ML19347F417
| ML19347F417 | |
| Person / Time | |
|---|---|
| Issue date: | 07/16/1979 |
| From: | Chilk S NRC OFFICE OF THE SECRETARY (SECY) |
| To: | Gossick L NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| Shared Package | |
| ML19347F399 | List: |
| References | |
| FOIA-81-97 NUDOCS 8105190221 | |
| Download: ML19347F417 (1) | |
Text
{;~.,,jo 1htb Mcs19 UNITED STATES
/..:
N'UCLEAR REGULATORY COMM[CTION M
e n
h W ASHINGT ON. D.C. 20555 q
du *-
/
July 16, 1979 CFFICE OF THE i
SECRETARY MEMORANDUM FOR:
Lee V. Gossick Executive Director for Operations FROM:
amuel J. Chilk cretary s
SUBJECT:
DISCUSSION OF UCS PETITION ON QUALIFICATION OF ELECTRICAL EQUIPMENT AND RESPONSES TO IE BULLETIN 79-01, 1:35 P.M., WEDNESDAY, JULY 11, 1979, COMMISSIONERS' CONFERENCE ROOM, D.C. OFFICE (OPEN TO PUBLIC ATTENDANCE)
The Commission was provided a summary of and a status report on corrective actions resulting from licensee identifications of unqualified electrical equipment and was informed that guidelines and acceptance criteria for final reviews of electrical equipment gaualifications will be completed in September 1979.
Commissioner Bradford expressed the view that adequate enforcement mechanisms should be developed to ensure that the cuidelines and criteria to be developed in the staff are implemented in a timely manner by licensees.
(ELD /IE)
(September,1979) cc:
Chairman Hendrie Commissioner Gilinsky Commissioner Kennedy Commissioner Bradford Commissioner Ahearne General Counsel Acting Director, Policy Evaluation k240Le$f / spy, qT quY 9
9 G-8105100 SN N
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2 I
CR5872 UNITED STATES OF AMERICA 2
NUCLEAR REGULATORY CO.'e ISSION 2 g!
4' y
PUBLIC MEETING
$j DISCUSSION OF UCS PETITION ON QUALIFICATION OF 6
ELECTRICAL EQUIPMENT AND RESPONSES TO IE BULLETIN 79-01
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7 8
Room 1130 9
1717 H Street, N. W.
j Washington, D.
C.
Wednesday, 11 July 1979 The Commission met, pursuant to notice, at 1:30 p.m.
12 PRESENT:
13 g;.;.:
DR. JOSEPH M.
HENDRIE, Chairman 14 VICTOR GILINSKY, Commissioner 15 RICHARD T.
KEdNEDY, Commissioner 16 PETER A.
BRADFORD, Commissioner 17 l
JOHN P. AHEARNE, Commissioners 18 ALSO PRESENT:
19 Messrs.
Jordan, Butcher, Hoyle, Stello, Lieberman, 20 !
Snyder, Moseley, Gossick, Denton, Eisenhut, and Moore.
qq0<d I
23
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C?3S72:
DISCLAIMER This is an unofficial transcript of a meeting of the United States Nuclear Regulatory Commission held on Wednesday,11 July 1979 in the Commissions's offices at 1717 H Street, N. W., Washington, D. C.
The meeting was open to public attendance and observation.
This transcript has not been reviewed, corrected, or edited, and it may contain inaccurncies.
- .;g The transcript is intended solely for general informational
(
purposes.
As provided by 10 CFR 9.103, it is not part of the formal or informal record of decision of the matters discussed.
Expressions l
of opinion in this transcript do not necessarily reflect final determinations or beliefs.
No pleading or other paper may be filed with the Commission in any proceeding as the result of or addressed L
to any statement or argument contained herein, except as the Commission may authorize.
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SELTZER /Mml Il P R O C E E D I :: GS fl cr5872'
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COMMISSIONER GILINSKY:
The Chairman has asked me lo
!' 'i to proceed.'He is unavailable. He :hould come in in the course 4
of the-meeting.
5
Mr. Kennedy, I understand, Also asked that we
-6 proceed and he expects also to be coming in soon.
i 7
So, why don't you go on with the briefing that yo:
1 l
8 have prepared.
l 9
MR. GOSSICK: F'ne.
10 I have asked Victor to introduce the speakers.
1 II MR. STELLO:
Okay.
12 The purpose of the briefing this af ternoon is' to 13 provide the Commission with the status of the review of the
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,iiii' Id qualification of electrical equipment, specifically with 15 respect to the responses to I&E Bulletin 79-01.
16 Review is still ongoing. Therefore, the nature of I7 the presentation today will be status report. It will be 18 concent'.ating on the two aspects of the bulletin; one which I9 required a 24-hour report of any deviations, where there was i
20 not -- unqualified equipment identified, as well as a comprehen'-
2If sive review of all electrical equipment.
22 Ed Jordan and Ed Butcher will be doing the briefing.
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t 23 Ed?
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MR. JORDAN:
- Okay, p? lArat Rrporters, Inc.
J 25 May I have th.e first slide, please.
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(Slide)
Y 2
The purpose of the bulletin, 79-01, which was
~
issued in February 1979, was to cause Licensees to identify 4
all electrical equipment which may be subjected to the 5f accident environment, and then review the qualification of I
6 each associated component and to verify that the required 7
safety related equipment will function if called upon.
8 The Licensees were requested by this bulletin to 9
review the documentation against the FSAR action environment, 10 and against the FSAR commitment for qualification.
11 WHere documentation was not available, Licensees 12 were to perform analyses or tests to verify thatqualification 13 was indeed existent.
14 The Bulletin was issued subsequent to Regional 15 Office followup on the circular 78-08, which was issued ~in 16 May of 1978.
The Circular required essentially the same thing 17 but did not require responses from the Licensees and didn't 18 give the timeframe.
19 COMMISSIONER GILINSKY:
Is that the difference 20 between a Circular and a Bulletin?
21 MR. JORDAN:
Primarily, yes.
22 The Bulletin notifies the Licensees --
23 MR. JORDAN: Yes.
24 It requests the Licensees to perhaps perform a (c.... 3.,c reponers, sne.
25 review, but doesn't require the Licensees to advise the l
I
4 a
. _c 5
Ih Commission of the results of that review, and it doesn,'t mm3-t g
2 j; normally specify timef rame.
ei L
COMMISSIONER AHEARNE:
Is it fair to say then that t
4 it is a distinction of how important you think it is?
a 5l MR.. JORDAN: True. That's right.
6 COMMISSIONER AHEARNE: Then what led to the conclusion 7
that what happened between May and February -- to reach the 8
conclusion --
9' MR. JORDAN: Okay.
The inspectors were following 10 up on the Licensees' action with regard to the Circular, and 11 they-found unqualified limit switches on the safety systems 12 inside containment existed in addition to those that had been 13 previously identified'in another Bulletin.
..m Ex--
14 They also found that in some cases Licensees were 15 unable to provide documentation to indicate that certain 16 components were. qualified such as transmitters, electrical 17 cables, motor insulation, cable splices and whatnot, so that 18 thing were not progressing as rapidly as we thought they should.
19 Well, that was the basis --
-20 COMMISSIONER GILINSKY: Could you tell me why we 21 went out with a Circular in the first place, because this 22
'followed our learning that in fact there had been unqualified
- W.%
23 equipment on reactors, didn't it?
l l!4 MR. JORDAN:
I believe that the thinking was that we i h,.i t wo.we inc.
25 had several bulletins that had hit specific issues, like limit,
9 3 v
ll 6
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. switches or components,and that a Circular which descr,ibe d --
2 requested the Licensees to examine the whole system, would
-suffice, and then our inspection program would followup on 1
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40 the-Circular.
5 1' 30.I think it is simply that we have matured somewhat 6
in the way we approach this.
7 COMMISSIONER BRADFORD: Well, wasn't the maturity 8
helped by the fact that the response rate to the Circular wasn' ;
9 all that good?
10 MR. JORDAN:
That's correct.
II COMMISSIONER AHEARNE:
But I thought that you didn't 12 have ' o have a response to a circular.
c 13 MR. JORDAN: Response meaning what the Licensees
<; is.
I'I did, not a written response.
II COMMISSIONER BRADFORD:
Let's see.
So that not I
only did they not give you written responses, but they also didn't.
I7 do' enough?
18 MR. JORDAN:
That's correct.
And they were doing I9 it at different rates.
Since we didn't specify the rate, then 20 Licensee X was taking it to heart and doing it fast, and i'
2I l Licensee Y was taking his time.
22 Okay.
The objectives of the Bulletin.
23 Next slide.
24 R..
(Slide)
.,.etet Reporters, Inc.
25 We discussed it.
They were to expedite the.
- I! -
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o-sm5 1;[ Licensee review of the electrical equipment qualification.
n 2
And now they require reporting on the part of the Licensee.
7 First of all, it caused them to promptly. evaluate 4
and report identification of unqualified equipment with'in
-5 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of that identification, followed by written --
l 6
COMMISSIONER GILINSKY:
Let me ask -- how do these t
7 Bulletins differ from previous Bulletins?
l
\\
8 Were the previous ones specific with regard to certain 9
kin..s ofequipment?
10 MR. JORDAN: Yes, we had two previous qualification-Il type Bulletins that were specific to like limit switches, a 12 particular type.of limit switch, a particular component.
