ML20008E255
| ML20008E255 | |
| Person / Time | |
|---|---|
| Issue date: | 10/16/1980 |
| From: | NRC COMMISSION (OCM) |
| To: | |
| References | |
| REF-10CFR9.7 NUDOCS 8010240466 | |
| Download: ML20008E255 (59) | |
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DISCUSSION OF SECY-80-325 - UNRESOLVED SAFETY ISSUES
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DATE: October 16, 1980 PAGES: 1 thru 57 AT:
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400 vi_T -4a Ave., S.W. Wasning a, D, C.
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1 1
UNIIED STATES OF AMERICA 2
NUCLEAR REGULATORY COMMISSION 3
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PUBLIC MEETING 4
DISCUSSION OF SECY-SO-325 - UNRESOLVED SAFETY ISSUES 5
6 7
8 Nuclear Regulatory Commission Room 1130 9
1717 H Street, N.W.
Washington, D.C.
10 Thursday, October 16, 1980 11 The Commission met, pursuant to notice, at 10410 a.m.
12 PRESENTS 13
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JOHN F. AHEARNE, Chairman of the Commission 14 VICTOR GILINSKY, Commissioner PETER A.
BRADFORD, Commissioner 15 JOSEPH M.
HENDRIE, Commissioner 16 STAFF PRESENT:
17 S AMUEL J. CHILK, Secretary LEONARD BICKWIT, General Counsel 18 K.
KNEIL H. SHAPAR 19 W.
DIRCKS E. CASE 20 C.
MICHAELSON E.
HANRAHAN 21 H. GECRGE 22ALSO PRESENT:
23 R. FRALEY, ACRS
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DISCLLE nis is an u= official ::anscrip: of a. nasc1=g of de Uni:ad States Nucisar Regulacory Co mdmaion held on 10-16-80 in da Commission's officas at 1717 3 Screet, N. W., Washing cu, D. C.
D e maat1=g was open :o public at:andance and observation.
nia =anse:1pt has not been reviewed, cor:sc:ad, or editad, and i
it may contain inaccuracias.
na =anscrip is incandad sola17 for gn=aral ' #orma:1onal purposes.
As providad by 10 CF3. 9.103, i: is see par of -de i
formal or informal record of decision of ha sa::ars discussed.
Expressions of op* don in this transcript dn not nacassarily reflac: f1=al decarm1=ations or baliafs.
No pleading or other paper may be. filed with da.Com=ise. ion 12 any precanding as -da rasul: of or addressed :o any sca:amant or argume== contained harmin, except as the Commission =ay authoriza.
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CHAIRMAN AHEARNE:
The Commission comes to meet 3once again an the subject of unresolved safety issues.
We 4aet earlier this year on July 17 to discuss proposed report Sto the Congress identifying new unresolved safety issues.
6The staff had recommended six such items.
7 As a result of the meeting, we sent a letter to 8 the Congress indicating that the report would be delayed 9pending further Commission review, and we asked the ACRS and 10the office headed by Carl Michaelson to examine the list and 11also to provide advice as to whether they saw additional 12 item s.
We have received f rom the ACES three additional 13
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14 items that they recommend, and f rom Carl Michaelson, two 15 additional items for further pos51ble incorporation into 16 existing lists.
We also now have a response from NRR with respect 17 18to those in which NRR agrees with one of the items 19 recommended by the ACES.
It suggests that another is 20 handled by an ongoing program and tha t a third be deferred 21pending examination of a contractor's report.
Ed suggests as far as the two recommended by 22 23 Michaelson, to study those and add them to the list to be
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24 studied and then to incorporate the comments.
We also have a memo from the Director of OPE that 25 a
ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE S.W., WASHINGTON. D.C. 20024 (202) 554 2345
3 1 Mr. Hanrahan has proposed that we not -- I think this is a 2 correct statement tha t we not include on the list of 3 unresolved safety issues items for which we have identified 4 programs in the Action Plan and focused resources on the 5 resolution, and in addition, has raised, with the great 6anount of foolhardiness that is characteristic of an 7 analysis, that we ought to reexamine the issue of unresolved 8 safety issues, obviously feeling that the many days spent 91ast time were such an enjoyment that we ought to repeat 10 th a t.
11 (Lauchter.)
12 MR. HANRAHAN:
I was not here to enjoy that.
13 CHAIREAN AHEARNE:
Yes, I know. That, in fact, was
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14 the first thought that crossed my mind.
15 (Laughter.)
16 MR. HANRAHAN:
I noted that tone in your 17 memo randum.
18 CHAIRMAN AHEARNE:
But nevertheless, it is 19probably a point that deserves consideration.
20 The main reason we are here, again, is because 21 Commissioner Hendrie, who had expressed a certain amount of 22reluc'tance on the initial six, then when he began to see the 23 growth, suggested strongly that we ought not to go ahead 24without an additional Commission meeting on this subject.
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25 So, before we go any further I will ask b
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1 Commissioner Hendrie whether he would like to expand on some 2of the remarks he has made in the past on these issues and 3 focus some of the direction on what we will taJ k about this
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4 mo rning.
5 Joe.
6 COMMISSIONER HENDRIE:
I will make a couple of 7 remarks to the extent that my voice holds up.
8 As several of us commented the last time we met at 9 ths table to discuss these things, the proposed list of 10 unresolved safety issues, in spite of the fact that staff 11 has culled them and they apparently meet criteria and 12 definitions, acquire a necessary number of points in various 13 assessm ents, I cannot get my intestinal gauge to tell me
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14 that numbers of them are, in fact, unresolved safety issues 15 1n the sense of Section 210.
16 I don't know what to do about that.
I suppose I 17could just shut up and let them be counted -- added to the 18 11st, but it has seemed to me worth some more discussion.
19 Things where it seems to me clear enough in a general way 20vhat has te be done, where at least the initial outlines in 21 some sense, the long-term direction exists where we are 22 moving in that direction, where we are moving in those 23 directions already but have not accomplished all the things
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24 ve foresee will have to be done, that does not seem to me 25 the sort of thing ye.u list as a Section 210 unresolved ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2346
9 5
1 safety issue and carry along for however many years it may 2 takw to accomplish the things that you now know you are 3 going to want to do and are finally able to say we have i
4 dotted the last "i" and crossed the last "t."
