ARNDT:
I don't see any particular reason to do so.
A j
8 MR. SIESS:
In ' 77, you did not give the ANSI i
'Ac 9
number.
That's references 13 and 2.
You might just check on E,
10 th at.
If I find where the reference to '71 was, I'll tel' vou.
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3 12 E
Testing of Instrument and Control Air Systems, forne rly g
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15 MR. MO RRISO'.i :
Right.
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MR. SIESS:
What is 1 and 2?
Is that zero?
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I7 MR. MORRISON:
It's just 1.68, then it starts out w
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IO I 1.68.1.
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What do the others cover?
I've i
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20
-torgotten.
4 2I That's all right, Sam can check.
I just didn't 22l check on it.
4 s
23 I have another letter here that looks like a couple 24 f of public comments.
Did everybody at cocies of these?
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3 25h From Houston Lighting & Power Company; Arizona Public d
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il ALDERSON REPORTING COMPANY. INC.
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2 MR. HINTZE:
Yes, we received those, and we passed 3
. those out at the beginning of the meeting.
4 MR. SIESS:
Okay, A1, you can bring us up to date 5
j on this one.
4 h
0 MR. HINTZE :
This guide was reviewed before this G
R 7
subcommittee in February 1978 and was subsequently issued s2 8
M for public comment on November 14th, 1980, d
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9 Comments were received from seven individuals P
10 j
during the comment period.
The discussion of the comments
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2 s
12 Subsequent to transmitting the guide to ACRS for
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review and concurrence, three additional sets of comments were E
14 g
received, and those were the ones that Dr. Siess just mentioned.
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In regards to those additional comments or additional sets of x
16 comments, I talked to each commenter individually, since our e
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the comments ear ty enough to be included, and so since these i
20 were not. included in the discussion, I talked with each one of 21-them individually.
~ 22 As f ar as Mr. Sumpter's comments regarding the i
23 total air supply demand being ambiguous and needs defining, in 1
24 i
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. guide "at normal steady state conditions following demand,"
ALDERSON REPORTING COMPANY. INC.
47 ar4-3 I
which would identify at what point we suggested.
2 MR. SIESS:
This is on which comment now?
3 MR. HINTZE:
These are the additional comments.
4 MR. SIESS:
And these are the additional changes?
e 5
g MR. HINTZE:
Yes, sir.
We are proposing in position 5 a
3 6
to add after " demand," that is "at normal steady state e
R 2
7 7
conditions, that's when the total air supply would be taking,"
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That 's acceptable to you, is what you 6
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me ant?
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Yes, sir.
He said simultaneous testing 12 i
is not necessary.
Individual testing as components are installed
^
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is sufficient.
Their big concern with that was that we wsre E
14 y
going to ask for a parametric study of how and when and the u
9 15 g
times analysis of how-each individual component in the system 16 responded.
e 6
17 0
When I explained to them what the purpose was, to E=
18
=
get an interaction between the various components, then they 19 j
were satisfied and they made no changes on the basis of that l
20 component.
t 21 On comment 8, or their comment in regards to the s
22 position 10, that simulataneous testing of components which 23 !
l required large air supplies was impractical, there are limitless
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numbers of. load combinations, Land they wanted large quantities 25,
j-of air defined.
Their concern was they could not identify the 4
l
. ALDERSON REPORTING COMPANY. INC.
48 ar4-4 1,
components requiring large air supplies.
I 2
The problem was what should the rest of the system 3
. be doing when they were testing it?
They would get different 4
answers if they just tested the large loads without anything g
5 else being operating, and so we suggested that it would be E
5 0
acceptable to us to add another phrase in position 10 which R
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says in the third line af ter " simultaneously," "while the s
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system is operating at normal steady state conditions," and d"
9 that was agreeable to us, and satisfied their comment.
?
10 MR. SIESS:
The same sort of thing, then?
E II MR. HINTZE :
Yes, sir.
k 12 i
MR. SIESS:
Go ahead.
=
13
=
MR. HINTZE:
Their comment No. 4 had to do with 3
14 2
the terminology safety-related vs. systems important to safety, 7
15 g
and it says it seems to ba beginning to have more items open
=
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We will have to concede that that comment e
17 certainly has a point.