13 And now this Bulletin we are saying, look at all 14 of your components that are required to function in an 15 accident environment and establish that they do have 16 qualifications.
17 So it was much, much broader.
I 18 MR. SNYDER:
Is it fair to say, Ed, that the 19 timing on the circular now of May 31st -- in fact it does 20 quote very 'strongly from the Commission's decision of April 21 13th, you know a couple of weeks before, a month before in 22 which it reflectec: that there was still an unsatisfactory 23 pattern ongoing.
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24 MR. JORDAN: Yes.
I a.;_u...: n poems, Inc.
25 MR. SNYC '.R :
A b:.ader kind of thing rather than ie n
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10 specific and-you quoted very heavily from the Commission's
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h 2( -order in the Circular and the Bulletin which followed up on, fi
- l just basically repeating the Circular, I' think.
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- 4 l
MR. JORDAN:
That's correct.
S' Okay.
So the Licensees were then required to l
6 include in.this 24-hour, 14-day report, an evaluation of-7 their basis for continued operation if they chose to continue 8
operating with components they identified as unqualified.
9 Ed Butcher will describe in a little more detail 10 later on the msults of those reviews. Some 31 plants identified!
11 and reported on unqualified equipment as a result of that 12 Particular phase of the Bulletin.
And this was distributed 7
13 in time over the time from issuance of-the Bulletin in February, 14 until the recent past.
15 COMMISSIONER AHEARNE: The qualifications that you 16 are holding them to are what?
17 MR. JORDAN: The qualifications are the FSAR 18 requirements, the discussion in the FSAR about the accident 119 environment.
20 COMMISSIONER AHEARNE: They don't refer specifically.
21 then to any IERS standard?
I n-n_
22 MR. JORDAN:
The later plants would, but the older
~
l P ants would not, 23 y
24 COMMISSIONER AHEARNE: And the later plants would
$[.Seret Reporters, tric.
25 end up referring to which then?
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- l l. mm7 1 E MR. JORDAN:
To the 1974 --
2 MR. STELLO:
'71.
The later operating planto in *71, 2
MR. JORDAN :
Okay.
y 4
COMMISSIONER AHEARNE: And none of them really 5'
referred to '74, for example.
e 6l MR. EELLO:
No.
l l
7 COMMISSIONER BRADFORD: What would typical language 8
be in the FSAR of a plant that was not committing itself to 9
1971 standards, but was just making a more general commitment?
10 MR. JORDAN: Well there would be a statement in the 11 FSAR as to the accident environment itself, the tcmperature in 12 the containment.
For instance we go to general radiation 13 levels.
=
14 COMMISSIONER BRADFORD: So that might actually be I
l 15 l more specific than would be involved sirply in a commitment 16 to meet the '71 standard?
17 MR. JORDAN:
That would be plant specific and have 18 less detail than the IEEE standard, i
19 COMMISSIONER BRADFORD: What kind of detail does 20 the IEEE standard have?
21 MR. JORDAN:
I will let Ed answer that.
22 MR. BUTCHER: I think the question is, what would 23 be in the FSAR for a plant that was not committed to the 24
'71 version of the standard, h=.Jeral Reporters, Inc.
I 25 And what would be there would be a specification k.
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p mm8 1j of'the environment inside containment, and the. design, basis 2:
of that temperature,-pressure, radiation --
3 COM:IISSIONER BEADFORD: That sounds more specific b
4 in fact than just the IEEE standare as of 1971.
5.$
MR. BUTCHER:
In those plants that did reference I
s 6
the standard as a basis for licensing, that information would 7
also be there.
The LOCA environment would have to be specified 8
in either' case.
9 In the case of those plants that reference the standard,-
10 there would be a further statement that would say the equipment II would be qualified 6 function in this environment in accordance, 12 with the provisions of the '71 version IEEE standard 323.
13 In the case of plants previous to the standards, 14 what it would say would be qualified to function in this l
15 environment, without specifically specifying a standard.
i 16 MR. JORDAN:
The next thing that the Bulletin 17 required was a report in 120 days of the Bulletin on the 18 documentation of the determination of qualifications of the 19 components, all of the components that are subjected to an 20 accident environment.
And these responses were due Jum 15th.
4 21 The final objective of the Bulletin was to feed back t
22 generic issues of unqualified equipment to all Licensees, 23 and we issued a revision to this Bulletin on June 4, which
,/..
24 fed back to Licensees the specific problems with ASCO solenoid 3.53er:1 Reporiers. Inc.
25 valves in which internal components had been found not to be
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'l [ environmentally qualified for radiation or temperature i
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Aa-
.il resistance at'certain pla'nts.
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And so, because these valves were rather widely 4!l used,1we provided this additional information to Licensees
- j t'"j. thas perhaps somehow h'ad not become. aware of this, a
6 1 I just happen to hav e a couple of the components-7 in my pocket.
8
.Vince, if you would switch to the backup slide --
9
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e 22 23 24 c[ ; cet Reporms. inc.
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This is the back-up side on the ASCO valves'.
5 2
. MR. JORDAN :
Okay, the circle components, the
.3 y ~ disc holder and pins are what I have.
And, for instance, 4;j'forthatpa$ticularvalve,
.i' they have an acetal component Y
5!
that's in many of the valves and are not qualified, and those 6
were replaced with a metal component-that then causes that 7
valve to be environmentally qualified.
8 So those are the two-components-that when exchanged 9
makes the difference for the valve being environmental or 10 not environmentally qualified.
11 COMMISSIONER AIIEARNE:
When you went on the 12 6-4 supplemental, did you adjust the reporting date of 6-15?
13 MR. JORDAN:
Yes.
We did not change the reporting 14 date, so we are bringing this material to the licensee's 15 attention.
16 We also identified in it a problem -- possibly 17 a problem with preventive maintenance with regard to aging 18 the components.
l 19 The coil that's up in the box to the right, if 20 energized according to the manufacturer, has a life of some 21 four years, so we're going to bring it to the licensee's
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22 attention that these should be replaced periodically.
l 23 So I think one could say that that might I
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24 constitute a success story for that component in that we have hFeder;l Reporters, Inc.
25 had no failures traced to that particular maintenance 6
h'
13 ar25-l
.If or to that environmental situation, and we were able, 'through 9
2 Ip the bulletin, to identify by the licensee _ identifying to us, ll and then we transmitted to all the licensees.
i 4e 1
May I have the next slide.
Slide 3, please.
5
[ Slide.)
6 The responsibility for action on the bulletin i
7 responses agreed upon within the NRC Staf f, so that I&E e
t 0
performs the tasks on the left, and NRR on the right, and we j
have, of course, a number of interfaces going through this 10 thing.
J 11 I&E performs the screening of the 120-day 12 l
reports.
NRR reviews the 24-hour, 14-day --
l 67 COMMISSIONER GILINSKY:
What are the conditions 14 for the 24-hour report?
15 MR. JORDAN :
That the licensee identifies unqualified 16 components and that he is then reporting in accordance with 17 tech spec.
t 18 We brought this particular reporting requirement 19 to his attention --
20 COMMISSIONER GILINSKY:
And NRR decides on the 21 level of seriousness, the safety significance
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MR. JORDAN :
That's right.
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23 COMMISSIONER GILINSKY:
-- of that report.
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E2 MR. JORDAN:
Yes.
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25 COMMISSIONER GILINSKY:
And that is reported on the
7 _
14
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I-l 120-day basis?
i l
MR. JORDAN:
120-day. basis, the licensee is e
3 i
reporting the sum total of his review, that is all of the 4o n
components required to be qualified, the level they qualify, 5
an'd on what basis they qualified.
0 COMMISSIONER AHEARNE:
Are you going to discuss t
7 what kind of 24-hour reports were received?
I O
j MR. JORDAN:
Yes.
Ed will discuss those.
So I&E screens the 120-day reports.
We are in the process of 10 doing that now.
We will initiate action on the deficient i.
11 I
reports.
That is those that are incomplete, have other 12 problems with them.
On that basis we.would consider 13 enforcement action, if we find enforcement problems with the j
14 4
licensee, then we would subsequently conduct what we are 15 calling an interim review.
16 This will be comparing the qualifications to the i
criteria that exist in the FSAR at this particular time.
18 Then we would be conducting a final review based on guide-19 lines that NRR will develop.
COMMISSIONER AliEARNE:
The NUREG that you mentioned 21 there, you mean it would be mentioned in the NUREG?
22 MR. JORDAN:
Yes, this is what we anticipate as 23 being the publishing of the results of the interim review.
i
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24 to.i.oerei nepon es. sac.
So, in addition to feeding back to the licensees, we would 25 publish a NUREG stating what the results were.
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MR. SNYDER:
Is that for each licens'e?
e 2
MR. JORDAN :
No.
a.
MR. SNYDER:
It's across the board on the subject?
- q d
d1 MR. JORDAN:
Yes.
5 COMMISSIONER GILINSKY:
Now is the failure to 6
have qualified equipment a violation of the license of I
i 7
regulation or commitment?
]',
8 MR. JORDAN:
Generally it's a failure to meet a commitment, to meet the FSAR requirement.
i 10 COMMISSIONER GILINSKY:
And how do w e regard that/
11 MR. JORDAN:
If you recall, in the Cook instance, 12 that was a materie.1 fault statement that was identified, and 13 so that was the enforcement action taken on that particular
- _c Id issue.
