ML19354D784
| ML19354D784 | |
| Person / Time | |
|---|---|
| Issue date: | 12/05/1989 |
| From: | NRC |
| To: | |
| Shared Package | |
| ML19354D782 | List: |
| References | |
| GL-89-13, NUDOCS 9001220045 | |
| Download: ML19354D784 (99) | |
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Nuclear Regulatory Commission Meeting:
Workshops for Generic
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Letter 89-13 (Service Water System
-Problems Affecting Safety-Related Equipment)
Docket No; a
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.lDCAllON:
Rosemont, Illinois
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ogg Tuesday, December 5, 1989 PAGES: 1 - 97 f
A, ANN RILEY & ASSOCIATES, LTD.
1612 K St. N.W, Suite 300 Mshington, D.C. 20006 (202) 293-3950
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MEETING:
WORKSHOPS FOR GENERIC LETTER 89-13 5_
(SERVICE: WATER SYSTEM PROBLEMS
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6 AFFECTING SAFETY-RELATED EQUIPMENT) 7 8
9 Rosemont O' Hare Conference Center 10 5555 North River Road 11-Rosemont, Illinois 60018 12 13 TUESDAY, DECEMBER 5, 1989 14 15 The Workshop met, pursuant to notice, at 10:00 a.m.,
16 ANGELA T. CHU, presiding.-
17 L
' 18 PRESENT:
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. 19 VERN HODGE, NRC, Reactor Engineer (Nuclear) 20 JARED WERMIEL, NRC, Section Chief
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l 21 DUANE NEITZEL, Pacific Northwest Laboratory 1
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- PARTICIPANTS::
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2 Vern Hodge-NRR/DOEA/OGCB 3-Jerry Wermiel NRR/ DST / DEST
- 4 Angela Chu-NRR/DRP/PDI 5-Duane Neitzel PNL-
- s 6
Dick Cooper USNRC RIII e
7' Richard Hague USNRC RIII 8
Robert L. Cole Commonwealth Edison 9
John Jacobson USNRC RIII 10 Duane Danielson USNRC RIII 11 Christine Pershey Commonwealth Edison /Braidwood 12 Station f
I i
13 Suman Mehta Sargent & Lundy Engineers 1
14 Andre Feliciano American Electric Power-i l
15 M.A.
Lester Cook Nuclear Plant 16 Steve Cherba Cook Nuclear Plant j
17 Eric Mallen Cook Nuclear Plant 1
18-Dave Lyon CECO LaSalle
- 19 Roman Gesior Commonwealth Edison
-20 Wilburn Hester Commonwealth Edison /CSD 1
21.
Marcia A. Jackson Commonwealth Edison l
'22 Steve Szumski Commonwealth Edison 23 Nancy Nowlan Stone & Webster Engineering 24 Brad Gooden Stone & Webster Engineering 25 Russell Gouldy Florida Power & Light L
i 3
L 1
Tim LaHann Impell Corp.
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2 LoriLArmstrong Impell 3
Dave DeGruch NUTECH
'4' Bob Fraser Northern States Power 5
Ed'Ekis Nalco Chemical company o
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-6 Thomas Zogimann Duquesne Light 7
Gene Kurtz
-NUS 8
Bill Jung Betz 9
Tim Erger Iowa Electric 10' Wendell Keith Iowa Electric 11 Philip Thompson Illinois Power 12J William closser Toledo-Edison 13 Jerold L.
Lee Toledo Edison 14 Roy T. Holliday Toledo Edison 15 Girija S. Shukla Detroit Edison 16 Larry Karas Detroit Edison 17 Carol Bergs Wisconsin Electric 18 Michael D. King Consumers Power
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19 Gary Szczypka Consumers Power 12 0 David S. Hollabaugh Union Electric 21 Tim Eckert EPRI 22 Max J. Hollinden Illinois Power, CPS 23 Patrick Finnemore Wisconsin Public Service 24 John Christensen Wisconsin Public Service e
25 Tony-Lewis Carolina Power & Light
4 4
1 William S. Knous NUTECH 2
Michael Bielinski Consumers Power
.3 Gary A. Weber Impell 4'
E 6
7 8
9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 m
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5 1
PR0CEEDINGS i
2 (10:00 a.m.)
3 MS. CHU Hello.
My name is Angela chu.
I'm a 4
project engineer from NRR.
I'm assigned as lead project 5
manager for this plan action for closing out actions for
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7 As you know, NRC has been studying problems affecting 8
the reliability of service water cooling systems for a number 9
of years.
In July of this year, we issued the Generic Letter 10 89-13, service water system problems affecting safety-related 11 equipment.
12 To assist the industry in responding to this Generic 13 Letter, NRC plans to hold four workshops to discuss the 14 guidance in Generic Letter 89-13, as announced in the Federal 15 Register notice on October 23rd.
16 Last week, we had Workahop 1 and 2 in Philadelphia 17 and Atlanta.
This is the third one of these workshops.
18 Thursday, we will have Workshop 4 in Denver.
19 We have a panel of four NRC technical staff and one 20 contractor assisting the NRC Office of Research.
Two of the 21 team members couldrdt be with us today.
22 Our team members are -- I will introduce all of them:
23 Dr. Carl Berlinger, Chief, Generic Communications Branch, NRR -
24
- he's not here today; Mr. Jerry Wermiel, Section Chief, Plant 25 Systems Branch, NRR; Dr. Vern Hodge, Technical Contact for
6 I
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Generic Letter 89-13, Generic Communications Branch, NRR; Dr.
1.
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Duane Neitzel, Research Contractor on Generic Issue 51, Pacific i
2 i
3 Northwest Laboratories; and Rudy Bernhard, Regional Inspector, 4
NRC Region II Office -- he is not here today.
5 Each of these individuals has been involved in the
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6 development of Generic Letter 89-13, and they are here to
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l 7
answer technical questions on this Generic Letter.
i 8
The meeting will begin with a brief presuntation on i
9 the contents of the Generic Letter by Dr. Vern Hodge.
Then, we 10 will have a question-and-answer period, until everyone drops 11 from exhaustion or 5 o' clock this afternoon, whichever comes i
12 first.
We will summarize the meeting before we adjourn.
13 In the Federal Register notice, we requested the 14 licensees and applicants to submit questions in writing.
We 15 received many such questions in the mail, as well as from the i
16 first two workshops.
We have organized these questions in 17 categories, one for each of the recommended actions in Generic 18 Letter 89-13 and also including a general category.
19 Today, we also welcome you to give us additional 20 questions in writing during this meeting.
We would like to 21 consider these questions as a group before we read them into 22 the transcript.
We'd like to receive your additional questions 23 by noontime today.
This will give us an opportunity to sort 24 all the questions and consider the answers.
This is because t.
25 we want an accurate record of questions and responses in the
7 1
transcript.
2 our plan is to make public these deliberations by I
3 issuing a supplement to the Generic Letter, consisting of
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4 r'esponses to broad categories of questions and references to 5
the transcript of these meetings.
This will be placed in the e.
6 public document room.
We hope to issue this supplement this 7
month.
l 8
These workshops are designed to continue NRC dialogue 9
with the industry.
So, licensees and applicants should feel 10 free to continue to submit questions to their NRC project 11 managers even after these workshops are completed.
i 12 We will break the meeting at 12 o' clock for lunch and 13 reconvene at 2 o' clock this afternoon.
14 How, Dr. Vern Hodge will review the contents of 15 Generic Letter 89-13.
16 DR. HODGE:
Thank you, Angela.
Greetings, everyone.
17 I've heard many comments up to now about the fact 18 that we don't have any coffee and pastries.
This is the 19 Federal Government's effort to achieve good health in the
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20 Nation.
21 I think most of you are familiar with the Generic 22 Letter, but if you will allow me a few moments to review the 23 contents and make some remarks about our purposes in writing 24 the letter, then we can proceed.
25 First of all, as stated in the Generic Letter, the
8 L
1 intent is to ensure that the industry is in compliance with t
2 General Design Criteria 44,'.45, and 46 of Appendix A of 10 3
C.F.R, Part 50.
These have to do with cooling water.
4 Can you show the first slide, and they can see the 5
words there?
6 (Slide.)
7 DR. HODGE:
Number 45 is on inspection of the cooling 8
water system, and 46 is on testing of cooling water systems.
9 Appendix B also contains regulations that we are 10 trying to ensure compliance with, particularly Section 11 on 11 test control.
That's on the next slide.
12 (Slide.)
13 DR. HODGE:
We think it's important to note that many l
14 plants were not designed with the capability for the functional l.
i 15 testing of heat transfer, which is the purpose of the service 16 water system, of effectively removing heat from safety systems, 17 structures, and components to the ultimate heat. sink, and the 18 original testing was done for flow, and one of the purposes of l
19 the Generic Letter is to also bring into focus the need for 20 establishing heat transfer.
1 i
21 In addition to ensuring compliance with the GDCs --
22 do we have the slide there, the one that's entitled " Purpose"?
l 23 (Slide.)
L 24 DR. HODGE:
We are concerned that the safety water l
T 25 systems be able to meet the safety requirements of effectively l
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transferring heat, and we want to ensure that service water
, - 4 2
systems will continue to meet the design and function 3
requirements and regulatory requirements for the life of the 4
plants.
5 Now, the " Objective" slide.
6 (Slide.)
h
.7 DR. HODGE:
We essentially said all that.
s It's our belief that once plants implement effective 9
continuing programs to meet these regulatory requirements, they 10 will achieve marked improvements in the reliability of the 11
' service water systems.
12 As stated in the Letter, and on the next slide, a
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13 very busy slide --
14 (Slide.)
15 DR. HODGE:
The recommended actions in the Letter I 16 will just summarize.
You can see the words there.
17 The first one is to establish a program to guard 18 against biofouling.
The second one is to establish and 19 implement an initial and periodic re-test program for heat 20 transfer.
21 Number 3, to conduct routine inspection and l
l 22 maintenance so that there will be no degradation of the system, L
23 or -- I shouldn't use the word "no",
but there will not be 24 degradation beyond what is acceptable.
The idea here is that 25 we want active maintenance programs that won't let degrading
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10
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1 systems proceed to a point where there is a safety concern 2
before corrective actions are taken.
3 The fourth recommended action is to conduct single-4 failure walkdowns of the service water system, and the fifth, 5
to review procedures, practices, and training programs to 6
assure that personnel will be aware of the importance of the 7
service water system and, most importantly, to cut down on the 8
incidence on human errors.
9 Go to next slide.
i 10 (Slide.)
11 DR. HODGE:
In this slide, we have listed some of the i
12 elements of the questions we have received, and we'll be 13 hearing more about some of these things later on.
14 Actions 1, 2,
and 3 apply to open-cycle systems.
15 Action 4 and 5 apply to both open-and closed-cycle systems.
16 We define, in the Generic Letter, the service water system as 17 those systems that transfer heat from safety-related 18 structures, systems, or components, to the ultimate heat sink, 19 and intermediate loops are considered part of that, if they 20 have that function.
21 We've h21 ped define this by also noting that a 22 closed-cycle system is not subject to significant sources of 23 outside contamination, has controlled water chemistry, and does 24 not reject heat directly to the heat sink.
An open-cycle t
25 system, therefore, is everything else.
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1 i
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11 1
An important concern expressed in the questions we've 2
received is concerning flexibility.
The staff in developing i
i I
3 the letter was sensitive to plant characteristics and 4
variations and did not want to be overly prescriptive.
- Indeed, 5
you may find some of the answers to the questions today are, 6
perhaps, vague.
7 Example were given for guidance, but the specific actions needed to meet the general objectives were left to the I
8 9
discretion of the addressee -- both licensees and applicants.
I 10 We have phrases like " alternative actions", " equally 11 effective", and we have used those a lot in order to give you 12 the needed flexibility, e
13 The next slide gives some examples of such 14 flexibility.
15 (Slide.)
16 DR. HODGE:
For Action 1, we included an Enclosure 1, 17 which described an acceptable program to the NRC, but licensees I
18 and applicants are free to choose an alternative course of 19 action if they can justify that it will satisfy the heat l
20 transfer requirements of the service water system.
l 21 one aspect of this that will be discussed this 1
22 morning might have to do with biofouling agents in the source 23 waters.
Recently, we have come to learn that a creature named 24
" zebra mussel" is infecting Great Lakes waters and may spread t
25 to other surface waters in the United States in a relatively
i 12 1
short time.
5
?
The Enclosure 1 program was developed by a 3
Government-sponsored research program.
We made the 4
recommendation that you look out for everything, essentially, 5
but, in particular, in the research program, the main W
6 biofouling agents identified were things other than the zebra 7
mussel.
8 Regarding Action 2, the frequency of testing and 9
performing routine inspections and regular maintenance 10 activities is to be determined by the addressee based on their 11 plant operation experience and unique design characteristics.
12 We'll have several questions on this point later on this 13 morning.
14 It was not our intent to disrupt plant operations or 15 change plant protocol but to give you a vehicle to ensure the 16 adequate heat transfer of the service water system.
17 Action 5, on practices, procedures, and training, our 18 flexibility is exemplified by improvements by just what I have 19 just said, by staying within the plant protocol.
20 Does our staff have anything else to add to this 21 introduction to the Generic Letter?
l 22 (No response.)
23 DR. HODGE:
Then, we can proceed with the questions 24 and answers.
1 25 What we have been doing in the previous two l
1 w
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13 1
workshops, and intend to continue doing, is showing the t
i 2
questions on the vu-graph and then reading answers that we have
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3 prepared, which will eventually be made public.
4 We then ask you, if you need a clarification, to step l
5 to the microphone, identify yourself, and ask your question, i
6 and all this will be going into a transcript.
After each 7
question, I will give you an opportunity to do that.
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As we near the noontime hour, we will ask if you have 1
8 9
additional questions that you want to submit in writing.
We'd i
10 be glad to accept those.
Then, over the 2-hour lunch break, we 11 will consider answers to those and be ready to discuss them in I
12 this afternoon's session.
13 Noting that the numbers of questions has been growing 14 as we proceed at these workshops, we do not think we will be 15 able to finish by noon, so we'll need to mop up the rest of the 16 questions after the lunch break.