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19 i
But we don't think this guide is a vehicle to n
20 I straighten all of that out.
21 MR. SIESS:
Have you got any idea what is?
22 MR. HINTZE:
In Appendix A, there is a very broad 23!
definition of what "important to safety" means.
Appendix B --
i 24 i.
currently we are proposing a revision to that, and it is s
25l' being prepared, which will make the language consistent with t
ALDERSON REPORTING COMPANY. INC.
ar4-5 49 l
I Appendix A, and use the term "important to safety."
2 MR. SIESS: It seems like what people want is a list 3
rather than a definition.
4 MR. EINTZE:
Yes, that's true.
S 5
MR. SIESS:
They have ruch a list on the Class 1 items.
E j
6; Doesn't one of the reg guides essentially have a list?
R I
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Yes, Reg Guide 1,29 has a list of j
8 what we classify as seismic category 1.
d 9
MR, SIESS:
Then I think that's what people are really
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10 looking for on "important to safety," somewhere short of E
5 II everything, but --
a f
I2 MR. EINTZE :
In addition to modifying our proposed l
13 modification to Appendix B, we are also in the process of
=
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.j 15 is going to use the term "important to safety" in the rulemaking
=
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I7 adequate guidelines for what is intended by that term, IO Mr. Van Brunt's comment had to do with the gradual P
I9 g
loss of air test as being unacceptable and unfounded, and does 20 not provide useful information.
21 My discussion with him convinced,him that was a 22 good test, and that we're willing to accept it on that basis.
23 l MR, SIESS:
He doesn't have a plant built yet, coes 24li he?
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ALDERSON REPORTING COMPANY. INC.
50 ar46 1
MR. HINTZE:
That might make a difference, I 2
suppose.
3 Mr. Leomis' comments regarding a requirement to the 4
defined air system, in talking it over with them, I found 5
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3 6
with what he was talking about.
They asked us to disregard those e
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The whole thing?
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Well, the first two comments regarding E
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the definitions.
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I thought Sargent-Lundy had a better d
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system for commenting on reg guides.
That QA is not operating,
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is it?
E 14 5
MR. HILTZE:
They were quite embarrassed about it.
Er 15 g
We recommend the guide should allow for appropriate testing to T
16 y
be done during other testing phases, and our response is we f 17 x
~ already do that.
We reference the parent guide, Regulatory 5m 18 Guide 1.68, which does provide that testing should be done
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after installation of structures, systems or components is 20 essentially complete, or to a degree that outstanding construc-21 tion items cannot. be expected to affect the validity of the 22 test.
23 i So I think we covered that already, and they were 1
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.s 25 'i Position C.6 on cleanliness requirements is ALDERSON REPORTING COMPANY. INC.
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insufficient, and they recommend we use an ISA standard, and 2
we agreed, so the ANSI standard ANSI MC 11.1, 19 7C or / ISA 7. 3 3
. will be referenced in position 6 as the quality standard for t
4 cleanliness.
5 MA. SIESS:
Those relate specifically to air?
A 6
MR. HINTZE:
Yes, sir.
And then the.r comment on R
7 position 8 discusses testing and testing sequences that lock in s
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definite methods.
They suggest we should recognize alternate d
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merhods, and I think ue really do, in all guides, or most guides,
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3 Y
I2 hm. SIESS:
You always recognize alternate methods?
13 MR. HINTZE:
Yes, sir.
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I4 The most significant change to the guide then is the u
e 15
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addition of position of C.11 which came at the suggestion of one
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Functional testing of e
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5 3
18 ensure that credible failures which result in an increase in
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I9 pressure in the supply system will not cause peak transient M
20 pressures above the design pressure of the system.
2l There have been some incidents where overpressure of 22 an air system has caused some sort of sticking of some of the 23{
components and caused them to malfunction during normal operation!
)
24 and so on.
25 We think that is a good test and, therefore, added F
ALDERSON REPORTING COMPANY. INC.
ar4-8 52 II it to the guide.
