ML19354D785
| ML19354D785 | |
| Person / Time | |
|---|---|
| Issue date: | 12/07/1989 |
| From: | NRC |
| To: | |
| Shared Package | |
| ML19354D782 | List: |
| References | |
| GL-89-13, NUDOCS 9001220046 | |
| Download: ML19354D785 (76) | |
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. water: system-Problem. Affeeting
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.g + -.$ h I E ( ,NE Thursday. December 7 198.9 PAGES:. 3,.., .s 1?.. 9 ,I'7-. .3 ?_ Ir I i e t + ANN RILEY& ASSOCIATES, LTD. 1:: 1612 K St. N.W Suite 300 Mahington, D.C 20006 7 (202) 293-3950 3go.,;;0(.46 900111 ppR ORG NRRB g
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NUCLEAR REGULATORY-COMMISSION 3-t q. Ull MEETING:-WORKSHOPS-s L. l5' - - -- - - - - -X -l .t! 'Af '6!'For: 7. GENERIC LETTER 89-13 (SERVICE WORK ORDER NO.-NRC-348-36 i 8 ' WATER SYSTEM PROBLEMS AFFECTING: 9 SAFETY-RELATED. EQUIPMENT) 11 0
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) 'll-The Registry Hotel 12' 2303 Quebec Street' 13 Denver, Colorado' e a " 14-Thursday, December 7, 1989 i 15 l 16 ' APPEARANCES: l 17 i '18 MS. ANGEL
- T.
CHU, PROJECT ENGINEER f ( 19 NUCLEAR REGULATORY COMMISSION l 20 DR. VERN HODGE, REACTOR ENGINEER 21 NUCLEAR REGULATORY COMMISSION 22-MR. JARED WERMIEL, SECTION CHIEF 23 NUCLEAR REGULATORY COMMISSION '24 DR. DUANE NEITZEL -( 25 PACIFIC NORTHWEST LABORATORY r !.O.'
2 1 IN ATTENDANCE: ,-( WOLF CREEK N.O.C. RICK L. RIETMANN,ONOFRE 2 GUY SHELTON SAN SO. Cw. EDISON MARCO D. AH6MADA HCUSTON LIGHTING AND POWER 3-PAUL B. COX TEXks UTILITIES MANU PATEL ,T.U. ELECTRIC LANSING TIMOTHY ECkERT, EPRI - SEkVICE WATER. ASSISTANCE \\< 4 GROUP. S-KEN HUKARI PORTLAND GENERAL ELECTRIC ARTURO P. 00RRAL,FT. PORTLAND GENERAL ELECTRIC . r'
- FRANCIS G.
BUCK CALHOUN OPPD 6' PATRICK J. DOLA STONE & WE STER ENGINEERING-CORP. TIMOTHY C. PRENGSR, STONE & WEBSTER ENGINEERING \\< 7 JONATHAN L. ANDERSON PACIFIC NORTHWEST LABORATORY ASHOK DAVE ARIZONA hUBLIC SERVICE CO. NELSON HALbAS ARIZONA PUBLIC SERVICE CO. 8 JOHN-S. TAGGAkT ARIZONA PUBLIC SERVICE CO. DARRON DAYEFORDS NEBRASKA PUBLIC POWER DISTRICT WILLIAM R. HENNE ENERCON SERVICE INC. 9 JEFFREY'P. NIBER TENERA ENGINEEkING SERVICES CHERYL ADAMS SOU HERN CALIFORNIA EDISON JARLATH M. CORRAN SOUTHERN CALIFORNIA EDISON 10 ALAN-S. COHLMEYER UADROX CORPORATION JOSEPH P. KOWALEW K ARKANSAS POWER & LIGHT MILTON HUTT -ARKANSA$ POWER & LIGHT 11 ALBERT D. T6TH USNRC REGION V IAN BARNES, UShRC REGION IV 12-13 14 x 15 16 17 18 19 20 21 '22 23 lt-24 25 4
3 1 l
- 1' PROCEEDINGS
! ' (L 'b MS. CHU: Hello. My name is Angela Chu and I'm a-I 2-h 3. Project Engineer from NRR.- I've been assigned:as the Lead 4-Project Manager for th m multi-plant action on Generic Letter 89-5 13. 6 As you know, NRC has ben studying problems affecting 7 the reliability of service water cooling systems for a number of 0 years. In July of this year, we issued Generic Letter 89-13, 9 Service Water Problems Affecting Safety Related Equipment. To 10 assist the industry _to respond to this Generic Letter, NRC plans 11-to hold four workshops to discuss the guidance in Generic Letter 12 89-13, as we announced in Federal Register October 23rd. Last 13 week we had two workshops, 1 and 2 in Philadelphia and in Atlanta.. '14 Two days ago we had Workshop 3 in Chicago. This is the fourth one 15 of these workshops. We have a panel of four NRC technical staff 16 and one contractor' assisting the NRC Office of Research. Our team 17 members,-two of them cannot be here today, but I'll introduce the 18 whole team. The first one is Dr. Carl Berlinger, Chief Generic 19 Communications Branch, NRR, he's not here today. Mr. Jerry-20 Wermiel, Section Chief, Plant Systems Branch, NRR; Dr. Vern Hodgc '21 Technical Contact for Generic Letter 89-13, Generic Communications 22 Branch, NRR; Dr. Duane Neitzel, Research Contractor on Generic .3 Issue 51, from Pacific Northwest Laboratories; Mr. Rudy Bernhard, 2 24 Regional Inspector, NRC Region 2, he's not here today. 25 Each of these individuals has been involved in the .n
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m 4 Il l development ofEGeneric Letter 89-13, and they ara here.to answer 4 2 technical questions on this Generic Letter. 3-The meeting will begin with a brief presentation on the r* 4 ' contents of' Generic Letter 89-13, followed by a question and 5 answer period until everybody drops from exhaustion, or 5:00-6 o' clock this. afternoon, whichever comes first. We will summarize 7 the meeting before we adjourn. 7 8 In the Federal Register we requested licensees and 9 applicants to submit questions in writing. We received many such lu-questions in the mail as well as from the first three workshops. 11 We have organized these questions in categories, one for each of 12 the recommended actions in the Generic letter, also including a 13 general category. 14 Today, we also welcome you to give us additional 15 questions'in writing during this meeting. We would like to 16 consider these meetings-as a group before we read them in to the 17 transcript. Therefore, we would like to receive your additional 18 questions by noontime today and this will give us an opportunity 19 to sort out questions and consider the answers. !his is because = 20 we want an accurate record in our transcript. 21 our plan is to make public these deliberations by 22 issuing a supplement to the Generic Letter consisting of 23 responses to broad categories of questions and references to the 24 transcripts of these meetings which will be placed in the public 25 document room. We hope to issue this supplement within this
R a 5 1 month. 2 These workshops are designed to continue NRC dialogue 3 with the industry service water system' reliability issu9. 4 Licensees and_ applicants should feel-free to continue to submit 1 5 questions to their NRC project managers, even after these 6 -workshops are completed. t 7 We will break the meeting at 12:00 o' clock for lunch 8.and reconvene at 2:00 o' clock this afternoon. Now, Dr. Vern 9 Hodge will review the' contents of Generic Letter 89-13. 10 DR. HODGE: Thank you, Angela. We appreciate all of 11 you coming to this workshop.. I want to now just review the 12~ contents of'the Generic Letter. 13 To begin, I will briefly summarize the regulatory '14 requirements which apply to cooling water systems. _Those 15 applicable to the service water system-are found in 10 CFR Part 16c 50, Appendix A, General Design Criteria, 44, 45, and 46; 44-17 addresses cooling water, 45, inspection of the system and 46, 18 testing of the cooling water systems. 19 And then Appendix B applies as well. In particular 20 Section'11 on test control. 21 The important point of this Generic Letter with respect 22 to this part is that -- you can show the next slide, Appendix B -- 23 is that the formalization of a test program and procedures 24 appropriate to periodically verify that the service water system 1 25 meets its design and functional requirements is put in place.
O' ) 1 6 j 't4, 1 1 .The purpose we'had in writing the Generic Letter, first .c 0 2: ofrall,'we' wrote this Generic Letter with a considerable 3 background on the subject. A number of operational events had l ,t 4 occurred over about ten years. We_had issued a bulletin and. 5 several information notices-and other events occurred indicating -i 6 lit may be time for an instrument such as a Generic Letter. 7 Our purpose was to insure that service water systems ? 8 are in compliance with the with the GDC's and the quality f 9 assurance requirements, to insure that the safety functions of 10- service water. systems are being met today, and to insure that 11 service water systems will continue to meet the design and 12 functional requirements and regulatory requirements for the life 13 'of the plants, 14-Our objectives are stated in much tue same words, to 15 assure'that all service water systems are in compliance with 16 regulations and other regulatory requirements and are maintained 17.in compliance. NRC firmly believes that changes and improvements L 18 in existing service water systems to implement effective L 19 continuing program such as described in the Generic Letter, to r 20 meet-our regulatory requirements will result in marked 21 improvements in the reliability of the service water systems. 22 In the Generic Letter we ask for -- or we made five 23 recommended actions. Just to list those in a form that's a 24 probably pretty hard to read, I will just summarize each briefly. b 25 The first recommended action was to implement and maintain a o.
s ._./ n 7 o 1 program to guard against biofouling. l ib 2 The second was to establish and implement a program for '3 both initial and periodic retesting'of heat transfer capebilities t 4 of the service water system, the heat exchangers. 5 The third one was to establish a routine and 6 maintenance -- routine inspection and maintenance program, 7 essentially to. allow -- excuse me, essentially to prevent the 8 service water system from degrading to a condition in which it 9 would not meet the. regulatory requirements, or would present a 10 safety concern before taking corrective action. 11 The fourth recommended action was to confirm that the l 12 as-built service water system meets its design requirements and 13 will perform its intended function in accordance with the i4 applicable licensing basis of the plant. This includes 15 confirmation of its ability to perform its required safety . 16 function in the event of a single active component failure. j 17 The fifth recommended action was to establish and 18 implement a procedure review.of -- a review of maintenance 19-practices, operating and emergency procedures and training 20 programs to insure that operators were aware of the importance of 21 the service water system and that human errors could be reduced. 22 The next slide shows some of our intentions in 23 formulating these recommended actions to improve the reliability - 24 of service water systems and some of the different attributes of ( 25 each. ~
? t ' i i i 8 -1 Actions 1, 2, and 3, for example, apply to open cycle g 1 2 systems. Actions 4 and 5 apply-to the entire service water a 'l 3 system including open and closed cycle systems. These have been' 4.-questioned of us since issuance of the letter. 5 The servict water system is defined as the system or 6 systems that transfer heat from safety related structures, 7 systems or components to the ultimate heat sink. And, as 8 discussed in the letter, we define a closed cycle system as that 9 portion of the service water system that is not subject to 10 significant sources of outside contamination, has control water (! 11 chenistry, and does not reject heat directly to a heat cink..And 12 follow an open cycle system then would represent everything else. l 13 When we developed this letter, the exaff sought to give 14 flexibility to licensees and applicants. We were sensitive to 15 unique plant characteristics and variations and we di? not wish to 16 be overly prescriptive. Examples were given for guidance, but the 17 specific actions need tc meet the staff's general objectives were 18 left to the discretion of the addressees. And, we included 19 language such as equally effective, alternative actions to 20 describe this flexibility. 21 The next slide gives some examples of that flexibility. 22 For-the recommended action on biofouling, we have included 23 enclosure one which represents a recommended program that is -{ 24 acceptable to the NRC. Licensees and applicants are free to -25 choose an equally effective program with justification.