From previous experience, 17 though, we should be finished by 5 o' clock, as some of you have 18 carly flights or other considerations to take into account.
19 We have divided these questions in categories.
The 20 first category is called " general", and then we have a category 21 for each of the recommended actions.
22 (Slides.)
23 DR. HODGE:
What level of detail should be included 24 in the descriptions of existing and proposed programs?
25 You notice I have there that the source of this
14 1
question is Philadelphia Electric.
In the Philadelphia t
2 workshop, someone asked if this would be done.
We had not done 3
it in the previous two workshops, but we have that information 4
now, for most of the questions.
5 So, when you submit your questions in writing, please a
6 identify yourself or your company.
7 To answer this question, the level of detail should 8
be sufficient to permit an inspector to evaluate the activities 9
performed, the conclusions drawn, and the problems encountered 10 and resolved.
Each recommended action delineated in the 11 Generic Letter, or equivalent, should be addressed in
. 12 sufficient detail to enable an inspector to evaluate the 13 action.
l 14 Is there any question on that?
15 (No response.)
L 16 DR. HODGE:
The next question:
The Generic Letter i
17 provides the licensee with a great deal of leeway in defining l
18 their programs.
This leeway is desireable and justifiable, 19 given the wide variation in conditions that may prevail.
It is 20 anticipated that the main mechanism for judging compliance with 21 the Generic Letter will be NRC site inspections.
During such l
22 inspections, what will be the basis for judging the
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23 acceptability of the program?
What is being done to promote 24 consistency in interpretations among regions?
4 25 The purpose of this Generic Letter is for licensees 1
3
i 15 l
1 and applicants to assure the NRC that the heat removal 2
requirements of the service water system are satisfied.
This 3
is, as we mentioned before, required by GDC 44, 45, and 46 and 4
Appendix B.
Each individual inspector is responsible, at all 5
times, for judging any regulated activity, including programs 6
designed to respond to Generic Letter 89-13, against the 7
regulations.
8 These workshops constitute, to date, the NRC affort 9
to promote consistency among the regions regarding Generic 10 Letter 89-13.
We plan to issue these questions and answers as 11 a supplement to the Generic Letter, hopefully this month.
12 Guidance will thus be available to inspectors, as well as 13 licensees and applicants.
14 The traditional method of issuing a Temporary 15 Instruction for inspection from headquarters to regional 16 offices will not be used for this Generic Letter.
At least, 17 that is not the current plan.
18 The proposed supplement to Generic Letter 89-13 will 19 also reference the transcripts for these workshops, which will
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20 be placed in the public document room.
Individuals among the 21 authors of the Generic Letter will be available by telephone to 22 licensees, applicants, and inspectors, and may participate in 23 selected team inspections.
24 That's the answer.
Is there any question?
1, 25 Okay.
The next question:
Similar regional meetings
i 16 r
I concerning Generic Letter 89-04 were conducted in the June 2
timeframe.
To date, the minutes from these meetings have not 3
been received.
4 I'm sorry, were there some questions on the previous
)
5 question?
6 PARTICIPANT:
Would we get these documents in time to 7
provide enough time to respond to it adequately?
8 DR. HODGE:
Hopefully, we'll get them out in 9
December.
If not in December, in early January.
10 MR. DANIELSON:
Duane Danielson of Region III.
11 Since you're not issuing a Temporary Instruction, 12 does that mean that you're not assuming that the region will 13 conduct inspections in this area?
14 DR. HODGE:
No, it does not.
The difference is that, 15 instead of headquarters asking for inspections, each regional 16 management will be able to decide on its own whether 17 inspections will be conducted.
18 The third guestion -- I'll start again:
Similar
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19 regional meetings regarding Generic Letter 89-04 were conducted 20 in the June timeframe.
To date, the minutes from these meeting 21 have not been received.
When can we expect the minutes from 22 the Generic Letter 89-13 meetings?
d 23 I think we have answered that question now.
24 Concerning Generic Letter 89-04, the minutes were 25 issued by letter dated October 25, signed by James Partlow,
m 17 1
Associate Director for Projects, NRR.
The minutes are being i'
2 distributed to all licensees, meeting attendees, NRR project i
3 managers, and the public document room.
4 Okay.
Are there any reactions to that question and 5-answer?
f-6 (No response.)
7 DR. HODGE:
Next slide, please.
8 (Slide.)
9
' PARTICIPANT:
I have one other question.
Will we be 10 able to get copies of these slides?
11 DR. HODGE:
No, Sir.
These will be made available in l
12 the supplement to the Generic Letter.
i 13 If we are looking into several options to determine 14 which one is the most beneficial, however we had not made a 15 decision by the date that our response is due, would it be 16 acceptable to explain this and confirm that whatever option is 17 chosen will be completed on time?
18 The purpose of the 180-day response time was to 19 obtain the commitments, plans, and schedules of licensees and 20 applicants to implement the recommended actions of the Generic 21 Letter or their equally-effective alternatives.
Your l
22 decisionmaking process should be a part of the plans and 23 schedules and submitted to the NRC when the response is due.
24 If additional circumstances prevent such submittal, such as
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12 5 regulatory requirements, technical specifications, or outside
e 18 1
government agencies, then adjustments of the schedule should be 2
arranged with the appropriate NRR project manager.
3 Any clarifications needed?
4 (No response.)
5 DR. HODGE:
Next question.
6 (Slide.)
7 DR. HODGE:
What was the basis or experience used to 8
determine the schedule of completion for items 2 and 4?
Do 9
these schedules consider utilities with more than one plant?
,10 These schedules were set somewhat arbitrarily.
It 11 didn't seem like there was any objection to them.
As we have 12 said before, the schedules are intended to be flexible and
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13 should be reported to the staff in the licensee's response with 14 justification, if the recommended schedule is not used.
15 Adjustments of the schedule should be arranged with the 16 appropriate NRR project manager.
17 Next question.
18 (Slide.)
1 L*
19 DR. HODGE:
Do recommended actions 4 and 5 apply to 20 closed cooling systems?
21 Yes.
The Generic Letter defines " service water 22 system" to include both open-cycle portions and intermediate 23 closed-cycle loops that function to remove heat from safety-24 related structures, systems, or components to the ultimate heat 25 sink.
Recommended actions 1, 2,
and 3, specifically apply to
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open-cycle portions of the service water system.
Recommended 2
action 2 can be extended to the closed-cycle portion, as i
1 3
conditions warrant.
Whether a cooling loop is open or closed
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is not called out for in actions 4 and 5.
5 Any clarifications needed?
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(No response.]
i i
7 DR. HODGE:
Next question.
8 (Slide.)
9 DR. HODGE:
If the CCWS is part of the scope for i
10 items 4 and 5 of the Generic Letter, would it be possible to 11 modify the completion date commitments to fit this into our t
12 already-existing SSFI schedule?
That's the Safety System 13 Functional Inspection schedule.
14 The answer is yes, and we discussed that above, as we 15 will again later, below.
16' Any questions?
l 17 (No response.)
l 18 DR. HODGE: -Next question, please.
I 19 (Slide.)
20 DR. HODGE:
Can we defer the unit 2 required action 21 dates so that the coincide with those of unit 1 -- that is, 22 October 1990 to April 1991 -- for unit 2?
23 Again, we refer you to our previous answers.
24 Next question.
1 25 (Slide.)
l
20 1
DR. HODGE:
For action items 4 and 5 of the Generic 2
Letter, this utility plans to utilize the information gathered 3
from an SSFI for the essential cooling water and component 4
cooling water systems.
The SSFI supports the Generic Letter's 5
reporting requirements.
However, the CCW SSFI is scheduled for n
6 1990.
Is it acceptable to separate the reporting for the ECW 7
and the CCW systems -- that is, extend the CCW portion of the 8
Generic Letter?
9 The answer is yes, as we have explained before.
10 Next question.
l 11 (Slide.)
l' 1
.12 DR. HODGE:
The actions proposed by Generic Letter 13 89-13 constitute new staff positions.
To perform the testing 14 and inspection requested by the Generic Letter, it may well be 15 necessary for licensees to make significant plant 16 modifications.
For example, licensees will likely be forced to 17 install new instrumentation in order to perform tests and to l
18 monitor test results.
Furthermore, changes will be required of L
19 procedures.
An additional requirement of a walkdown has been 20 made.
21 The proposed tests may be beyond the licensing basis 22 of the plant.
These requirements seem to fit the definition of 23 a "backfit" under 10 C.F.R. 50, Paragraph 109 (a) (1).
24 Therefore, why were the requirements in the Generic Letter e
25 promulgated under the provisions of Section 50.54 (f)?
I' l
21 l
1 Our answer is that the NRC concluded that it was not l
2-assured that licensees and applicants are in compliance with 3
existing regulations -- namely, the GDC 44, 45, and 46 and 4
Appendix B.
The regulatory requests for information 5
represented by the Generic Letter is designed to give that l
6 assurance.
7 Next question.
t 8
(Slide.)
9 DR. HODGE:
Was a backfit analysis of the testing and E
10 inspection requirements performed?
Will the staff make that 11
. analysis available to the public?
In particular, did the 12 staff's backfitting analysis, if any, justify the need for 13 actions on closed systems?
14 The staff did not do a backfit analysis, as required 15 by 10 C.F.R. 50.109.
However, it did do an analysis for review 16 by the NRC Committee to Review Generic Requirements, known as 17' CRGR.
Since the CRGR reviews all proposed bulletins and 18 generic letters, among other proposed staff actions, this may
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19 properly be referred to as a regulatory analysis pursuant to 10 1
L 20 C.F.R. 50. 54 (f).
This analysis was not made public, due to its 1'
21 pre-decisional nature.
It may be made public on approval of 22 the Director of the Office Nuclear Reactor Regulation.
1 l
23 Indeed, the staff was not able to justify inclusion 24 of closed systems in the recommended actions of the Generic g.
25 Letter -- we're specifically referring to action item 2 here --
l i
22 j
1 l
'l as it'had once proposed to do.
Accordingi.y, it relaxed its 7
2 position on recommended action 2 with respect to closed-cycle
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3 cooling systems.
4 Any reaction?
j r
1 5
(No response.)
e =
6 DR. HODGE:
Next question.
{
7 (Slide.)
l 8
DR. HODGE:
The next question came to us from the i
y 9
Atlanta workshop.
I 10 Many of your responses this morning fall back to the 11 standard NRC position that the licensee should provide adequate 12 assurance that they have a program or actions in place to 13 satisfy the Generic Letter concerns.
This position could 14 create a problem later, when the inspector shows up to review 15 our program.
What kind of_ guidance will the NRR research staff
- 16 be providing to the inspector?
l.
17 If you don't provide specific instruction in l
- 18 something like a TI, the acceptability of a given program will 19 be left to the opinion of an individual inspector.
When will L
20 this type of guidance be available?
j'
. 21 We think we have answered this question.
22 Yes, Sir.
23 PARTICIPANT:
What will be the basic difference l
24 between this guidance and the TI?
25 DR. HODGE:
A Temporary Instruction is like any l
23 i
3 1
inspection module containing several parts -- purpose, t
2 objective, guidance, and inspection requirements and reporting 3
requirements.
These instructions are sent from the -- in 4
previous years, they were sent frem the Office of Inspection 5
and Enforcement in Washington to the regional offices for them 6
to incorporate into their inspection program for a temporary 7
period of time.
8 The essential difference would be the absence of the 9
section on inspection requirements.
Each inspector would be 10 free to inspect what he felt was needed to be inspected.
11 MR. WERMIEL:
Let me expand on that a little bit.
12 By definition, the Temporary Instruction is i
13 temporary.
The actions that are taken to improve the 14 reliability of the service water system are intended to be t
15.
permanent.
So, whatever inspection guidance, if any, we were i
16 to issue, should eventually become part of the core inspection 17 program itself.
18 Because we believe the intent of the current l
19 inspection programs for ensuring reliability of safety-related 20 systems is sufficient, we felt it was best to provide any 21 additional guidance to inspectors through the means that we're 22 doing here, and that is, hearing from you people, knowing what 23 issues and what concerns you have, providing them the guidance 24 through the supplement to the Generic Letter in this fashion i
l 25 ought to be enough to ensure that there is consistency among
'i 24 1
the regions when inspections are performed.
t
'2 The Temporary Instruction vehicle is just not 3
appropriate for this sort of an action.
4 DR. HODGE:
Thank you, Jerry.
5 Yes, Sir.
e-6-
MR. ECKERT:
Tim Eckert with EPRI.
7 If I understood what I just heard you say, you're B
saying that the supplement that is going to be issued is one of 9
the primary means by which we're going to educate the regional 10 inspectors.
11 DR. HODGE:
Correct, in addition to these workshops.
12 MR. ECKERT:
Okay.
With these workshops, I'd like to i
13' get a feeling as to how many regional inspectors are actually 14 showing up to these workshops.
15 MR. COOPER:
I can give you a feeling.
I'm the 16 Engineering Branch Chief in Region III.
Dick Cooper is my 17 name.
18 I've got Duano Danielson, whom you've already heard
'19 ask a question.
He's the Section chief of Mechanical and 20 Process Inspection.
He works for me.
21 John Jacobson is one of our staff inspectors who will 22 be involved, perhaps, in these, and also with us today is Dick 23 Hague, who is a section Chief over a number of the plants' 24 projects.
25 What we intended to do with this information is
r i
.I 25 J
l disseminate this to our inspectors in each branch, who will be i
2 probably be involved in inspecting your compliance with the 3
Generic Letter. - We don't have anybody here per se, but we have 4
a' means.
We have one staff individual who will be involved, j
5 and we intend to disseminate these questions and this 6
information to those who will be involved in inspecting your 1
7 facilities.
.i 8
Does that answer your question?
9 MR. ECKART:
Thank you.