15 There may be instances where the failure to have a 16 qunlified component is somewhat innocent -- maybe that's I7 the wrong term to use, but it was inadvertent in the process, B
18 and we become smarter over a period of time.
COMMISSIONER BRADFORD:
I gather that there's 20 a much more specific than I thought commitment in the FSAR 21 fcr all these plants that you have equipment qualified to a 22 clearly specified environment; is that right?
23 MR. JORDAN:
I think it's perhaps more implied I
.w..
J than specific, because the criteria require that the plant l
24 j
a.r.o.rzi n. port.ri, sne.
25 I be-able to sustain an accident, and the PSAR describes the i:
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i accident requirement, so you just have to put those~two 2
I together and assume all of the. components required to j
function'should meet that criteria.
i 4 ll 1;
COMMISSIONER AHEARNE:
Are thera explicit state-1 5
ments that lay that on as a requirement?
I follow the f
6 implication --
t 7
MR. JORDAN:
In some FSARS, there are.
I wouldn't f
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8 say that's the case of all.
Let me just refer to Ed.
9 MR. BUTCHER:
I think the types of equipment 10 you find in the FSARs run the full spectrum.
The sense of 11 the commitment would be the component -- a component will be i
4 12 supplied that's capable of functioning in an accident fjj 13 requirement.
That commitment could be implied or implicitly I#
stated.
15 One way to imply it would be for the licensee to 16 say that the plant is designed in conformance with general I
I7 design criteria called a specific one, and certainly that I
I 18 would be an implied commitment to provide a qualified 19 component.
20 COMMISSIONER AHEARNE:
But you are saying that 21 there is no standard commitment required that all components 22 5fp in the plant shall be qualified to function in the environment !
i 23 as specified in such-and-such?
==
6 2e MR. BUTCHER:
I'll let Vic address that.
He DFederot Coporters, Inc.
25 certainly has had more experience with pSARs than I have, but N
17
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.p i
I!! I would say in nany. cases I have seen such implicit
-- or n
2 specific commitments-and others I have not, depending upon i.
~q the age of'the plant, the time of licensing, and the i
e licensing process that existed at that time.
5 MR. STELLo:
I think it's very difficult to try to ck 6
describe in a sentence, or a-paragraph, something that 7
will cover all of the applications.
Some cases have t
8 application because of the questions and answers, you are 9
dealing with a very specific component (Inaudible.)
COMMISSIONER AHEARNE:
Would you use your microphone, 11 please.
l MR. STELLO:
A very specific component, where that 13 I
particular component, test conditions for it are identified I
I 14 in quite a bit of' detail.
In some cases even the test 15 procedures are part of the operation, and in some cases 16 test reports.
I7 So it covers a large spectrum of conditions.
18 When they try to get it all inclusive, all components for 19 all conditions. I think there it has described it as best as 20 it can be.
It covers a fairly complete spectrum.
Up until 21 the time you get into the standard.
Well, the standard was 22 l fL available 3-23, 1971, for the equipment that was necessary 23 for equipment there to meet that particular standard.
i.
24 Ar.d there the_ equipment, I think, fairly -- you had a
$>Feoerd Reporters, Inc.
25 blanket statement to ce"er all safety equipment with cne I
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18 ar1 I
standard, but prior to the standard it really is a large S,
rariety of ways that it's described.
p COMMISSIONER AHEARNE:
But after the standard. --
MR. STELLO:
After the standard it's comprehensive
~ ;j and inclusive.
c-l
'*1 COMMISSIONER BRADFORD:
Except any vagaries in the 7l standard itself would then be reflected in cormitments to O
meet it.
MR. STELLO:
That's true, to the extent they 10 exist they clearly are there, yes.
11 COMMISSIONER BRADFORD:
And the standard itself had l, I2 anough problems with it that it was replaced within three 13 i
i Jr years.
MR. STELLO:
It clearly was replaced in three 15 years.
I'm not going to sit here and argue how much of an 16 improvement at the matter, but there clearly are some new i
I7 things that were added.
Some of the largest issues that 18 we're faced with in the reviews was the concept of aging, and 19 that was a new concept introduced for the first time in the 2C
'74 standards.
21 COMMISSIONER BRADFORD:
The '71 standard came into g
22 I
being and fairly quickly became referenced in Licensee commitments' I
23 jfrcs '71 on. The '74 standard was in place for five years, 24 iikeroi nepon.es. ine.
which was-longer than the '71 standar-3 was ever in place, 2 '
yet we still don't have any operating plants that reference
19
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I[ the '74 standard; is that right?
2 MR. STELLO:
The '74 standard was adopted for 2 y reviews that were in the construction permit process.
11
?:R. DENTON:
I think it nicht be useful to have a I
1 5I member of that standards committee, who is here today, Mr. Ross 6
Moore describe what led to the development of the 874 7
standard and some of the reasons, perhaps, why it has not 8
i found full adoption to date.
i 9
MR. MOORE:
I'm not sure I can remember with i
I 10 great specificity what happened in those days, but i
j; certainly the 1971 standard was -- the IEEE undertook that I2 at the old AEC regulatory group's request because we found 13
]p just such a variety of qualification methods.
Right after i
I#
the '71 came out, there was seversl issues that it didn't-15 very well address, and one was aging, and that is being 16 able to run a qualification test on a piece of equipment, but 17 simulates a 40-year old piece of equipment.
18 Well, '74 went into that.
That is still a very D
difficult problem.
20 COMM.TSSIONER AHEARNE:
I;ent into it to the extent 21 of requiring it -- not saying how it was going to be done?
22 MR. MOORE:
That's correct.
And there was a lot 23 of opposition to including that in this standard when l
24 nobody really knew how to do accelerated aging tests en pico.r.' c pon.ri. inc.
25 everything.
But our fealing was that the best way to get F
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20 ar9 l
progress made was to put it in the standards so that people e<
would have to start working on it, and I think that the
? results have shown that to be true.
s ns I remember one of the other dif ferences 5I between '71 and '74, I believe it clarified? a litt,le bic more 6!
the extent to which you could rely on analysis -- or a I
l 7'
stronger requirement for testing versus analysis.
I ibic 8
Those are, I believe, the typical areas between the two, '74 still -- certainly we would like to see more 10 specificity than is in there now, and I know that what's 11 we're working on in Staff to get more specific, and margins 12 to account for a variation of the units off the assembly T=
13 line, conditions -- the adequacy of the simulation of the
.=.
14 accident environment, so that there was a requirement for margin.
COMMISSIONER AHEARNE:
1 don't underste - 9 hat you 17 mean by margins.
18 MR. MOORE:
Oh, I'm sorry.
It's a requirement j
19 l that you test out a temperature higher than you expect in
'O the accident environment pressure or for a longer period than 2I you expect the device to have to operate.
2 MR. SNYDER:
Does that include, Ross, the 23 question of double LOCA peak testing in the '74 standard 24 versus the single peak in the -- is that typical of the D.Federst CDeporters, Inc.
25 [ kind of margin you're talking about?
I e
21
.or10 l'
I MR. MOORE:
Right.
The envelop --
+-
MR. SNYDER:
But you hit it twice, when in fact q if there was an accident of that sort, you'd never see the second cne; is that correct?
5 i
MR. MOORE:
Right.
It covers a possible error i
6!
in predicting the accident environment of simulating it in 7l ' the test, of variations between units off assembly lines.
t 8
That's what it's aimed for.
9 It's not very rigorously derived, but the idea 10
.is to go well beyond what you think it will have to meet.
COMMISSIONER GILINSKY:
Thank you.
I 12 cnd 2 13 14.
15 ll 16 17 18 19 1.
20 21 P 22 i
i 23 i
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24 Ace Federst Reportets, Inc.
25 t
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-E-3&4 mte 1 COMMISSIONER AHEARNE:
I'm not sure if this question 2-is for Ross, but'do we then now require the '74 standard to be 3,, met for plants that are now under construction?
?
4 MR. MOORE:
We have a date for cps.
What is the 5
cutoff date for '74, somebody who is closer to it than I am?
l i
6l There is a date established for cps: beyond that l
7 date, required to meet the '74 standards; prior to that, the 8
1971 --
Aren't we already in that da te?l 9
COMMISSIONER AHEARNE:
10 7.ce there any plants left that are now being held to '74 11 standards?
12 MR. MOORE:
No, not in the operating license.
13 COMMISSIONER AHEARNE:
For construction?
14 MR. MOORE:
Aren't they required to -- the new cps l
15 [
should -- construction permits are making commitments to meet 16 it.
17 COMMISSIONER AHEARNE:
To meet it.
18 MR. MOORE:
Right.
19 COMMISSIONER AHEARNE:
Okay.
I 20,
MR. DENTON:
I think I can help on that a bit.
We I.
21 ! Put Comanche Peak as somehow the plant that would meet the
- s 22
'74 standard.
I think within the staff there are serious i
23 doubts as to whether the '74 standard can be met literally.
24 COMMISSIONER AHEARNE:
That was my next question.
p.rmvet temnm. ire.
I 25 MR. DLNTON:
A lot depends on-how you interpret the b
23
.-Q 2
- lI al L
l' standard, what you think the standard means, and I think that's 2 0 why the staff has had so
- h difficulty with this issue, is taking those words in the standard and how dc you translate e
these into tests.