9 1-For-recommended action two, testing of heat transfer l 2' capability, we include an enclosure two to represent a program 3 that would be acceptable to the NRC. Licensees and applicants 4 are also free in this case to devise equally effective programs. 5 For example, they could use frequent regular. maintenance instead + 6-of testing in some cases. 7 Also, with regard to this particular action and also 8 the following action three on routine inspection and maintenance, 9 some of the flexibility offered is licensee determination of 10 frequency of testing or maintenance. That's to be determined Ell -based on their own plant operating experience and unique 12 characteristics. -13 It is not our intention to disrupt-normal plant 14 operations with respect to this letter, or to make any 15 unnecessary change in plant protocol. 16 Action five asks for review of practices, procedures. 17 and training. ~We expect that improvements in these things would 18.be made within existing plant protocol, while meeting the staff's ~ overall objective to insure that the safety system cooled 19 20 equipment, or service water system cooled equipment would meet its 21' intended safety function by reducing human errors, as I've said 22 before. 23 That's my introduction of the Generic Letter. Does 24 anyone have any reaction or does the staff wish to make any p 25 comment?
g-1 10 1 We. will proceed then with discussion of the questions i b 2 that we have received in writing before the workshops began, and 3. at each workshop held previous to this one. We have organized 4 these in categories of questions. The first one is a. general t 5 category. t 6 And my procedure this morning will be to read the 7' questions and.then give the staff answers. We would ask that if a ~ 8 any of the audience would like to comment on any of the answers 9 that they step to the microphone, identify themselves for the 10 transcript and ask their question, at which we will try to respond 11 as best we can. 12 We will do this for every question. The whole 13 operation should take perhaps three hours. When we near the
- 14. 112:00 o' clock time, we will ask if anybody wants to submit a l
15 question at this workshop in writing, and ask to receive those at l-16 that time, l I 17 Our plan right now is to take a noon recess and 18 reconvene at 2:00 to take up the rest of the questions and to 19 take up those questions offered in this meeting.
- 20 Yes, sir?
Could you identify yourself please. 21 MR. RICK RIETMANN: Rick Rietmann from Wolf Creek p 22 Nuclear Operating Corporation. Could we get a copy of those 23 questions and answers? 24 DR. HODGE: No, I'm sorry, we don't have those i 25 available. Our plan is to conduct these workshops, write down
3 11 K 1 the questions and answers to Generic questions -- excuse.me, 'Y .2 write down-the answers to-Generic questions, and issue them in 3 the form of a supplement to the Generic Letter. Transcripts are 4 being made of these meetings.. Those transcripts will be 5 available to the public. The supplement of the Generic Letter 6 will reference those transcripts. 7 If you're worried, for example, that answers to these 8 questions should be in hand before the first response date comes, 9 I would hasten-to relieve that worry. We will try to get the a 10 supplement out this month or early in January, only for reasons of 11 helping you understand what questions and answers were. 12 The first question is what level of detail should be 13 included in the descriptions of existing and proposed programs. 14 And, as you can see, we have identified the source of this 15' question by utility. This was in response to a question offered '16 in the first workshop. And so, if you don't mind identifying 17 yourself when you submit questions in writing, we would like to 18 have that for the transcript as well. 19 The level of detail should be sufficient to permit an 20 inspector to evaluate the activities performed, the conclusions 21 drawn and the problems encountered and resolved. Each 22 recommended action delineated in the Generic Letter or equivalent 23 should be addressed in sufficient detail to enable an inspector to 24 evaluate the action. 25 Is there any reaction to that answer? We'll proceed on
6 12 1 to the next question. 2 Generic Letter 89-13 provides the-licensee with a great 3 deal of leeway in defining their programs. This leeway is 4 desirable and justifiable given the vide variation in conditions 5-that may prevail.- It is anticipated that the main mechanism for 6 judging compliance with Generic Letter will be NRC site 7 inspections. During such' inspections what will be the basis for 8 judging the acceptability of the program? What is being done to 9 ' promote consistency in interpretations among regions? 10 We say the purpose of the Generic Letter is for 1 11 licensees and applicants to assure the NRC that the heat removal i L 12 requirements of the service water system are satisfied. This is i 13 required'by regulations, as we have mentioned. Each individual 14 inspector is responsible at all times for judging'any regulated 15 activity,-including programs designed to response'to Generic ~ 16 Letter 89-13 against the regulations. t L 17 These workshops constitute to date the NRC effort to l 18 promote consistency among the regions regarding Generic Letter 19 89-13. We plan to issue these questions and answers as a 20 supplement to Generic Letter 89-13 this month. Guidance will 21 thus be available not only to licensees and applicants but also 22 to-inspectors. L 23 The traditional method of issuing a temporary 24 instruction for inspection from headquarters to regional offices ,4 l I .25-will not be used for this generic letter.
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13 m. I' 1 The proposed supplement.to Generic Letter 89-13 will 2.also reference the transcripts for these workshops which will be 3-placed in the public document room. Individuals among the 4 authors of the Generic Letter will be available by telephone to 5 licensees, applicants and inspectors and may participate in 6 selected team inspections. 7 Are there any questions? The next. question then. 8 Similar regional meetings regarding Generic Letter 89-04 9 were conducted in the June, 1989 time frame. To date the minutes 10 from these meetings have not been received. When can we expect 11 the minutes from the Generic Letter 89-13 meetings? 12 Concerning Generic Letter 89-04, the minutes were 13 issued by letter dated October 25, 1989, signed by James Partlow, 54 Associate Director for Projects, Office of Nuclear Reactor ~ 15 Regulation. The minutes are being distributed to all licensees, 16 meeting attendees, NRR project managers and the public document 17 room. -And we have discussed how you will get the results of these 18 meetings. 19 Any questions? Proceeding on. 20 If we are looking into several options to determine 21 which one is the most beneficial, however, we have not made a 22 decision by the date that our response is due, would it be 23 acceptable to explain this and confirm that whatever option is 24 chosen will be completed on time? 25 The purpose of the 190 day response was to obtain the
14 p' 1 commitment, planstand schedules of licensees and-applicants to j p 4 2 implement the recommended actions of,the Generic Letter, or their 3 equally effective alternatives. Your decision-making-process 1 '4 should be made a part of the plans and schedules and submitted to 5 the NRC when the response is due. 6 If additional circumstances prevent sdch submittal, 7 such as regulatory requirements, technical specifications or 8 outside governmental agencies, then adjustments in the schedule 9 should be arranged with the appropriate NRR project manager, 10 Any questions? okay, next question. l l 11 What was the basis or experience used to determine the 12 schedule or completion for items 2 and 47 Do these schedules 13 consider utilities with more than one plant? f 14 The basis for the schedule was an appearance of L 15 reasonableness. Schedules are intended to be flexible and should 16 be reported to the staff in the licensee's response with L 17 justification, if the recommended schedule in the Generic Letter 18 is not used. Adjustuents to the schedule should be arranged with 19 the project manager. 20 Any reaction? Next question. 21 Do you recommend that actions 4 and 5 apply to closed 22 cooling systems? 23 Yes, the Generic Letter defines service water system to
- 24. include both open cycle portions and intermediate closed cycle 4,
25 loops that function to remove heat from safety related
1 E 15 l 1 structures,-systems (or components to the ultimate heat sink. j v 2 Recommended actions 1, 2, and 3 specifically apply to- ~ 3 open-cycle portions of the service water systems. Recommended 4 action 2 can be extended to the closed cycle portions as 5 conditions warrant. Whether a cooling-loop is open or closed is 6 not called out for actions 4 and 5. 7 Any need for clarification? Okay, next question. 8 If_the CCWS is part of the scope for-items 4 and 5 of 9 the Generic Letter, would it be possible to modify the completion 10- date commitments to fit this not our already existing SSFI
- 11. schedule? 'SSFI is Safety System Function Inspection.
12 And the answer is yes, and refer to our previous i 13 discussions. 14 Questions? Next question. 15 Can we defer the Unit 2 required action dates so that 16 they coincide with those of Unit 17 That is from October, 1990 17 to April, 1991 for Unit 2. And, as we have mentioned before, 18 this leeway is available with justification. 19 Next question. 20 For action Items 4 and 5 of the Generic Letter, this 21' utility plans to utilize the information gathered from a safety 22 system function inspection for the essential cooling water and 23 component cooling water systems. The SSFI for the ECW system 24 supports the Generic Letter reporting requirements. However, the 4-25 CCWS SSFI is scheduled for 1990. Is it acceptable to separate the
16 7 1 reporting for the ECW and CCW systems, that is, extend the CCW Y 2l _ portion: of the Generic Letter? 3 And the answer is yes, as we have said before. 4 Need for clarification? Okay, next question. 1 5 .The actions proposed by the Generic Letter constitute 6 new staff positions. To perform the testing and inspection 7 requested by the Generic Letter, it may well be necessary for y 8 licensees to make significant plant modifications. -For example, 0-licensees will'likely be forced to install new instrumentation in 10' order to perform tests and to monitor test results. 11 Furthermore, changes will be required of procedures. 12 An additional requirement of a walk down has been made. The 13 propo' sed test may be beyond the licensing basis of the plant. I 14 These requirements seem to fit the definition of a backfit, under I 15 10 CFR 50.109 Paragraph A1. Therefore, why were the requirements 16 in the Generic Letter promulgated under the provisions of Section 17 50.54(f)? 18 The NRC concluded that it was not assured that 19 licensees and applicants are in compliance with existing 20 regulations, namely, general design criteria 44, 45, and 46 of 21 Appendix A of 10 CFR Part 50 and Appendix B of that part. 22 The regulatory request for information represented by 23 the Generic Letter is designed to gain this assurance and does 24 not constitute a backfit, i 25 Any questions? Next question is, was a backfit
17 1 analysis of-the testing and inspection requirements performed? 2.Will the staff make that analysis available to the public? In 3 particular, did the staff's backfitting analysis, if any, justify 4 the need for_ actions on closed systems? 5 The staff did not do a backfit analysis as required by 6 10 CFR 50.109; however, it did do an analysis for review by the 7 NRC Committee on Generic requirements, CRGR as it's commonly-8 called. 9 Since the CPGR reviews all proposed bulletins and 10 generic letters, among other proposed staff actions, this may 11 properly be referred to as a regulatory analysis pursuant to 10 12 CFR 50.54 (f). This analysis was not made public due to its 13 predecisional nature. It may be made public on approval of the 14 Director of the Office of Nuclear Regulatory Regulation. Excuse 15 me. I got that wrong, Nuclear Reactor Regulation, NRR. 16. Indeed, the staff was not able to justify inclusion of 17 closed systems in the recommended actions of the generic order as 18 it had once proposed to do. Accordingly, it relaxed its position 19 on recommended action 2 with respect to closed cycle cooling 20 systems. '21 Any need for clarification? Okay, next question. 22 This question was asked in one of the workshops. Many 23 of your responses this morning fall back to the standard NRC 24 position that the licensee should provide adequate assurance that 25 they have a program o actions in place to satisfy the Generic
18 'A 1 _ Letter concerns. This. position could create a problem later when 'p;l 2 the inspector shows up to review our program. What kind of 3 guidance will the NRR and research staff be providing to the 4-inspector? 5 If you don't provide specific instruction in something G like a TI, that's temporary instruction, the acceptability of a 7 given program will be left to the opinion of an individual 8 inspector..When will this type of guidance be available? 9 And we believe we have answered this question. Is i 10 there any discussion? Yes, sir? 11 MR. ALAN COHLMEYER: My name is Alan Cohlmeyer for p 12 Quadrex.. As regards issuing or not issuing of temporary i 13 instruction, I wonder why this is different than for example l 14 Generic Letter 89-10 on motor operated valves where they did say l 15 that they would issue a temporary instruction within about a year. 16 Could you explain why the difference? 17 DR. HODGE: I don't know. Do you know, Jerry? l-18 MR. WERMIEL: No, I don't know why there's a l-l 19 difference. I know what thinking went into our position that a 20 TI wasn't appropriate for this particular Generic Letter. That 21 is, temporary instruction is generally intended for inspection of 22 a one shot deal or a particular one-time action that we ask -23 licensees to take. The program that's being implemented for 24 improving its service water is intended for the life of the f 25 plant.