10 DR. HODGE:
The last question in this general i
11 category was when does the NRC envision inspections to begin on 12 this letter?
j l
l 13 We say they should begin after individual licensees 14 indicate they have implemented their programs, such l
15 inspections will probably not begin until late 1990.
i 16 Now, we turn to questions on action 1, biofouling.
i l
17 (Slide.)
l 18 DR. HODGE:
The first question:
When determining 19 whether a plant has clams in its source water, does l
20 consideration need to be given to the presence of clams in the 21 plant vicinity -- that is, the local environment -- or solely 22 in the water body source of cooling water?
l 23 The purpose of this recommended action is to enable a 24 licensee or applicant to know if the service water system might l
25 be subject to biofouling.
All potential sources of water for
I i
26 1
the service water system should be examined annually for the 2
presence of biofouling species.
If no waters in the local 3
environment of a plant can get inside piping and components to 4
cause biofouling degradation of the heat transfer function of 5
the service water system, then such waters do not need to be L
6 sampled.
7 Any need for clarification?
4 8
(No response.)
9 DR. HODGE:
Next question.
10 (Slide.)
11 DR. HODGE:
What is the definition of " lay-up"?
12
" Lay-up" means the filling of a system.
Those 13 service water cooling loops normally operated with water in the 14 system,_even in a standby condition, should contain chlorinated 15 or equivalently-treated water, rather than untreated water.
16 Yes, Sir?
17 MR. BIELINSKI:
Mike Bielinski, Consumers Power.
18 How do you define the period for lay-up?
A refueling 19 outage or extended lay-up?
c 20 DR. HODGE:
Do you want to treat this?
21 MR. NEITZEL:
This relates to biofouling, and the 22 time period is the period that would allow biofouling to become 23 a problem in the lay-up of a system, especially one that has 24 sediment, and then lay-up of the unused component for the heat j
25 exchanger can become fouled and lose its heat-removal function.
i 27 1
That defines the period of lay-up.
So, it can vary with the t
2 climate.
3 DR. HODGE:
Additional questions?
4 MR. HOLLABAUGH:
Dave Hollabaugh, Union Electric 5
Company.
6 That's not to confuse lay-up with standby.
Is that 7
correct?
8 MR. WERMIEL:
That's correct.
The concern, I 9
believe, is the same kind of concern.
It can become fouled,
?60 depending on what system connects to it, and you may not know 11 it, because it is on standby, and you may not use it very often 12 at all.
13 so, you need to be aware of fouling in that kind of a 14 condition, as well, but you're right.
I would not equate lay-15 up conditions with standby conditions.
It's not the same 16 thing, although both are subject to potential fouling 17 mechanisms that could cause degradation in heat transfer.
18 DR. HODGE:
Anything else?
19 (No response.)
20 DR. HODGE:
Next question.
21 (Slide.)
22 DR. HODGE:
What constitutes an infrequently-used I
23 component?
Paragraph C in Enclosure 1 in the Generic Letter says 24 4
25 that redundant and infrequently-used cooling loops should be
P 28 1
flushed and flow-tested periodically at the maximum design flow 2
to ensure that they are not fouled or clogged.
This l
I 3
. recommended action refers to ECCS loops or other safety-related 4
cooling loops that are normally in the standby condition.
5 The next sentence says that other components in the
[
t 6
service water system should be tested on a regular schedule, to 7
ensure that they are not fouled or clogged.
This recommended 8
action refers to pumps, pipes, valves, strainers, or other 9
components, even in loops in which water is normally flowing.
10 Often, flow is inadequate in these loops without being detected t
11 in the absence of such testing.
12 Consider a system in which water is normally flowing 13 with parallel branches and in which the states of components in 14 the branches are not often changed.
For example, branch 15 throttle valves initially set before the plant began operation 16 may not be controlled by procedure.
Subsequent changes in the 17 throttle valve positions, for various reasons, or clogging of 18 these or other components in the branches would upset the 19 initial system flow balance without detection.
20 Any clarifications?
21 (No response.)
22 DR. HODGE:
Okay.
Next question.
23 (Slide.)
24 DR. HODGE:
To what extent should fire-protection
,i 25 systems be addressed in response to the Generic Letter?
1 29 l
l I
1 The Generic Letter is not designed to focus on fire-e-
i 2
protection systems but to incidentally include them if they use 3
untreated water that could be subject to the service water
[
4 system ills described in the Generic Letter.
5 Question?
j 6
MR. CLOSSER:
Bill Closser with Toledo Edison.
l 7
Most of us have codes which we have to live by for 8
state regulation on fire protection.
There was a question f
9 posed -- on some plants, fire protection is used as a 10 supplement for service water.
Are those the kind of complaints 11' that you were addressing in this case?
}
t 12 MR. WERMIEL:
Exactly.
The real concern is where you l'
13 may have an interconnection between the service water system 14 and the fire-protection system.
15 MR. CLOSSER:
So, those of us that do not have 16 interface between service water and our fire-protection system L
17 for backup need not really pursue this avenue.
Not as part of this program.
That's 19 correct.
1 20 MR. CLOSSER:
All right.
Thank you.
l
- 21 MR. NEITZEL:
As long as the potential for fouling is 22 not there.
That's the concern.
As long as the potential for 23 fouling -- that's what the big concern is here, end the fire 24 protection system's needs.
j t
25 MR. CLOSSER:
Well, the fire-protection system could m
30
-1 be fouled if it draws f;rts the wrong water system, but the
.t 2
intent of the Letter, is ey understanding, is clearly to ensure 3
that safety-related heat exchangers and safety-related 4
components function in case of an accident.
We're looking-at 5
fire protection from this standpoint, and those are designed to 6
meet state codes, which are already required.
7 MR. WERMIEL:
You're correct.
If your source of 8
water for fire protection is also subject to fouling, we would 9
expect that whatever program you have in effect at your plant i.
10 will consider that fouling and ensure that you get adequate 11 flow, but you don't have to include that as part of the program 12 that you address in response to the Generic Letter.
Correct.
13 MR. CLOSSER:
All right.
Thank you.
14 DR. HODGE:
Next question.
15 (Slide.)
16 DR. HODGE:
If it can be shown that the introduction 17 of mollusks into the service water system is not plausible 18 based on service water system design and make-up water system 19 design, can the requirements of the Generic Letter concerning 20 both inspection for and control of mollusks be waived?
21 The purpose of the Generic Letter is for licensees 22 and applicants to assure the NRC that the heat removal 23 requirements of the service water system are satisfied.
If 24' this can be done by this proposed program, then it is 25 acceptable.
s,
--a
---a
_--------_---,------__a
_-,--,-,--_m
- --+
31 1
Questions?
l 4
2 (No response.)
3 DR. HODGE:
Next question, please.
4
[ Slide.)
r
?
5 DR. HODGE: to the Generic Letter 6
recommends varying requirements for service water systems based 7
on intake structure configuration and location.
In a service a
8 water system in which the suction point of the service water
'9 pumps is in the collecting basin for the ultimate heat sink, as 10 the cooling tower, would the basin be considered the intake 11 structure, or would the source of basin make-up water be 12 considered the intake structure?
j l
13 Our answer is that each licensee or applicant should 14 define the scope of the intake structure.
The authors of the 15 Generic Letter considered that an intake structure would 16 contain all the waters eventually used in the system.
17 We have also treated this question earlier.
18 We have a question here.
Tony?
19 MR. LEWIS:
Tony Lewis, Carolina Power and Light.
20 Suppose you have a service water system that had 21 normal service water and emergency service water.
We should be 22 looking at not just the emergency service water but the 23 possible effects on the normal service water which would be up 24 the cooling tower?
25 MR. WERMIEL:
Only if the normal service water
~~-
32 1
system, in some way, could impact the functioning of your 2
safety-related or emergency service water.
In other words, if 3
there are interconnections that you cycle at diffe ent times 4
that could introduco water from the non-safety systems to the 5
safety systems, that needc to be considered in your program.
6 MR. LEWIS:
Thank you.
7 DR. HODGE:
Next question.
8
[ Slide.)
9 DR. HODGE: describes an acceptable 10 program to the NRC to implement recommendation number 1 of the 11 Generic Letter.
This program includes biocide treatment, 12 regardless of whether the plant is susceptible to microscopic 15 biological fouling or not.
Will a program that does not 14 include biocide treatment be acceptable to the NRC?
15 The answer is yes, for good cause shown.
16 Next question.
17
[ Slide.]
18 DR. HODGE:
Recommendation 1 states that initial 19 activities should be completed before plant start-up following 20 the first refueling outage beginning 9 months or more after the 21 date of this letter.
What is the intent of the phrase " initial 22 activities"?
23 Does it mean the first round of activities -- namely, 24 inspections, flushes, biocide trestment, etc. -- has been 25 completed, or the mechanisms have been put in place which will
q; 33 11
. culminate in the implementation of the program -- namely
\\
biocide discharge permits submitted, procedures written and 2
3 approved, etc.?
4 Both these possibilities could be included in the 5
intent of the phrase.
For those-activities involving an 6
outside governmental agency, the licensee or applicant should 7
arrange a needed adjustment in the schedule with the 8
appropriate NRR project manager.
For those activities 9
involving procedural changes or new procedures, " initial 10 activities" refers to those inspections or other activities by.
11 which the need for procedural changes or new procedures are 12 identified.
13 Any questions?
14 (No response.)
15 DR. HODGE:
Next question, please.
16 (Slide.]
17 DR. HODGE:
We use well water (raw water) as'a source 18
'to the fresh-water fire-protection storage tanks.
Do we need 10 to chlorinate these thanks, or do we need to conduct full-flow 20 surveillance tests on all fire-protection piping runs?
We 21 presently only surveil the fuel pumps for flow, not the piping 22 runs.
We do not presently chlorinate these tanks.
The service 23 water system per se is not used to fill these tanks.
Separate 24 well pumps are used.
(
25 I have a long answer here.
34 1.
The recommended program described in Enclosure 1 of 2
the Generic Letter was developed by a Government-sponsored m
3 research program.
If a licensee or applicant chooses an L
4; alternative course of action from that recommended in Enclosure
-5
- 1',
it should assess the potentials for macroscopic biofouling i
a.'
6 and microbiologically-influenced corrosion, commonly known as 7
MIC, and justify that.
The alternative course of action will 8
result in satisfaction of the heat-removal requirements of the j
9 service water system.
H 10 Paragraph B of Enclosure 1 of the Generic Letter 11' recommends chlorination whenever the potential for a j
12 macroscopic biological fouling species exists.
Such a N
13 potential may not exist for these wells, but the potential for
. 14 MIC should also be considered.
1
[
15 Paragraph C recommends flow-testing of infrequently-16 used loops periodically at the maximum design flow rate to 17 ensure that they are not fouled or clogged.
If the fire-
)
I 18 protection piping runs are subject to biofouling but the water lU' 19 is not treated to protect against biofouling, then the full-
'20 flow testing of them may be necessary to ensure minimum 21-potential for clogging.
This paragraph also recommends L
22 chlorination to help prevent MIC.
l 23 Any response?
l 24-(No response.]
3 l
25 DR. HODGE:
Next question.
L o
35 1
[ Slide.)
2 DR. HODGE:
Does the visual inspection of intake 3
structure apply to the intake piping, as well?
If so, will NRC 4
give guidance as to replacement criteria of piping?
If not, is 5
B-31.1 for wall thinning appropriate criteria?
6-The scope of the intake structure was purposely left 7
vague to afford licensees and applicants sufficient flexibility 8
in resolving problems and planning their responses to the 9
Generic Letter.
The NRC does not have an official position on 10 pipe-replacement criteria, but B-31.1 should be appropriate for 11 plants so designed.
12 Any discussion?
13 (No response.)
14 DR..HODGE:
Next question.
15 (Slide.)
16 DR. HODGE:
Larva sampling is difficult to do.
We 17; already have a sampling commitment, but we don't want to do 18 this and can justify not doing it.
19 The earlier that a licensee or applicant can identify 20 the presence of a biofouling species in a so'urce body of water 21 for the service water system the better chance they will have 22 to control the situation and prevent a potential safety 23 problem.
24 Any reflection?
25
[No response.]
36' f
1-DR. HODGE:
Next question.
2 (Slide.]
3 DR. HODGE:
This is several questions.
4 With regards to Enclosure 1, will NRC give guidance 5
on use of biocides other than chlorine?
6 No.
The NRC is interested in the effective heat 7
transfer of the systems.
We are not in a position to consult t-8 on the various biocide treatments.
9 Do we need to continuously chlorinate if, under our 10 inspection program, we find no evidence of macroscopic fouling?
11 Do NPDES-discharge limits take precedence to this?
12 The program described in Enclosure 1 represents a 13 program acceptable to the NRC for implementing the recommended 14 action 1.
A licensee or applicant can choose to pursue an 15 equally-effective alternative course of action, if justified.
1.6 Precautions should be taken to obey Federal, state, and local 17 environmental regulations regarding the use of biocides.
This 18 includes the National Pollutant Discharge Elimination System 19 (NPDES) discharge limits administered by the U.S. Environmental 20 Protection Agency that were referenced in the question.
21-Next question.
22
[ Slide.)
23 DR. HODGE:
Is demineralized water acceptable for use 24 in wet lay-up of stagnant service water piping?
25 This question must be decided by the licensee or
37 1-applicant..The result should be that the heat-removal n
.2 requirements of the service' water system are satisfied.
To 3
. accomplish-this,-the NRC recommends that such piping be flushed 4
And flow-tested periodically to ensure absence of clogging and 5-that chlorinated or equivalently-treated water be used to fill I
6 service water loops before lay-up to help prevent MIC.
7 Any reaction?-
8 (No response.]
L 9
DR. HODGE:
Next question.
10 (Slide.]
11 DR. HODGE:
Do Generic Letter 89-13 requirements 12 apply to-the fire protection systems which are not fed by 13 either the service water system or the service water intake?
14 I believe we discussed this before, but again, our 15 answer is no.
However, if the fire protection system source 16 water is subject to fouling or corrosion, then a periodic 17 monitoring program should be established to detect system 18 degradation.
c
~~
19 Next question.
20 (Slide.]
21 DR. HODGE:
Does the generic letter imply that 22 biofouling monitoring methods are required?
Are sidestream or 23 inline monitoring methods necessary?