5 I selected long-term upgrading of training and 6 qualifications and operating personnel as an example of this 7 kind of. thing.
8 (At 10:17 a.m.,
Commissioner Gilinsky entered the shearing roos..)
10 I know it meets your criteria because you worked 13 hard to scan against those criteria, but it does not seem to 12me like an unresolved safety issue in the sense of a Section 13210.
I must say I have the same difficulty with operating
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14 procedures. There is not a great mystery about what we want 15 to do about training and qualification of personnel, and 16 there is not a great deal of mystery about what we want to 1
17do about operating procedures.
18 We want to upgrade the first and review and 191mprove the second, and I think any of us could sit down and 20 this afternoon in a few hours sketch out a general program 21 to go about that.
In fact, it has already been done.
This 22 wo rk is on its way in a pretty strong way in staff 23 initiatives, and it does not seem to me the sort of thing 24 that one carries on this list in spite of the definition and i
25 scre enin g.
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1 I also have some concern that as a practical 2 matter, you know, when budget. time comes around, you try to 3 figure out what you are going to prepare for a set of smash 4 slides which are really going to grab first the Budget SReview Committee and then really grab the Commissioners and 6,then make a big splash with the OP.B examiners.
7 I am afraid unresolved safety issues has gotten to 8 the point where it is recognired by enough people so all you 9have to do is say "new unresolved safety issue," boy, and 10 you have yourself another 20 people and $10 million.
- And, 11 you know, if I were a division director I would be out there 12 working that just as hard as I could because it is a let 13 easier to do it that way than to justify it in other ways.
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14I wonder if there is some of that at interest here.
15 I hnve some difficulty also with the questions 16 about if you take one thing out of the Action Plan, or two 17or three as we have here, and put stars on them and say they 18 are Section 210 unresolved safety issues, what does the 19 resource distribution pattern then look like as regards 20 these items and other Action Plan items which I would regard 21 as of equivalent importance?
22 Now, if you tell me that the designation means 23 that they will get resources guaranteed, tha t suggests that 24 there are other items which in the array of the Action Plan 25 are of equal importance that will not get resources or will ALDERSoN REPORTING COMPANY,INC, O
400 VIRCINIA AVE, S.W., WASHINGTON, D.C. 20024 (202) 554-2345
7 Inot get them in the same measure, and that causes me to 2 scratch my head.
3 On the other hand, if their designation is 4 unresolved safety issues, it does not affect the resource 5 distribution in that fashion.
And then, I don't know that I scare to hear arguments that say this is the way to really 7make sure you are focusing and work on these things.
8 Okay, those things sort or come together.
It 9 seems to me that some reconsideration of the definition of 10 the criteria are appropriate.
Whether we would end up 11 changing them or not, I don't know.
I do think some 12 discussion is useful.
I think OPE has suggested some useful 13 possible avenues.
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One final thing that concerns me is what seems to 14 15 be a tendency to lump everything that we ought to be working 160n into this category.
There are seven new ones proposed 17and nine others for further study, and thus candidates for 18 adding to'the list.
That amounts, in effect, if all of them 19go, amounts to doubling the number of Section 219 unresolved 20 saf e ty issues this year, and I have my doubts that that is 21either necessary or desirable.
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22 CHAIRMAN AHEARNE:
All right.
23 Victor do you have any comments you would like to
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24 make to start with?
COMMISSIONER GILINSKYs Nc, I am here to hear what 25 C
ALDERSoN REPORTING COMPANY. INC, 400 VIRGINIA AVE, S.W., WASHINGTON, D.C. 20024 (202) 554-2345
8 1 staff has to say.
2 CHAIRMAN AHEARNEs Peter?
3 COMMISSIONER BRADFORD:
No.
4 CHAIRMAN ASEARNE:
All right.
I guess what I 5would first propose is to let Ed have a chance to make his 6 case on a new definition and excluding the Action Plan 7 1tems, because I think if we change the definition it might 8 affect or may not affect any of the items on the list, but 9 at least it would be nice to know the standard we are 10 ap plying.
Similarly if he convinces us
- hat if it is in the 11 Action Plan, it ought not be on the list.
12 Ed.
12 MR. HANRAHANs As far as the Action Plan items are
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14 concerned, I don 't quite see the benefit of adding those to 15 another list when the Commission has already spent a great 16 deal of time in identifying items to be undertaken, going 17 through priority screening on them and allocating and 18 dire c tin g resources to be spent on them, and given 19 instructions both to the staff and the boards on how to -
treat those matters.
20 21 Now to classify some subset of those as unresolved 22 saf ety issues,has the smack of double counting, to have 231tems carried in two different categories, and I think it 24 provides some confusion, if not for ourselves, perhaps for 25 th boards and others outside.
And th e la w, Section 210, k
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9 1 requires a plan and a course of action to resolve these, and 2 this is, indeed, exactly what the Action Plan has done.
It 3 has provided a plan and the resources to carry out the 4 resolution and the implementation of these matters.
5 I think I would secondly argue that there is, from 6my viewpoint, little if anything in the Action Plan that 7 fits the notion of unresolved safety issues.
The items that 8 have been proposed, I share Commissioner Hendrie's view on, 9do not seem to me to fit tha t definition, a t least my own 10 personal definition of it.
11 I think the fundamental difference that we have 12with the staff on this is that I would feel it ought to only 13 include those items where the adequate protection of health
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14 and safety, that level is in question where it is uncertain 15as to whether that is achieved or not. We have impismented a 16 requirement which we believe covers it, but I am not sure 17 and we need to' learn something.
18
'Je have to develop some knowledge, data and 19 information to understand the phenomenon.
20 CHAIRMAN AHEABNEs But those'are two different 21 p oin ts.
The first point, that you are concerned about 22 double counting, does not address whether or not the item 23should be on the list f rom its substantive significance but
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24rather is it on some other list.
25 M3. HANRAHAN:
That is right.
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CHAIRMAN AHEARNE:
The second one 2
MR. HANRAHAN:
Should it be on the list at all?
3 CHAIRMAN AHEARNEs That is right.
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4 ER. HANRAHAN That is right, two separate --
5 CHAIRMAN AHEARNE:
I guess my own reaction is I am 6a lot more sympathetic to your second point than your 7 first.
I don't myself have any problem with keeping it on 8 two lists.