2 l
- 12. SIESS:
Ar. ; the second line in that, would you 3
have any objection in changing that "which" to a "that"?
4 MR. HINTZE:
Do I have any objection?
No.
5 j
MR. SIESS:
Do you have the editor here?
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6 VOICE:
Yes, sir.
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7
' IR. SIESS:
Are you the editor?
Okay.
f8 In connection with your responses to the public d"
9 comments on page 3, comment 6 and your response to Mr. Councill 's 3
10 comment related to tests following maintenance, it did not seem
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It just said S
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maintenance where you had changed the words to indicate the e
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That's Northeast Utilities.
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Before you leave Councill --
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to
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MR. SIESS:
He said verification of air quality is j
always included as part of an acceptance criteria, as part of 21 an air compressor guide.
No, C.2, C.3, I believe.
He says 22 the verificatory testing described in' items 2 and 3 is 23 i
performed during the start-up and testing.
Additional testing
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following maintenance should be restricted to those components 25l where maintenance was performed, and it didn't seem to me that
' ALDERSON REPORTING COMPANY, INC.
I ar4-9 53 your response really responded to that comment, because there I
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2 are requirements to duplicate those tests following maintenance; 3
. right?
4 MR. HINTZE:
Yes.
We had another comment on what 5
y dose mean by major modifications, and we tried to clarify that.
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But your response is not correct.
It R
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I guess " unnecessarily" is the operative word there?
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Yes.
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Okay.
You just didn't go on.
I see 3
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what you mean.
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Yes.
On the next to the last paragra=h l i
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1.68.3 will dwarf the most complex integrated tests presently e
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being performed in the industry."
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MR. SIESS:
Mr. Councill doesn't make any other kind.
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Have you discussed this with him?
22 MR. HINTZE:
No, I did not talk to him personally k
23 4 g
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24 I MR. CARBON:
Does thut statement trouble you?
Does 25 i l
9
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l ALDERSON REPORTING COMPANY. INC.
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ar4-10 54 1
something here that is just impossible, essentially?
2 MR. HINTZE:
I took it more to mean that it would 3
dwarf what they are currently doing, as far as ch cking the 9
4 systems out, and that's true, because they are doing, as I e
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understand it, very little.
So to ask them to do something n
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would be --
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7 MR. CARBON:
But it's in that category.
n 8
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Yes.
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I think there is more to it than that, eh 10 E
because if you read back earlier in his letter, I think he is
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concerned about some of the tests, some of the requirements d
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of testing feeder lines and testing various combinations and E
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systems, where he says something about a large number of E
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combinations of permutations, and it was almost an infinite
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number.
I think he said something about that in here.
16 The analysis part you got rid of, didn't you?
i 17 g
MR. HINTZE:
Yes, sir, much to the dismay of some C
2 18 4
g people.
I 19 g
MR. SIESS:
I'm sorry, that was in connection with 20 the analysis where he said the scope was infinite.
It's not 21 in connection with the test.
The 1.68 series -- how has 22 it worked out so far?
This is mainly < hat?
I&E enforces this, 23 i
I guess, anti where does this come in the PSAR?
Chapter 14, in i
24 g.
the start-up test?
Does it come in Chapter 14?
s 25 :
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FLR. NATT:
Jim Watt.
ALDERSON REPORTING COMPANY, INC.
ar4-ll 55 I
Pre-operational testing of the safety systems is 2
covered in 1.68, 1.79 and some of the others.
Chapter 3
14 is where those are addressed.
f 4
MR. SIESS:
And I&E then checks on their inspections 5
g as to whether these things are being done?
9*
3 6
MR. WATT:
They confirm that the tests have been R
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performed.
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8 MR. SIESS:
Has I&E found the 1.68 series helpful N
9 so far in their work?
Z h
10 MR. hATT:
I can only speak from hearsay, but
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12 E
had not been effective, and that was why it was being developed 4
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Because they are really the users, N
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z d
I0 MR. MORRISON:
Yes.
e h
II MR. SIESS:
I just wondered what kind of feedback 5
3 18 you get from them.
k II 2
MR. MORRISON:
Well, as you recall, we had a major 20 revision of the basic 1.68 guideline, the large amount of feedback 21 from I&E experience.