I ree the standcrd as intended to envelop Si all pieces of equipment regardless of the tine it had to 6
operate.
r l
l 7
In order to simplify the process, we have ended up j
l 8
going back and looking piece by piece at equipment, how long
{
l 9
it had to actually operate and what it's environment was.
We 10 have not really achieved any efficiency from the standard in Il that sense yet.
12 MR. JORDAN:
The status of the responses from the t:.;,.
13 licensees, the 120-day responses, I guess, are that the 57 14 plants that are covered by this bulletin have responded.
The i
15 11 SEP plants are excepted.
They are further along in the 16 review of environmental qualification than the bulletin
~
17 requires.
Also,' Indian Point 1 and Humboldt Bay were excepted f
18 since they are operational at this time.
19 The adequacy of the responses are being screened, and 20 the responses from our viewpcint, in a prelitinary fashion, I f 21 range from what we feel is very thorough to poor.
And we will 22 be contacting licensees.
We have contacted some licensees 23 already, requesting additienal information necessary for us i
24 to perform our review.
precers r..porwri, inc.
25 COMMISSIONER BRAT?ORD:
What would a poor response --
t
' ;i
24
?to.3.
3, l'
what would the characteristics be that would make it poor?
2s MR. JORDAN:
In not providing the information that y
- , was requested.
We requested a very extensive listing of fl a
components and the environment to which they are subjected and Si the manner of their qualification.
And some licensees have 6,
made what I would say are blanket statements that don't give 7
us the information we need in order to evaluate adequacy.
l 8
COMMISSIONER BRADFORD:
So if a licensee listed a i
f 9
particular component and then decides what's qualified by
{
t 10 analysis, is that suf ficient?
A
~
11 MR. JORDAN:
That's going to be the basis of our 12 review, so that we can correlate across the 57 plants.
For i
13 instance, if we have a specific component that another licensee 14 has qualified that particular component by test, then perhaps 15 we can determine adequacy and be able to feed that information 16 back to the licensee.
17 So we're going to have a very large matrix of f
I 18 information.
19 COMMISSIONER BRADFORD:
But will you ever actually 20 check either the analytical methods of the tests that lie 21 behind the assertions that they qualify?
22 MR. JORDAN:
We may.
We're not far enough into it 23 to say at this point.
4 24 The inspection process intent is to determine the
>Fmer:J R:Wrters, lrw.
f 25 validity of the licensee's assertions in his bulletin response.
j 25 p.t a,4 COMMISSIONER BRADFORD:
How long would a typical 2
bulletin: response be? How many items are covered?
How many I
L
. pages?
MR. JORDAN:
Hundreds of itens, and the respor.ses 5 d, are ranging to a half an inch thick.
So a proper response is 6
a quite lengthy document.
7l I
May I have the next slide, please.
l I
8 (Slide.)
9 Af ter the screening that we were just discussing, 10 we are going to conduct the interim review, and this is being 11 performed by a task group consisting of IE headquarters, I2 IE regional and NRR personnel.
And the object there is to 13 provide the widest possible perspective and to ensure consisten 14 l review of all licensees.
15 This process will facilitate verification in ques-16 tionable areas by inspection.
And I believe if we encounter, i.
I7 for instance, problems with a component that was stated by the l 18 licensee to be qualified by analysis, through our experience I
I i
19 that we didn't feel was correct, then certainly we would i
1 20 review that in more detail.
21 So there is going to be judgment involved in these.
22 l The final reviews, once the final acceptance l
i 23,j eriteria and guidelines are generated, will be performed by l
24 ) the same task group.
So that this will be a relatively long-
$NFederet Reporters, Inc.
j 25 life task group.
This is very large effort.
We anticipate
.: 1 5 l
+
.I I
l i, several man-years of work will be required to corpletee the 2'
reviews.
And as far as the schedule, projection is that the 3
final review will be completed by March of next year.
The 3
interim review will be ccrpleted by September.
And we plan 4
l' 5
to try to resolve the open issues by June 1980, by one year 6
from now.
7 At this point Ed Butcher will discuss the results I
8 of the review of the licensees' 24-hour notifications and i
I i
9 development.of guidelines for our final review.
10 MR. BUTCHER:
Could I have the next slide, please?
11 (Slide.)
e i
12 To date, in connection with the 24-hour reporting 13 requirement on bulletins, we have received reports of five 14 different types of components.
These reports are significant 15 in that they are different from those components where the 16 question is one of adequately documenting its qualification.
17 In the case of these components, the licensee has declared 18 that he has reason to believe that these components are not l
19 suitable for function that they are to perform in the LOCA 1
20 environment.
21 Specifically, the components are NAMCO stem-mounted 22 limits, which are the limits we have identified in the f
g.
23 bulletins, and the licensees in turn reported them where they l
l 24 have them, in accordance with the 24-hour requirement.
There i tee rwe,.i ':esonen. w.
l 25 have been some containment isolation valve operators reported, si i
ist:
6 27 l1,, three plants at one station.
2f COMMISSIONER GILINSKY:
What is a valve operator?
I 2l MR. BUTCHER:
Excuse me, I didn't hear you.
I 4.q COMMISSIONER GILINSKY:
What is that componen ?
L 5
What is a valve operator?
6 MR. BUTCHER:
In this case, I believe it was an
.,l 4
7 electric valve, a motor to drive the actual valve disk.
8 There has been two plants at one station that 9
reported an insulated instrument control cable terminal lugs 10 where they had some insulation on the --
11 COMMISSIONER GILINSKY:
What kind of isolation valves 12 are these?
Are these the large purge valves?
13 MR. BUTCHER:
These particular valves, my recollection 14 is that they were drain valves.
They weren't large purge 15 valves.
They were process type valves.
i 16 In two plants at one three-unit station, aluminum 17 limit switch housings on containment isolation valves were 18 found which were subject to degradation in the chemical sprays.,
19 And the ASCO pilot solenoid valves which we spoke about 20 L earlier were also discovered, at ten plants and seven stations.'
21 May I have the next slide, please?
N.
22 (Slide.)
23 In summary, there have been 31 plants at 19 stations,
$h--
24 operated by 13 dif ferent utilities, that have reported DFederot Reporw,s. inc.
25 unqualified equipment.
i.
k
m 0.td,7 l I
il 28
't I, -
r 1
COMMISSIONER BRADFORD:
In how many cases is that 2 +. unqualified equipment equipment that was called to their atter. tion by NRC as being unqualified?
l 4
MR. BUTCHER:
The only one -- I believe the limit i
5 'l switches were the only ones that were-called to their 6
attention by the NRC.
Now, af ter' the first ASCO solenoid l
7 valve problem was reported to us by one utility, it would be l
8 immediately turned around and reported to others, and it was 9'
disseminated throughout the industry by word of mouth and by the 10 manufacturer, and they began to come in.
11 So I guess you might consider that one kind of --
12 oh, yes, the 14 and 10 plants.
In all cases, the licensees 13 have agreed to replace the equipment where a safety-related 14 function was involved.
15 COMMISSIONER AHEARNE:
Now, I notice that you have 16 your 31 plants, you add up all these 31.
So I conclude that 17 no one plant had two of these things?
18 MR. BUTCHER:
No.
In some cases there were plants
..i 19 that had more than one of these items.
20 COMMISSIONER AHEARNE:
Well, is it then that there 1
211 are more plants than are lis ted on this slide, or is it the i
22 31.that's the wrong number?
23 MR. BUTCHER:
Thereare31plantsthathavereported{
i
~E 24 unqualified equipment.
In some cases, they have reported more ;
predeer amorwri. im:.
25 than one' type of unqualified equipment..
0 4
Pta 8 1
29 1
MR. EISENHUT:
Steve, the numbers don't add up
- - correctly.
3 COMMISSIONER GILINSKY:
What you're saying is, it's 4
less than 31 plants.
5 ll COMMISSIONER AHEARNE:
It's either less than 31 6
plants or there are more numbers here.
7 MR. EISENHUT:
We'll get you the actual numbers.
i 8
I assume the slide before was more accurate.
It certainly l
9 delineates the right numbers.
10 COMMISSIONER GILINSKY:
Let me ask you how you would 11 handle a situation where there is unqualified equipment.
Say 12 the licensees have agreed co replace equipment.
What happens?
13 Do you order them to do that or what?
14 MR. BUTCHER:
So far, it hasn't been necessary to 15 [ do that.
With the 24-hour report, the licensee is also 16 required to report his proposed action to correct the problem 17 and his basis for continued operation, if in fact he doesn't 1
18 elect to shut down immediately and replace it.
19 COMMISSIONER GILINSKY:
So he tells you how fast he's 2C ! going to replace that piece of equipment?
21 MR. BUTCHER:
That's correct, and he tells us why that doesn't represent a hazard to the health and safety of the l 22 23 public if he proposes to continue to operate that plant during l 24 that period.
p FWeret Regners, lrw.
'25 COMMISIONER AHEARNE:
And this' is what NRR is il
Yt 3 30 a
l' reviewing?
2h "R.
BUTCHER:
That's correct.
3i COMMISSIONER AHEARNE:
Now, in each of those cases h
4 he has to respond in 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
Does NRR have a similar window 5
in which they reach a judgment as to whether or not to accept 6 I that?
7 MR. BUTCHER:
I would say that our response -- we C
are aware of it, we immediately examine it and make a judgment 9
as to the significance, and that's done immediately, say within i
10 the hour of one receiving or one or the other individuals 11 working on it.