cL g 19-II For that reason, it was felt that the existing 3 Y s 2. inspection program for insuring safety functions of safety 3' related systems-was appropriate and we would allow the regions 4 the necessary flexibility in implementing that part of the 5 inspection program as we always had. 6 .The only thing additionally that was needed was further 7 instruction to them on the kinds of things that have been [ 8-occurring over the years that we recognized were causing-9 degradation of service water and therefore, needed to be looked 10 at more specifically. And, we felt that we could do that quite 11 easily and quite appropriately through this question and answer 12 format,'with the supplement to the Generic Letter itself. 13 MR. COHLMEYER: I could say the same words about the 14 Generic Letter, motor operated valves, it's going to be an 1. l 15 ongoing continued program for the life of the plant. 16 MR. WERMIEL: And I agree with that. I don't know why 17 there's a difference. I know -- as I say, I don't know the ~18-thinking for that particular action at all. I only know the l 19 thinking that went into this Generic Letter. 20 MR. COHLMEYER: Okay. Thank you. 21 DR. HODGE: Any other questions? 22 The next question and this is the last question that we 23-received in the general category. When does the NRC envision 24-inspections to begin on this letter? 25 Our opinion is that the inspections should begin after
i U 20 1-individual licensees indicate they have implemented their jp t 2-program._ Such inspections will probably not begin until-late i 3 -1990. 4 Turning now to the category on action 1 on biofouling, 5 the first question received was, when determining whether a plant ~ 6 has clams in its source water, does consideration need to_be given '7 to the presence of clams in the plant vicinity, at the local-i 8 environment, or solely in the water body, source of cooling water? j 9 The purpose of this recommended action is to enable a 10- licensee or applicant-to know if the service water system might l I 11 be subject to biofouling. All potential sources of water for the
- 12. service water system should be examined annually for the presence 13 lof biofouling species.
i 14 If no waters in the local environment of a plant can a 15 get inside piping and components to cause biofouling degradation 16 of the heat transfer function of the service water system, then '17 such waters do not need to be samples. 18 Any question? Next question. 19 What.is the definition of lay-up? 20 Lay-up means the filling of a system. Those service ~ 21 water cooling loops normally operated with water in the system, a 22 even in standby position, should contain chlorinated or 23 equivalently treated water rather than untreated water. 24 Any discussion? Yes, sir? 4 l 25 MR. GUY SHELTON: Guy Shelton, San Onofre Nuclear
I" t 4 P:o 21 -j 1:LGenerating: Station. What period of time are you talking about r J 2-being~1n a standby condition? 3 DR. HODGE: Duane, can-you answer that question? 4-MR. NEITZEL: Yes.- Tuesday, the same question was. 5 asked, almost word for word. There is no time limit on this 6 definition. The idea of chlorinating or treating a system that 7 is laid up is to prevent biofouling from becoming a problem from 0 8 - degradating the service water system, so the time definition for 5 lay-up, as it deals with this question is how'long would it take a 10 biofouling organism to become a service water problem, and 11 therefore, so that the individual environment, individual system, 12 even individual components within a system, therefore, there you 13 have your definition of time. 14 DR. HODGE: Additional questions? Okay, next question. 15 What constitutes an infrequently used component? 16 Paragraph C in Enclosure 1 in the Generic Letter,ays that redundant and infrequently used cooling loops should be 17' l' L 18 ' flushed and flow tested periodically at the maximum design flow 19 to insure that they are not fouled or clogged. This recommended 20 action refers to ECCS loops or other safety related cooling loops j 21' that are normally in the standby-condition. 22 The next sentence says that other components in the L 23 service water system should be tested on a regular schedule to l 24 insure that they are not fouled or clogged. I l 25 This recommended action refers to the pumps, pipes, 1 I
f;L f: 22' 1= valves, strainers or other components, even in loops in which i 2 -water is normally flowing. Often, flow is inadequate in these 3= loops without being detected in'the absence of such testing. 4 consider a system in which water is normally flowing, 5 with' parallel' branches, in which the states of components in the 6 branches are not often changed. For example, branch throttle 7 valves initially set before the plant began operation, may not be 8 controlled by procedure. Subsequent changes in the throttle valve 9 positions for various reasons, or clogging of them or other l \\ 10 components in the-branches, would upset the' initial system flow l 11 balance without detection. 1 12 Any discussion on this ansvar? Next question. 13 We have several questions related to this one and we I 14 intend to read each one separately and ask for your reaction, so i 15 bear with us. 16 To what extent should fire protection systems be 17 addressed in response to the Generic Letter? 18 The Generic Letter is not designed to focus on fire l l 19 protection systems, but to incidentally include them if they use 1 20 untreated water that could be subject to the service water system 1 L L 21 ills described in the Generic Letter. 22 Any discussion on this question? Next question o 23 received was, if it can be shown that the introduction of L 24 -mollusks into the service water system is not plausible, based on 25 service water system design and makeup water system design, can L
P ^ 1 it 23 e 'l the requirements of this Generic Letter concerning both 2_ inspection for and' control of mollusks be waived? i
- 5-our response is, the purpose of the Generic Letter is-1 4
for: licensees and applicants to assure the NRC that the heat 5 removal requirements of the service water system are satisfied. 6 If this-can be done by this proposed program, then it is 1 7 acceptable. 8 Any discussion? Next question. 9 to Generic Letter 89-13 recommends varying 10 requirements for service water systems based on intake structure 11 configuration and location. In a service water system in which 12 the. suction point of the service water pumps is in the collecting 13 basin for the ultimate heat sink, the cooling tower, would the 14 basin be considered the intake structure, or would the source of-15 basin makeup water be considered the intake structure? 16 Each licensee or applicant should define the scope of 17 the intake structure. The authors of the Generic Letter consider 18 that an intake structure would contain all the waters eventually 19 used in the system. Now, we've discussed a question similar to 20 this before. l -: 21 Any discussion from the audience? Next question. 22 The Enclosure 1 describes an acceptable program to the 23 NRC to implement recommendation 1. This program includes Biocide 24 treatment regardless of whether the plant is susceptible to l 25 macroscopic biological fouling or not. Will a program that does ~1
q 1 o e 1 '1 F 24 J 'l not include' Biocide treatment be acceptable'to the NRC?. j [ 2 And_the answer is yes, for good cause shown. 4 3 Any questions on that? Next question. ? 4 Recommendation 1 states that initial activities should 5 be completed before plant startup, following the first refueling 6 outage beginning nine months or more after the date of this i 7-' letter. What is the intent of the phrase initial activities? 8 Does it mean the first round r activities, inspections, flushes, 9 Biocide treatment, et cetera, l..s been completed? Or,_the 10 mechanisms have been put in place which will culminate in the 11 implementation of the program, such as Biocide discharge permits 12 submitted or procedures written and approved. 13 Both these possibilities could be included in the .14 - intent of the phrase. For those activities involving an outside 15 governmental agency, the licensee or applicant should arrange a 16 _needed adjustment in the schedule with the appropriate NRR project 17 manager. 18 For those activities involving procedural changes or 19 new procedures, the initial activities refers to those 20 inspections or other activities by which the need for procedural 21 changes or new procedures are identified. 22 Any questions? Next question. 23 We use well water, raw water, as a source to the fresh water of fire protection storage tanks. Do we need to chlorinate 24 f 25 these tanks or do we need to conduct full flow surveillance tests
I b 25 1 on all five protection piping runs? We presently only surveil the - 2 fuel-pumps for flow, not the piping runs. We do not presently 3 chlorinate these tanks. The service water system per se is not 4. used to fill these tanks, separate wall pumps are used. 5 Our answer is a little more lengthy. The recommended P 6 program described in Enclosure 1 was developed by a government-7 sponsored research program. If a' licensee or applicant chooses 8 an alternative course of action from that recommended, it should 9 assess the potentials for microscopic biofouling and 10 microbiologically influenced corrosion, commonly called MIC, and 11 justify that the alternative course of action will result in i 12 satisfaction of the heat removal requirements of the service 13 water system. 14 Paragraph B of this enclosure recommends chlorination I 15 whenever the potential for a microscopic biological fouling 16 species exists. Such a potential may not exist for these wells, 17 but the potential for MIC should also be considered. L 18 Paragraph C of Enclosure 1 recommends flow testing of 19 infrequently used loops, periodically, at the maximum design flow e-20 rate, to insure that they are not fouled or clogged. If the fire L 21 protection pumping runs are subject to biofouling but the water is 22 not treated to protect him against biofouling, then the full flow 23 testing of them may be necessary to insure minimum potential for 24 clogging. 25 This paragraph also recommends chlorination to help
b + 26 1 pr c. 1 prevent MIC. Any discussion on this one? j V 2 The next' question received then. 3 Does the visual inspection of intake structure apply to 4 the intake piping as well? If so, will NRC give guidance as to 5 replacement criteria of piping? If not, is B31.1 for wall 6 thinning appropriate criteria? 7 The scope of the intake structure was purposely left 8 vague to afford licensees and applicants sufficient flexibility 9 in resolving problems and planning their responses to the Generic 10 Letter. The NRC-does not have an official position on proper 11 placement criteria, but B.31.1 should be appropriate for plants so 12 designed. 13 Any reaction to this question? Next question. 14 Larva sampling is difficult to do. We already have a 15 sampling commitment, but we don't want to do this and can justify 16' not doing it. 17 We say the earlier that licensee or applicant can 18 identify the presence of a biofouling species in a source body of 19 water for the service water system, the better chance it will have 20 to control the situation and prevent a potential safety problem. 21 Any reaction? Next question. 22 .This is a three-part question. With regards to 23 of the Generic Letter, will NRC give guidance on use t 24 of Biocides other than chlorine? 25 The answer is no. The NRC is interested in the
i,R 27 1-' effective. heat transfer of the systems. We are not in a position g ~,y 2 'to consult on the various Biocide treatments. 3 Next question, do we need to continuously chlorinate if 4 under our inspection program we find no evidence of microscopic 'S fouling? Does WPDES discharge limits take precedence to this? 6 And I believe that should be NPDES. = 7 Our answer is, the program described in Enclosure 1 8 represents a program acceptable to the NRC for implementing the 9 recommended Action 1. The licensee or applicant can choose to 10 pursue an equally effective alternative course of action if 11 justified. Precaution should be taken to obey federal, state and 12 local environmental regulations regarding the use of Biocides. 13 This includes the National Pollutant Discharge Elimination System, 14 NPDES discharge limits, administered by the U.S. Environmental 15 Protection Agency that were referenced in the question. 16 Any discussion? 17' Is demineralized water acceptable for use in we lay-up 18 of stagnant service water piping? 19 This question must be decided by,,the licensee or 20 applicant. The result should be that the heat removal 21 requirements of the service water system are satisfied. To 22' accomplish this, the NRC recommends that such piping be flushed 23 and flow tested periodically to insure absence of clogging and { 24 that chlorinated or equivalently treated water be used to fill 25 service water loops before lay-up to help prevent MIC.