Does the NRC have a 24 preferenca concerning the methods of visual, UT, radiography or 7
25 electrochemical probes to monitor for biofouling?
38 11 The answer is yes, biofouling monitoring of the
^
2-source water is necessary.
Sidestream or inline monitoring is 3-
. effective and could be used for this purpose.
The NRC has no 4
preference concerning methods of biofouling-monitoring or non-5-
destructive service water system examination, provided that the 6'
selected method is effective.
Any question? -
7 (No response.]
8-DR. HODGE:
The next question.
9
[ Slide.]
10 DR.. HODGE:
When stating we should be aware of-other
'll plants, facilities, et cetera, that use the same service water 12 source, for example, river; and their biofouling problems, how 13 far does that extend?
Within five miles?
Fifty miles?- Please 14 clarify.
L 15 Now,.the source of this question is-a statement made 16 in the Philadelphia workshop in which we said that it's 1
17 appropriate to use in your inspection program, results from l
18-other plants downstream or upstream.
But for this particular l
19
- question, the NRC cannot place a speed limit on biofouling l
20 awareness.
L 21 Conditions at each site will determine an appropriate 22 program on how far away to monitor for biofouling.
The l
23 licensee should use the best available site-specific 24 information and establish an appropriate monitoring program.
f 1
25 Any questions?
j 1
1 39
)
l 11 (No response.)
- f, 2
- DR. HODGE:
The next question.
3 (Slide.)
4 DR. HODGE:
Speaking about Action _ Item One, if the e
5-current sampling program which was initiated to detect Asiatic o
6 clams has-not found any mollusk infestation, do the sampling i
,7 methods have to be modified-to detect Zebra mussels.
The 8~
recommended sampling methods-and Recommended Action One are 9
intended to be general enough to allow licensees and applicants 10-to become aware of macro biofouling agents early enough to i
11 prevent the-associated fouling problems from adversely
-12 affecting the safety related function of the service water 13 system.
14 We recently issued Information Notice 89-76, entitled L
15 Biofouling Agent, Zebra mussel to discuss this problem.
Are 16-there any questions?
l l
17 (No response.]
p 18 DR. HODGE:
If not, the next guestion.
~19 (Slide.)
20 DR. HODGE:
Some state regulations do not permit the I
21 use of biocides above a minimum detectable level, yet Enclosure 1
22 One appears to require biocides while cautioning plants not to 23 violate state and local regulations.
l 24 Since it is not possible in some jurisdictions to use t
25 any biocides without violating state and local regulations,
'E
- + -
.. m--
m- -
.m
40 1-what' alternative to biocides are acceptable to the Staff?
~;'
2
'We remind you that Enclosure'One is a recommended 3
program that would-be acceptable to the NRC.
It is not 4-required and we have discussed this before.-
Are there any 5
questions on that?
6 Let me turn to the next question.
7 (Slide.)
8 DR HODGE:
What is the basis for requiring treatment I
'9-of fire protection-systems that use raw service water as a-10
- source?
Again, this is another question that has been L
11' discussed here.
l 12 The next question.
13 (Slide.)
i l
\\
'14 DR. HODGE:
Talking about inspection of intake 1
15 structure each refuel cycle; could inspection of other intake 16 structures, namely fossil units, on the same body of water that 17 have been in place and in service for up to-forty years, be 18-used to justify either to extend the frequency of inspection or 19 maybe no inspection at all?
-}
20 The inspection of the intake should not be restricted 21 to potential macro invertebrate fouling.
If the current 22 program in place at the fossil unit mentioned has been shown to j
23 be effective to date for detection of fouling, including
)
I 24 biofouling, mud and silt, then it may be sufficient for future 1
25 monitoring, however, the licensee or applicant should be aware
~
'x
.f.
w 41 3
and consider possible rapid. changes 11n environmental conditions
- 7.
and ensure'that'their' program includes the best available site-2
+
- 3
^ specific information.
4:
Any discussion on that?
5
.(No' response.)
.1 6
-DR.-HODGE:
Next question.
s 7
(Slide.]
- 8. '
DR.EHODGE:
That's the second sentence there.
For-9 NTOL plants, when does Generic Letter 89-13 have to be
'E i
- 10'
_ implemented?
11
.The program should be in place at the time of initial 12:
licensing; was our response.
Any questions?
13~
PARTICIPANT:
I have a question.
g 14 DR. HODGE:
Certainly, g
- -15 '
PARTICIPANT:
You say the plan.should be in place on L
'16 initial licensing?
What if that is one week after the Generic 17 Letter?
Does that make sense?
l 18-DR. HODGE:
Within the framework of the Generic l'-
19 Letter.
This Generic Letter was addressed to applicants as 20 well as licensees.
9 21' MR. WERMIEL:
If the plant is that close'to getting a 22 license, then, of course, the kind of schedules in the letter 23 would apply.
This was meant for a plant that is currently in 24 NTOL, which I doubt is even relevant to anybody here, in which p
25 the program has to be place by the time they get their license,
, uv i
t oc.
42
,t
.1 assuming that-there's sufficient time for that to occur.
LT
[n
~ 2
PARTICIPANT:
Well, let me be a little ignorant here.
3-In dealing with Comanche Peak,.which I believe is an NTOL plant e
4 5
MR. WERMIEL:
Correct.
p 6
PARTICIPANT:
I was really anticipating that all-M 7
these things had to be done prior to the_ starting up after the' 8
first refueling; is that not true?
9 MR. WERMIEL:
I don't believe so.
It' depends on 10
'whatever schedule Comanche Peak is on.
I don't happen to know 11-
. what that schedule is.
The best-time for them to have that-
'12 program in place is before they get their license, and that's-L 13
.what's intended.
14~
PARTICIPANT:
I may have to go back and re-read it.
L 15J What section of the Generic Letter gave me a special rule I I
.16 because I was NTOL?.
17-MR. WERMIEL:
I. don't believe that the Generic Letter 18
' talks about rules speci-fically --
L 19 DR. HODGE:
It does not.
The reporting. requirements E
20
~ paragraph just says that the responses should be due 180 days 21 after the date of the letter and at the first refueling.
-22 PARTICIPANT:
That does not give us a lot of time, 23 the people here in this region with this kind of question.
I'm
-24 sure whatever schedule Comanche Peak is on, they cali negotiate i
25 an implementation for this generic letter and its
43 1
recommendations-with the staff..
3 2
- Now, I_ don't know what schedule they're on.
I don't.
3 know what active date'--
4 PARTICIPANT:
It will still require it at the first 5
refueling, now, or the next refueling.
6 MR. WERMIEL:
No, traditionally, the staff on NTOL, 4
7-usuallylhas whatever programs there are to;be included based on 8'
Generic: Letter, bulletins or whatever, in-place at the time of 9
initial licensing.
That has almost always been the Staff 10 practice.
11 DR. HODGE:.
Any other questions?
12 (No response.]
13 (Slide.)
14-DR. HODGE:
The next question is on redundant and l
[
15 infrequently used cooling loops.
Define " infrequently used."
1' L
16 The wording in " frequently used cooling loops" is intended to i
17
' apply to those normally in standby mode under stagnant flow l..
l 18 conditions.
L
~
19 The Generic Letter 89-13 program should address means 20 for ensuring against fouling under such conditions.
21 If performance testing is done on all heat exchangers 22 periodically, will this satisfy the intent of the 23 recommendations?
24 Yes, periodic performance monitoring on all -- of all 25 safety related heat exchangers is acceptable, provided it
h A
44 1-1
. ensures heat transfer capability, not merely flow or pressure 2
drop.
Any questions on those answers?
Phil.
3 PARTICIPANT:
I know that at this time, EPRI is doing 4
some research on further Delta-T testing correlations to heat 5
transfer.
Will those be acceptable to the NRC when the-f 6
evaluations come out, if they come out positive?
7 DR. HODGE:. As long as they demonstrate heat 8
transfer, I would believe so, yes.
9 PARTICIPANT:
All right.
10 DR. HODGE:
The next question.
11 (Slide.]
12 DR. HODGE:
This is the last question in the category
't 13-on Action One.
If yearly inspections of a plant service water-14 intake-structure shows no indication of Asiatic clams and
' 15 testing results indicate that corrosion is not 16 microbiologically influenced; is it acceptable to continue with i
17 the annual inspections for clams and to perform maintenance and L
18 testing as required in Actions Two and Three of Generic Letter
~
19 89-13, in lieu of a cnlorination injection program?
20 Our response is that this appears to be reasonable 21 for good cause shown, and we refer you to previous discussion.
1-22.
Any questions?
23 (No response.)
24 DR. HODGE:
Turning now to the largest category of I
25 questions received on Action Two on heat transfer testing, the i
f~
I h
45 1
first question.was;'should,the proposed heat exchanger, heat 1
2' transfer testing method be provided for prior NRC review and j
3:
approval.
4' The answer:is no.
5 Next question.
6-(Slide.]
- 4. :
7 DR. HODGE:
Is it acceptable to determine the most 8
restrictive heat exchangers in each group for testing, in lieu 9
of testing every heat exchanger?
The purpose of the Generic 1CE
' Letter is.for licensees and applicants to assure the NRC that i
11-the-heat removal requirements of the service water system are l
12 satisfied.
i If this can be done by this proposed program, then it 13 14 is acceptable.
15 Next question.
16 (Slide.]
l L
17 DR. HODGE:
Has the NRC reviewed the EPRI Service 18 Water Working Group document prepared by Duke Power'and Toledo 19 Edison describing several methods of heat transfer testing?
If 20:
so, is the temperature effectiveness acceptable?
Which methods-21
.are acceptable?
22 The Staff has not formally reviewed this document, 23-but has received a draft copy.
A method of heat transfer 24-testing is acceptable for purpose of satisfying the Generic 25 Letter if it can be used to assure the NRC that the heat it a
46 1
removal requirements of the service water' system are satisfied.
't Y
2
.Any reaction?
4 3
.[No response.)
e 4
DR. HODGE:
Next question.
-5 (Slide.)
6 DR. HODGE:
If the pressure drop across the heat 7
exchanger at design flow is less than or equal to the 8
manufacturers' specifications,.is heat transfer testing I
9-required, provided-the baffles have been inspected to ensure 10 that the flow is not bypassing the coils?
11 The objective is not to satisfy.the manufacturer's 12 specification for flow in a heat exchanger, so much as it is to
~
.o 13 assure.the'~ heat removal requirements of a service water system.
-14 If the latter assurance can be achieved by showing its
?
15-condition to be necessary and sufficient, then heat transfer l'
161 testing would be superfluous.
17 PARTICIPANT:
Let's get a clarification on that.
I 18 have heat exchangers and I'm able to show that it removes the-
" ~
19 designed heat transfer it's supposed to remove, but at a 20 different water temperature or a different flow rate.
As long i
21 as I'm getting the heat transfer capability, it may not meet 22 the manufacturer's pressure drop, flow rate and things like L
23 that.
24~
DR. HODGE:
You'd have to extrapolate to the design gl 25 conditions.
a.
m; q;
47.
1 PARTICIPANT:
Heat transfer is not necessarily making
- g; 2
lthe heat exchanger match the original manufacturer's sheet as 3
far as pressure drop and things like that.-
4 IMR. HODGE:
That's under design conditions.
5:
MR.-WERMIEL:
We're looking to ensure that the heat
~'=
6:
transfer requirements that have been identified in the FSAR'or i
7 other licensing basis documents are satisfied, and~to ensure 8
that most of the specifications have -- are at a minimum.
9-We're not looking to ensure that the original margin of the 10 system is~ restored necessarily; only that you're satisfied that 11 1 you removal' design basis --
12 DR. HODGE:
Next question.
(
-13 PARTICIPANT:
According to the FSAR, not all heat 14-exchangers are designed for a given heat load.
Some of them 15 strictly require -- some of the small ones are strictly 16 required to maintain the temperatures on barium coolers and 17 things like that.
1 18 Are you anticipating requiring us to do heat transfer 19 testing on those?
We could easily do just a monitoring 20 program, temperature monitoring program to assure that they're 21 functioning properly.
22 MR. WERMIEL:
That's fine, for something like that, 23 the small heat exchangers, that's perfectly --
24-PARTICIPANT:
- Okay, a
25
[ Slide.)
48 lI DR. HODGE:.Okay, the next question is; to what 2-
_ extent can. routine maintenance or cleaning of heat exchangers 3
' replace testing?
4 The licensee'or applicant should determine the 5'
appropriate frequency of testing or maintenance activities to 6
assure that the heat removal requirements of the service water 7
system are satisfied.
For a given heat exchanger, a licensee
=
8 or applicant may elect to clean, replace, repair, or otherwise 9
maintain it initially before beginning a routine testing 1
10 program.
11' If the licensee or applicant elects not to conduct 12 routine testing program for the heat exchanger, then a routine 13 maintenance program may be necessary.to provide the sought 14 assurance.
In the absence of a routine test program, no basis 115 may be available for detecting potential degradation of heat 16 transfer performance.
17 In the absence of such a basis, the frequency of i
18 maintenance may have to be a maximum value to provide the
^
19 sought assurance.-
20 MR. GOULDY:
I have a question on it.
21 DR. HODGE:
All right.
22' MR. GOULDY:
Russ Gouldy, Florida Power and Light.
i-23-So you're saying we can't perform standard maintenance on 24 refuelings, if we find no problems, as opposed to our initial l
?'
25 test program?
i, l
49 p>r 1
DR. HODGE:
Yes.
4 2
MR. GOULDY:
We have one site that who wants to do j
. 3 that and one site who doesn't want to continue its. testing.
- 4 DR. HODGE:
Yes, there is a paragraph in the Generic 5
Letter addressing that possibility.
The intent of that 6-paragraph was for small ones, though.
7 Any other questions?
8
[No response.)
9 DR. HODGE:
Next question.
10 (Slide.)
11 DR. HODGE:-
In an effort to minimize the amount of 12 time that a single redundant division of safety-related 13 equipment is out of service, some utilities employ a divisional 14 outage: concept for major plant outages.