At that point we may make a judgment that there is 12 not enough here to determine how significant it is, so we 13 immediately contact the licensee. I would say within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 14 we make a pretty firm judgment in our own minds as to how f
15 significant it is.
16 Again, all we're doing is auditing his process, l
17 because he has already made this judgment.
18 COMMISSIONER AHEARNE:
But it's not his responsibility l
19 to determine whether it's adequate to protect the health and l
20 safety.
2 MR. BUTCHER:
The ultimate judgment, I suspect it's 22 up to us to verify his judgment.
But he has the first respon-I 23 sibility.
I 24 COMMISSIONER AHEARNE:
Now how many times did you l
%Feeral Eesmners, lre.
f 25 j agree with -- I guess what I'm trying to get at is, were there o
I l
b ha10 r;
31 L -
5 i
I any cases in which he identified a piece of equipment, you i'
2-guys. thought that's really sericus and you disagreed with his --
j i
MR. BUTCHER:
In some cases we -- we have yet to q
disagree with his judgment that the plant can be cpercted 3
4 5,
safely.
In some cases we disagreed with the extent of his 6;I actions to be taken in the interim.
Then we suggested he I
7 should take some other actions, and we furthermore strongly 8
suggested if he didn't then we would have to take some appro-9 priate action to see that he did.
10 And in all cases we were able to very shortly A
II implement what we felt was necessary.
12 MR. EISENHUT:
I think another reason for these is L...
[g 13 most of these -- it turns out most of the items we saw in the 14 j
previous chart were rather insignificant.
That is, there was 4
15 something pretty straightforward to do.
If a valve has a 16 problem where you're not sure that the valves are closed l
17 during an accident environment, you can close it ahead of time 18 and lock it shut.
19 There were, of course, a number of events over the 8
20 last year or so on environmental qualification issues where 21 we have taken action where we have had a difference of opinion, h.
22 starting, I believe with the Cook situation.
So there has 23 been a number, both in connecters -- there's been some on
>^
24 terminal blocks.
So those, I think, are the examples where M$ tral EPporters, irtC.
25 there were ones where there's been a difference of agreement I
it
_ 11 32 t
i betwven us and the licensee on these.
They've been rather 2
straightforward.
So in all of these cases I think we agreed eventually, citer scme discussion with the licensee -
S' MR. PUTCHER:
On this slide is sunnarized the 6: general factors that went into the licensee's determination f
i I
7 I. and our subsequent evaluations.
And in all cases, it was some 8
l combination of these factors, more than one, that led to the 9
determination that there was a basis for continued operation.
3-02 10 If there are no further questions, I will go to the II next slide.
12 (Slide.)
13 The other msjor activity that NRR hes in connection 14 with response to the bulletins has been to develop the guide-i 15 :I lines which IE will use in the final reviews of the 120-day 1
16 !
responses.. These guidelines will be developed by the Division 17 of Operating Reactors in NRR.
In conjunction with our 18 preliminary review, we will undertake a review in parallel and u
19 in concert with I&E of a few selected 120-day responses, and 20 ' we will continue with the reviews of the SEP information, 21 y which is very similar in nature to that which we requested in L
fthe79-01 bulletin.
22 i
23 l And from these reviews we will develop a set of 24 l guidelines which will identify acceptable methods of q ceral Eeporters, litC.
-i 25,
tion for plants of this particular vintage, with these
- l 33 i
particular applications.
These general guidelines will be
. established with particular emphasis on the fellowing -- the 3.; aspects that we have listed here of IEEE 323 1974.
It is not 2
our intent to attempt to backfit per se the standard, bt is 5
our intent to look at the standard as kind of a benchmark in i
61 establishing the criteria, and where we feel it is not necessary 7
to come to the letter of the standard, the 1974 version, we 8
will establish a basis for not having to come to the letter of 9
that standard.
10 In many c ases, it ma,r be impractical or not 11 desirable to implement the letter of that standaro on an 12 operating reactor.
13 COMMISSIONER AllEARNE:
Such as in aging we d c't 14 run --
l i
15l MR. BUTCHER:
Aging is probably a fairly good 16 i example, because in our reviews what we will be able to do j
l 17 with aging is we'll probably be able to identify some particu-le lar components that we will require aging.
In fact, we have j
i 19 already identified one, the ASCO solenoid valve.
We have l
20 already established a qualified life for that.
And components 21.. of materials of a nature similar to that, where we have iden-22 l tified those materials as subject to aging degradation, we l
h 23 ] can establish that as a requirement.
j l
24 COMMISSIONER BRADFORD:
When you say "a qualified j
l Jewet Remrters, W.
{
- 25 ' life," am I _ right in understanding that means it's qualified 1
a
a Sto:13- ;
[;
34 h
- I for a period of-time, but then it will have to be tested again 2,
before it can be used-any longer than that?
MR. BUTCHER:
It's qualificc. such that if a LOCA 4"
were. to occur at the end of its qualified life, the component
~
5 0 would still perform in its LOCA environment.
6 COMMISSIONER BRADFORD:
If that period were five years, 7
what would the licensee have to do at the end of five years?
8 MR. BUTCHER:
He'd have to perform maintenance to replace 9
the component.
In this case, it would be to replace that 10 particular internal, if that were the thing; or some other
~
II mitigating action, place it in an enclosure so it won't see 12 the LOCA environment, something to mitigate the aging problem.
fp 13 I think that's about all we have, I
t Id COMMISSIONER AHEARNE:
On this list of 24 items, 15 are there any that NRR viewed as being serious?
I6 MR. BUTCHER: I think we view the ASCO solenoid I7 problem as being probably the most significant, in that its 18 failure mode was a bit tricky.
It was difficult to establish I9 a f ail-safe mode.
It was difficult to predict which way it 20 g would fail, and therefore that was significant to us.
In the 21 case of the ASCO solenoid valve, there was a whole spectrum i
22 of things that we made the licensees do in order to satisfy 23 us.that'they were acceptable.
24 The factors that I have listed here that would
~
4.oer t repori.... ene.
25 form a basis for continued operation of all those components, 4
b
ft
) 14,
- j 35 I
we looked at.
The ASCO solenoid valves -- I see here in front 2
of me, it looks like four of those valves played a ro3e in
- p that decision.
So we piled Itver unon layer.
a j
i COMMISSIONER AHEARNE:
As far.as equipment, those 5
are the ones on that list that you viewed as being most serious?
6 MR. BUTCHER:
Yes, that's correct.
It took us the 7
longest to resolve that one.
I won't say that decision was f
8 hard and firm made as easily as the others.
i' 9
COMMISSIONER GILINSKY:
I wonder if you can give us 10 some indication or at least your impression of why there was Il equipment out there that isn't -- wasn't qualified?
Is it a 12 failure of quality assurance?
Is it lack of attention, or a 13 failure to understand the requirements, or our not having 14 stated the requirements precisely?
15 MR. BUTCHER:
I think I probably could give you-an 16 example of each one of those, and I suspect all the other j
17 members of the staff here could also cite examples that would 18 be -- would say that each one of those is a factor.
I don't 19 think I could point to one specific thing that occurred in I
20 1 I
every case.
21 !;
Certainly a heightened awareness of the qualification i
22 problem brings these things to our attention in recent years.
j 23 l
I would have to say that perhaps there could have been a OA -- l i
24 I don't want to use the word " breakdown," but let's just say "at R worters, IM.
25 at the small individual component level, in the early days of t
s e
[
% 15
{!
F 36 t
'1,'the industry, I think perhaps it was easy to forget those kinds 2
of things.
There are hundreds of them in the plant and it's
.;q quite possible that one could have been lef t out in the design l
4" specification.
- i
-5 COMMISSIONER BRADFORD:
Is there a pattern in the 1
6 answers you actually got that in fact indicates the problems.
I i
7 tend to be greater in the earl'ar plants, the 11 earliest, because they would have responded in this context?
8 t
l 9
MR. BUTCHER:
I couldn't answer that question.
I 10 haven't analyzed the data.
11 There is one aspect that we probably ought not to 12 overlook, and that is in the case of the limit switches.
It's l
j 13 only been in recent years that we have come to recognize the 14 importance of post-accident monitoring and things like that, t
15 at least in the level of detail that we have gone into in 16 recent years.
And therefore it is not surprising that you would 17 find a thing like a limit switch, that provides position 18 indication, not having been given a great deal of consideration 19 when they were qualifying equipment in the earliest plants.
l 20 r' I think that accounts for 14 of these different cases, whatever i
0 is wrong with my arithmetic.
21 l
22 (At 2:20 p.m., Chairman Hendrie entered the room.)
23 COMMISSIONER BRADFORD:
Did you get responses from l
24 all the plants?
i p.: nevon.... sac.
25,,
MR. BUTCHER:
Yes, there have been responses, at
)
1
.4
!ta 16 37 1
least 120-day responses.
They have at least responded to the 2
bulletin.
The question of adequacy, I think I can't speak to 39 that.
CO"SISSIONER BRADFORD:
Well, in cases where the 5 i responses.we-inadequate, have they been notified that they 6 f have more to do and been given a schedule to'do it?
7l' MR. JORDAN:
That is what we are doing now with the 8
screening.
Some of the licensees have been notified, that l
9 where there was an obvicus problem.