MR. SIESS:
How has it been working since you got it 23 l out?
4
_(
MR. MORRISON:
I can only say we haven't got any 25 l requests that I am aware of for further revisions to it.
1 ALDERSON REPORTING COMPANY. INC.
J 56 cr4-12 i
II MR. SIESS:
That's good, because the object is to 1
2 make the job easier as well as better.
I think this one is a 3
step in the right direction.
We have seen enough air problems 4
in the past two or three years to last u.
for a lifetime.
g 5
I don't have it with me, I gave it to somebody here, 9
3 6
{
but I just saw one from a plant that has been in operation n
i 7
-- I think it was Millstone 1 that got the grit out of the n9 8
M dehumidifier or something in their air system and loused the d"
9 whole thing up, and I can't understand why it waited six years E
10 g
to happen.
=
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It was some plant rhat's been operating about six 12 E
years, and they fouled up a bunch of solenoids.
I rhink it 13 g
happened three times before they found out what was causing it.
E 14 g
They thought it was sand.
x 9
15 g
They had analyses made, and finally found out he 16 g
stuff in the dehydration column, the dessicated column, would l
h decompose under use, but why it took six years to happen, I x
5 18 don't know.
There's nothing that said they changed the material A
19 '
j or anything else, and it bothered me, because usually I expect l
20 '
l things to happen in the first year or so.
t 21 MR. CARBON:
I have one more comment here.
I don't 22 l know Councill.
Maybe he makes strong statements, but he is i
23 '
the senior vice president from what I would consider a rather i
24 i g
successful power plant operator, and I would think it might be s
25 i appropriate to at-least look into his co= ment in a little more l
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ALDERSON REPORTING COMPANY. INC.
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MR. HINTZE :
I can do that, yes.
3 MR. SIESS :
I will second that, because I get all 4
of Northeast Utilities' correspondence, since I have both 5
j Haddams Neck and Millstone 1 and 2, and they write very good e
6 letters and long letters and complaining latters, and one of R
R 7
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does.
jc h
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some cases.
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They are very well reasoned letters.
I cannot really z
16 g
judge them, you know, from the basic data that well, but as Max 17 says, they are running two plants and they have got quite a few E*
years of experience behind them, and I think they have done a
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pretty good job and have said some things that are worth 20 listening to.
21 They are soma of the more constructive criticisms I 22 have seen.
23 '
I think it's very encouraging we got a comment
(
from General Electric that leads to an addition to a reg guide, 25 i
rather than a deletion.
l l
ALDERSON REPORTING COMPANY. INC.
1 i
ar4-14 58 i
l Ii (Laughter. )
1 2
Safety is not something the NRC can do all by itself.
I 3.. g,.ve got ro have help.
I 4
MR. MATHIS:
Chet, I have a couple of questions.
i.
5 g
MR. SIESS:
on other than "important to safety"?
n I
6 MR. MATHIS:
Yes.
On these tests where you either l
R R
7 gradually decrease or increase the pressure, I fail to see n
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What are you going J
9
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pressure increases, and I guess my que.stion is, other than 13 g
find the leak, what are. you going to do about it?
What are you e=
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x 2
15 x
MR. HINTZE:
I have always thought that it would z
g.
16 verify that it worked as you designed it to do.
Most valves, I 17 think, are designed to what they call fail-safe.
You can either z
18 say, well, vi designed it that way, and therefore it's going to i
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work that way, or you can perform the test to see if it does.
20 So that's one thing you can verify that works as designed.
21 MR. SIESS:
Now is that really what you =eant when 22 you had the analysis in there that _you took our in two places?
23 Because you want to see whether it works as it was analyzed to i
24 1
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do?
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1 2U1. HINTZE:
One of the problems that our licensing I
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took it out.
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But there are no surprises?
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Is there a possibility that somebody 22 assumes when there is a drop in air pressure, everything fails 1
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That's the unsafe interaction you would i
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Without an analysis -- if they don't 3
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That experience will undoubtedly help us 3
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There is one other point in here, and
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Is this in the scram system?
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That could be done periodically.