1s 28 11 Any.need for clarification? okay, the next question. 1 1 O 2 Do Generic Letter 89-13 requirements apply to the fire 3 protection systems which are not fed by either the service water ~ 4 system or the service water intake? 5 The answer is no. However, if the fire protection 6 system source water is subject to fouling or corrosion,,then a 7 periodic monitoring program should~be established to detect 8 systen degradation. 9 . Any questions? Next question. 10 Does the Generic Letter imply that biofouling i 11. monitoring methods are required? Are side stream or in-line 12. monitoring methods necessary? Does the NRC have a preference s 13 concerning the methods of visual, UT, radiography or 14 electrochemical probes to monitor for biofouling? 15 Yes, biofouling monitoring of the source water is 16 necessary; side stream or in-line monitoring is effective and 17 could be used for this purpose. The NRC has no preference 18 concerning methods for biofouling monitoring or nondestructive 19 service water examination, provided the selected method is 20 effective. 21 Any questions on this one? Next question. 22 When stating we should be aware of other plants, 23 facilities, et cetera, that use the same service water source; 24 for example, rive, and their biofouling problems, how far does i 25 that extend, within five miles, fifty miles? Please clarify.
( / 29 1L -This question was raised at one of the workshops. The - p 2 NRC cannot place a speed limit en biofouling awareness. ~ 3' Conditions at each site would determine an appropriate program or 4 how far away.to monitor for biofouling. The licensee should use 5 the best-available site specific information and establish an 6 appropriate monitoring program. ~ 7 Any questions? Next item. 8 On Action 1, if the ctarrent sampling program, which was 9 initiated to detect Asiatic clams, has not found any mollusk 10 infestation. Do the sampling methods need to be modified to 11-detect ZEBRA Mussels? 12 The recommended sampling methods in recommended Action 1 13 are intended to be general enough to enable licensees and 14 applicants to become more aware of macro biofouling agents early 15 enough to prevent the associated fouling problems fro:a adversely 16 affecting the safety related function of the service water system. 17. Recently we issued Information Notice No. 89-76, .18 entitled "Biofouling Agent: ZEBRA Mussel," to address this 19 question. 20 Does the audience have any questions? Okay, the next p _.- 21 item. L 22' Some state regulations do not permit the use of y 23 Biocides above the minimum detectable level. Yet Enclosure 1 to 24 the Generic Letter appears to require Biocides while cautioning 25 plants not to violate state and local regulations. Since it is i u a
a x ( 30 '1' not possible in some' jurisdictions to use any Biocides without 2 violating state _and local regulations, what alternatives to_ 3 Blocides are acceptable to the staff? 4 We' discussed this question, or one related to it, 5 before. Does_the audience have any questions? okay, next 6-question. 7 What is the basis for requiring treatment of fire r 8 protection systems that use raw service water as a source? 9 I believe we handled this question earlier. Any 10 questions from the audience? Okay, next question. 11 Concerning inspection of intake structure for each 12 refueling cycle, could inspection of other intake structures, 13 namely fossil units, on the same body of water that had'been in place and in service for up to 40 years, be used to justify 14 15 either to extend the frequency of the inspection or maybe no 1 16 inspection at all. 17 Our answer is the inspection of the intake should not 18 be restricted to potential macroinvertebrate fouling. If the 19 current program in place at the fossil unit mentioned has been 20 shown to be effective to date, for the detection of fouling, t 21 including biofouling, mud and silt, then it may be sufficient for 22 future monitoring. 23 However the. licensee or applicant should be aware and 24 consider possible rapid changes in environmental conditions and 25 insure that their program includes the best available site 3
W 31 ~1-specific information. 7b 2: Any need for discussion on this question? Any comments 3' from the staff?- Next question. 4 For NTOL plants, when does Generic Letter 89-13 have to 5 be implemented? 6 The Generic Letter 80-13 should be'in place at the time j l 7 of initial plant licensing. l 8. Any need for. clarification? Next question. 9 Concerning redundant and infrequently used cooling 10 loops. Define infrequently used? 11 The wording infrequently used cooling groups is 12 intended to apply to those normally in a standby mode under 13 stagnant flow conditions.. The Generic Letter 89-13 program 14 should address means for insuring against fouling under such 15 conditions. 16 Any reaction? ' Next question. 17 If performance testing is done on all-heat exchangers 18 periodically, will this satisfy the intent of the recommendation? 19 Yes. Periodic performance monitoring of all safety-20 related heat exchangers is acceptable, provided it insures heat 21 transfer, not merely flow or pressure drop. 22 Any discussion on that one? If you have any -- the 23 next question. 24 If yearly inspections of a plant service water and d 25 intake structure shows no indication of Asiatic clams, and
32 testing results indicate that corrosion is not microbiologically 1 2 influenced. 3 Is it' acceptable to continue with the annual 4 inspections for clams and perform maintenance and testing as 5 required in Actions 2 and 3 of the Generic Letter, in lieu of a 6 chlorination injection program. 7 Our response is that this appears to be reasonable for-O 9000 cause shown. And we refer you to previous discussion. 9 Any questions on that one? 10 We have one more question on this category on the .11 biofouling recommended action. It was introduced at the last 12 workshop and so we scribbled out an answer here. 13 For a fire protection system supplied by raw water 14 which meets flow requirements and does not provide safety related 15 cooling, are any actions required? 16 And the answer that was scribbled out is no. That concludes that category. Turning now to the 17-I 18 category on Action 2, heat transfer testing, the first question 19 received was should the proposed heat exchanger heat transfer 20 testing method be provided for prior NRC review and approval? 21 And the answer is no. Next question. 22 Is it acceptable to determine the most restrictive heat 23 exchangers in each group for testing in lieu of testing every heat 24 exchanger? 2S The purpose of the Generic Letter is for licensees and
g%. 33 'l ' applicants,to assure the NRC that the heat removal requirements of 2-the service water system are satisfied. If this can be done by -3; this proposed program, then it-is-acceptable. 4 Is.there any need for discussion on this question?, 5 MR. MILTON HUTT: My name is Milton Hutt, Arkansas 6 Power & Light. Does that apply to the base line test as well, or 7 the followup test? 8-DR. HODGE: We do intend for you to determine a base 9 line and this mostly applies to the followup testing program, 10 that's correct. Did you want to clarify, Jerry? 11 DR. WERMIEL: No, that's fine. 12 DR. HODGE: Okay, next question. 12 Has the NRC reviewed the EPRI Service Waterworking 14 Group document prepared by Duke Power and Toledo Edison, 15 describing several methods of heat transfer testing? If so, is 16 the temperature effectiveness method acceptable or which methods 17 are acceptable? t L -18 The staff has not formally reviewed this document but I 19 has received a draft copy, a method of heat transfer testing is 20 acceptable for purposes of satisfying the Generic Letter if it 21 can be used to assure the NRC that the heat removal requirements l l 22 in the service water system are satisfied. 23 Any question? Next question. 24 DR. HODGE: If the pressure drop because the heat i 25 exchanger at design flow is less than or equal to the l-
e Y\\ v 34 1 manufacturer's specification, is heat transfer testing required? b 2 Provided the baffles have been inspected to ensure that the flow 3 is not bypassing the coils. 4 The objective is not to satisfy the manufacturer's ] 5-specification for flow in heat exchangers so much as it is to 6 assure the-heat removal requirements of the service water system. .7 If the latter assurance can be achieved by showing-this o. 8 condition to be necessary and sufficient, then heat transfer 9 testing would be superfluous. 10 Next question? 11 To what extent can routine maintenance or cleaning of 12 heat exchangers replace testing? 13 A licensee or applicant should determine the 14 ~ appropriate frequency of testing or maintenance activities to 15 assure that the heat removal requirements of the service water 16 system.are satisfied. For a given heat exchanger, a licensee or 17-applicant may elect to clean, replace, repair or otherwise 18 maintain it initially before beginning a routine testing program. 19-If the licensee or applicant elects to not conduct a 20 routine testing program for the heating exchanger, then a routine L. 21 maintenance program may be necessary to provide the sought 22 assurance. In the absence of a routine test program, no basis may 23_ be available for detecting potential degradation of heat transfer 24 performance. In the absence of such a basir, the frequency of l_.$ 25 maintenance may have to be a maximum value to provide the sought p i L f
35 1 assurance. b TL 2 Any discussion?_ ~3 Next question: In an effort to minimize the amount of 4 time that a single redundant division of safety-related equipment 5 is out of service, some utilities employ a divisional outage 6-concept for major plant outages. By utilizing this concept 7 significant maintenance work activities, for example system flow 8 balance test, standby diesel generator teardown, electrical 9 distribution, bus work, et cetera, are performed on an' alternating 10 outage schedule for each division. This permits comprehensive 11 maintenance on each division to be performed while reducing the 12 overall impact on redundant safety system availability. The 13 -ability of the utility to implement and maintain a service water 14 heat removal capability monitoring program would be significantly I 15 enhanced by the installation of permanent plant monitoring 16 equipment. Installation of dedicated monitoring equipment would 17 also reduce the impact on future -- of future testing on service 18 water and heat exchanger availability. 19 For a utility that employs the divisional outage 20 -concept and wishes to install permanent plant equipment to 21 perform the system testing identified in GL 89-13, is it 22 permissible to defer baseline data acquisition for one division 23 of the service water system until the second refuel!ng outage 24 following the issuance of a generic letter? b 25 My response is that this request appears to be
r IWO 36 .1 reasonable for. good cause shown. Any request for an adjusted' 2L schedule should be arranged through the project manager. 3 Next question: What is really required b y the 4 sentence on adequacy of chemistry control programs in the first 5 paragraph.of Page 5 on the Generic Letter? 6-Even though a closed cooling loop may contain water 7 with controlled chemistry, the potential exists that the loop may 8 be contaminated by inleakage, inadequate chemistry controls or 9 materials in the system before a -- before the current chemistry 10 control program became effective. 11 An example of this was recently disclosed at the EPRI 12 service water system reliability improvement seminar at 13 Charlotte, North Carolina, on November 6th through 8th, this 14 year. And the internal study discussed there, optical 15 examination of the primary side of the decay heat removal heat 1 16 exchanger tubes disclosed no fouling. The tubes were shiny 17 bright. Optical examination of the closed component cooling heat 18 exchanger however disclosed significant fouling.- The tubes did 19 not reflect any light. The problem was a paraffin-based packing 20 material inadvertently left in the system from construction days. 21 Suppose the licensee in this case can. argue that it has 22 a chemistry control program for water circulating through the CCW 23 heat exchanger but can't show that the program has been in place 24 since the system was initially filled? 25 A proper response to the Generic Letter then would
37 -1 include testing _that CCW heat exchanger. _At any point in the I 2 program, if the resultant finding of degraded heat transfer 3-cannot be explained or remedied by' maintenance in the open-cycle p 4 portion of the system, as would be possible:in this case, the CCW 5 heat' exchanger should be tested and, depending on those results, 6 the DHR heat exchanger should be tested..The process should'be 7 continued until.the problem is remedied. 8 Any reaction on this one? 9 Next question. Do both emergency service water systems l 10 and normal service water system need to be reviewed? 11 Yes. The NRC is concerned about the safety-related 12 effects of both systems. Sometimes the mode of operation of_a l + 13 service water system is changed in emergency conditions to 14-introduce uncontrolled water and thus potentially introduce 15 'biofouling agents, corrosion products, and silt that may n [ 16 adversely affect the heat transfer performance-of the system. 17 Any clarification on this one? 18 Next-question. Does our CCWS need to be addressed as 1 19 part of our response? 20 We have recently shown through eddy current testing on 21' the CCW heat exchangers that the physical barrier between the 22 service water and component cooling water systems is adequate. 23 Make up to the CCW is via make up water. 24 And we refer you to previous discussion on this one. l 25 Any questions?