By utilizing this 15 concept, significant maintenance work activities -- for
- 16 example, system flow balance tests, standby diesel generator 17 teardowns, electrical distribution BUS work, et cetera -- are 18 performed on an alternating outage schedule for each division.
19 This permits comprehensive maintenance on each 20 division to be performed while reducing the overall impact on 21 redundant safety system availability.
The ability of a utility 22 to implement and maintain a service water heat removal 23 capability monitoring program would be significantly enhanced 24 by the installation of permanent plant monitoring equipment.
25 The installation of dedicated monitoring equipment
a
- 50 1
would also reduce _the impact of future testing on service water 2
and heat exchanger availability.
For a utility that employs 3
the. divisional outage concept and wishes to install permanent 4
plant equipment to perform the system testing identified in the
'S-Generic Letter, is it permissible to defer baseline data 6
acquisition for one division of the service water system until 7.
the second refueling outage -- following the issuance.of the 8
~ Generic' Letter?
9 Now, we say that this request appears to be 10 reasonable for good cause.
Any request for an adjusted 11 schedule should be arranged through the appropriate project 12 manager in NRR.
Any discussion on that question?
i
- t 13 MR.- WERMIEL:
I would just point out to the h
14 representative from EPRI that would also apply to an NTOL, 15.
depending on the specific projected licensing date and the type 16 of action that the licensee is contemplating.
l l
17 This is really intended for an operating plant, but l
L[
18
-could be applied to NTOL as well.
-19 DR. HODGE:
The next question.
l 20
[ Slide.]
21 DR. HODGE:
What is really required by the sentence 22 on adequacy of chemistry control programs in the first l
23 paragraph on page 5 on the Generic Letter?
24 Even though a closed cooling loop may contain water j
25 with controlled chemistry, the potential exists that the loop
,______a
w
J',
n 1
51 1
may be contaminated by in leakage,/ inadequate chemistry i
2 controls or materials in the system before the current 3-chemistry control program became effective.
4 An example of.this was recently disclosed at the EPRI 5
Service Water System Reliability Improvement Seminar at 6
Charlotte, North Carolina, on November 6th through 8th.
The i
7 internal study discussed there, optical examination of the 8
primary side of the decay heat removal heat exchanger tubes
{
9 disclosed no fouling; the tubes were shiny bright.
I 10
. optical examination of the closed component coolisg 11' heat exchanger, however, disclosed significant fouling.
The 12 tubes did not reflect any light.
The problem was a paraffin Y
13 based packing material inadvertently left in the system from 14 construction days.
15 Suppose the licensee'in this case can argue that it L
16-has a chemistry control program for water circulating through L
17 the CCW heat exchanger, but can't show that the program has 18 been in place since the system was initially filled.
A proper 19' response to the generic letter then would include testing of 20 the CCW heat exchanger.
21 At any point in the program, if a resultant finding
-22 of degraded heat transfer cannot be explained or remedied by 23 maintenance in the open cycle portion of the system as would be 24 possible in this case, the CCW heat exchanger should be tested, 25 and depending on those results, the DHR heat exchanger should
qm I
52 I
e l
a k
- 1; be tested.
2 The process should be continued until the problem is 3'
remedied.
6 4
An'y qpestions?
f 5'
(No response.)
3 6
DR. HODGE:
The next question then.
-.7
[ Slide.)
8 DR. HODGE:
Do both emergency service water systems 9-and normal service water systems need to be reviewed?
10
.Yes, the NRC is concerned about the safety-related j
.11 effects of both systems.
Sometimes the mode of operation of a p
12--
service water system is changed in emergency conditions to L
L J 13 introduce uncontrolled water and thus potentially introduce i
K 14 biofouling agents, corrosion products and silt that may 15 adversely ~ affect the heat transfer performance of the system.
16 Yes, sir?
l_
17 MR. HOLLINDEN:
Max Hollinden, Illinois Power.
This ja 18 doesn't mean that we have to look at non-safety related?-
19 DR. HODGE:
Correct.
20 MR. HOLLINDEN:
Only for safety related service water l
- 21 as well as shutdown service water?
22 DR. HODGE:
That's right.
Does our CCWS need to be 23
. addressed as part of our response?
We have recently shown 24 through eddy current testing of the heat exchangers that the 25 physical barrier between our service water and closed component
53 IL cooling water is adequate.
Makeup to the CCW is via makeup
'2 water.
3' I think we've discussed this question before.
The 4
next question.
5 (Slide.)
6 DR. HODGE:
The author of this question asked about-7' Recommendation Number Three.
I think he really might mean 8-Recommendation Number Two, although three could fit the 9
que'stion.
10 Recommendation Number inree does not specify a 11 frequency for heat exchanger inspections.
Is it the NRC's l
12 intent that the utility establish the frequency of these l
- 13-inspections?
Yes, the Recommended Action Two indicates limits.
14 l.
15-Initially, tests should be conducted at least once every fuel 16 cycle.
More frequent testing may be necessary to enable a 17 conclusion that the heat removal requirements of the system are l.
L 18 satisfied.
After about-three tests, a licensee or applicant l
l 19 may be in a position to set a differing test frequency, 20 however, the final determined testing frequency should not be 1
21 less than once every five years.
22 Any questions on that?
23 (No response.)
24 (Slide.)
25 DR. HODGE:
The next question received; what is meant
54 1-by." frequent regular maintenance?"
can frequency be determined 2._
int a similar method as test frequency?
3 Recommended Action Two' calls for heat exchanger 4
performance testing.
For small heat exchangers, such as 5
lubeoil coolers, et cetera, testing might be excessively 6'
burdensome compared to the maintenance of the heat exchangers.
D 7
A licensee or applicant can choose alternatively to routinely j
8 maintain the heat exchangers instead of testing them.
9 Either the frequency of maintenance of frequency of
.j 10 testing should be determined to assure that the equipment will 11-perform the intended safety functions during the intervals 12 between maintenances or tests.
13 Any response?
l 14~
(No response.)
-15 DR. HODGE:
Next question, j
16 (Slide.]
17 DR. HODGE:
Why were three tests chosen?
Could a 18 different number, more or less, be appropriate?
19 The number three is the minimum number needed to 20 establish a trend.
A larger number would be appropriate, but a 21 smaller number is insufficient.
22 Next question.
23 (Slide.)
24 DR. HODGE:
The generic letter does not specifically 25 address testing of automatic safety features actuation which
I 55 e
1-may be required to provide the required service water flow to y
2-safety related heat exchangers.
Does the NRC have any 3
recommendations on functional tests of systems?
4 We respond that the Generic Letter was written with
-5
'the tacit assumption that all other regulatory conditions would j
6 be. observed.
In particular, functional testing required by l
- s. -
7 technical specifications must be accomplished independently of 8
the recommended actions of the Generic Letter.
9 Where there is overlap, credit may be taken for the 10 Tech Spec required functional tests. 'The procedures, results j
11 and considerations of such tests should be documented with 12-response to the Generic Letter and retained in appropriate I-13 plant records..
li 14
.Next question.
y 15
[ Slide.)
16 DR. HODGE:
The term "all heat exchangers" is used.
L 17 Does this imply every heat exchanger of a given design must be l
18 tested, or where more than one identical heat exchanger is 19 used, can one representative unit be selected?
20 Recommended Action Two calls for testing of the heat I
21 transfer capability of all safety related heat exchangers 22 cooled by service water.
The service-water is defined as the 23 system or systems that transfers heat from safety related 24 structures, systems of components to the ultimate heat sink.
25 Each heat exchanger, therefore, regardless of
l 56 j
i 1:
l redundancy, should be_ tested or maintained initially to
'I 2
establish that the heat removal requirements of the service 3
water system are satisfied.
Existence of identical conditions 4
can then be used to determine the best test or maintenance 5
frequencies to assure that the heat removal requirements of the 6
service water system are maintained.
7 PARTICIPANT:
When you say each heat exchanger'should 8
be tested initially, is that one time or three times?
9 MR. WERMIEL:
Once you've established a baseline; in 10 other words, you've done the initial cleaning and you are 11 satisfied that the system is now meeting the requirements of 12 transfer capabilities, if you can then indicate in some way 13 that there are redundant heat exchangers that are seeing 14 identical conditions, in the same loop, there shouldn't be any
-15 difference, and then you may assume perhaps the most limiting 16 heat exchanger of that same type in that loop for future 17 periodic verification.
18 I can envision a case where that might actually 19 occur.
But the~ initial verification is intended to include all 20 system heat exchangers that have a safety function.
21 PARTICIPANT:
I understand that, but the initial 22 verification could be a one cleaning / testing phase and not the 23 series of three?
7 24 MR. WERMIEL:
That's correct.
1 25 DR. HODGE:
Another question?
L r
57 1
PARTICIPANT:
Yes, this is for your open water
- U 2
system?
3 DR. HODGE:
Excuse me?
4 PARTICIPANT:
Is this for the-open water system or
.5 the closed water?
We would plan to inspect only closed water.
g 6
DR. HODGE:
As the Generic Letter is written, it's J.
7 for the open water.
8 PARTICIPANT:
Only the open; thank you.
9' PARTICIPANT:
Didn't we talk earlier about using a 10 representative part of the group, choosing one restrictive heat 11 exchanger out of a group and making that representative of the 12 rest of that group?
1 13 MR. WERMIEL:
Initially, you've got to satisfy 14 yourself that all the system heat exchangers are doing their l.
11 5 jobs.
I don't know how you can do that by testing one heat 16-exchanger of a group when the one right next to it may be 17 fouled initially, u
18 Subsequent, for periodic verification, because of 19 identical. conditions, because of identical location or
- 20 something of that sort, the periodic program may not need to l
l 21 include more than the most limited heat exchangers.
l 22.
PARTICIPANT:
I would think that we would do that in 23 the case of ECCS room coolers.
All of them are at the same l
24 elevation.
All of them see roughly the same flow and the same r.
4, 25 usage.
I would think you could argue that --
V
h P
l' -
58-
-1 701. ~ WERMIEL: 'For something like a fan cooler unit as 2:
a room cooler, yes,~perhaps we could.
That may be an 3
. exception.
I'm speaking of tube heat exchangers primarily.
-4 DR. HODGE:
Any additional discussion?
5
[No response.)
1,-
6 DR. HODGE:
The next question.
7~
-7
.(Slide.)
8 DR. HODGE:
What is meant by "the relevant 9
temperatures should be verified to be within the design 10 limits?"
Does this-imply testing should be conducted with the 11 design basis heat load?
Is it acceptable to conduct testing 12 for all heat exchangers at off-normal conditions, providing 13 accurate and' relevant data can be acquired and analytical.
-?
.14 methods used to determine.the heat transfer capacity at design L
15 conditions?
-j L16 Enclosure Two in the Generic Letter contains much
[
l" 17 discussion about verifying the various parameters to be within L
18 design limits.
Testing with design basis heat loads is 19 recommended. ideally.
i l
20-If testing can be done under design conditions, it l
21 should be done under those conditions.
Realizing that this may 22 not be practical in non-accidental circumstances, the next best 23 step is to conduct tests under off-design conditions and 24 analytically correct the results to the design conditions.
25 Such a procedure is acceptable where it is necessary,
v-2 s
i T-8+
59 c
IL but not where testing under design conditions is practical.
)
2 Any questions?^
(:
j 3.
(No response.)
J 4
DR. HODGE:
Next question.
.1
-5 (Slide.)
T 6
DR. HODGE:
If the maintenance period is known, why k
7 can't a test be performed before maintenance to establish a 8-data point for the required testing or maintenance?
If the 9
overall maintenance has been three or more fuel cycles, could 10 this'be used to establish the test frequency?
r 11 Is it necessary to retest a heat exchanger after 12 maintenance if the work performed was a restoration only; that 13 is, cleaning and not tube pluggimg, and testing had previously 14 been conducted with clean heat transfer surfaces?
15 All these steps are acceptable alternatives to the 16-acceptable program outlined in Enclosura Two in the Generic 17 Letter.
The justifications that these alternative procedures
.18 assure that the heat removal requirenents of the service water 19 system are satisfied, should be documented and retained in 20 appropriate plant records.
21 Any questions?
22 (No response.)
23 DR. HODGE:
Next question.
24 (Slide.]
25 DR. HODGE:
What level of documentation is required
60 I
to justify excluding closed cycle system heat exchangers from 7
2 testing to verify heat transfer capability?
3 The goal of the Generic Letter is to obtain assurance 4
that the heat removal requirements of the service water system 5
are satisfied.
To exclude a closed cycle system heat exchanger 6
from testing, it should be shown that the chemistry of the 7
primary fluid and the heat transfer characteristics of the heat
=.
8 exchanger have been controlled since the time the system was 9-first filled.
10 Next question.
11 (Slide.)
12 DR. HODGE:
Recommended Action Two, paragraph 4, 13 states, " Tests should be performed following corrective 14 action."
Would bulleting tubes be considered as corrective 13 actions?
Our answer is yes.
16 Next question.
17 (Slide.)
18 DR. HODGE:
Recommended Action Two, paragraph 5 19 states that frequent regular maintenance is an acceptable 20 alterative to testing.
What is meant by " frequent regular 21 maintenance?"
Does this mean more frequently thaa if testing 22 were performed?
23 This paragraph further states that this alternative 24 might apply to small heat exchangers located in low radiation 25 areas.
Would low radiation areas be defined by ALARA l
61 1
practices, or less than 100 MR per hour?
2 The frequency of periodic testing or regular 3
maintenance is to be established by the licensee, once 4
sufficient data has been collected.
The frequency should 5
ensure that unacceptable degradation does not occur between O
6 testing or maintenance cycles.
o 7
Low radiation areas, as intended in Generic Letter 8
89-13, are included in the licensee's ALARA progran so that 9
radiation levels will not preclude personnel access for 10 scintenance or cleaning of heat exchangers.
Any questions on 11 that?
12 Next question.
13 (Slide.)
14 DR. HODGE:
To what degree should a utility endeavor 15 to monitor real time corrosion rates of the service water 16 system?
Is trending of heat exchanger performance and visual 37 inspections sufficient documentation of the component's 18 internal condition?