I do not think it will be double resource 9 allocated. I would suspect the same, that resources would be 10 focused on the question, and the fact that it is embedded in 11 a list generated by the revie's process does not, to my mind, 12 eliminate it from its consideratiot. on the unresolved safety 131ssu e list.
14 The second one is a much more significant point, 15 to my minds does it meet some sort of a criterion that you 16 1ay down for what should be --
17 MR. HANRAHAN It har nothing to do with whether 18 an item is in the Action Flan or not. That is what I am 19 s ayin g.
20 COMMISSIONER GILINSKY:
Where does the requirement 21 to present this list to the Congress cone from?
Is it frbm 22 the Reorganizatica Act?
23 MR. HANRAHAN I believe so.
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24
.tR. SICKWITs Section 210.
COMMISSIONER GILINSKY:
It ays the plan has to be 25 l
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11 1 submitted to Congress?
2 MR. BICKWITs Yes, annually.
3 MR. HANRAHANs I think the fundamental difference
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41s should tae definition or the application of the 5 definition -- and I think it is less important whether we 6 rewrite the definition and submit it to Congress as to what 7 our application of the definition is -- should that include 8 1te.ns which improve the level of safety where we believe 9that an adequate level of safety is already achieved.
10 In my mind, it ought to be on generic issues.
11 Now, the problem there is generic issues gets to be a long 12 1aundry list of 100 and some items, and they can get diluted 13 th er e.
That is another problem.
That list ought to be i
14 culled out to those which are only important to safety.
15 The less, I think, in people's mind tha t they are 16 derived from the. thought of safety -- they don't really 17contain everything in those.
18 COMMISSIONER GILINSKYs I was going to say in some l
19 sense our safety budget is a plan to deal with unresolved 20 sa f e ty issues.
21 MR. CASES It could be looked at that way.
22 MR. DIRCKS:
We are ;etting in the business of 23aaking lists.
I begin to wonder how many lists we are going 24to keep making.
The point that Ed made and Commissioner
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because I was tending to agree that by 25 made that if ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 564-2345
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1 selecting out certain Action Plan items and putting them on i
2 the unresolved safety item list, do we implicitly give more 3 priority to those items on that list?
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MR. CASE:
Let me respond to that.
Basically, 5 there is a different management approach applied to
.6 unresolved safety issues, different from the approach that 71s being applied to the TMI Task Action Plan.
If it is an 8 unresolved safety issue, it is in a branch with a full-time gdedicated task manager for getting that job done, with a 10 line manager responsible for cetting all of them done, and 11 an assistant director and a director.
12 COMMISSIGNER GILINSKY:
Why don't we do that for 13 ev erything?
14 CHAIRMAN AHEARNE:
You don't have enough people.
15 MR. CASE:
You don't have enough people 16 COMMISSIONER GILINSKY:
We have to pick out the 17 things we think are most important.
18 MR. CASE:
Precisely. And it has been our 19 ex pe rien ce, rightly or wrongly, that tha t ma nagement style 20 works better to get issues resolved than appointing a task 21 manager without line responsibility.
22 CHAIEMAN AHEARNE:
Ed is answering tha t in 23 som e wh a t a different way, but yes, putting it on a list does
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24 say that these are more important.
25 MR. DIRCKS:
Then it implicitly says other items.
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CHAIRMAN AHEARNE:
Explicitly does, absolutely.
2 MR. CASE:
But it does not necessarily mean that a there vill be a diff erent amount of resources.
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4 MR. DIPCKS:
But you have not seen the process by 5 which some decisions are made, and these are special items Bunder the Action Plan, and others are less special.
7 COMMISSIONEB GILINSKY:
I suspect some kinds of 8 problems lead themselves more to this approach than others, 9and they probably are the ones that can be completed, you 10 know, where you can write out a plan for completing it.
11 MR. CASE:
In general where you have a fair idea 12of what you intend to do and therefore can schedule it out 13 and describe the steps.
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COMMISSIONER GILINSKY:
And these sort of 14 15 co ntinuin g, chronic concerns.
16 MR. CASE:
More generalized concerns.
As our 17 comment on the ACRS suggestion on the single-f ailure 18 crit erion, the adequacy thereof, our answer to that is where 19we find specific applications of the single failure are not 20 good enough, then curing that problem would become an 21 unresolved safety issue rather than the whole general 2aoroblem of the adequacy of the single-failure criterion.
CHAIRMAN AHEARNE:
Ed, what is your reaction to 23 24 0PE's suggestion?
25
!3. CASE:
Well, way back when when we started the fk i
ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
W 1 process, there was a considerable staff dialogue, and I 2 think led by me: why put TMI items on the unresolved safety 31 tem list?
Basically for the same reason he is raising.
4 Basically the purpose seemed to be to single things out and 5to get an Action Plan going and get them done.
And if that 6 vere the basic purpose of unresolved safety issues, you 7already have that purpose, so why do both.
8 But unfortunately, the Congress defined something 9 Called unresolved safety issue and said put them on a list, 10 never mind whether you have six or twelve ways of resolving 11 them or management styles; put them on a list.
So, I guess 12it is my thinking that in doing it Ed's way, although 13 pragmatically is equal, in my judgment does not meet the I
14 requirements of what the law says.
I am indifferent to the 15 way it is done.
Let me make tha t clear.
16 MR. HANRAHANs I don't think Congress suggested a 17 11st. They said develop a plan providing for specification 18 and analysis of unresolved safety issues -- all lower case 19 1etters -- relating to nuclear reactors, and take action 20necessary to implement corrective measures with respect to 21 such issues.
22 Now, the Congress,'you know, in the Act and in the 23 1egislative history that I have looked at, does not really 24 define unresolved safety issues in a way that you can come 25avar from, as I am sure you probably well know from past Ii i
ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE, S.W. WASHINGTON, D.C. 20024 (202) 554-2345
15 1 experience in this matter better than I do.
2 But it is not a notion of a list.
It says a plan.
3 MR. CASES It says specify, though, and it came in 4 a context where we had a bunch of generic issues without 5 priority established s_cong them, and a history of not 6 resolving them in any shtrt period of time.
So, Congress in 7 effect said do something about that.
8 MR. HANRAHAN:
I understand th-t.
g MR. CASE:
Cut that list down to something 10 mana geable.
11 MR. HANRAHANs I was just saying I think the list 12comes from our own implementation.
13 YR. CASES Well, perhaps.
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14 COMMISSIONER HENDRIE:
So does the definition.