I t ' 38 f L yr 1-Next question. Recommendation No. 3, and here'I think
- i
- 2<
the author may have meant Recommendation No. 2 but No. 3 could l 3 apply, does not specify a frequency for heat exchanger 4 inspections; Is it the NRC's intent that the utility establish J -5 the frequency of these inspections? 6 Yes. The Recommended Action II indicates limits. 7 Initially tests should be conducted at least once every fuel w 8 cycle. More frequency testing may be necessary to enable a 9 conclusion that the heat removal requirements of the service 10 water system are satisfied, i e 11-After about three tests, a licensee or applicant may be
- 12' in a position to set a differing test frequency.
However, the-13 finally determined testing frequency should not be less than once r '14 every five years. 15 Any need for clarification? 16 Next question. What is meant by frequent regular l 17 maintenance? Can frequency be determined in a similar method as 18 test frequency? l 19 Recommended Action II calls for heat exchanger 20 performance testing. For small heat exchangers such as lube oil 21' coolers, et cetera, testing might be excessively burdensome l' l 22 ' compared to maintenance of the heat exchangers. 23 A licensee or applicant can choose alternatively to k I. 24 routinely maintain the heat exchangers instead of testing them. 25 Either the frequency of maintenance or frequency of testing ~
I u* 39 l 1-should be determined, to assure that the equipment will perform c 11 i 2 the intended safety functions during the intervals-between-3 maintenances or tests, s 4 Any. discussion on this: 5-THE AUDIENCE: Yes. Joe Kowalowski with Arkansas Power 6 and Light. i o 7 For the lube oil coolers, does that imply that we could 8 institute that regular maintenance without doing a baseline on 9 jacket lube oil coolers and small canister lube oil coolers? 10 DR. HODGE: Well, if you only insist -- or if you only 11 intend to do maintenance -- 12 MR. KOWALOWSKI: Yes. '13-DR. HODGE: You don't need a baseline, I don't think. 14-Would you agree, Jerry? p 15 DR. WERMIEL: That's right. 16 Then -- you'll know whether the heat exchanger is clean
- 17. or not because you've already, presumably, maintained it.
So, 18 yes, that's okay. ~ 19 DR. HODGE: Next question. Why.Were three tests 20 chosen? Could a different number, more or less, be appropriate? a 21 The number three is the minimum number needed to 22 establish a trend. A larger number would be appropriate, but a 23 small number is insufficient. 24 Any reaction to that? { 25 Next question. Oh, excuse met there's a question. l f
g. 40 1 1 THE AUDIENCE: Yes. John Taggart, Arizona Public 2 _ Service. t 3 When you start talking about three tests, if we perform 4 a' test and -- and baseline it' at its -- at its designed 5 condition, after several years of service you certainly wouldn't 6.need to' perform that test every -- each refueling. Correct? 7 If you -- if you had five years of service and you're 8 still meeting design specification on the heat exchanger, then 9 essentially there has been no degradation during that period of i 10 time. I 11 DR. HODGE: Well, that's correct. 12 MR. TAGGART: Then -- 13 DR. HODGE: Then there would be no need to change the -- 14 to determine the frequency of testing or maintenance except for 15 once every refueling cycle, or ultimately no less than once every ~ 16 five years. 17 Is that a good answer? 18 DR. WERMIEL: That's right. 19 DR.-HODGE: Next question. The Generic Letter does not 20 specifically state -- excuse me, does not specifically address 21 testing of automatic safety features actuation which may be 22-required to provide the required service water flow to safety-23 related heat exchangers. Does the NRC have any recommendations on 24 functional tests or systems -- excuse me, of systems? t 25 The generic letter was written with a tacit assumption
_r l, 41 1 that all other regulatory conditions would be observed. In 2 particular, functional testing independent -- required by 3 technical specifications must be accomplished independently of the f 4 recommended actions of the Generic Letter. t 5 Where there is overlap, credit may be taken for the 6 tech spec required functional test. The procedures, results and 7 considerations of such tests should be documented with response to 8 the Generic Letter and retained in appropriate plant records. 9 Any need for discussion? 10 Next question received. The term all heat cMchangers 11 is used. Does this imply every heat exchanger of a given design 12 must be tested, or where more than one identical heat exchanger is 13 use3 can one representative unit be selected? 14 Recommended Action II calls for testing of the h eat L 15 transfer ccoability of all safety-related heat exchangers cooled 16 -by service water. The service water system is defined as the 17 System or systems that transfer heat from safety-related 18 structures, systems or components to the ultimate heat sink. 19 Each heat exchanger, regardless of redundancy, should 20 be tested or maintained initially to establish that the heat 21 removal requirements of the service water system are satisfied. 22 The existence of identical conditions then can be used to 23 determine the best test or maintenance frequencies to assure that i t 24 the heat removal -- that the heat removal requirements of the 25 service water system are maintained.
42 1 Any discussion? l 4 i I 2 Next question received. What is meant by the relevant f 3 temperatures should be verified to be within the design limits? 4 Does this imply testing should be conducted with the design basis 5 heat load? Is it acceptable to conduct testing for all heat 6 exchangers at off-normal conditions, provided accurate and 7 relevant data can be acquired and analytical methods used to 8 determine the heat transfer capacity at design conditions? 9 in the Generic Letter contains much i 10 discussion about verifying various parameters to be within design i 11 limits. Testing with design basis heat loads is recommended 12 ideally. If testing can be done under design conditions, it 13 should be done under those conditions. i4 Realizing that this may not be practical in non-15 accidental circumstances, the r. ext best step is to conduct tests 16 under off-design conditions and anP?.ytically correct the results 17 to the design conditions. such a procedure is acceptable where it 18 is necessary, but not where testing under design conditions is 19 practical. 20 Any questions? 21 Okay. The next question we received was: If the 22 maintenance period is know, why can't a test be performed before 23 maintenance to establish a data point for the required testing or 24 maintenance? If the overall maintenance period has been three or 25 more fuel cycles, could this be used to establish the test ~
~ l L 43 I frequency? Is it necessary to retest the heat exchanger after i ? i 2 maintenance if the work performed was a restoration only, that is 3 cleaning, not tube plugging? And testing had been previously j 4 conducted with clean heat transfer surfaces. 5 We say all these steps are acceptable alternatives to 6 the acceptable program outlined in Enclosure 2 in the Generic 7 Letter. The justifications that these alternative procedures 8 assure that the heat removal requirements of the service water 9 system are satisfied should be documented and retained in 10 appropriate plant records. 11 Any discussion on this answer? 12 Next question. What level of documentation is required i 13 to justify excluding close-cycle system heating exchangers from 14 testing to verify heat transfer capability? 15 The goal of the Generic Letter is to obtain assurance 16 that the heat removal requirements of the service water system 17 are satisfied. To exclude a closed-cycle heat exchanger from t l 18 testing, it should be shown that the chemistry of the primary 19 fluid and the heat transfer characteristics of the heat exchanger f 20 have been controlled since the time the system was first filled. 1* l 21 Any discussion on this one? 22 Next question. Recommended Action II, Paragraph 4, 1 23 states: " Tests should be performed following corrective 24 actions". Would bulleting tubes be considered as corrective ( 25 action?
i 44 1 The answer is yes. i 2 Next question. Recommended Action II, Paragraph 5, t 3. states that: " Frequent, regular maintenance is acceptable 4 alternative to testing." What is meant by frequent, regular 5 maintenance? Does this mean more frequently than if testing were 6 performed? 7 This paragraph further states that: "This alternative 8 might apply to small heat exchangers located in low radiation 9 areas." Would low radiation areas be defined by ALARA practices 10 or less than 100 MR per hour? 11 our answer is the frequency of periodic testing or 12 regular maintenance is to be established by the licensee once t 13 sufficient data has been collected. The frequency should ensure 14 that unacceptable degradation does not occur between testing or 15 maintenance cycles. 16 Low radiation areas as intended in Generic Letter 89-17 13 are included in the licensee's ALARA program co that radiation 18 levels will not preclude personnel access for maintenance and 19 cleaning of heat exchangers. 20 Any need for discussion on this one? 21 Next question. To what degree should a utility 22 endeavor to monitor real-time corrosion rates of the service 23 water system? Is trending of heat exchanger performance and ~ 24 visual inspections sufficient documentation of the components' 25 internal condition?
l i 45 1 It is not necessary to determine numerical real-time I' 2 corrosion rates in the service water system. The licensee's l 2 3 monitoring program should be sufficient to identify degradation 4 and take the necessary corrective action before the system 5 performance is unacceptably affected. 6 Trending of data is the recommended approach to 7 monitoring system performance. 8 Any questions? 9 The next question received. Generic Letter 89-13 seems 10 to imply that periodic maintenance, that is cleaning, of small 11 acceptable heat exchangers is acceptable in lieu of performance 12 testing. If so, is the refueling maintenance frequency 13 acceptable? i i 14 The answer is yes, this is an acceptable initial 1 15 frequency and may be acceptable in the long term with 16 justification based on data from a minimum of three refueling 17 outages. 1 18 Any discussion on this one? 19 Next question. For heat exchangcrs that cannot be 20 tested at the design heat removal rate, what is the NRC 21 recommended method to extrapolate the test data to design 22 conditions? Does the NRC have any additional recommendations for 23 extrapolating test data taken at very low loads, for example ten { percent design load or less to design condition? 24 25 The staff does not have a recommended method of
) 46 1 extrapolation. However, the EPRI service water system working 2 group has been developing such guidance as have some licensees 3 such as Duke Power. These may be places to start when developing 4 appropriate testing programs. i 5 No questions? 6 .Next question. Generic Letter 89-13 states that I 7 " Tests should be performed on heat exchangers before and after 8 corrective action is performed." What is meant by corrective 9 action? 10 Corrective action is any action that would improve the 11 heat transfer capability of the heat exchanger. 12 Yes, Sir? 13 THE AUDIENCE: Guy Shelton; Southern california Edison. + 14 Our CCW system, the service water is piped where we can 15 backflush it as necessary by monitoring flow and delta P. The i 16 reason we asked that question is, would you consider that to be 17 corrective action? Because this is something we do generally once 18 or twice a month. 19 DR. WERMIEL: I wouldn't say so, no. 20 No, I wouldn't consider that kind of an activity 21 corrective action. You're not correcting a degra -- a known 22 degradation, are you? You're -- 23 MR. SHELTON: We're doing a more -- 24 DR. WERMIEL: -- you're doing it more or less as a 25 preventive measure, correct?