19 It is not necessary to determine numerical real time 20 corrosion rates in the service water system.
The licensee's 21 monitoring program should be sufficient to identify degradation 22 and take the necessary corrective action before the system 23 performance is unacceptably affected.
The transfer of data is 24 a recommended -- trending of data is a recommended approach to 25 monitoring system performance.
4
.: s 62 1
1 Any questions on that?
2
[No response.)
3 DR. HODGE:
The next question.
4
[ Slide.)
5 DR. HODGE:
The Generic Letter seems to imply that 6
periodic maintenance; thtt is, cleaning, of small, accescible 7
heat exchangers is acceptable in lieu of performance testing.
8 If so, is a refueling maintenance frequency acceptable?
9 Yes, this is an acceptable initial frequency and may 10 be acceptable in the long term with justification based on data 11 from a minimum of three refueling outages.
A question?
12 PARTICIPANT:
I think the question asked if frequent 13 maintenance in lieu of testing was acceptable, and if you're 14 not doing any testing at all with no data to base -- you're not 15 doing any more frequent maintenance.
The question is; is 16 frequent maintenance acceptable completely in lieu of testing?
17 DR. HODGE:
Yes, that question has been answered 18 before.
It is acceptable.
This question, I believe, asked if 19 the initial frequency of once per fuel cycle sufficient?
We,
20 again, answer yes.
21 (Slide.)
22 DR. HODGE:
The next question is; for heat exchangers 23 that cannot be tested at the design heat removal rate, what is 24 the NRC recommended method to extrapolate the test data to
! ?
25 design conditions?
Does the NRC have any additional L
L p
63 1
recommendation for extrapolating test data taken at very low t
2 loads, for example, less than 10 percent design load to design 3
conditions?-
4 We respond; the Staff does not have a recommended 5
method of extrapolation, however, the EPRI service water system 6
working group has been developing such guidance as have some o
7 licensees such as Duke Power.
These may be places to start 8
when developing appropriate testing programs.
9 Next question.
10 (Slide.)
11 DR. HODGE:
Generic Letter 89-13 states that tests 12 should be performed on heat exchangers before and after 13 corrective action is performed.
What is meant by " corrective 14 action?"
15 Corrective action is any action which alters the 16 condition of the heat exchanger to improve heat transfer 17 performance.
18 Next question.
19 (Slide.)
20 DR. HODGE:
Recommended Action requires that the 21 relevant temperatures should be verified to be within design 22 limits.
Also, Enclosura Two, Item 2-A states, " Perform 23 functional test!ing with the heat exchanger operating, if 24 practical, at its design heat removal rate to verify its 25 capabilities."
64 l
1 Temperature and flow compensation should be made in l
2 the calculations to adjust the results to design conditions.
3 It is not practical to test the heat exchangers at design heat
[
4 removal rates.
Also, we are unable to find a method that has 5
the requisite level of precision to adjust the test'results to 1
0 6
design conditions.
7 Please discuss an acceptable method to adjust the 8
test results to the design conditions.
Also, provide the 9
scientific bases or reference for the proposed method.
10 Also, the heat removal test cannot be performed on 11 the containment spray heat exchangers because there is no heat 12 source.
13 The only test that can be performed is a pressure L
14 drop test.
Is this acceptable?
If not, what is recommended?
l 15 As mentioned previously, NRC does not have a 16 recommended test method.
With regard to testing of containment i
17 spray heat exchangers, as with all safety related heat j
exchangers, a pressure drop test alone is not sufficient to 18 19 satisfy the indicated heat transfer capability concerns.
20 If a heat exchanger cannot be practically tested, 21 then the licensee may propose a program of periodic inspection, 22 maintenance and cleaning as an alternative.
We are aware, 23 however, of one licensee who was able to test the containment l
24 spray heat exchanger by heating the refueling water storage l'
25 tank water approximately 10 degrees Fahrenheit and then
+
-a--
. -m
l L
65 l
L 1
performing temperature monitoring tests as well as pressure j
l 2
drop tests.
[
3 Any reactions?
4 MR. FELICIANO:
I have a question on that.
5 DR. HODGE:
Okay.
6 MR. FELICIANO:
Andre Feliciano, American Electric 7
Power.
You just stated that by heating the RWST water 10 l
i 8
degrees, you can perform a heat transfer test on the CTS heat 9
exchanger.
That is if the CTS heat exchanger has a loop that 10 allows you to do that.
11 Now, if you don't, then the only method that would be 12 allowable should be a maintenance program and a pressure drop 13 program; is that correct?
14 MR. WERMIEL:
That's right.
15 DR. HODGE:
That's right.
How much detail does the 16 NRC expect for the response to Action Two?
Would the proposed
(
17 test / maintenance / inspection method for each heat exchanger be 18 necessary?
19 Specific details of the licensee or applicant program 20 in response to Action Two must be developed and retained as 1
s 21 part of plant records.
Submittals to NRC in response to this 22 generic letter should provide only enough information to 23 sufficiently describe the approach to be taken for each heat 24 exchanger; that is, tests, maintenance and inspection.
. 4 25 Those heat exchangers not being included in programs f
i 1
66 1
under Action Two should be identified and the basis given for 1-1 2
being excluded.
Grouping of heat exchangers into categories 3
based on the approach to be used, would be acceptable.
t 4
Any questions?
5 (No response.)
l 6
DR. HODGE:
Next question, please.
7 (Slide.)
8 DR. HODGE:
Is the NRC staff stating that a technical h
9 evaluation of a heat exchanger's capability to perform its l
[
10 design safety function cannot be used in lieu of initial 11 testing?
12 Therefore, all heat exchangers must be tested and 13 even maintenance or cleaning cannot be used in lieu of initial 14 testing because it would require a technical evaluation to l
1 15 determine maintenance or cleaning frequency.
16 Also, when considering several identical heat 17 exchangers in one loop, do all the heat exchangers require L
18 testing or maintenance or cleaning?
19 The answer is no.
The initial, heat exchanger test 20 program may consist of both performance testing of some heat 21 exchangers and maintenance or cleaning of others.
The Staff's 22 previous response on the initial test program was intended to 23 ensure that the licensee has established a baseline for all 24 safety related heat exchangers served by the service water i
25 system, and therefore is confident that they can perform their
67
)
I 1
heat removal function.
I 2
As further clarification, if there are several l
3 identical heat exchangers in one service water loop, a licensee 4
may perform testing or develop a maintenance or cleaning 5
program for those heat exchangers based on the most limiting
(
6 one as part of their initial test program.
7 Justification on the basis of comparable service 8
conditions should be included in the response when all 9
identical heat exchangers are not tested.
Any discussion?
10 (No response.)
11 DR. HODGE:
Next question, please.
12 (Slide.)
i 13 DR. HODGE:
We would like to limit heat exchanger 14 performance testing to one unit, since the two units are 15 identical.
Is this an acceptable approach?
16 Not totally.
We've discussed this in previous 17 questions and we refer you to that discussion.
18 Next question.
19 (Slide.)
20 DR. HODGE:
Referring to Action Item 2, can the test 21 program include data taken during routine operating intervals 22 with minimum load on heat exchangers and extrapolate it to 23 substantiate adequate heat exchanger performance?
Or, when j
does the NRC consider it impractical to test a heat exchanger 24 25 at the design heat removal rate?
+.
i i
I i
68 1
We have discussed this question before.
Next i
2 question.
3 (Slide.)
h 4
DR. HODGE:
If maintenance is performed in lieu of i
l 5
testing for degraded performance of the heat exchanger, how.
6 extensive does the maintenance have to be?
That is; does 7'
maintenance have to be performed on both sides of the heat 8
exchanger or just on the service water side?
9 We refer you to previous discussions.
Next question.
10 (Slide.)
11 DR. HODGE:
This has some background to it.
They're 12 talking about Recommended Action 2, asking an item of i.
13 clarification.
Can you move it down one to paragraph --
14 Angela?
i JE (Pause.)
16 DR. HODGE:
Do all safety-related heat exchangers i
l 17 connected to or cooled by service water or raw water have to be l
t l
18 tested or verified clean by maintenance to ensure satisfaction 1
19 of the heat removal requirements prior to plant start-up 20 following the first refuelling outage beginning nine months or 21 more after the issuance of the generic letter?
22 our answer is yes.
23 The reason he asked that or the Licensee asked that, 24 if the heat exchanger was cleaned 13 or possibly 18 months 25 prior to issuance of this generic letter and found to be clean L
l m
m.-
r=
1 F
69 1
or tested and found acceptable, and the current program does
^
2 not call for recleaning or testing for three years, then the 3
program would have to be revised, f'
4 Also, trend data may already exist indicating that 5
there is no need to clean or test on less than a five year 6
interval.
If the heat exchanger is part of a larger component, 7
that is not scheduled for maintenance, all these being reasons 8
for asking the question.
9 The generic letter is designed to provide flexibility 10 in determining a justifiable alternative program for testing.
11 The goal of the letter is to assure that the heat removal 12 requirements of the service water system are satisfied, j
13 Any reaction from the audience?
l l
14 (No response.)
]
15 DR. HODGE:
Next question.
16
[ Slide.]
l 17 DR. HODGE:
The Advisory Committee for Reactor i
18 Safeguards on June 14tl., '89 issued a letter to the commission 19 noting five areas of concern with which "CBARG, that's the 20 Nuclear Utility Backfit Action Reform Group, agrees.
21 Some of the concerns were accommodated in the generic 22 letter.
However, we are interested to know the resolution of 23 the following -- and it goes on for a couple more -- yes, l
4.
that's right.
24 25 An intermediate closed cooling water system is exempt I
70 l'
from the generic letter provided it is not subject to-
't 2
significant sources of contamination, is chemistry-controlled 3
and does not reject heat directly to a heat sink.
However, the 4
adequacy of the chemistry control program must be verified over 5
the total operating history of the plant.
The ACRS questioned 6
whether the absence of an adequate water chemistry control 7
system over any part of the operating history of a closed cycle 8
system was adequate justification for including the system 9
within the scope of the generic letter.
10 How did the Staff resolve this concern?
11 The Staff relaxed its position on including closed 12 cfcle cooling systems in Recommended Action II, but added the 1
13 precautionary recommendation that if degradation of heat 14 transfer cannot be explained or remedied by maintenance of the 15 open cycle part of the service water system then testing may l.
16 have to be selectively extended to the closed cycle part of the L
17 system.
18 Then the second part of their question was are plants 19 requirad to review closed cooling water system operating logs 20 for the history of the plant to verify adequate chemistry l
21 control?
l l"
-22 Again, Licensees and Applicants are required to 23 assure the NRC that the safety related heat removal l
24 requirements of the service water system are satisfied.
If 1
25 review of closed cooling water system operating logs for the
i 71 1
history of the plant can help provide this assurance, then that 2
would be an acceptable part of the program.
3 Any reaction to this question?
i 4
(No response.)
5 DR. HODGE:
Next question.
6 (Slide.]
's 7
DR. HODGE:
Would a program involving inspection and 8
maintenance activities in lieu of a performance test program be 9
an acceptable program for all heat exchangers and components?
10 I think we have discussed this before.
11 Next question.
P 12 (Slide.)
13 DR. HODGE:
Programs acceptable to the NRC in 14 response to the generic letter actions 1 and 2 were identified.
15 What are some examples of acceptable-inspection and maintenance 16 programs in response to e; tion 3?
17 The NRC has not defined an acceptable program for
,18 action 3.
However, the generic letter is designed to give the 19 licensee or applicant sufficient flexibility in developing an 20 appropriate program.
Refer to several questions above bearing 21 on the several aspects of such a program.
22 Any questions?
23 (No response.)
24 DR. HODGE:
Next question.
25 (Slide.)
t.
72 1
DR. HODGE:
This is the last question on this i
2 category.
Is it acceptable t.o elininate heat exchangers from 3
the testing requirement of action 2 if they are in parallel E
I 4
and/or in series with other heat exchangers which are tested i
5 and operated under similar service conditions, for example
.=
I 6
velocity, temperature, process fluid?
l'*
7 Refer to the EPRI heat exchanger performance 8
monitoring guidelines for the service water systems.
9 We have discussed this question before also, t
10 Do you want to say something, Jerry?
11 MR. WERMIEL:
Yes.
It is now 10 'til 12:00, so if 12 you have got any questions, we'd like to have them now and that i
13 will allow us time to prepare a response if we can.
qi 14 What we plan to do when we get back is finish the 15 remainder of the previously identified responses to questions.
There's not that much and depending on whatever, what other 16 1
17 additional questions you have this afternoon we may have to l
l 18 meet for maybe un hour or so.
l 19 DR. HODGE:
Jan you identify yourselven if you want 20 to submit questions to us?
l 21 MR. WERMIEL:
Yes.
On any written questions --
22 DR. } LODGE:
The question has been placed forward thet 23 since we only have just a few questions to finish up our 24 prepared material and only one or two questions will be coming 7
l 1,
25 from the floor, we could consider those tempor -- well, L
l l
i
,A..
I i
r l
73 I
extemporaneous -- well, at the same time --
2-(Laughter.)
3 DR. HODGE:
-- and then continue the meeting until 4
its conclusion, probably another 30 minutes should do it.
5 Do you want that?
All right.
Then let's be back 6
here at ten after 12:00.
7
[Short recess.)
8 DR. HODGE:
Hay I have your attention.
Has everyone i
9 had a chance to submit questions to us?
10 Have we received all questions from this audience?
11 I take it that we have.
12 We can continue to discuss the questions that we have 13 received before this workshop and then we will discuss the 14 questions that we have received from this audience.
15 The next category is on action 3 about routine (4
16 inspection and maintenance, can everyone hear me all right?
17 Recommendation 3 states " Ensure by establishing a 18 routine inspection and maintenance program that corrosion, D.
L' 19 erosion cannot degrade the performance of the safety-related u
20-systems supplied by service water" (emphasis added).
j, 23 It would seem unrealistic to assume that a program 22 could be developed that will ensure absolutely no degradation 23 of the system.