15 MR. HANRAHAN Tha t is correct.
16 COMMISSIONER HENDRIEs They leave it to us to 17 define.
18 CHAIRMAN AHEARNEs I guess what you are saying 1g f rom your interpretation there that we could go back and say 20some of the items are incorporated in the Action Plan, and 21 the task actions following on the Action Plan handle some of 22them.
23 MR. HANRAHAN:
And I belleve the staff proposes in l
24 the annual report to include a chapter on the Task Action 25 Plan and progress made.
Everything there fits the l
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16 1 definition of Section 210.
You know, it does not fit 2 specifically the way we have gone about it over the last 3 year or two, but it does' fit the legislative definition.
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4 CHAIRMAN AHEARNE:
'Jhich way would you come out on S it?
That is, taking Action Plan items, and Ed's point 6 basically is going back to'the Congress saying that some of 7 these issues which arise in this sort of significance here 8 1s one way they are handled.
They are in the Action Plan 9and the Action Plan allocation of resources, and here are 10 these other items which are not embedded in the Action Plan, 11 and then here is the separate --
12 COMMISSIONER GILINSKY:
I was hoping all these 13 expressions of views would cancel each other ought.
I.
14 (Laughter.)
15 I wouldn't have to face the questica.
16 I think that if we are singling out -- if we are 17 sa ying there is this list of important items, then if we are 18 sa ying others of them are in the Action Plan list, I think 19 we pretty much have to say which ones are where and are 20 Co mp a rable.
If we are just going to reference the Action 21 List as including a whole bunch of other items, I wonder --
22 MR. HANRAHAN:
You have established priorities.
COMMISSIONER GIIINSKY:
I don't have a clear view 23 24 of i t, to tell you the truth, and a definite suggestion to 25 mak e. But I do -think, at least by the beginning of Joe's At.DERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2346
17 1rewarks, I do think I understand the gist of them and I 2 think I have said similar things in the past, that there are 3 diff eren t sorts of safety issues, there a re hardware issues, 4 there are general concerns and you cannot lump them all 5together and just put them on a lisc,, because you are going 6to handle them differently and their significance is 7 different.
8 I don't know whether that is any pexticula r help.
9 CHAIRMAN AHEARNE:
I would guess the resolution of 10 this meeting is really going to be we are going to have to 11 go back and think on a number of things.
12 Joe.
13 COMMISSIONER HENDRIE:
What was the --
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CHAIRMAN AHEARNE:
It is basically proposing to 14 15 take, I think, the first five items out and say that they 16are incorporated in the Action Plan.
17 MR. CASE:
The staff's original proposal.
18 CHAIRMAN AHEARNE:
Yes.
19 COMMISSIONER HENDRIE:
Now, let 's see. Wha t was 20 the seventh item?
That is, out of the array of things 21 proposed by the ACES.
22 CHAIR AN AHEARNE:
Control system reliability.
23.
COMMISSIONER HENDRIE:
From Michaelson's office, 24 control system reliability ?
25 CHAIRMAN AHEARNE:
Yes.
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COMMISSIONER GILINSKY:
If I can just add a 2 thought here, I am concerned tha t we have a number of 3 dif f erent tracking systems, really, and where an issue falls i
4 depends in part on history.
5 CHAIRMAN AHEARNE4 Yes.
6 COMMISSIONER GILINSKY:
That does not seem to make 1
7a lot of sense to me.
8 CHAIRMAN AHEARNE:
We are driven to some extent 9
C3MMISSIONER HENDRIE:
It has a patchwork feeling 10 to it that makes me uneasy.
It may all work out just fine, 11 but 12 MR. HANRAHANs I cannot be sanguine about that.
13 MR. DIRCKS:
The point Ed made -- I don',t know
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14 whether he made it or not, but maybe I will make it for 15 him.
We are getting awfully detailed about what list 16 st aething f alls in basically because of some definition.
I 17 think the work is going to be done.
18 CHAIRMAN AHEARNE:
The only really important tgissue, I believe, is for us to try to make sure that we 20 understand what are the significant problems that have to be 21 vorked on, and that adequate resources are placed on that 22 w o rk.
So, for example, I find it interesting tha t in all of 23 the suggestions tha t have come up, I don't find anyone
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24 commenting on the other organiration system saying that is 25not a problem.
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The debates are how I want th a t to be addressed, 2 where is that to be addressed; but everyone agrees here are 3 problems that have to be worked on.
For myself, all I am
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4 concerned about is here are the important problems and what Sare the resources for it?
6 We have this other layer -- it is sort of a 7 translation. We have to translate something we have 8 requirements on the outside to translate into, and at least 9 there are a number of groups that are interested in our 10 operation which utilize what we do not put on the list as a 11 very significant factor in a number of the licensing 12 hearings.
13 MR. CASE:
Yes, indeed.
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CHAIRMAN AHEARNE:
So we are not, I think, 14 15 co mpletely free just to say, well, we will look inwards and 16 no t worry about what list something is on.
17 MR. DIRCKS:
That is true, but underlyinc it all 181s the work that it requires.
19 CHAIRMAN AHEARNE:
If he were to come in or Ed 20were to come in and say we don't have the resources to work 21on the problem, we are not going to work on these problems, 22 or if, sa y, Carl raises an issue and NRR comes back and says 23there is a big debate, one' p erson saying that is a problem,
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24 the other person saying ab solu tely not a problem, that would 25be some significant resolution to work out.
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COMMISSIONER GILINSKY.
Also, it seems to me -
2 MR. CASE You'have t'o recognize that you avoid 3 that debate, if there is one, by saying okay, I will not 4 argue, but as you come to priorities, then I will argue.
5That is where the debate is.
6 COMMISSIONER GILINSKY:
That gets settled, I 7 assume, in the budget. I mean that is the list of lists, 8 1sn't it?
g MR. DIRCKS:
The operational plan 10 COMMISSIONER GILINSKY But we do need to have --
11 I mean the requirement set by the Congress for the list, 12 vhich obviously we have to comply wi th, we ourselves ought 13 to have a piece of paper that lists the things we think are
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14 im po rtan t.
You ought to have that~, we ought to have it.
15 0ther people ought to have it.
Obvicusly we will have all 16 different sorts of problems on it.