47 1 MR. SHELTON: Yeah. To -- 2 DR. WERMIEL: Yeah, that's -- 3 MR. SHELTON: For any blockage of tubes? 4 DR. WERMIEL: No. I would -- I say that's more 5 consistent with a typical monitoring program, the idea is to pick i 6 up any problem before it becomes a problem. 7 I think the intent of the generic letter, from the 8 standpoint of corrective action, was where you're taking an 9 action because you know you have a problem that needs to be 10 corrected. 11 DR. HODGE: Other questions? 12 The next question received is a little bit longer. 13 Recommended Action II requires that the relevant temperature 14 should be verified to be within design limits. Also Enclosure 2, j 15 Item 2A, states: " Perform functional testing with the heat l 16 exchanger operating, if practical, at its design heat removal 17 rate to verify its capabilities. Temperature and flow 18 compensation should be made in the calculations to adjust the 19 results to design conditions." i 20 It is not practical to test the heat exchangers at 21 design heat removal rates. Also, we are unable to find a method 22 which has the requisite level of precision to adjust the test 23 results to design conditions. ( 24 Please discuss an acceptable method to adjust the test 25 results to design conditions. Also provide the scientific bases
l 'i'. g 1 or a reference for the proposed method. t 2 Also, the heat removal test cannot be performed on the 3 containment spray heat exchangers because there is no heat 4 source. The only test that can be performed is the pressure drop 5 test. Is this acceptable? If not, what is recommended? 6 Our answer is, as mentioned previously NRC does not 7 have a recommended test method. 8 With regard to testing of containment spray heat 9 exchangers as well as with all heat -- safety-related heat 10 exchangers, a pressure drop test alone is not sufficient to 11 satisfy the indicated heat transfer capability concerns. 12 If a heat exchanger cannot be practically tested, then 13 the licensee may propose a program of periodic inspection, 14 maintenance and cleaning as an alternative. 15 We are aware, however, of one licensee who was able to i 16-test the containment spray heat exchanger by heating the 17 refueling water storage tank water, approximately ten degrees l l 18 rahrenheit, and then performing temperature monitoring test as l l 19 well as pressure drop test. 20 Any discussion from the audience? 21 Next question. How much detail does the NRC expect for 22 the response to Action II? Would the proposed test or 23 maintenance or inspection method for each heat exchanger be .24-necessary? { 25 Specific details of the licensee or applicant program ~
49 1-in response to Action II must be developed and retained as part i' 2 of plant _ records. 3 Submittals to NRC in response to Generic Letter 89-13 4 should provide only enough info *tmation to sufficiently describe 5 the approach to.be taken for each heat exchanger. That is, test 6 or maintenance or inspection. 7 Those heat exchangers not being included in programs 8 under Action II should be identified and the basis given for 9 being excluded. 10 Grouping of heat exchangers into categories based on 11 the approach to be used would be acceptable. 12 Any discussion? 13 Next question. Is the NRC staff stating that a l 14 technical evaluation of a heat exchanger's capability to perform 15 its design safety function cannot be used in lieu of initial 16 testing? { 17 Therefore, all heat exchangers must be tested and even 18 maintenance or cleaning cannot be used in lieu of initial testing l l 19 because it would require a technical evaluation to determine l 20 maintenance or cleaning frequency. I 21 Also, when considering several identical heat 22 exchangers in one loop, do all the heat exchangers require 23 testing or maintenance or cleaning? 24 The answer is no. The initial heat exchanger test 25 program may consist of both performance testing of some heat
i 50 1 exchangers and the maintenance or cleaning of others. 2 The staff's previous response on the initial test 3 program was intended to ensure that the licensee has established a 4 baseline for all safety-related heat exchangers served by the 5 service water system and therefore, is confident that they can 6 perform their heat removal function. 7 As further clarification, if there are several l 8 identical heat exchangers in one service water loop, a licensee 9 may perform testing or develop a maintenance or cleaning program 10 for these heat exchangers based on the most limiting one as part 11 of-their initial test program. Justification on the basis of 12 comparable service conditions should be included in the response 13 when all identical heat exchangers are not tested. 14 Is that clear? 15 Next question. We would like to limit heat exchanger 16 performance testing to one unit, since the two units are 17 identical. Is this an acceptable approach? l 18 Not totally. Refer to our previous discussion. l 19 Any questions? L l 20 Okay, the next question received was talking about 21 Action Item II. Can the test program include data taken during 22 routine operating intervals with minimum load on heat exchangers 23 and extrapolated to substantiate adequate heat exchanger 24 performance? or when does the NRC consider it impractical to test [ 25 a heat exchanger at the design heat removal rate?
1 1 51 1 And we just refer you to our previous discussion on i 2 this question. 3 Next question. If maintenance is performed in lieu of 4 testing for degraded performance of the heat exchanger, how l 5 extensive does the maintenance have to be? That is, does 6 maintenance have to be performed on both sides of the heat 7 exchanger or just on the service water side? 8 Again, we refer you to our previous discussion. 9 Next question. In reference to your Recommended Action 10 II, do all safety-related heat exchangers connected to or cooled 11 by service water or raw water have to be tested or verified clean 12 by maintenance to ensure satisfaction of the heat removal 13 requirements prior to plant start-up following the first refueling 14 outage beginning nine months or more after the issuance of the 15 letter? 16 And the answer is yes. The reason this question was 17 asked, if a heat exchanger was cleaned 13 or possibly 18 months i 18 prior to issuance of this generic letter and found to be clean, t 19 or tested and found acceptable, and the current program does not 20 call for recleaning or testing for three years, then the program 21 would have to be revised. l l 22 Also, trend data may exist, indicating that there is no I 23 need to clean or test in less than a five-year interval. ( 24 If the heat exchanger is a part of a larger component 25 that is not scheduled for maintenance. That's also a reason for
52 1 asking the question. 2 We add to the discussion. The generic letter is 3 designed to provide-flexibility in determining a justifiable 4 alternative program for testing. The goal of the letter is to 5 assure that the heat removal sys -- that the heat removal 6 requirements of 'the service water system are satisfied. i 7 Any discussion on this? l 8 Next question. The Advisory Committee on Reactor 9 Safeguards, ACRS, June 14, 1989 letter to the Commission noted i 10 five areas of concern with which NUBARG, that's the Nuclear i 11 Utility Backfit Action Reform Group, agrees. Some of the 12 concerns were accommodated in the generic letter. However, we 13 are interested in -- to know the resolution of the following: An 14 intermediate closed cooling water system exempt from the -- G -- 15 from the generic letter provided it is not subject to significant 16 sources of contamination, is chemistry-controlled, and does not 17 reject heat directly to a heat sink. However, the adequacy of the i 18 chemistry-controlled program must be verified over the total 19 operating history of the plan. The ACRS questioned whether the 20 absence of an adequate water chemistry-controlled system or any -- 21 over any part of the operating history of a closed cycle system 22 was adequate justification for including the system within the 23 scope of the generic letter. 24 How did the staff resolve this concern? 25 The staff relaxed its position on including closed . - -. ~
l i 53 ? I cycle cooling systems in Recommended Action II, but added the 2 precautionary recommendation that if a degradation of heat 3 transfer could not be explained or remedied by maintenance of the 4 open cycle part of the service water system, then testing may have 5 to be selectively extended to the closed cycle part of the system. 6 Are there any questions on this one? 7 Next question was, or the next item was: Are plants + 8 required to review closed cooling water system operating logs for 9 the history of the plant to verify adequate chemistry control? 10 Licensees and applicants are required to assure the NRC 11 that the safety-related heat removal requirements of the service 12 water system are satisfied. If review of the closed cooling water 13 system operating logs for the history of the plant can help 14 provide this assurance, then that would be an acceptable part of 15 the program. 16 Next question. Would a program involving inspection 17 and maintenance activities in lieu of a performance test progran 18 be an acceptable program for all heat exchangers and components? R19 And we have discussed this, or question related to l l 20 this, before. l l 21 Next question. Programs acceptable to the NRC in 22 response to Actions I and II were identified. What are some 23 examples of acceptable inspection and maintenance programs for [ 24 Action III? 25 The NRC has not defined an acceptable program for l
l i 54 E 1 Action III. However, the generic letter is designed to give the f i, 2 licensee or applicant sufficient flexibility in developing an 3 appropriate program. 4 And we've discussed this before. 5 Is there any discussion on this point? 6 Next question. Is it acceptable to eliminate heat t 7 exchangers from the testing requirement of Action II if they are 8 in parallel or in series with other heat exchangers which are 1 9 tested and operated under similar service conditions? For 10 example, velocity, temperature, process fluid. 11 And the question -- the questioner refers us to EPRI 12 heat exchanger performance monitoring guidelines for the service 13 water systems. And we have discussed this question before. 14 Any questions from the audience? 15 In this category we received an additional four 16 questions from the Chicago workshop. A number of these have 17 long questions and short answ6rs. e 18 In Enclosure 2 of the generic letter a statement is 19 made that testing should be done when necessary -- or with 20 necessary and sufficient instrumentation. Flow measurement is 21 one of the two key parameters when measuring heat exchanger i 22 performance. It is also the most difficult, since most plants 23 never provide a means to measure individual flow rates to service { 24 water users. In general, orifice plates and interior tubes, pitot 25 tubes and flow nozzles are the only recognized traceable type of 1
55 1 low measuring devices. All of which require intrusive elements. j i 2 To be able to utilize such devices would require plant 1 3 system modifications at great expense to the utility and its j 4 customers. A less expensive alternative to this would be to use 1 5 non-intrusive, non-traceable devices such as transit-time 6 ultrasonic flow meters, which with current technology give very 7 reliable results. Trending of data taken with such devices would 8 appear to be equally effective for detecting degradation in 9 cooling water systems. Would the NRC recognize the value and 10 benefit of using such devices and accept programs which utilize 11 them? 12 And the answer is yes. l 13 Any questions on that? 14 Next question was: Thermographic cameras could 15 potentially be used to scan the tubes on air-to-water heat I 16 exchangers to see temperature profiles of the tubes and detect l 17 tube blockage or sediment in the tubes. Will the NRC accept such 18 qualitative checks rather than quantitative measurements to prove 19 that a heat exchanger is not fouled? 20 The answer is yes. However, additional means should be 21 included in the program to ensure adequate heat transfer. 22 Any questions on that one? 23 The next question was: Is off-the-shelf -- if off-24 the-shelf software is reviewed for technical adequacy and 25 subsequently utilized to perform heat exchanger performance
I 56 i l 1 calculations, will it be acceptable to the NRC? 2 Again, the answer is yes. 3 The last question. If a heat exchanger performance 4 reveals that a heat exchanger is in a degraded condition, the 5 first obvious question will be as to what the impact of the 6 degraded condition is on system operability. Will a heat 7 exchanger performance program be considered the same as a plant. 8 surveillance program with the same ramifications for questioning 9 plant or system operability? If so, is the NRC considering asking 10 licensees to include limiting conditions for operation statements 11 in their technical specifications? 12 Yes. If a heat exchanger heat transfer capability is 13 shown to be degraded below levels needed for design-basis heat 14 removal, then it is considered inoperable. The staff does not 15 intend to -- that elements of these programs be included in plant 16 technical specifications. 17 That concludes the questions for the category on heat -- 18 on Recommended Action II. It is close to 12:00 o' clock. We 19 would wonder if there are any questions to be submitted to us in 20 writing from this workshop. 21 Could you identify yourselves if you have questions? 22 Okay. You don't need to specify -- speak them now. We 23 just want to know how many. The thought being that we only have a 24 small number of questions remaining, we could continue at this l { 25 point rather than taking a noon recess and just take a ten-minute l