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So you may have others like that.
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A good design for tripping, but not a x
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fou say it should not be 25 too difficult to measure the total flow at tne outlet.
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He thinks it's easier to calculate it 2
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A general question:
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meeting on guides and comments on that; am I correct?
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On 1.97 we did, yes, sir.
3 MR. SIESS:
Have you got any criterion of when you t
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One rer. son we send it back to the
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25 MR. CARBON:
Well, I encourage what apparently is a 1
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This guide applies the pre-operational 3_!
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That in usually correct, in tech specs.
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The answer is there is no regulatory 22 guide on periodic testing.
1 23 l MR. SIESS:
There just hasn't been a need for it.
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Okay.
I'd like to nitpick just a little s'
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on page 2, under B, the third paragraph, you have 2
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testing verify that the design will respond appropriately."
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I tried to get rid of analysis.
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In the last line on that page, pre-l E
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This is a pre-operational test, so you want to make l
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What you want it.to do is the right thing when you i
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That's right.
And it seems to me futurity i
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Do you not want to say "will 3
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Especially in the discussion.
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Where the intent is intended.
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2-3 comes out.
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Okay.
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I get your purpose now, t
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you say here that the guid( presents pre-operational testing 20 provisions for instrument and air systems and so on, to help 21 ensure the instrument and air system components have been i
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25 MR. WENZINGER:
The initial testing does, to a l
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limited degree, confirm that the design is adequate.
2 MR. RAY:
But the design can still have deficiencies 3
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Whether or not they will perform is what f
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Is that your purpose in the value of it?
It I4 seems to ha it's to ensure that it does perform, period.
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some place, or where are they, or what are they, where it is 20 specified that the instruments and control air systems are 21 important to safety?
Is this in the CFR, the Code of Federal 22 Regulations, some place?
23
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It should be in the General Design 4
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25 li MR. RAY:
Do the users get the GDC?
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MR. SIESS:
Oh, yeah, that's in Part 50, 2
}LR. RAY:
It's under the Code of Regulations then.
3 MR. HINTZE:
Whether it's important to safety or not 4
depends on what you design it to do, what its function is.
Maybe 2
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The indication I got of this guide, or R
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Instrument and air system has been E
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Some of them.
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The final resolution to me would have 21 been a simple indication somewhere in your discussion that 22 the CFR or GDC requires or specifies that the instrument and i
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That should be in the introduction.
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We mentioned criterion 1 in the introduc-1 2
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You have to know what they say in order 4
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One of the problems with our system is M
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The design er teria does not call out x
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how you do it, it specifies what they do.
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20 certain functions, then they are important to safety.
21 Air systems in general have not been considered by 22 the applicants as safety syctems or important to safety.
23f MR, SIESS:
Because they assume if they were lost, 1
24 everything failed-safe.
25 MR. KINTZE:
That's right.
We are trying to say, now, I
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they have f ailed safe and you have to test them, and that's 3
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Your response in general implies that the 5
two systems are important to safety, period.
But why?
Where?
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When?
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clear without equivocatic; that these are important to safety, 5.
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doesn't mean anything.
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I think the last sentence of the 24
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to ensure the reliability and functions important to safety.
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I don't think the last sentence in the 3
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Let me read it.
It says:
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Commission's regulations mus t specify what's bothering me.
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Proper operation.
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ALDERSON REPORTING COMPANY. INC.
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the operability and functions important to safety in the 2
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Jerry, simply to say flat out it is now a
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It's supposed to implement a graded 16 y
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But it hasn't been used there.
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I can't go so far as to say it 21 hasn't been done.
Any responsible organization or utility 22 has to use a graded system.
23 MR. SIESS:
The point I'm trying to make is the 24 i
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get the regulations straightened out.
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MR.WENZINGER:
As Mr. Hintze mentioned, there is 2
work underway tc do that.
MR. SIESS:
I hope we come out with two grades.
We 4
used to have a seismic 1-1/2, if I'm not mistaken.
It's a 5
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Yes, another question.
This one, too, is a 20 nit, but did you say that the section discussion of public 21 comments has not been looked at by your editor?