Could you clarify that the intent here is to g,
establish a program which would ensure that the system cannot 24 25 degrade to the point at which its ability to perform its safety
L_
1 F
74
[
.1 function is impaired?
l 2-The authors of the generic letter concur in this 3
interpretation.
1 i
4 Any questions?
't 5
(No response.)
6 DR. HODGE:
Next question.
i 7
(Slide.)
8 DR. HODGE:
Must all safety-related service water 9
piping.be cleaned or only the piping that is susceptible to 10 corrosion buildup, that is, low flow areas.
Nondestructive 11 examinations would be used te confirm the areas needed to be 12 cleaned.
f*
13 Recommended action 3 is-intended to provide assurance 14 that open cycle service water piping and components do not have 15 degraded performance from corrosion, erosion, protective 16 coating failure, silting and biofouling.
Once this assurance 17 is made, the routine maintenance and inspection program can 18 concentrate on those piping segments that are susceptible to
- ~
19 these problems.
20 Would it be considered acceptable to omit from 21 inspection piping which is practically inaccessible -- that is, 22 underground piping based on inspections of practically 23 accessible piping?
j our answer is that inaccessibility itself would not 24 25 be a sufficient reason for not inspecting.
However, if
PO
~
)
o i
'I b
75
- d Sk,
1 additional justification including operational data and prior w
((
2 history are available along with an evaluation which clearly l
l
]
1 justifies that inspections would not be necessary, then j
]
l' 4
inspection could be precluded.
)
1 5
Any reactions?
l s
6 (No response.)
i
+
7 DR. HODGE:
Next question.
8 (Slide.)
9 DR. HODGE:
Refer to Item 3.
Does the maintenance 10 program have to include sampling of any crud or sediment found 11 to determine its source?
12 I didn't read the emphasis right.
13 Does the maintenance program have to include sampling 14 of any crud or sediment found to determine its source?
For 15 example, during routine maintenance a small amount of sediment 16 was cleaned from a heat exchanger and the only documentation 17 stated that it appeared to be a normal corrosion deposit.
la Our answer is that if the maintenance program can 19 assure that the heat removal requirements of the service water 20 system are met, then it is acceptable.
The better the root 21 cause analysis of a problem is however, the more effective will 22 be the corrective action.
23 Any reactions to that?
k.
24 (No response.)
25 DR. HODGE:
Next question.
i 76 1-
[ Slide.)
2 DR. HODGE:
Refer to Item 3.
If minimum fouling is 3
found during maintenance it should be acceptable to assume that 4
the heat exchanger can still perform to the original design 5
specification.
Does the NRC have a problem with this 6
assumption?
4 7
The NRC Staff cannot judge the adequacy of heat j
8 transfer capability based on the broad statement of minimum i
9 fouling.
The Licensee must determine what fouling level 10 requires corrective action and justify the approach taken.
11 Any questions on that one?
12 (No response.)
L i
13 DR. HODGE:
Next question.
14 (Slide.)
15 DR. HODGE:
Under specific action 3A on page 6 of the 16 generic letter, what constitutes excessive accumulations of 17 biofouling agents, corrosion products and silt?
l L
18 The Staff does not have a quantitative criterion for l
19 this parameter but notes that recently one plant removed more 20 than 20 tons of such accumulations from its service water 21 system.
If such accumulations cause degradation of the heat 22 transfer capability of the system as shown by performance trend l
23 data, then such accumulations are excessive.
24 l 7 Any reflection on that question?
i 25 (No response.)
I'
)
i l!
J 77 q
1 DR. HODGE:
Next question.
2 (Slide.)
3 DR. HODGE:
And this will be the last question of 4-category 3 -- are plant work requests adequate, relevant 5
documentation to support the inspection and maintenance 6
documentation requirement of specific action 3.
l 7
Yes, as long as they can be made available to an NRC 8
inspector.
9 Now in category 4 on single failure walkdown, we i
10 received a number of questions.
11 The first one is to what extent does this walkdown 12 have to be performed?
We are presently conducting a design i
13 basis documentation reconstitution effort.
A system walkdown 14 is performed only if a problem is identified during 15 documentation review.
Walkdowns are not conducted all the time 16 and are not full scope.
Is the intent to complete walkdowns as 17 required to ensure system meets the licensing basis for the i
18 plant or to verify the as-built condition?
19 The intent of the recommended action is to verify 20 that the as-built condition of the system is sufficient to 21 ensure performance of the intended function of the service 22 water systen.
The phrase "in accordance with the licensing 23 basis for the plant" was inserted for fairness to those plants 24 licensed before a single failure criterion was instituted in 25 the regulations.
E p
i t
78 i
L 1
A design basis reconstitution suffices for the L
4 2
walkdown inspection recommended here.
3 Any questions?
4 (No response.)
5 DR. HODGE:
The second question was a service water 6
system walkdown inspection was completed in 1986 at our plant.
7 can we take credit for that effort for this action or must we 8
repeat it now to meet the two-year criterion?
9 You may take credit for the 1986 walkdown to meet 10 this recommended action.
The suggested time of two years to 11 qualify the word "recent" was not meant to be rigidly 12 interpreted.
The NRC is interested in the walkdown being done 13 now or recently, not in the distant past.
14 Next question.
15 (Slide.)
16 DR. HODGE:
Does the system walkdown take into 17 account piping, valves and in-line components?
What about 18 cabling walkdown?
Is our 79-14 valkdown sufficient to address 19 this?
+
20 We think they are referring there to the Bulletin 79-21 14 on seismic qualifications of piping systems.
22 The system walkdown should take into account 23.
everything about the system.
The recommended action 4 is 24 intended to make maximum use of other pertinent activities in 25 reviewing the system but it is not sufficient to depend on 10
I-9 79 1.
year old reviews to ascertain the condition of the system i
2 today.
3 However, we understand that Bulletin 79-14, " Seismic 4
Analyses for As-Built Safety-Related Piping Systems," is not t
5 closed at all plants, so if the walkdowns have been done 6
recently, they would be acceptable.
7 Any questions?
8 (No response.)
I 9
DR. HODGE Next question.
10 (Slide.)
11 DR. HODGE:
Recommendation No. 4 discusses system 12 walkdown inspections.
GPU Nuclear assumes that the intent of 13 the walkdown is down to the level of a flow diagram only.
Does 14 the NRC agree with that assumption or do we intend for a more l
15 detailed walkdown?
16 Single failure inadequacies can occur in control 17 systems as well as equrpment into which water flows.
We note 18 that single failure inadequacies have been found in some plants 19 apart from routine surveillance procedures.
20 In addition, consider whatever else was said this 21 morning.
22 Any questions?
23 (No response.)
24 (Slide.)
25 DR. HODGE:
The next question received was are there l
t
80 1
any specific requirements that are new that should be added 2
into existing single failure analysis?
Explain what is meant 3
by " reconstitution of the design basis of the system is not 4
intended."
5 The recommended action 4 for single failure walkdown 6
was not designed to incorporate any new feature into existing 7
single failure analysis techniques.
The phrase " reconstitution 8
of the design basis of the system is not intended" refers to 9
excessively difficult determinations of design data.
For 10 example, this may be the case for small, skid-mounted heat 11 exchangers that were purchased as piece parts of larger units 12 of equipment and for which design data may not have been i
13 provided to the Licensee or Applicant by the vendor, 14 It would be enough to demonstrate that the equipment 15 module of which the heat exchanger is a part could do its job.
16 Next question.
17 (Slide.)
18 DR. HODGE:
Please elaborate on the requirements of 19 item 4, specifically what is intended by confirmation of the 20 performance of the service water system in accordance with a 21 desitJ*. basis without a reconstitution of the design basis?
22 Also, is it intended by this requirement to perform a 23 complete single failure analysis of the service water system?
24 Our answer is the Licensee is expected to confirm 25 that the installed, as-built system satisfies the design
3 z
l i-l
~
81 i
i a -
requirements stated within the plant's licensing basis -- that l
1 2
is, the FSAR, the tech specs and additional licensing 3
documentation.
4 A single failure analysis is to be part of this 5
confirmation.
l' 6
Any questions?
\\
7 (No response.)
y 8
DR. HODGE:
Next question.
9-(Slide.)
f i
i 10 DR. HODGE:
The generic letter states that the l
11 licensee should verify that the service water system is in 12 accordance with the licensing basis of the plant.
Is the
.4 13 licensing basis in the context of this generic letter 14 considered to be the FSAR and tech specs or will a more 15 expansive interpretation be used?
16 We say the licensing basis is as defined in the FSAR, j
17 tech specc, and other licensing documentation.
It is not the l
H1,8 Staff's intent that the licensing basis be redefined when
+
19 addressing generic letter 89-13.
20 Next question.
1...
21 (Slide.)
L 22 DR. HODGE:
Action item 4 of generic letter 89-13 23 states that system walkdown inspections are required to confirm 24 the as-built configuration service water system.
As a 25 recently-licensed plant, we are confident that our
~-
=
82 1
configuration control program satisfies this requirement.
We 2
believe system walkdowns are unnecessary for our utility.
j 3
This position appears to be reasonable for good 4
cause.
Ongoing programs that contain results pertinent to 5
generic letter 89-13 should be referenced in the response as t
6 justification for an equally effective program and retained in i
7 appropriats plant records.
8 Any questions?
9 (No response.)
10 DR. HODGE:
Next question.
11 (Slide.)
12 DR. HODGE:
If other design-related issues are being 13 addressed by other regulatory actions, is it acceptable to 4
1 14 exclude them from the scope of review for action 47 l
15 We refer you to the previous question.
16 Any discussion?
17
[No response.)
l 18 DR. HODGE:
The last question in category -- for 19 action 4 is with regard to action 4, which requests 20 confirmation that the service water wystem will perform its l
L 21 intended function in accordance with the licensing basis for 22 the plant, which specific licensing basis uust be reconfirmed 23 at this time, only the single active failure review?
24 I believe we have answered this question.
l 25 Yes, sir?
~
m 83 4
1-PARTICIPANT:
Question -- what was that answer?
Yes 1
2 or no or up to our judgment?
3 DR. HODGE:
It could be all three, I guess, i
4 (Laughter.)
5 MR. WERMIEL:
Let us read the answer to A again and
?
6 see if that doesn't help --
7 DR. HODGE:
The very first question?
Okay.
"The 8
intent to the recommended action is to verify that the as-built 9
condition of the system is sufficient to ensure performance of 10 the intended function of the service water system.
The phrase 11
'in accordance with the licensing basis of the plant' was 12 inserted for fairness to those plants licensed before a single 13 failure criterion was instituted in the regulations.
4 i
14 A design basis reconstitution" -- for which Question L
15 A was talking -
" suffices for the usikdown inspection 16 recommended.
1 17 PARTICIPANT:
I guess my concern in this regard is 18 that there is generally more to a licensing basis for a system 19 than single failure criterion -- there's one of potentially 20 many criteria based on what your case studies would indicate or 1
21 that there are perhaps other design concerns.
22 What specifically I am looking to learn from this 23 workshop is what constituter a walkdown criterion, what 24 constitutes review criteria that will address a minimum t
25 complement of licensing basis requirements.
If that is simply
84 e
r 1
to verify that the system is capable of withstanding a single l
2 active failure, then that would be the answer, but again given 3
that the licensing basis addresses other elements, you're I
4 concerned that that would be too limited of an approach 5
MR. WERMIEL:
To be more specific, I don't think we io 6
are asking you to go back and re-review the sub-calculations 7
for example that established the transfer requirements or heat S
removal requirements for various complements.
That would be 9
beyond the scope of what we intended by this particular item.
10 However, in the cource of examining your system you 11 ought to be able to confirm that the minimum capability 12 intended with regard to single failure complement configuration l
4 13 and this sort of thing, the things that you would normally pick 14 up with a walkdown, are satisfied without necessarily having to 15 go back and review all the paper that constituted the original 16 design, those calculations, that sort of thing.
17 PARTICIPANT:
If you are conducting a walkdown and 18 you are trying to determine the adequacy of the component 1
I*
19 systems that are being walked down, it would seem that you l
L 20 would have to have something to compare it against.
2.1 MR. WERMIEL:
Yes, you'd have presumably two sets of 22 things -- perhaps an P&IE and perhaps a piping arrangement 23 drawing or a layout drawing of the system.
Those are the sorts 24 of things.
i I
25 For example, you could determine if there were pipes
~.
l.I g
85 l
t 1
and cords missing.
You could determine if the configuration-1 2
wasn't correct.
You could determine if there was a valve 3
that's actually in the system that isn't on a diagram, that 4
sort of thing.
5 PARTICIPANT:
How would this tie back into one of the 4
e 6
principal concv*ns, that of single failure?
I am not sure if I d
7 can connect the two just yet.
8 MR. WERMIEL:
Okay.
You have designed the system to 9
satisfy single failure capability. Presumably the system as 10 documented will do that.
In the course of doing the walkdown, i
11 you are going to make sure that the system as diagrammed and 12 documented is actually what is installed.
l 13 If you have doubts that the diagram itself is for a 14 system that can actually satisfy the single failure criterion,
(
25 then you have to go further than what I think was envisioned by
[
16 the generic letter.
17 We did not envision you going back and re-18 establishing that you have a system that is indeed single l
19 failure proof, so to speak.
20 PARTICIPANT:
So I guess what I am hearing is that l
21 you can go out into the plant and conduct a walkdown against l
22 the design drawings which identify the features of the system, 23 such as pipe supports and perhaps control system configuration 24 and just basically as-built, that system in the field against j
25 what's on paper and conclude that you are reading the licensing i
86
[
.1 basis for the plant if there is conformity between the as-built L
2 condition and the as-designed condition.
3 MR. WERMIEL:
I would say so, yes.
That is what was 4
intended by the generic letter.
5 D..
HODGE:
Is there additional discussion on this-R
=
6 point?
e 7
Yes, sir?
8 p'RTICIPANT:
Let me try to summarize that for myself
-9 in a different manner.
Say a recent vintage plant, say five 10 years or less, was designed, single failure designed, the 11
-intent of action item 4 is to confirm your design against a 12 single action failure?