vb j 57 1 break if -- and wind this workshop up in early enough time for you i 2 to -- to accommodate any travel requirements you may have. 3 Would that be okay? 4 MR. WERMIEL: Yeah, it looks like -- there are no [ i 5 additional written questions at all at this point? 6 DR. HODGE: There is one individual that said he had a 7 question. One, two. 1 S MR. WERMIEL: Okay. 9 DR. HODGE: So if you would, submit those questions to 10 use -- 11 MR. WERMIEL: Let us have those. 12 DR. HODGE: And then we'll take a ten-minute break. 13 MR. WERMIEL: All right. 14 DR. HODGE: So be -- be back -- what time do you have? 15 11:53? 11:43? Okay, close to 12:00 then. 16 (Whoreupon, a short recess was taken.) I l 17 DR. HODGE: Is everyone in the room? Have we received 18 all questions in writing that are intended to be submitted? Jerry 19 tells me that we have received six questio.ps and one of them is a l 20 multi-parter, multiple part question. It may be appropriate to 21 adjourn now for lunch, rather than go on. What does the group i 22 feel? Let's go as they say. 23 MR. WERMIEL: Okay. 24 DR. HODGE: I would like to reiterate we had passed 1 25 around a meeting attendance sheet, if anyone has not signed that
58 1 sheet, we would appreciate it if you would for the transcript .i 2 purposes. 3 We turn now to the category on Action 3, Routine 4 Inspection and Maintenance. Recommendation 3 states insure by 5 establishing a routine inspection maintenance program that 6 corrosion, erosion cannot degrade the performance of the safety 7 related systems supplied by Service Water, emphasis added. 8 It would seem unrealistic to assume that a program i 9 could be developed that will insure absolutely no degradation of P 10 the system. Could you identify that the intent here is to 11 establish a program which will insure that the system cannot 12-degrade to the point at which its ability to perform its safety 13 function is impaired. And the authors of the generic letter 14 concur in this interpretation. Next question. 15 Must all safety related service water piping be 16 cleaned, or only the piping that is susceptible to corrosion l 17 buildup, that is low flow areas? Non-destructive examinations l 18 would be used to confirm the areas which needed to be cleaned. 19 Recommendation Action 3 is intended to provide L assurance that open cycle service water piping and components do 20 21 not have degraded performance from corrosion, erosion, protective L 22 coating failure, silting and biofouling. Once this assurance is i 1 23 made, the routine maintenance and inspection program can 24 concentrate on those piping segments that are susceptible to these 25 problems. Any questions on that? o
t 3 59 1 Next question, would it be considered acceptable to 2 omit from inspection piping which is practically inaccessible, 3 that is underground piping, based on inspections of practically 4 accessible piping. our response, inaccessibility itself would 5 not be a sufficient reason for not inspecting. However, if 6 additional justification including operational data and prior 7 history are available, along with an evaluation which clearly 8 justifies that inspections would be necessary -- excuse me, would 9 not be necessary, then inspection could be precluded. 10 Next question, does the maintenance program have to 11 include sampling of any crud or sediment found to determine its 12 source. For example, during routine maintenance, a small amount 13 of sediment was cleaned from a heat exchanger and the only-14 documentation stated that it appeared to be a normal corrosion 15 deposit. (. 16 If the maintenance program can assure that the heat 17 removal requirements of the service water system are met, then it 18 is acceptable. The better the root cause analysis of a preblem 19 is, however, the more effective will be the corrective action. 20 Any questions on that? 21 The next question, if minimum fouling is found during 22 maintenance, it should be acceptable to assume that the heat 23 exchanger can still perform to the original design specification. 24 Does the NRC have a problem with this assumption? s 25 The NRC Staff cannot judge the adequacy of heat
F i I l 60 1 I transfer capability based on a broad statement of minimum 2-fouling. The licensee must determine what fouling level requires 3 corrective action, and justify the approach to be taken. Any l 4 questions on that answer? 5 Next question, under specific Action 3A on page 6 of 6 the letter, what constitutes excessive accumulations of 7-biofouling agents, corrosion products and silt? r. 8 The Staff does not have a quantitative criterion for 9 this parameter, but notes that recently one plant removed more 10 than 20 tons of such accumulations from its service water system. 11 If such accumulations cause degradation of the heat transfer 12 capability of the system, as shown by performance trend data, then 13 such accumulations are excessive. Any reaction?. s 14 Next question, are plant work requests adequate 15 relevant documentation to support the reinspections and 16 maintenance documentation requirement of specific Action 3? 17 The answer is yes, as long as they can be made 18 available to an NRC inspector. And that constitutes all the 19 questions for the recommended Action 3 on routine maintenance and 20 inspection. 21 Turning to the category for Action 4, the Single 22 Failure Walkdown, we have several questions. 23 To what extent does this walkdown have to be performed? { 24 We are presently conducting a design basis documentation 25 reconstitution effort. A system walkdown is performed only if a
I \\ i L a 61 ) i f-1 problem is identified during documentation review. Walkdowns are l \\ 2 not conducted all the time and are not full scope. Is the intent i 3 to complete walkdowns as required to insure systems meet the 4 licensing basis for the plant or to verify the as-built condition? 5 The intent of the recommended action is to verify that 6 the as-built condition of the system is sufficient to insure 7 performance of the intended function of the service water system. f 8 The phrase, in accordance with the licensing basis for the plant [ I 9 was inserted for fairness to those plants licensed before a single 10 failure criterion was instituted in the regulations. A design 11 basis reconstitution suffices for the walkdown inspection 12 recommended here. Any questions? 13 Next question, a service water system walkdown 14 inspection was completed in 1986 at our plant. Can we take 15 credit for that effort for this action, or must we repeat it now s 16 to meet the 2-year criterion? 17 You may take credit for the 1986 walkdown to meet this l 18 recommended action. The suggested time of two years to qualify 19 the word "recent" was not meant to be rigidly interpreted. The 20 NRC is interested in the walkdown being done now or recently, not 21 in the distant past. 22-Next question, does the system walkdown take into l 23 account piping, valves, and in-line components? What about 24 cabling walkdown? Is our 79-14 walkdown sufficient to address ( 25 this? l t f
62 1 1 79-14, we believe, refers to Bulletin 79-14 and our i 2 answer; the system walkdown should take into account everything 3 about the system. The recommended Action IV is intended to make 4 maximum use of other pertinent activities in reviewing the 5 system, but it is not sufficient to depend on 10-year old reviews 6 to ascertain the condition of the system today. 7 However, we understand that Bulletin 79-14, " Seismic 8 Analyses for As-Built Safety-Related Piping Systems," is not 9 closed at all plants. So if the walkdowns have been done 10 recently, they would be acceptable. Any questions? 1 11 Next item. I don't recognize that. Can you take that 12 one off for the moment. Yes, thank you. Save that one until the 13 end. 14 Recommendation number 4 discusses system walkdown 15 inspections. GPU Nuclear assumes that the intent of the walkdown l 16 as down to the level of a flow diagram only. Does the NRC agree 17 with this assumption, or do we intend for a more detailed 18 walkdown? 19 We discussed this and add single failure inadequacies 20 and concur in control systems as well as equipment in which water 21 flows. We note that the single failure inadequacies have been 22 found in some plants apart from routine surveillance procedures. 23 Okay, next question. 24 Are there any specific requirements which are new that 25 should be added into existing single failure analysis? Explain
i i 63 1 what is meant by reconstitution of the design basis of the system l' 2 is not intended. 3 Recommended Action 4 for single failure walkdown was 4 not designed to incorporate any new feature into existing single 5 failure analysis techniques. The phrase, " reconstitution of the 6 design basis of the system is not intended" refers to excessively 7 difficult determinations of design data. For example, this may be 8 the case for small skid mounted heat exchangers that were 9 purchased as piece parts of larger units of equipment and for { 10 which design data may not have been provided to the licensee or 11 applicant by the vendor. It would be enough to demonstrate that 12 the equipment module of which the heat exchanger is a part could 13 do its job. 14 Questions? 15 AUDIENCE: Ken Hukari, Portland General Electric. 16 Could I-hear you repeat that again -- just repeat it again, 17 please? 18 DR. HODGE: Sure. The question is, explain what is 19 meant by reconstitution of the design basis of the system is not 20 intended. 21 The recommendation was not designed to incorporate any 22 new feature not existing single failure analysis techniques. This 23 phrase refers to excessively difficult determinations of design 24 data. For example, this may be the case for small skid mounted l 25 heat exchangers that were purchased as a piece parts of larger l l l
I [- 64 1 units of equipment and for which design data may not have been l i l 2' provided to the licensee or applicant by the vendor. i 3 It would be enough to demonstrate that the equipment 4 module of which the heat exchanger is a part could do its job. i S AUDIENCE: part of my question here was, what about 6 some of the contractor calculations that have been bought by the l [ 7 utilities and since found to be, some of them in error, by the NRC 8 in their audits, I think. And does that mean we should go back 9 and check some of our design basis background calculations, maybe 10 random or complete? l 11 MR. WERMIEL: Let me answer that, Vern. [ 12 DR. HODGE: Sure. 13 MR. WERMIELt As far as this generic letter is 14 concerned, we did not intend any licensee to necessarily go back 15 and verify design calculations for heat transfer for the service I 16 water system. However, if you know of an already existing problem 17 or suspect that such a problem may exist, then by all means it's 18 very appropriate to go back and look into that. 19 But the particular recommendation here was only with 20 the assumption that you have an adequately design basis, you 21 don't believe you have any problem with it, and now all you need 22 to do is make sure that the design basis is being met by the 23 system that's installed in the plant. That's all we intended. j 24 AUDIENCE: That if you run into any differences between 25 those -- on your tests, then it's time to go back and -- I
L 65 1 MR. WERMIEL: Exactly, precisely. You should not 2 ignore a situation where you found a problem or really suspect a 3 problem. Not at all. 4 AUDIENCE: Thank you. 5 DR. HODGE: Any other questions? o 6 The next question was, please elaborate on the 7 requirements of Item 4, specifically what is intended by 8 confirmation of the performance of the service water system in 9 accordance with the design basis without reconstitution of the 10 design basis? Also, is it intended by this requirement to 11 perform a complete single failure analysis of the service water 12 system? 13 The licensee is expected to confirm that the installed 14 as-built system satisfies the design requirements stated within 15 the plant's licensing basis, that is the FSAR, the technical 16 specifications and additional licensing documentation. A single 17 failure analysis is to be part of this confirmation. Any 18 questions on this answer? 19 Next question, the generic letter states that the 20 licensee should verify that the service water system is in 21 accordance with the licensing basis of the plant. Is the 22 licensing basis in the context of this generic letter considered 23 to be the FSAR and tech specs or will a more expansive { 24 interpretation be used? 25 The licensing basis is as defined in the FSAR, tech