Problems don't all come 171n neat packages.
But we do need to have sort of a 18 continually updated and rol.1.ing list of what we think is 19 important.
20 MR. DIRCKS:
Important items.
21 COMMISSIONER GILINSKY:
Just to do our work, and 22 it ought not to be that you say, oh, yes, that one came up 23 1n '78 and therefore it is sone other list, and the TMI
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24 1tems -- well, I don't know.
25 MR. KNEIL:
Mr. Chairman, in connection with
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21 1 responding to the Bingham Amendment, we are proposing a plan 2 to resolve the question that you are addressing here, the 3 various lists, and we are developing a plan to bring the 4 various lists together.
5 COMMISSIONER GILINSKY:
A list of lists.
6 MR. KNEIL:
Right.
To maintain a list and to 7 prioritize a list.1 8
COMMISSIONER GILINSKY There is something called 9the book of lists which I saw in a bookstore.
I don 't know 10 whether any of our lists qualify for that, but we certainly 11 ough t to try to get them in.
12 (Laughter.)
13 MR. KNEIL:
'Je are trying to take th e lead in
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14 developing a plan which will resolve that, and then the 15 11sts we have will be generally available and people will be 16able to focus on them and agree with them or take issue with 17 them.
18 MR. CASE:
In terms of priorities.
19 MR. KNEIL:
Right.
20 CHAIRMAN AHEARNE:
Let me, if I could, try to 21 focus back for a minute on the issue Ed has raised. 'li we 22 g0 forward to an unresolved safety issue list to the 23 Congress, should we or should we not incorporate in that the items drawn on the TMI list?
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24 COMMISSIONER uENDRIE:
I have to ask a question 25 i
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4 22 1 first.
2 CHAIRMAN AHEARNE:
All right.
3 COMMISSIONER HENDRIEs Karl, you have a crowd out 4 there called the generic
-- what is it -- Generic Issues 5 Branch?
6 MR. KNEIL:
Generic Issues Branch, yes.
7 COMMISSIONER HENDEIE: And you have USIs and assign 8 task managers among your staff, and there are task action 9 plan s.
There are a great number of generic issues, you 10 know, that start at some pretty interesting things and 11 trickle off to, I don 't know, better ways to count the 12 numbers of toasters that might be used in the year 2010 from 13 the standpoint of demand forecasts, environmental reviews 14 and so on; great stuff, maybe next year.
Ho w about that.
15 Now, all of that comes under your purview in 16 generic issues, righ t?
17 MR. KNEILs In the sense of monitoring and 18 coordina ting, that does, yes.
C3MMISSIONER HENDRIEs And so you sort of have to 19 20 so rt out which of these get more and which get less 21 attention and time.
MR. CASE:
That is a forthcoming job.
22 C33MISSICNER FENDRIE: Now, where does the great 23 i
24 Action Flan fit on this?
MR. CASES Not at all.
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23 1
COMMISSIONER HENDRIE:
That is, Karl does not have 2 any special resposibility for tracking the Action Plan.
3 HR. KNEIL4 We are monitoring the Action Plan.
We
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4 are contributing to and monitoring the Action Plan.
5 MR. CASE:
In case anybody says what is the status Sof something.
7 COMMISSIONER HENDRIE:
Are you the monitor for NRR7 8
MR. KNEIL:
We are the monitor. There are three 9 organizations that have the responsibility, and we work 10 toge ther, MP A and us, Generic Issues Branch, and Harold 11 Denton's staff, and we have a system where we are going to 12 publish every three months a list of all the tasks in the 13 Action Plan and what their status is and who is responsible
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14 and what the schedules are.
That will be coming out every 15 three months.
Part of that is already available.
It has 16not been published yet because it is not complete, so you 17 vill be able to readily find any task and what its status is.
18 MR. CASE:
It is a reporting function.
19 MR. K3EIL:
It is a reporting function, that is 20 co rr ect.
21 "R.
CASES Not a management function.
22 COMMISSIONER HENDRIE:
Okay. I am trying to sort 23 out what becomes, for instance, of the staff effort on 241one-term upgrading of training and qualifications of 25 operating personnel if that item stands simply as one of the ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W WASHINGTON, D.C. 20024 (202) 554-2345
4 24 1 Action Plan significant headings as it does only as against 2 bein g both Action Plan and designated USI.
3 Now, if it gets designated a USI, you will have a 4 task manager for it.
5 Now, what will get done or not done that would get 6 done or not done if it were not a USI -- can you help me to 7 see the difference in the way this one would'get treated, 8 for instance?
9 MR. KNEIL:
All right, I will give you my personal 10 Views on that. I think it is a management function.
11 COMMISSIONER HENDRIE:
I have given you mine.
12 (Laughter.)
13 MR. KNEIL':
It could be designated USI without
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34 putting a task manager f rom my branch.
I do not think it is 15 essential -- at the moment all the ' ISIS in my branch, for 16 task managers in my branch, they report to me, but I do not 17 think that is an essential feature of it.
But more 18 importantly, I guess, my perception of work on generic 19 issues by the staff is that when the generic issue is put in 20 a line branch, it may or may not get done because it is 21 subservien t to work that has higher priority, whereas in our i
22 branch it has first priority and, you know, we work full-time at the job.
23 24 So the line branches have major responsibilities 25 1n operatin7 reactors and in reviewing case work, so that
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25 1 generic work tends to get the short shrift on that.
2 ME. CASE:
Thus the reason for the branch.
3 MR. KNEIL:
That is right.
4 MR. DI' CKS:
The case we jurt mentioned, say the S upgrading of operating management, this was singled out in 6such a startling manner in the Actica Plan and we have 7 Hanauer's division basically set up to do this, and I guess 8 four of the six items almost are in Hanauer's division.
I 9 don't know what higher management focus could be given.
10 MB. KNEIL:
I would agree with that.
My 11 discussion is basically in terms of what our experien'ce has 12 been in the past.
13 COMMISSIONER HENDRIEs I agree with you,
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14 pa rticula rly while over the years we have had many of these 15 generic tasks and in'the line branches they do tend to get 16 shoved aside as more pressing things get in, but for items 1711ke these, operating procedures, control room design or, 1elet's go back to the first one, long-term upgrading of 19 training ani qualifications of operating personnel, if it 20were a USI and you had a guy who was the task manager on it, 21 he would primarily be monitoring and nagging people, i
22 presumably in Hanauer's crowd, the operator training and 23 qualification s crowd, saying get on with it and so on.