That's basically the sole intent of 13 that confirmation, if you can demonstrate an active l
14 configuration program will apply to your plant, then a walkdown l
l 15 may not be required -- if you provide that single failure --
16 DR. HODGE:
That's right.
17 MR. WERMIEL:
That's correct, particularly if you 18 have got some nechanism in place for that program that's l~
19 periodically instituted.
In other words, when you make design I
. 20 changes, this program has been shown to be effective.
You've 21 incorporated those design changes, you did the right set of 22 documents'and this kind of thing.
23 FARTICIPANT:
Who doesn't have a program like that?
l 24 MR. WERMIEL:
Many plants have such programs but I 25 believe inspectors will tell you that they are not always very
'V
87 1
effective becauce we go and we check and we find cases where 2
the program was supposed to pick up the design change didn't 3
adequately pick it up, the procedures weren't properly revised 4
and incorporate some changes that were made, things of that 5
nature.
6 Those types of examples incidentally are in the 7
. enclosure, the AEOD case study that was enclosed in the generic 8
letter.
9 PARTICIPANT:
So you could perhaps rely on your 10 inspection, past inspection history as a basis for exempting 11 yourself from taking any new action on this item?
12 MR. WERMIEL:
Yes, if you want to.
If you have got 13
-- a program and it's been inspected before and you're 14 confident with it, it hasn't shown any problems in the past I 15 believe that could be an adequate way of addressing this 16 particular issue.
17 I hate to say categorically it's going to be okay but la if you're confident in it, who am I to argue?
Because I don't 19 know what it is.
20 DR. HODGE:
Well, that program may be there and 21 acceptable of course we are also interested in the single 22 failure walkdown.
23 MR. WERMIEL:
Well, keep in mind that eventually all 24 plants will be inspected so it is not me you have to convince, 25 it's the usual NRC inspection team that would show up or other i -.
,i
~
88 i~
people-that show up.
4
(
2 I'd be real confident if I've actually already had a 3
review of that program by some independent inspector, the NRC
~
-4 or INPO or something.like that.
I wouldn't be so confident if E
5 no one else had ever looked at it.
g.
T 6!
DR. HODGE:
Anything else?
'7
-The category on action 5 we received one question:
8 Please discuss what constitutes the desired response for action 9-item 5, which is confirming the adequacy of maintenance 10-practices operating and emergency procedures and training that 11 involves a service water system.
12 The letter states that the confirmation should h[
i 13 include recent reviews of practices, procedures and training 14 modules.
Please provide some guidance for performing an t-
'15 adequate review, w
-[
16 Also, are there any other actions which the NRC Ei'
'17
- recommends as part of the confirmation?
lf
+.
({
18 The Staff has no specific guidance on what 19 procedures, training, and maintenance practices should be 20 evaluated or. revised.
The intent of this item is to increase 21 personnel awareness of the importance of the service water 22 system with the aim of reducing operator errors.
==
I-23 Personnel or procedural errors were identified as a m.
h-24 significant source of service water system failures in the AEOD
-E' 25 case study.
ung i
25 j
i P-l EF
.. ~ ~ -
89 1
Any-reaction to that?
4-
-2 (No response.)
3:
DR. HODGE:
That. concludes all the questions that we 4
=have' received and had prepared answers for before this 5:
workshop.
o 6
We would like to now turn to the questions that you 7
have submitted to us and treat them in much'the same way.
8 The first one is should the single failure analysis 9
of the service water system include motive power -- that is 10 electrical, pneumatic, et cetera -- to active components, 11 motors, valves, et cetera?
If so, should it be limited only to 12 the delivery of the motive power to the component and not the 13 single failure reliability of the motive power sources, that is 14 do not need to do single failure analyses on motive power 15 system.
16 We respond yes.
The Licensee should consider single 17 failure in power operated equipment or components that are part 18 offthe service water system.
Single failuree in power supply o
19 systems themselves do not need to be considered under this 20-generic letter.
21 P3RTICIPANT:
Could you read that again?
22 DR. HODGE:
The question should the -- the question 23 is should the single failure analysis include motive power to 24 active components, and we say yes.
The Licensee should g
25 consioer single failures in power operated equipment and
, ;t t
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- w 90 l'
' components.that are a part of the service water system.
-1" 2
In contrast, single failures in power supply systems 3
fthemselves do not'need to be considered under this generic
~4 letter.
In other words, I think we are defining it so that you 5
have to just go back.to the source of power.
If' transmission o
6 of power-to the service water system is-single-failure free, J7 then we're satisfied.
8 Did you have a question?
9 PARTICIPANT:
For example, on a valve close 10
-- on a single failure analysis you don't care about why it 11 doesn't close -- you know, whether it's mechanically bound or 12 it doesn't have electrical power or whatever?
I'm not sure as 13 far as a single failure analysis goes whether it makes any 14 difference as far as the valve is concerned.
15 MR. WERMIEL:
That's true. The kind of single failure 16 analysis you might do is the sort of thing you do in a check 17 analysis that you submit.
There you don't go back to review 18 of the specifics of the power supply system itself -- you don't 19 look at failures and individual relays, the breakers or buses, 20 that sort of thing.
21 DR. HODGE:
The second question submitted to us just 2
22 now, for a fire protection system supplied by raw water, which 23 meets flow requirements and does not provide safety related 24 cooling, are any actions required?
And our answer is no.
25 However, we recommend that such systems if subjected to
91 11
~biofouling be laid up with treated water.
77 2<
Is that' accurate and fair?
Okay.
3 It turns out we understand that we should have 4
'r'eceived four additional questions, but we did not until-this 5
' workshop'so'let's just consider those now.
6 In Enclosure 2 of the generic letter a statement is 7
made that testing should be done with necessary and sufficient 8
instrumentation.
Flow measurement is one of the two key
-9 parameters when measuring heat. exchanger performance.
It is 10 also the most difficult since most plants never provide a means 11 to measure individual flow rates to service water users.
In 12 general, plates, tubes and flow nozzles are the only recognized i
13 traceable type of flow measuring devices, all of which_ require
,14 '
intrusive elements.
15 To be able to utilize such devices would require 16
' plant system modifications at great expense to the utility and
'17 its customers.
A less expensive alternative to this would be 18 to-use non-intrusive non-traceable devices such as transit time 19 ultrasonic flow meters which with current technology give very
~
20 reliable resultc.
Trending of data taken with such devices 21 would appear to be equally effective for detecting degradation
^
22 in cooling water systems.
Would the NRC recognize the value 23 and benefit of using such devices and accept programs which 4
,[
24 utilize them?
And the answer is yes.
25 Yes, sir?
i
m 92
.1 PARTICIPANT:
Whatsrange of accuracy on-these-
,t-2-
instruments do you consider acceptable?
3 MR. WERMIEL:
I guess that would depend on the flow
.4 that you're measuring.
I'm not familiar with the details of 5
some'of these instruments but I know some of them are not real 6'
good.
Again, we're trying to get an assurance that the heat u
7 exchanger can remove sufficient heat.
We're not hung up on 8
particular accuracy in particular applications.
If you believe 9
you're getting the kind of information you need to ensure heat 10 transfer.with these instruments under the conditions you're 11 using them, then I would go with it, particularly if you're l-l
[
12 able to show that it is working.
l ft 13 DR. HODGE:. Does that answer your question?
R14 PARTICIPANT:
Yes and no.
15 DR. HGDGE:
Yes, sir?
E
' 1 <6 PARTICIPANT:' This doesn't help a lot.
There was a 17 NUREG document in 1985 that talks about instrument 18 uncertainties -- it gives you a methodology for taking into 19 account instrument uncertainties.
20 DR. HODGE:
Yes, sir?
21:
PARTICIPANT:
One further comment.
The ultrasonics -
-22
- are they traceable --
23 DR. HODGE:
Your question is, are they traceable? They are.
s-25 Well, as we'll probably get to, maybe we can just say n
l 93 1I that we're not. interested in you-absolutely proving a minimum
]
d6 H
2 level of-performance capability as we are interested in;you
~
3 showing that you're able to transfer sufficient heat in-an
~4-accident.
J 5
.(Slide.]
o=
6 DR. HODGE:
The next question was, thermographic
-7 cameras could potentially be used to scan the tubes on air to 8
. water heat ~exchangers to see temperature profiles of the tubes 9-and detect tube blockage or sediment in the tubes; will the NRC 10 accept such qualitative checks rather than quantitative 11-measurements to prove.that a heat exchanger is not' fouled?
12 Yes, however, additional'means should be included in the
]
13 program to ensure adequate heat transfer.
14 MR. WERMEIL:
In other words, to look for -- in the 15
. initial check is fine, but how do you_know that fouling that 16 you've seen is or is not causing the problem without doing the i
17 next step, and that is taking it out, or doing the heat 18 balance check on the heat exchanger?
The visual check for 19 fouling may not be enough.
20 DR. HODGE:
The next question.
.21~
(Slide.)
. 22 DR. HODGE:
Is off-the-shelf software -- or, if off-23 the-shelf software is reviewed for technical adequacy and 24 subsequently utilized to perform' heat exchanger performance 25 calculations, will it be acceptable to the NRC?
And the answer i
0.
-L
u 94-1 is yes.
[
2 The following question, if a heat exchanger 3
performance test reveals that a heat exchanger is in a degraded 4-condition,Lthe first obvious question will-be as to what the 5-impact of the degraded condition is on system operability.
~6 6-
.Will a heat exchanger performance program be considered the
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7 same as a plant surveillance. program, with the same 8-ramifications for questioning plant or system operability?' If 9
so,-is the NRC considering asking licensees to include limiting 10 condition for operation statements in our technical
.11
. specifications?
12 I'll go back. The first question, will the heat 7
13
= exchanger performance program be considered the same as a plant 14 surveillance program, with the same ramifications for
'15 questioning plant or system operability?
The answer is yes.
16
- If a heat exchanger, heat transfer capability, is shown to-be 17 degraded below levels needed for the design basis heat-removal, 18 then.it is considered inoperable.
19 Next question.
20
[ Slide.]
21 DR. HODGE:
If so, is the NRC considering asking the 22 licensee to include limiting condition for operation statements
-23t in their technical specifications?
The Staff does not intend 24 elements of these programs to be included in plant technical f
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25 3p - ' " ! ~a ti ont.
~
U r
-95 11-Any questions?
4 2.
Well, that concludes all the questions we have.
3-Excuse me, you have a question?
4 PARTICIPANT:
I have a couple of questions.
Do.you 5
anticipate any additional recommendations --
y 61 MR. WERMIEL:
In answer to your question, no, we do
- ?dL 7
not anticipate any additional recommendations in the j
-i 8'
supplement.
The supplement will be nothing more than the more-9 detailed information notices.
In other words, those -- that 10' information that we're,giving you here is all that will go in
]
F
_11 it, j
'12
.Now, in the-future as we learn more we have,.I guess,
'{-
13 a continuing program to determine based on operating experience 14 and analysis, this sort of thing, what, if any additional 15 criteria or recommendations or guidance needs to be promulgated 1
i 1 15 and if so.in what form?
Is an information notice sufficient, a 17 generic letter, that sort of thing, but as far-as this action l
18
-goes now, nothing more will be in the supplement than the 19 current questions and answers that you've just heard.
20 DR. HODGE:
The questions and answers will be the i
21-guidance.
22 MR. WERMIEL:
If you're concerned that your response 23 hinges on some of these questions and answers, then you want to 24 make sure that your response is consistent with what we're 25 saying today and believe it's important I would do just what we w
96' JL-said in-answer-to some of the questions ~already asked,-and that
- j..
^'
2 is, get some relief from the schedule for your response.
- Now, 3
I= don't anticipate there's going to be much of a delay getting 14 this out, but, again, if there is and you're concerned about
'S instrumentation then the schedules are intended to be flexible.
6 MR. WI; TEL:
I don't understand myself how the
-is 7-issuance of the supplement would affect that response.
We're 8
essentially just asking for commitment at that time.
9 DR. HODGE:
We're not asking for final response on 10~
January 18th, we're just'asking for o commitment with plans and 11 schedules for accomplishing the recommendations or-their 12 equivalence.
13 Before we leave we circulated earlier a list for 14 names and organizations and telephone numbers of attendees.
15 Has1anyone not signed that list?
A whole bunch of people.
We 16 appreciate your signing this list because we intend to read it 17 into the transcript and make it a part of the proceedings.
18 We appreciate your attendance at this workshop.
As 19' we mentioned, this is the third of four workshops and the last 20 one will be given the day after tomorrow in Denver.
We plan to 21' incorporate all your questions and the ensuing discussion in 22
,this supplement to the generic letter and I intend to work on 23-it tomorrow so that we can advance the schedule as much as 24 possible.
This being the holiday season, of course, 25 availability of personnel is getting to be a problem, but we
~
>-l*
i 97 1
.,?'
-1; still hope toiget the CRGR to review this proposed supplement r
i1 i a-
- 2 later this month and with their approval we.would Issue.it.
3 Is there anything else that needs to be said?
E 4
Okay, well, if you would-sign the attendance sheet
- s 5
we'd appreciate.it and without any further questions the
- )'
6 meeting will be adjourned.
7 (Whereupon, at 1:00 p.m., the meeting adjourned.)
9
' 10 11 12 13 14 15 16 17-18 w
19
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20 21 22 23 4,-
24 25
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[b REPORTER'S CERTIFICATE i
This'is to certify that the attached proceed-ings before the United States Nuclear
. Regulatory-Commission JWL
'in the matter of:-
T E.
NAME OF PROCEEDlNG:
Workshop Generic Letter 89-13 DOCKET NUMBER:
PLACE OF PROCEEDING:
Rosemont, Illionis were held as herein appears, and that this'is the original transcript.thereof for the file of the United States Nuclear Regulatory Commission 4
taken-by me and.thereafter reduced to typcwriting by me or under the direction of the court report-
. ing company, and that the transcript is a true.
and accurate record of the foregoing proceedings, t
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[
-d 5674 4 f
Ronald N.
LeGrande Official Reporter Ann Riley & Associates, Ltd.
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