And we are continuing to I
10 notify the rest of them.
We have a task group meeting tomorrow' II to continue screening.
We do it on a regional basis.
I2 COMMISSIONER BRADFORD:
Is there an overall staff I
l
"=
13 view on the feasibility and wis 3om of taking enforcement action I 14 against a licensee who has unqualified equipment?
Can it be 15 done, and if so, should ii he done?
16 MR. JORDAN:
This is on the general case where, 17 let's say, the 31 licensees that reported having unqualified i
18 equipment?
Is that the example you are proposing?
I9 COMMISSIONER BRADFORD:
Well, that's a good starting a
2C place.
il 21 ')
First of all, does the current regulatory structure 22 i
give a basis for action of that sort?
Are the PSAR commitments 23 clear enough?
Is the '71 standard clear enough to enforce 24 anything against anyone?
And following that, if the answer p,..i ceponers inc.
I 25 is yes, should we be taking actions of that sort?
N' t
U
..i 38 e
1 MR. JORDAN:
Well, the lator plants that do indeed 2.- have.the equivalent of the '71 star.dard, the answer is yes.
2 An'd as far as our plans for some action, that's part of the
- j. review process.
We will look at that aspect of it.
That's 4
not forencst in our review process.
6" Foremost is verifying that the components are 7
qualified.
4 8
COMMISSIONER BRADFORD:
But the issue isn't really g
9 a new one at this point.
It's been what, 18 months since the 10 D.C. Cook connecters --
Il MR. JORDAN:
That's right, and that one was a t
I 12 relatively clear case.
- 12 13 MR. SNYDER
You found there that you had no grounds !
14 for strong enforcement action, right, as I recall, at Cook?
l 15 MR. MOSELEY:
In that case we did take the enforce-16 ment action.
17 MR. SNYDER:
I'm sorry, excuse me.
18 MR. MOSELEY:
The response that we have to give is 19 that it varies by licensee, and we will have to look at them 20 almost on a case by case basis.
2I "
COMMISSIONER BRADFORD:
Let's see.
Can I ask that 22 lI one of the things that you do be ta try to bring that situation 23 to an end.
Obviously, it is not acceptable to be able to d
i2 24 L take er forcement action against a licensee in one olace for hoer.' neponers, inc.
25 a set of events that you couldn't enforce against another 9
I I!
4
eta,lk '.
39 I
licensee in another place.
MR. MOSELEY:
But we can't retroactively place requirements that did not exist, either.
3, s
CO 1MISSIONER EPJ.DFORD:
I understand that, but !
5 think we would want to have the regulatory framework be such 6
that regulations, at least as to the future, can be enforced 7
formally in this area.
8 MR. MOSELEY:
Yes, sir.
I think we have that.
I I
9 think the early answer is certainly true, but for the newer
~
I 10 plants these things are much more uniform and standard, and we would have a better basis --
I2 COMMISSIONER BRADFORD-My point is that if a LOCA 13 occurred, it isn't going to worry about whether it's occurring Id in an older plant or a newer plant, and we've got to have a 15 l way of making sure the equipment is qualified in the oldest 16 '
plant as well as the newest.
{
t I7 MR. MOSELEY:
Yes, sir.
18 COMMISSIONER BRADFORD:
It just doesn't make sense I9 g to me to say that we have no way to enforce the requirement f
20 'I i
for qualified equipment in an old plant --
2l h MR. MOSELEY:
I think we are not communicatinc.
I i
22 was talking about enforcement in terms of saying, what are you 23 going to do, why did you let this happen, and so on.
The 24 bulletin itself is going to result in having qualified
>Federet C:' porters, Inc.
25 t equipment, no question about it.
{. --
r
~
u kta 19 40 h
'I' COMMISSIONER BRADFORD:
Okay.
2[
MR. STELLO:
Let there be no question, we are going to establish that all plants have qualified equipment.
Given
'l that that purpose is accomplished, in the process of accerplish-I 5
ing it you can ask the question whether or not there needs to 6
be an enforcement action against a particular licensee for i
6 7
something that's flagrantly omitted, not done.
And I think.
t 8
that has to be done based on the license conditions that were f
9 issued with the plant when it was licensed, and it will have l
f i
10 to be in that context to decide.
1
~
11 I don't believe it's appropriate to try to take an i
12 enforcement action for a plant that is very old that doesn't l
13 have clear language as to what was required using today's I
14 views.
But I think it is appropriate to make them all meet j
j 15 q the safety requirements, irrespective of time of licensing.
l 16 COMMISSIONER BRADFORD:
Yes, I think I would agree l
17 with that.
But what I understand you to have said is that i
18 the bulletin will, in effect, sweep aside the situation as it l
1 i
19 exists now, which is that the different commitments in different 20 FSARs, depending on the time, depending on whether or not they l
21 '
reference the '71 standards, makes uniform enforcement 1
22 difficult, if no t impossible, as of today.
23 MR. STELLO:
Uniform enforcement to me is a concept i
24 i
where you enforce the license requirements that were imposed p ene.: n.=neri. irw.
25 b on the particular licensee and do that uniformly, recognizing r-4 that.the license requirerents de indeed vary.
A
e MIMI?pv 41 0
r COMMISSIONER AHEARNE:
I thought I understood'it.
Now
- I don't.
2 (Laughter.)
COMMISSIONER BRASTORD:
I think I understand it, but 5 don't like it.
U 6f (Laughter.)
7 COMMISSIONER AHEARNE:
Let me see.
I would like to
! separate -- I am not asking about penalties against someone, B
so 9
if that is what you mean by enforcement action, that's not the 10 question I am asking.
So, you might ask a question:
Can you
.i 11 take enforcement action?
And the question really would be:
Can '
I 12 you exact a penalty against someone?
That's not my issue.
13 The question, though, is:
Can you require all of the 14 plants, independent of what ?.evel of commitment they might have, r
15 ;:whether it is pre-71 standard or 71 standard, can you recall all a
L 16 h the plants to meet some uniform level of qualification of equip-17 '{ ment?
1 18 MR. STELLO:
Yes.
Now, enforcement, though, covers a 19ldifferent spectrum of things, up to and including civil penalties.
0 2C'The way ia which you apply that obviously needs to depend --
21 COMMISSIONER AHEARNE:
Right.
That wasn't my question.
22 iso that you will be requiring the equipr.:ent in all of the plants 23 L to meet some minimum tandard of operability in the environment o
I 24 ;that the plant might be expected to be in in an accident?
der Federsi Ceporters. Inc. l 25 MR. STELLO:
Yes.
I thought that was the purpose of
pv2 42 i
n i Ed's last slide.
You might want to put that up again.
- 2 COMMISSIONER AHEARNE:
That's what I thought I under-3, stood.
/
(Slide.)
5 MR. STELLO:
That's the purpose, as I understood it, 6 iof your last slide, Ed.
7 MR. BUTCHER:
The second statement there is:
"We 8; attempted to find the criteria upon which they would be measured."
l 9}
COMMISSIONER AHEARNE:
That would be independent of
,1 10 hwhich plant and when.
i 11 MR. BUTCHER:
Right. And there may in some cases be 12 some enforcement necessary to bring them up to'that level.
i
[{J 13 COMMISSIONER AHEARNE:
That's what I thought I under-l 14,! stood.
f 15 ;I MR. JORDAN:
That's why we have the interim review and 16 lthen the final review, because in a short time frame --
l 17 COMMISSIONER AHEARNE:
Okay.
18 MR. STELLO:
Everybody understand it?
I5 !
COMMISSIONER BRADFORD:
That's what I understood, as I
t 20'well.
But that looks entirely to the future.
We still are in 21 ! the situation at present in which it do basically the one that t
'vic has described:
Consistent enforcement consists of enforcing 22 l
ll 23 ; inconsistent conditions or inconsistent amendments by different llicensess.
n=.C 24 Jee Feceral Cecorters, Inc.
25.
COMMISSIONER AHEARNE:
Is your point, Peter, as to when l
'pv3 43 i
i will the equipment in the older plants be qualified?
COMMISSIONER BRADF'ORD:
That's the next question.
A 1
I was talking earlier about enforcement action,
,clud-ing civil penalties or whatever, in the content of the regula-f, tory framework that we have now.
And it sounded -- I was think-6 l1ing it would be very difficult to be doing uniformly, and that l
7 ghasn't changed.
What 8
What about that next question, as to that last slide?
9 When do you see that program being completed?
MR. BUTCHER:
We have set a goal of September for II completing the guidelines, and that's not to be a simple task, 12 it's not t<- be taken lightly, because we do anticipate there 13 could be some backfitting involved in that.
14l COMMISSIONER AHEARNE:
That's quite likely.
15 MR. BUTCHER:
I would say it's quite likely.
COMMISSIONER AHEAFNE:
If there would be backfitting I7 required, wouldn' t that sort of make it more important to get 18 it done as soon as possible?
1
- 1c I
~
MR. BUTCHER:
We regard September as as early as pos-20 sible tc do the kind of adequate job we believe is necessary.
2I COMMISSIONER AHEARNE:
But you wouldn't want to let it
[
22 slip beyond that.
!i 23 h MR. BUTCHER:
I would say next September; the following 9'4 ISeptember would probably be too long.
I agree with you.
That's 4 tI eoea' Reporters, Inc.
0 G
'S the conclusion we have come to also.