22 In any case --
23 '
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.The revisions have not been, no.
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In the wri,teup, there is at least one 25 s place of poor grammer and anot'er misspelled word.
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You are absolutely right.
The discus-2 sion of public comments was not.
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That never goes beyond the Public
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That's a good comment.
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Anything else?
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Nothing in May.
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Is this likely to stand up 21 under the new organization?
22 MR. MORRISON:
Yes, cir.
The new organization will 23 not come up with any in the next couple of weeks.
24
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Not move any faster than the old 25 '
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MR. MORRISON:
Unless Research suddenly has some 2
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regulauory guide.
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Hot research information should never 3
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20 out an errata to Regulatory Guide 1.97 to defer the implementa-21 tion date for those instruments pending the results of the 22 additional information that is being developed, including that that we expect to get or NRR expects to get from a contract.
24
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Do you 'want to add anything to that?
25)
StR, HINTZE:
He's got a copy of it.
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ALDERSON REPORTING COMPANY, INC.
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MR. SIESS:
I'm just reading it.
Let's take a minute 2
to read it.
3 On that item, I don't see any objection to that.
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delay implementation for a reasonable time after you know what 3
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regulatory guide.
I think that was based en the discussion d
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We thought that, inadequate guidance was
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21 Well, I think the committee will probably have 22 serious doubts that the emergency response facilities with all 23l the Reg Guide 1.97 instruments in them can be completed by n
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That's to design the 25l system, procure it, inspect and install it, check it out.
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l have seen some esti=ates on other things and it just looks --
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It's in the implementation letter f
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that transmits the requirement.
I think, Dr. Siess, what the 5
Staff is basing that date on is the f act that way back in ' 79 n
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the utilities were put on notice that these facilities were R
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they can't get delivery on the darn things.
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MR. FIMT E:
You won't find it in there, Sam.
It's 4
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It's in a letter that went out February the 18th, I
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I don't think this will give us any problem.
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20 after the full committee and there wasn't any way to handle it, 21 I guess.
22 That is going to happen from time to time.
It's 23 hard enough to go to the full committee.
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Do you have to look it up?
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I was reaching for the microphone.
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20 MR. SIESS:
Under your group?
21 MR. WENZINGER:
No, in a different division.
22 MR. MORRISON:
That's in Division of Engineering a
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Technology.
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Yeah, I know it is.
4 So most of the Division 1 s tandards will -- what do 5
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They have a siting and environmental x
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It looks like some of the
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20 MR. MORRISON: Right.
21 MR. SIESS:
That's not too far off.
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So we didn't lose any of our friends, did we?
23 i
MR. MORRISON:
Who a re your friends?
24 !
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25 MR. SIESS:
Well, some kind friends, anyway.
Anybody i
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82 0:5-20 I f that doesn't bring any reg guides in May are my friends.
2I I don't know whether Sam mentioned it, but there is 3
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That shouldn't bother us.
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I would think it would depend to a 21 large extent on the amount of material that you have to review.
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Half a day we can squeeze in here, but a I
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hank you, gentlemen.
The neeting is adjourned.
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Mr. Samuel J. Chilk Secretary to the Cornissioners
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Dear Mr. Chilk:
COM;iENTS Oil REGULATORY GUIDE 1.68.3 PRE 0PERATIONAL TESTING 0F INSTRU".ENT AIID C0flTROL AIR SYSTEMS Houston Lignting & Power Company has reviewed the above Regulatory Guide and offers the following corr.ents:
1.
Regulatory Position C.5 calls for the nessurenent of the total air suoply demand. This can be determined at the "steadv state /
nomal" mode of operation. There are no practical methods avail-able to measure the total air suoply demand for all oossible operatino conditions. There is an almost limitless nunber of combinations of loads and sequences of operation which nicht s
qualify as the total a'ir. supoly derand at.any one tice. The
. term " total air suoply demand" is ambiguous and should be-defined as to preclude misinterpretation.
I 2.
Regulatory Position C.8: Sinultaneous testing of the.instrunent l
and control air systen should not be necessarv.
Individual l
testing of the air operated valves as thev are installed should j
be sufficient to verify their proper response in a loss-of-air-supply event.