/
24 MR. NNEIL:
There are two ways --
\\
COMMISSIONER HENDRIE: Each of these things, each I
25 I
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l ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W. WASHINGTON, D.C. 20024 (202) 554 2345
26 1of these items that are from the Action Plan and are 2 proposed as USIs, are fairly big pieces of stuff.
3 MR. KNEIL:
That is cutt =vt.
4 COMMISSIONER HENDRIEs It is not as though a 5 single task manager in your branch is able to make a 6 substantial impression on the job by his own personal 7 efforts in doing the work. The value is more in the 8 monitoring and the keeping up to date on progress and 9 whistlin g when progress seems to bog down.
10 MR. KNEIL:
That is not totally true.
The 11 managers we have now are not just program managers; they are 12 technical managers, and to a certain extent, that is the 13 philosophy I think we intend to follow. In other words, we
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14will move people in and out of the branch in terms of their technical interests and" capabilities in a specific USI.
In 15 16 other words, they are not just program managers; they are 17 people who are technically either competent or strongly 18 interested in a particular area that a USI addresses.
19 CHAIRMAN AHEARNE:
Keeping with tha t, it might be 20 en tirely possible that these three are on the list to have 21 managers in Hanauer 's branch.
MR. KNEIL:
I would think that is a management 22 decision.
23 CHAIdMAN AHEAENE:
Yes.
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24 COMMISSIONER HENDEII:
Furthermore, when you get 25 l
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27 1 one like long-term upgrading of training and qualifications 2 of operating personnel, and you have a whole branch chief 3 over in Hanauer's crowd who has that specifically as, if not 4 his only, at least his major enterprise, so I don't --can S one of your task managers be the manager of something which 6seems to require at least a branch and maybe more elsewhere?
7 CHAIRMAN AHEARNE:
I think Ed wants to --
8 MR. CASE:, I am not disagreeing with the direction g you are going, but one thing you perhaps ought to appreciate 10 1s one of the jobs in this task was considering licensing of 11 maintenance personnel, people who are not now licensed 12 operators, to upgrade them and consider this other subject.
13 I would dare say that if the task were in Karl's
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14 g rou p, what would you do about presently nonlicensed 15 operators would get higher priority than it would get in 16 Hanauer's group because he sees the need for upgrading the 17 qualifications of existing pbople.
He has a big job to do.
18 And beyond tha) he.has license cases that are dependent on 19 his output.
20 So that is the kind of difference that gets 21 1nvolved in this management style.
CHAIRMAN AHEARNE:
I think I had better give Peter 22 i
4 23a ch ance to comment on this because I at last have to give 24 Karl and Ray and Ed a chance to debate these other three
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251ssues.
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l 28 1
COMMISSIONER BRADFORD:
Okay.
I won't take long j
2on this one.
I would keep any issue that we felt was, in 3f act, an unresolved safety issue, I would keep that on the 4210 list as well as the TMI -- I would leave it in the 5 Action Plan and I would keep it on the list.
One thing, I 6 don't think that the Action Plan will necessarily carry 7 forward into the future, say, for three or four or five 87 ears in the same way that the unresolved safety issue list gvill.
10 And as the Action Plan loses its sense of being a 11 whole separate document, we would then have in the future 12 either to pick these things up and make them unresolved 13 saf ety issues or to con tin ue to sort of carry them in some i
14 sepa rate account.
15 For another, I am not sure that the Congress, in 16 requirin g a list of unresolved safety issues, would --
17 gran ted we could explain it in a letter to them or 18 some thing, but would consider it fully consistent with what 19 they had in mind if we had issues that we considered to meet 20 all the earmarks of being USIs but we were not including l
21 them in the 210 report on the basis they were off on some 22other list somewhere.
what I would CHAIR %AN AHEARNE:
Let me turn to 23 I
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24 11ke, Ed, is.you to give your argument why you did not
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25 accept first Karl's and then Ray's points, and then give i
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9 29 1them a chance to comment on that.
2 ER. CASES Karl, why don't you do that?
3 MR. KNEIL:
The ACES suggestions first. They 4 proposed three additions: DC power supply reliability, 5 single-failure criterion, and control system reliability.
6In the first place, we agree that all these are subjects of 7 merit and importance, and the question asked whether or not 8you are making them an unresolved safety issue hinges on 9their present status and their a ttractability.
10 For DC power system reliability, we have'a 11 contractor report that has been written and which two drafts 12have been reviewed -- it is being done by Peactor Safety 1G and which we will have a draf t that has the safety
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14 management blessing available for the ACFS review by about 15 November 15.
16
'de feel that since this study has been done, it is 17 important to focus on what the results of the study are 18before we make it a USI or consider making it a USI. The 19 single-f ailure criterion --
CHAIRMAN AHEARNE:
Ray, would you like to comment 20 21 on t h at ?
MR. FRALEY:
Well, I think you are aware in the 22 Committee's report, they felt that important safety issues l
23 i
24 sh ould be on the list whether they were going to be resolved
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1n six months or not.
The timing they did not think was an 25 ALDER $oN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHtNGTON, o.C. 20024 (202) 554 2345
6 30 1
1 appropriate criteria.
So, the fact that this is probably 2 going to be resolved within the next few months was not 3 persuasive.
4 They do consider this -- and just let me say that 5this issue was first raised early in 1977, and the staff in 6'78 did do a probabilistic assessment, W ASH-1400 kind of 7probabilistic assessment, which was not, you know, 8 dispositive, and agreed that at least one more year's work 9 was necessary.
That is now going to be forthcoming, I 10 guess, in the Sandia report.
it I should not really speak for the Committee, but 12 the Committee doubts that this will be dispositive of the 13 1ssue even now or when it comes out in November, and that
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14 this is an important safety issue. There are many incidents 15where the DC power supply has been degraded.
One of them, 18 1n fact, resulted in a fire at a nuclear plant in an 17 emergency diesel engine in the generator, and tha t these 18 re presen t enouah precursors so that this should be getting gg fixed, not studied.
20 I think there are a long list of these precursors, 21 1f you will, that are enough to say we really need to take a 22 good look at this.