66 t 1 specs and other licensing documentation. It is not the staff's 2 intent that the licensing basis be redefined when addressing 3 generic letter 89-13. t 4 Next Question, Action Iem 4 of generic letter 89-13 5 states that the system walkdown inspections are required to e 6 confirm the as-built configuration of the service water systems. 7 As a recently licensed plant, we are confident that our 8 configuration control program satisfies this requirement. We 9 believe system walkdowns are unnecessary for our utility. 10 And NRC says this position appears to be reasonable for 11 good cause. Ongoing programs that contain results pertinent to 12 generic letter 89-13 should be referenced in the response as 13 justification for an equally effective program and retained in 14 appropriate plant records. Any discussion on this? 15 Next question, if other design issues are being 16 addressed by other regulatory actions, is it acceptable to 17 exclude them from the scope of review for Action 47 And we have 18 discussed this question already. 19 Next question, with regard to Action 4 which requests 20 confirmation that the service water system will perform its 21 intended function in accordance with the licensing basis for the 22 plant, which specific licensing basis must be reconfirmed at this 23 time? only the single active failure review? ( 24 And, again, we ask you to refer to previous 25-discussions. l
67 I 1 We received one additional question in this category j s 2 from a previous workshop, and this is the one that I asked you to 3 save until the end. Should single failure analysis of the 4 service water system include motive power? Electrical, 5 pneumatic, et cetera? To active components, motors, valves, et i e 6 cetera? If so, should it be limited to only to the delivery of 7 the motive power to the component a'd not the single failure 8 reliability of the motive power sources. That is do not need to 9 do a single failure analysis on motive power system. i 10 our answer is yes, the licensee should consider single 11 failure in power operated equipment or components that are part of 12 the service water system. The single failures in power supply 13 systems themselves do not need to be considered under generic 14 letter 89-13. Any clarification needed? 15 Okay. That completes the category dealing with the 16 single failure walkdown inspection. 17 And in the category for Action 5, the procedures 18 review, we received one question. Please discuss what 19 constitutes the desired response for Action Item 5. Confirming 20 the adequacy and maintenance practices of operating emergency 21 procedures and training that involves the service water system, i 22 The letter states that the confirmation should include 1 23 recent reviews of practices, procedures and training modules. 24 Please provide some guidance for performing an adequate review. 25 Also, are there other actions which the NRC recommends as part of l
i 68 I i the confirmation? 2 our response is, the staff has no specific guidance on 3 what procedures, training and maintenance practices should be 4 evaluated or revised. The intent of this item is to increase i 5 personnel awareness of the importance of the service water system 6 with the aim of reducing operator errors. l 7 Personnel or procedural errors are identified as a 8 significant source of service water system failures. We refer 9 you to the wording in Action Item 5 in the generic letter itself. 10 Any need for clarification? l 11 All right. That completes the questions that we had 12 received in writing before the workshops and each workshop except 13 this one. We received a number of questions and Jerry Wermiel 14 will address those. 15 MR. WERMIEL: Okay. I'll go through those questions 16 that we just received from the floor here. Before I begin, I was 17 asked by a participant to identify the Regional Representatives in 18 this workshop and I thought I would do that, so that you can 19 become familiar with those people that will be involved from 20 Regional Headquarters. Mr. Al Toth, Region 5 is here and Mr. Ian 1 Barnes from Region 4 is here. I believe both are Section Chiefs 21 22 involved in this effort. 23 The questions that were received from the floor here ( 24 are not in any particular order. I'll just go through them, and 25 I'll ask that if there's any amplification that either Vern Hodge ~
E 69 1 or'Duane would purpose to make sure that they do.
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.First question, this one is from Arkansas Power and 3 Light. If the utility performs a baseline test that exceeds the 4 design requirements, but is below the manufacturer's rating for 5 the component heat exchanger, does the NRC consider this as a a 6 concern in that the design margin has been lowered? 7 And our answer is, no. The staff is not concerned that 8 a licensee maintain the initially specified design margin for a 9 heat exchanger. If a licensee chooses to operate with a reduced 10 margin, then this is acceptable, provided the design basis heat 11 requirements, heat removal requirements are still satisfied. Any 12 further amplification that needed? 13 The second question, also from Arkansas Power and 14 Light, this licensee is scheduled to chemical clean the entire 15 service water nystem in the Fall of 1990. Does this constitute 16 an acceptable method to restore thermal performance in lieu of 17 performance testing for the first outage? 18 And our answer is, the licensee should justify such an 19 approach to satisfy this part of the generic letter. Since 20 chemical cleaning is a corrective action, some follow up 21 verification such as visual examination or limited performance 22 testing may be appropriate. In other words, merely chemically 23 cleaning a system doesn't necessarily assure you that the system {l 24 has been based lined which is the word that we use without 25 necessarily performing some additional verification of some sort.
i 70 Is there any discussion on'that? -1 '{.' 2 The next question is ftom Houston Lighting and Power 3' and it reads, the SSFI method currently being used to satisfy 4 recommended Actions 4 and 5 is manpower intensive. Can program ) 5 -deficiencies identified in.the open loop system be applied 6 horizontally to the closed loop systems in lieu of an additional t 7 SSFI? x 8 And our answer is, yes, a licensee may decide that 9 based on other actions already taken, such as an SSFI on the open 10 loop system, that application of deficiencies identified from this 11 to the SSFI to the closed loop system is sufficient. And that is 12' provided the licensee confirms that the existing configuration i 13 control program has been applied to the closed loop system. l' 14 In other words, if you've identified efficiencies from (.' 15 an SSFI programmatic concerns, and have applied them to other 16 safety related systems such as the component cooling water system, 17 and are satisfied that the existing configuration control program 18 you've already implemented for the component cooling water system 19 is sufficient, and you don't expect there to be any other 20 problems, then that would be sufficient in addressing the generic L. 21 letter's concern for this item. Any additional clarification 22 needed? 23 In brief, we're not asking that you necessarily do a 24 complete SSFI or manpower intensive design verification effort on 25 each and every aspect of your safety-related cooling water
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I system.- Only that which we've already identified and described N -2 in answer to the other questions. 3 I have two questions now from pGE, question one, 4 restate what you would consider acceptable.as impractical i 5 conditions for testing. As a followup to that, what are 4-6 acceptable alte" tives, especially for utilities not privy to .7 EPRI information?
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Our answer is, an impractical condition would be a 9 situation where flow or means of applying heat load cannot be 4 l 10' achieved based on the system configuration. An acceptable L 11 alternative for such a situation is a periodic inspection and 12 maintenance program for such heat exchangers. And I believe wo 13 already discussed this to some extent when dealing with the I L 14 containment' cooling heat exchanger. 15 We also amplify that impracticality itself is not a 16 sufficient reason for precluding any heat exchanger from I' 17 performance verification of some sort. 18 The second question, what if performance heat exchanger 1 ) 19 testing conditions that is off design cannot be used to 20 demonstrate acceptable heat transfer because low delta T combined 21 with instrument inaccuracies is insufficient, is maintenance E _22 inspection our only alternative? 23 And our answer is, yes, if reasonable resulto cannot be i 24 obtained from periodic performance testing, then inspection 25 maintenance is an appropriate alterative. Any followup to that? l
72 ~1- 'Okay.. I now have a series of four questions, I ,,y 2 believe, and these are from Nebraska Public Power District. 3 Question one. in' lieu of taking annual water samples to determine 4 if Asiatic clams have populated the water source, can we perform 5 annual visual inspections of sample heat exchangers cooled by ' c ' 6 river water? ^-' 7 Our answer is, the purpose of sampling the water source 8 itself is to insure sufficiently early identification of l 9-potential fouling means. However, if the best available site 10 specific information does not indicate a means of biofouling, 11 then visual examination of a sample of service water system heat L 12 exchangers may be sufficient with proper justification to detect I 13 fouling. 14 Question two, since macroscopic biological fouling and I 15 MIC has not been a problem at our site, does that exempt us from 16 the recommendation for chlorinating systems using raw water before 17 lay-up? '18 The answer is, yes, with appropriate justification
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20 Item 3, periodic visual inspection of small heat l-21 exchangers such as seal water coolers as a class, do they need to 22 be inspected when the pump is inspected? 23 And our answer is, once a licensee has established that l [ 24 a small heat exchanger such as a sealed cooler is performing l L 25 satisfactorily, the licensee may choose to justify an extended a--
73' 1 program of periodic inspection. For example, up to five-years-2- based on' existing operating conditions. For example, if the 3 cooling loop itself is not subject to fouling mechanisms, then an ~ 4-extended program of inspection may be appropriate. Any followup-5 discussion on that one? to 6 And the last item, is periodic maintenance adequate to s 7 address' lay-up without chlorination? 8-And our answer is, yes, with appropriate justification 9 provided.. And that's all I have. 10 If there's no other question or comment, we can provide 11 a very brief summary of where we plan to go from here and then we 12 can conclude the session and adjourn. s 13 DR. HODGE: There may be one potential.for continuing 14 dialogue here concerning the item in Action 2 on taking 3 tests. l 15 Perhaps the wording in the letter is a little bit not 16-understandable. We intend for -- at first we intended for
- 17. licensees and applicants to do the three tests to establish i
18 appropriate testing or maintenance frequencies without doing any L_, 19 -corrective actions, the thinking being that testing a clean 20 system doesn't tell you very much every time. You want to know
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y 21 if the system is being degraded. 22 We allowed then the possibility for a licensee to clean L .3 the system before testing, we don't want to just require 2 7 licensees to test a system with no good reason. So they could 24 1 l 25 clean the system and then perform testing in a periodic retest
74 'l manner.- 1 l 2 And~then the intention of the three tests was to 1 _ establish the frequency in the best way. That may have been a 3 4 _ point that needed to be clarified. Is there any question on t 5 that? 6 Have we answered your questions sufficiently well this 7 morning? If there's any other discussion, we invite you to ask ( 8 that now. 9 MR. WERMIEL: Keep in mind even if nothing comes to 10 mind right now,_you're free to call anybody from the staff at any-11 time with any further follow up questions or anything that you 12 find unique to your facility that you'd like the staff to 13 consider. We're available, as well as direct contact with your 14 project manager, that's always permitted and is always welcomed. 15 DR. HODGE: The only difference being that such 16 questions may not find their way into print. 17 MR. WERMIEL: That's correct. 18 DR. HODGE: Okay. Well, if there are no other e 19 questions,.I thank you for your attendance and the meeting is 20 adjourned. 21 (Whereupon, at 12:43 p.m., the meeting 22 was adjourned.) 23 f 24 25 ~
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i REPORTER'S CERTIFICATE 4 l This is to' certify that the attached proceed-ings before the United States Nuclear Regulatory Commission in the matter of: q NAME OF PROCEEDING: Generic Letter 89-13 DOCKET NUMBER: PLACE OF PROCEEDING: Denver, Colorado 4 were held as herein appears, and that this is the original transcript thereof for the file of the United States Nuclear Regulatory Commission taken by me and thereafter reduced to typewriting 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. l /C) b W[ // # / / M, &- /s [ s.m,w. c. a / w Ronald N. LeGrand Official Reporter Ann Riley & Associates. Ltd. _T 4 a _'g 'Yg i}}