=
e*
h 44 I
COMMISSIONER BRADFORD:
And then theres a pdriod 2
beyond September which would be required actually to bring the 2, plants into compliance with whatever you've done?
-~
MR. BUTCHER:
That's correct.
I COMMISSIONER BRADFORD:
You propose to be specifying 6I that time, whatever it was, after September?
7 l
MR. JORDAN:
I estimate that time as being March of
.8 ; 1980 that we would complete the final review process against
.l 9
this criteria for all those 57 plants, and then by June of next 10 ! year we would have resolved the issues that were developed by II imposing that review.
12 (Commissioner Kennedy arrived at 2:32 p.m.)
13 COMMISSIONER BRADFORD:
In reviewing respone:e:: now, Id does the '74 standards play any role in your method of review I;
15 to be used informally?
MR. BUTCHER:
In reviewing the responses to date?
il I7 l COMMISSIONER BRADFORD:
Yes.
18 MR. BUTCHER:
To date, we didn't make judgments as to I
the likelihood of the component failing in its environment.
We E
concluded that it -- the probability was that it would fail.
II'Now, what is the conseque. ace of its failing.
So, really, there 22 was no need to apply a standard to determine whether it would b
23 1 fail or not fail.
.24 Maybe I didn't understand the question.
In review-tcvJedef a' Reporters. ant.
l st ing the 24-hour responses, we weren't making a judgment as to
yo l *.
45 whether the qualification of the equipment reported in the 24 I
hours was adequate or not.
The licensee declared that he 2
believed it was not qualified.
CO'1MISSIOF;R BdDFORD:
The goestien I had in nind:
5 When you get a response, you have different people working, meet-6 iing differerit responses.
They have the licensee's commitments l7 lin front of them; they have the 1971 standards.
8 COMMISSIONER AHEARNE:
Are you talking about the 9( 24-Lour or 120 days?
i 10 !
COMMISSIONER BRADFORD:
120 days.
And they have to Il make some kind of a judgment as to whether or not these responses 12 are adequate or not and the equipment is qualified.
13 -l Now, taere isn't necessarily a lot of the '71 4;_
Id N standards to go by, and, in some cases, at least, there isn't; 15 very much in the PSAR.
What are they using, then, in the situa-16 l tion in which different reviewers come to different conclusions il 17 [ on similar information?
I I8 i
MR. JORDAN:
I think I can answer that.
The review h
M g is being done by a task group so that they're going to be hold-20 ing hands essentially and doing the review, and the interim 21 portion of the review is where there will be differences because 22 h they will be using as criteria the licensee's commitments and k
23 !! the accident environment for that particular plant. And it will 1,
24 li be the final review that this is, you know, all brought together g
uesewe, cewnen. w. p 25"and the' influence of hte 1974 standards will be in the criteria e
f, PW 46 g
1 for that review.
So, there are two parts.
COM"ISSIONER AHEARNE:
Peter, may I?
COMMISSIONER BRADFORD:
Certainly.
1 COMMISSIONER AHEARNE:- More in the sense of clarifi-
! cation, in the process you will end up, I guess, finding that 9
6 ) there -- or you have already found -- the 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> were those l7 j where the licensee felt the equipment wasn't qualified.
8 MR. BUTCHER:
The licensee or his supplier.
9 (commissioner Gilinsky leaves room at 2:35 p.m.)
COMMISSIONER AHEARNE:
And the 120 days, possibiv 10 11 you might find some other components which you conclude where l
12 the licensee didn't, but NRC may conclude, that they aren't 13 qualified.
3" 14 !!
Now, to some extent, that means the plants are, and 15.i I don' t know what the right term is -- out of compliance with 16 the tech specs or whatever requirements are laid on.
Now, does 17 that require a formal waiver from the director of NRR or the 18 director of I&E in order for the plant to continue to operate?
19,l MR. STELLO:
Let me try to answer your question.
I 20 ' think, if it follows classically, as most reviews do, you look
~
- 1"at something and the licensee thinks it's okay.
You argue that 1
22 l you don' t think it's okay.
Then the natural thing is to try to I4 23, find out a way to resolve it, which means you may have to run a I
24 l test which, hopefully, both parties agree to, this is the test Awes..i neponen. inc. l 25 i to run.
And if 3 e does indeed turn out okay, we both accept it.
wr
~
47 ii i:
1 If it doesn't turn out okay, something needs to be done, depend-2 ing on the components, such as the examples before you.
Then
,you decide what the right course of action might be.
If it can be something where you can lock a valve closed or whatever, it
~
5 may allow the time to go in and replace the compoent.
If not,
- S 6 / then you may have to go ahead and replace the compoent reasonably 7 quickly.
8' As far as whether or not you need to cover at that 9
point you might have to order them to change it if there's disa-Ti 10,greement.
If he says "No,"
then you're faced with the need to 11 order them.
I 12 COMMISSIONER AHEARNE:
But the situation -- I think
_f 13 what I am at least concluding you are saying is that this doesn't 14 f fall into the category of items which flip a switch and that it 15 ! switch being either the plant has to automatically because of o
16 the legal requirements shut down, or that some one of the direc-17 tors has to have a waiver to stay up.
18 MR. STELLO:
You could give it a waiver, if that were l
19 appropriate.
I think where I would see most of the issues come,
%'they come to the point where a licensee thinks it's okay, he has 21 done something he thinks justifies the qualification of the com-22 h ponent, and there is going to be a difference in view.
i 23 lj If we feel strongly enough, then we have the tools to f
lM 'take the action we need to require him to do something.
an w oe,s nem ne...inc.
25 '
COMMISSIONER AHEARNE:
I was wondering more of a
pi;8 48
'l A
different situation:
You both agree this is something that must be changed, and the licensee wants to have it continue to 2
operate.
Is there a situation where, in order'for that to happen, there has to be a formal waiver given?
5 MR. STELLO:
You could give an exemption to it, if 6 h that's what's appropriate.
0i 7
CHAIRMAN HENDRIE:
I think the answer must be, John, t
I 8 'i that it certainly is within the realm of possibility that those I
9 circumstances could arise.
It may not occur in a great many bi 10 cases, or it might not even occur in any.
But I think it would 11 be very hard to say, "No, no, that's just not a configuration i
12 which can possibly arise.
[h 13 COMMISSIONER BRADFORD:
When you described this 14 f earlier as an audit typ e of review, which it clearly is, but I:
15 3 let me get a feel for the scope of the audit, you will have 57 h
16 half-inch thick responses to deal with.
A lot of things can i
17 be qualified by analysis and some qualified by testing.
I 18 Have you any feel for what percentage, if any, of 19bthoseanalysesandtestsyouaregoingtobeabletoverify 20 yourselves?
21 MR. JORDAN:
What we were asking for was the for the 22 h licensee to provide the documentation for his position of the 23 0 qualification so that we have through the Circular 78-08 the H
2 Einspection program verified some of those documents already.
Ace Fedr z! Reporters. Inc. tj e
'20 COMMISSIONER BRADFORD:
It's not so much the
,av y 49 I
documents.
What I am curious _ about is actually do we deed
~
scmewhere in the research program we have asked for before a
, testing program of our so that we indicate we could do some of these tests ourselves?
5 PR. JORDAN:
Yes.
And, of course, on connectors, we 6 i did some tests ourselves.
i I
7 COMMISSIONER AHEARNE:
We have been attempting --
l 8
(INAUDIBLE) 9 (Laughter.)
'N MR. JORDAN:
We' d be in a better position, I think, 4
II to identify additional tests that we ought to be doing inde-i 12 pendently after reviewing these packages.
I don't know at
.O 13 !this point.
P Id
.MR.
SNYDER:
That's still an open item, I think, on 15 the list for the April Comm ssion decision.
16 MR. STELLO:
Yes.
I7 MR. EISENHUT:
That's still an open item.
I think i
18 the response will be coming up shortly.
It may entail sort of 3
a combination; it may entail, after we go through these reviews,
~~
-~ we may come down and say certain of the items should be tested, m3 and we may go out to an existing lab and suggest that we inde-22 h pendently test certain typical components in addition to the i
22 [ Sandia approach that Research is doing.
2'. h, 1
We may also, you will see in this proposal coming m.reste i neoorie,i, eac.
SC i
forth, we certainly have several alternatives or options in it.
F Fv6s -
50
- 1 4
Lt n
1-One of the options would be having our own testing facility 2 where we test a large number of them.
3 I think these reviews will help give us an input into
_.c where we really want to go for that kind of testing program.
'I, COMMISSIONER BRADFORD:
At the. moment, what you get il 6 Lwould be something that's qualified' by testing, you would learn N
7 ( the data of the test and where it had been done?
8 MR. STELLO:
Typically, there would be a test report 9[ documenting the results.
I 10 COMMISSIONER BRADFORD:
And might the tests have 11 also been done by the licensee?
Il MR. STELLO:
I know, in some cases they have been, 13 and in other cases they have been in labs.
g; 14 COMMISSIONER BRADFORD:
It sounds like a situation 15,: that cries out for some mechanism for independent verification.
i 16 MR. STELLO:
The whole question of independent
~
17 verification is a very difficult one of how much of that you do 18 do, talk about environmental qualification --
19 COMMISSIOENR BRADFORD:
The first step we have to get 20 over is the decision to do some.
~
21 '
COMMISSIONER KENNEDY:
Is it not true we are doing n
22 l some?