In fact, it is my understanding that 23some utilities have fixed their DC power supplies without
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24 benefit of changes in the ACES requirements, because when it 25 surf aced, they realized there were some problems with those ALDERSoN REPORTING COMPANY. INC, C
400 VIRGINIA AVE., S.W WASHINGTON D.C. 20024 (202) 554 2345
31 1 systems and they went ahead and did improve their 2 reliability.
3 But we have not yet seen fit to change our 4 requirements.
5 CHAIRMAN AHEARNE:
Any other comments on the DC 6 power supply?
Okay, the next one.
7 MR. KNEIL The next suggested addition was the 8 single-f ailure crite rion, and I think Mr. Case covered t ha t,.
9the gist of my answer on tha t ea rlier ef f ectively.
We 10 believe that we should look at systems and determine in 11 which systems the single-f ailure criterion is not adequate 12to provide the degree of assurance we require.
And when we 13have identified those systems, then we can procead to make
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what we should do on those systems as USIs.
14 --
15 As a matter of fact, one of the proposed USIs does 16 follow this even without the benefit of IREP.
The 17 perception is at the noment that the a'uxiliary feedwater 18 systems and the requirement for integrity in the steam 19 generators and integrity in the primary loop for natural 20 circulation may not be adequate even with the single-failure 21 criterion, being adequate to assure decay heat removal.
22 So, one of the USIs we have is one to explore 23 alternate ways of decay heat removal.
So that is exactly 24 the kind of USI that we would expect to fall out of the IREP
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32 1 various plants and various designs.
2 CHAIRMAN AHEARNE:
Ray.
3 MR. FPALEY I think, again, the members I have 4 talked to feel the IREP studies will contribute to a better 5 understanding of this problem, but they do not think they Swill resolve it, for the following reasons.
The IREP study 7 1s limited in scope.- It only looks at 11 plants, not 8necessarily all of the designs that we need to worry about.
9 We may miss a couple of very critical designs in the IREP 10 studies.
11 Number two, it is not optimized, really, to look 12at this kind of a f ailure, and by the various assumptions 13 you make and the criteria that you establish, you may miss
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14 this kind of thing or at least de-emphasize it.
15 And third, they don't think the IEEP studies have 16 a high enough priority, the same priority that should be 17 associated with this particular item, and that it should be 18 given higher priority, this particular aspect. So, although 19 the IEEP studies may help in this area, they feel it 20 warrants high priority attention as a separate item 21 optimized with respect to this matter.
22 CHAIRMAN AHEARNE4 Does anybody else have any 23 comm en ts ?
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24 MR. KNEIL:
I could comment a little bit further 25on that.
To me the single-failure criterion is a nice
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33 1 thin g.
It sort of falls out of systems analysis.
If you do 2 analyses on lots of systems, you find that you are 3 single-f ailure proof.
You find out you increase reliability 1
4 on those systems very significantly.
5 I see no reason to believe and really no promise f
6 to show that some kind of further general analysis will come 7out with some kind of general criterion that you can then i
8 reapply further to assure that additional reliability is 9 achieved in a system.
10 MR. CASE:
In other words, it does not look like a s
11 couble-f ailure criteria is the answer.
There may be places 12where a single-f ailure criterion is not good enough and you 13 substitute in specific areas rather than develop some i
14overall criteria.
15 3R. FRALEY:
I think in fact that is true that you 16 may want to supplement it, not necessarily abandon it.
B-17for example, common mode failures -- the single-failure 18 criteria has provided systems that are really pretty good, 19so that it is now the ccamon mode f ailure that is i
20 controlling in many cases, but we don 't analyze that.
21 The analysis of ATWS showed that, that when you 22do, you know, a single-failure random mode analysis, the 23 systems are just swell. When you do a common mode failure, 24 they are not anywhere near that good and they need to be
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25 fixed.
The single-failure criteria does not require common
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O 34 1 failure mode analysis.
2 COMMISSIONER GILINSKYs The issue would be, then, 3 where does the single-f ailure criteria need to be 4 su pplemented.
S MR. FRALEY:
That-is really the issue.
)
6 COMMISSIONER BR?.0 FORDS Except to thesextent I 7 guess you are talking about the conditions in the operating 8 plants.
What you would really be stating is the generic 9 safety issua is -- I guess it is the backfit half of the 1
10 proposition you stated s that is, where has the 1
11 single-f ailure _ approach led to inadequacies, and what 12 changes need to be madh?
)
l 13 MR. FRALEY Well, I think we are finding all of 34 the time tha t systems that et Lt.ought were reliable enough 15 rec 11y aren't reliable enough.
I mean the aux 131ary 16feedwater system --
17 C3MMISSIONER BRADFORD I understand that.
All I 18am saying is from the point of view of whether or not this l
l 1915 really an unresolved safety issue, I don't think anyone l
20would say tha't simply the abstract matter of reformulating 21 the single-f ailure criterion was -- it met the standards of l
22an unresolved safety issue. To put it in terms of its l
23 forward-backward distinction, to pick up the backward half
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24 of it, what you are really asking is what is there in the 25 plants that is different from what it should 11 as a result I
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35 1of the single-failure criterion analysis.
That would seen 2 to me to be the unreso.'.ved safety issue part of the 3 single-f ailure question.
4 MS. FRALEY:
Well, I think we are finding that 5some of the systems in existing plants are not good enough.
l l
6They were designed to the single-failure criteria, but we 7are now determining that they are not really good enough.
8 We need to take another look at them with some other 9 Criteria to supplemen t them.
10 COMMISSIONER HENDRIE:
In that case I don't e
11 under stand --
12 MR. KNEIL:
IREP will identify those systems where 13 su p plem e nta ry fixes are necessary.
There is no promise of a
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14 general kind of fix, I do not think.
I think it is going to 1S be specific.
l 16 CHAIREAN AHEARNE:
I think that perhaps the most 17 -- i s it fair to say that the more important issue you are 18 r aising, the ACES does not think enough resource priority is 19 going to IREP?
20 MR. FRALEY:
Well, I think they think that IREP is 21 su pposed to solve a lot of problems for us but it is not 22necessarily optimized to look at any one. This is important 23enough to have a study that is optimized in this regard.
24 COMMISSIONER HENDRIE:
But where would it lead?
I
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2Scannot understand what the Committee wants out of this. The N.