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3.
Regulatory Position C.10: The requirenent for coerating conoonents requiring large cuantities of instrument ana contrul air simul-taneously is imoractical. There are alnost limitless conbinations of loads that would require testing under this position. The statement "large quantities of air" needs to 50 defined for clarification.
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%uston tiftic.3 & n:mer cer: pry Mr. Samuel J. Chilk U.S. Nuclear Regulatory Cc=ission Page 2 4.
General Coments: The shift frca requiring preoperational testing of safety related systens to systems that are i=:ortant to safety is beginning to have more and more ite=s caen to interpretation.
It is felt that some guidelines are needed to identify those ite s which are important to safety.
1 Very truly yours, r
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J.R. Sucpter Manager Nuc1 ear Services Depart ent BIB /kw e
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snr.cs Attention:
Docketing and Service Branch N'#
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Subject:
Regulatory Guide Cc=ents on Proposed Revision to R.G. 1.S3 (To Be Issued as Regulatory Guide 1.58.3)
File: 81-010-026
Dear Sirs:
Arizona Public Service Cc:npany has reviewed the subject Regulatory Guide. Our coments are attached.
Very truly yours, E. E. Van Brunt, Jr.
APS Vice President, fluclear Projects AtlPP Project Director EEVBJr/flEM/av Atti-hment
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J. Vorees (w/ attach.)
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Atomic Industrial Foru:n (w/ attach.)
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Attachment to ANDD-17256 - JMA/NEM February 9, 1981 Comments Comments on Proposed Revisicn to R.G.1.80 (To Be Issued as R.G.1.68.3) i C.
Regulatory Position 8 The requirement of the gradual loss of air test is considered to be~ unacceptable and unfounded. This test does not provide useful information for the plant operations staff and would be a lengthy and costly test to perform. For this reason, we reccmmend that this new requirement not be in the new Regulatory Guide 1.68.3.
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February 17, 1981
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fL't AC,a-4 Secretary of the Cormission U.S. Nuclear Regulatory Cornission Washington, D.C.
20555 Attention:
Docketing and Service Branch
Dear Sirs:
Enclosed are our cor ments on Proposed Revision to Regulatory Guide 1.80 (To Be Issued As Regulacory Guide 1.58.3),
Preoperational Testing of Instrument and Control Air Systems Task RS 709-4.
We appreciate having been given the opportunity to cor. ment.
Yours very truly, h
J.
. Loomis, Head Nuclear Safeguards &
Licensing Division l
JSL:LAL:cjr l
Enclosure Cooies:
R.'F. Janecek (1/l)
G. P. Wagner (1/1) d,,g'i.,
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PROPCSED REVISION TO REGULATORY GUIDE 1.30 (TO 3E ISSUED AS REGM ATORY GUIDE 1.63.3) v...S.,.-sL,;.u-Or A
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AND CONTROL AIR S*! STEMS TASK RS 709-4 General 1)
A definition is required for the terms ' instrument air system' and ' control air system.'
2)
The term " LOAD" is ambiguous.
A definition of how this word applies would help clarify this guide.
3)
Several conponents and syste= test requirements, that
~
are to be tested as part of preoperational testing,are discussed.
We recc==end that the Regulatory Guide shculd allow for appropriate testing to be done during other testing phases, as long as documentatien require =ents are satisfied.
Itens that could be tested during the construction phasa could be relief valve setting, and s v. s t e m.c l e a n i n e., etc.
Specific-Paragraph C.6.
Cleanliness recuire=ents are insufficient as provided.
The regulatory guide should reference or endorse an applicable standard such as standards issued by ISA (Instrucent Society of A= erica).
Paragraph C.B.
This paragraph discusses testing and testing sequences thrA diock-in" definite =ethods of testing to be accomplished.
This item should recognize alternative =ethcds that may he acceptable to the intent of this section but performed caring circu= stances Eb.at are more efficient or dictated by plant specific circumstances.
Due to unique situations that may arise, we recc==end that the Regulatcry Guide should allcw more latitude by each plant to perform test (s) that meet _ the intent of this paragraph.
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