~"
23 [
MR.-STELLO:
We have done the first -- or attempting, 24ljasCommissionerAhearnesays; 4-I don't know what the status is --
/.ce.Feders' Reporters, Inc. l
-25 ' to. test connectors ourselves, and where some consideration has
)
. pv il '
51 e
been given to testing additional components beyond that which
'^
components are selected and how much of that to do, I think, is 3
something that is owed to the Commission.
I think that will
- have to be considered.
The Commission will have to decide how Iymuch of that it does want to do.
And I guess the appropriate (0; time to discuss it would be when this paper backup --
i 7i COMMISSIONER BRADFORD:
Could you give me a back-U 8
ground on what the drawbacks are?
What are the arguments 9 } against some testing?
!I 10 MR. STELLO:
I don't have any against doing some Il testing.
I think, to me, it's a decision of how much of the 12 ' resources you want to put into that particular activity.
If it 13 turns out to be a tenth of a cercent, it might be well worth-14 ;while.
But I think it needs more th7ught than I want to be-15 able to say I have given it sitting here.
16 And there is a paper.
It is a particular issue that I
17 l I have been giving a great deal of thought to, the whole ques-i, 18 tion of independent testing and verification,from an inspection I?hointofview. And philosophically, I clearly believe more of it 22 is needed.
21 o COMMISSIONER BRADFORD:
Lee, do you know offhand JX 22,;when that paper is scheduled to come up?
1 23 1
MR. GOSSICK:
That standards paper on qualification 24 l testing?
- .::, resar.' nenoriers ene. I 25 MR. STELLO:
I thought Research had the lead on that.
i I
r pviz 52
(
H I
MR. EISENHUT:
I am not sure exactly khat th'e 2
detailed schedule is, but I know I read the draf t report about 2
a week ago. So_it's getting close, I think.
CO.*.MISSIONER AHEARNE :
_Let me ask a related question.
I,Is there'any money being proposed in the next year's budget for 1
6f it?
t 7
MR. GOSSICK:
I can't enswer you.
O MR. STELLO:
Inspection and Enforcement has some 9
money for additional independent verification testing.
But it 10 '4 covers, again, a broader picture.
Radiographs of piping systems.
So, we have some staff in that area and have the start of a pro-12 gram.
I think it is one htat deserves more thought and 13 deliberation than we can give here.
COMMISSIOENR KENNEDY:
Could you sort of outline the 1
ed j", general components of such a program?
Wouldn't one have to b
6 determine which items you want to cover,and that would be a il I7 function of their significance to various safety systems, I I8 suppose?
"l Secondly, I suppose, you would also take into account la 20 and I am just thinking out loud at this point -- it would ol'take into account the likelihood of failure and the consequences of that failure of that system.
If it's not of any consequence, n
23 !!you could spend a lot of resources on that for not too much i
2 ' benefit.
t 3:e.Fruanworte<i.inc.l And thirdly, wouldn't you want to take account of how l
n pv13
.s 53 t
I 'much' testing you would have to do in a statistical sens'e to give you any-kind'of assurance of the cuality of a whole batch?
'I 1
mean, are those some of the things you would have to'-- there e
must he others.
5 MR. STELLO:
Oh, yes, but it's even broader.
I-n 6 ' include, for-example, independent radiography, and the whole 7Lconcept of independent verification testing.
It's again, how i
8 big is the sample size, or how big-does it need to be?
How
-96i much of it do you want to do?
Do you want to take concrete 10 samples and bring them to a laboratory independently, measure II concrete strength?
U g
COMMISSIONER KENNEDY:
Is that what this paper is ar
<. c;.g 13 addressing?
N MR. STELLO:
This is strictly on the environmental 15 testing of components.
That's a big order.
I0 COMMISSIONER AHEARNE:
Are you thinking about time ti e
I7 !! tests?-
4 IO l
MR. STELLO:
Yes.
Ic h endf5
~p.
COMMISSIONER AHEARNE:
Which is different in the 2C sense that some of the testing program is more generic, at 2I " least to research.
i-r-
22 i
23 l 24 {<
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MELTZER 1
MR. STELLO:
I think the question'of' environmental
-5872 0
testing has_ generic implications.
-There are a 1~arge number of plants that use similar 4.' ' components as indicated on one of those slides. So it does 5. have the capability to go across many lines.
$}
COMMISSIONER BRADFORD: One other question.
7 What will the legal basis for uniform enforcement 4
-8 ultimately turn out to be?
Tlat is, as a result of the 9
Bulletin process, you will have come up with a requirement and t
10 [ -apply it across the board,backfitting if necessary.
11 But then if a year from now you find unqualified i
12 equipment is still in place, what will you be enforcing against 13 at that point?
14 Will it be a Bulletin, a Regulation, revisions to 15 the FSARs?
g 16 MR. STELLO:
Again it goes back to the earlier 17 question Commissioner Ahearne asked.
I If we make a formal 18 backfit requirement proposed as a licensing requirement, 19 the array of things the Licensee has to do,
(
then they become 20, part of the license and you enforce them in that context.
21,
If'he adopts them as part of his license, than they 22 are again enforceable.
23 f If he just agrees to adopt them in some infornal
{
1
~
24
- way, E :rei R: porters, Inc.
then you have covered the whole spectrum of problems I am !
cd 25 sure the attorneys will see in terms of the degree of
- ' T 55
- 3:
t mm2 enforceability.
And I think we are probably going to wind up with
- hat spectrum of plants.
a.
COMMISSIONER BRADFORD: But in the case of someone who simply agrees to.put tF3 equipment in place, what happens 5-si '
?
then if that didn't get done, if it hasn't formally been made 6l 3
part of the licensing?
l 7
f MR. STELLO:
I have a feeling that is a legal question.
CHAIRMAN HENDRIE: I presume we can get an order j
saying we consider it appropriate to the health and safety requirements of each plant to do it.
COMMISSIONER BRADFORD: You can get it done, but is 13
=
L I
that also a situation where penalties can be invoked?
I 14 i
MR. LIEBERMAN: No, the Chairman is correct.
Obviously you can issue an order, but if it is only a commitment to do something a civil penalty couldn't 17 i
be imposed.
A material false statementcould not be found unless the statement is clear in a license application that a Licensee will, in fact, have a specific component qualified i
to some standard.
21 h I
COMMISSIONER BRADFORD:
Well, let me just leave it, for my own part then 1 feel that whatever co res out of l
1 your effort in September, it ought to include an enforceable 24 i
kt Federet Reporters, Inc.
regimen, including the possibility aCress the board of
'.
- 4
- i 56 w
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- '3
)
penalyzing those who, after the time they were supposed to have 2
qualified equipment, still don't.
MR. STELLO:
I must tell you I also have the thought in mind of whether or not you ought to raise that question of f
5g need for a change in Regulations to enhance or elevate the a
6 status of Bulletins and their response.
7 (Commissione r Gilinsky arrived at 2:50. )
8 COMMISSIONER BRADFORD: The final thing, I guess, as 9
a result of.TMI I gather there is some talk of equipment that 10 didn't used to be considered safety related may now be.
11 Would that process conceivably have an impact on 12 the work you are doing here as well?
13 MR. BUTCHER:
In the initial planning for the q;;g ldevelopmentofthesecriteria,weproposedasystemsapproach.
14 15 And that certainly would involve things like that.
16 The first thing in the systems approach would be 17 to make a determination of what ought to be qualified in the P ant, notwithstanding what the license originally required.
l 18 19 That's our thinking at this point.
As the criteria develop 2 0,' we may determine it is not practical to do that.
That is quite 214 a job. So, at least we are thinking in that direction.
k.
22 COMMISSIONER AHEARNE:
I want to make sure I under-23 stood that last answer.
sq 24 You are saying, your conclusion is it would be a very ke Federst Reporters. Inc.
25,
big job to decide what equipment ought to be qualified at the i
r, E. %
l 57 3
l mm4 v
'I
' plant?
MR. BUTCHER: Nc, I don't think I meant that.
it What I meant to say was the first step in determining whether equipment is adequately qualified or not is to 5[ determine what you need to be qualified.
0 In order to do that, you go about it in a systems 7
approach.
One shortcut.has been determined. Everything in i
t 8
the containment ought to be qualified.
That would certainly be a shortcut to elim inate the need to do that kind of 10 I review.
l 11 l
MR. STELLO:
I think what comes out of the Three 12 Mile Island Lessons Learned, the identification of equipment 13 that will.have to be elevated in a safety status, will be i
specifically identified.
And that equipment would just add i
15 l to the list of equipment.
16 And I suspect since it has not now been qualified, I7 I
documents would have to be supplied showing how it would be, i
18 or modified so that it would become qualified.
But I would think that would be a specific list 20 %
of equipment.
o 2I ]
CHAIRMAN HENDRIE:
Anything further?
22 (No response) 23 Let me seize then on the pause and say, thank you 2e very much, even though I wasn't able to be present at the ta.remi cwonm, inc.
25 front end of this discussion.
i I
i H
58
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nr.5 I
COMMISSIONER AHEARNE: Well, having been here throughout all, thank you very much.
d CHAIRMAN HENDRIE: I assume the front end was
~
- useful, t '
(Whereupon, at 2:53 p.m.,
the hearing in the 1
61 above-entitled matter was adjourned.)
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25
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