ALDERSoN REPORTING COMPANY,INC, 400 VIRGINtA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
O 36 1 only way you are going to advance from the single-f ailure 2 criterion, which is a very useful shorthand method for 3 improving the reliability of systems, the only way you are 4 going to do better than that is to go over to a full-blown S risk assessment in which you take account of all manner ef 6 things and in all manner of combinations.
7 We have already started on that in the IRE?
8 program. Now, if the Committee wants to say, why, you ought sto have 3000 people doing IREP on every' plant, they can say 10 that, but they know perfectly well it is not practical.
So 11 I cannot see what a study of the single-failure criteria 12 Would produre other than the perfectly obvious opposition 13 that you ougnt to go ahead and look at these plants on a 14 risk assessment basis the way we are doing through IREP and 15 the follow-on programs and try to identify the high-risk 16 sequ ences which ought to be knocked down and pulled down in 17 pr o b ability.
18 COMMISSIONER GILINSKYs Let's see.
Is it trua 19 that the alternative to applying the single-failure 20 criterion is to do a full-blown analysis?
It seems to ne 21 that COMMISSIONER HENDPIE:
Once you go past the 22 23 single-f ailure and say, well, how about a two-failure 24 crit eria.
COMMISSIONER GILINSKY:
Well, that is not what 25
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l ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554-2345
37 1they are saying.
I mean it seems to me that they are asking 2 the thing be looked at from a certain point of view, I mean 3not just doing a grant analysis, but really looking around 4 at it by intuition and their own experience and so on.
5 COMMISSIONER HENDRIE:
I am saying we are doing 6 that, and I cannot understand what it is further they will 7 achieve.
8 COMMISSIONER GILINSKY:
It sounds as if IREP is a 9 rather grander effort which takes account of '-- well, 10 approaches the problem on a broad f ront.
11 MR. FRALEY:
But only for a limited number of 12 plan t designs.
13 COMMISSIONER GILINSKY.
Well, still.
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14 COMMISSIONER HENDRIE:
An initial cut.
i 15 COMMISSIONER GILINSKYs It is a prettf grand 16 effort which is not likely to move alon: ver y ra pidly, and I 17am just trying to put my own interpretation on the 18 suggestion here. It may well be that if we asked the 194' estion precisely and orient ourselves toward trying to 20 identify places based on our experience, based on judgment, 21 based on intuition where the single-failure criterion may 22Well need to be' suppleme nted, a more selective a pproach may 23 produce important results in a shorter time scale.
COMMTSSIONER HENDRIEs I do not think so because
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24 25the only way you do it short of the quantitative analysis of I
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O 38 1 risk assessment is just on the basis of individual staff 2 members ' gut judgments, and then what you will get, they are 3 highly sele tive judgments in which you will be fixing some 4 -- because some staff members' internals feel that way, we
-7 5 will be spending resources to fix some 10 per unit per
-3 Syear problem and ignoring 10 per unit year problems.
7 It is precisely that difficulty which the risk 8assesscent methodolocy gives you a way to handle and to deal 9 with those things.
You come to the outliers, the high risk 10 elem ents first.
11 C3MMISSIONER GILINSKY:
Intuition, judgment and so 12 on.
I think I did not mean that you fix the requirements on 13 the basis of just feeling, but that you try to identify the
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14 problems and areas for limited analyses on that bases.
I 15 m e an we talk about methodology. We are just trying to talk 16 about getting more quantitative about the risks, and it is 17not as if we are talking about electrodynamics or some i
18 met hodology. We are just trying to use all kinds of ways to 19 0 et more quantitativ8 and to identify the risks better.
20 As I hear the difference here -- and correct me if 21 I am wrong, Ray -- en the one hand we are being asked to 22 su pp ort an approach that advances on a broad front and is 9
23 bound to advance slowly, and I think it is something we do 24 w a nt to support and are supporting.
But it may well be that 25a kind of analytical scouting operation may end up gaining a ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
39 1 very large f raction of what is eventually going to be gained 2 by this army advancing forward a step at a t ime.
3 CHAIEMAN AHEARNE:
Probably more of a platoon.
4 MR. FRALEY:
I think the Committee has certainly 5 supported probabilistic assessment. They are one of its most l
6 staunch supporters.
But I think if you look at the history yof ATWS, you find that sometimes v do in the meantime have 8to make some deterministic decisions because the technology I
i 9 dust has not been developed to the point where you can do r
10 things quickly.
11 I think, you know, that was shown in the ATWS case.
12 CHAIRMAN AHEARNE:
Let us move on to the control 13 system reliability.
14 MR. KNEIL:
In the case of control system s
15 reliability, it was an issue that we focused on.
The ACRS, 16 I think --
17 CHAIRMAN AHEARNEs You agreed with it.
l 18 MR. KNEIL:
They put a new slant on it, and we l
19 thought that that raised its significance to the point where 20we should adopt it.
l 21 CHAIRMAN AHEARNEa Okay.
Now, they mentioned that 22 reliability of nonsystem information is an impcrtant issue, 23 and your comment is that further study 24 MR. KNEIL:
Yes, we agree that should be an item 25for further study, put that in that category.
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ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554-2345
0 40 1
CHAIRMAN AHEARNE:
Are you disagreeing with the reliability of nonsafety system information, as 2 concept that 3 far as the issue itself, do you disagree that it is 4important?
5 MR. KNEILs No.
6 ER. CASE:
I think he means further study for 7 possible inclusion as a USI.
8 ER. KNEIL:
Correct.
9 CHAIRMAN AHEARNE:.It is possible to read your 10 comment that you were not really sure that might be a 11 pro blem.
12 MR. KNEIL:
It is our fault in putting it in an 13 ambiguous way.
I 14 CH AIR AN AHEARNE:
Okay. Now, obviously you could 15 dredge up some recent history.
16 (Laughter.)k 17 CHAIRcAN AHEARNEs Any other comments on control 18 system reliability?
Did they adequately address your 19 concerns?
20 MR. FRALEY:
As I understand it,.they have 21 adequately addressed them.
CHAIEMAJ AHEARNE:
Nov let's move into AEOD's 22 23 co mm ents.
(
24 MR. KNEIL:
The way we underst ad it, they had two 25 1tems that deserved f urther studies rather than they believe
! (.
1 ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
41 1 should be USIs at this stage, and those items were safety 2 implications of steam generator transients and accidents and 3 piping and use of highly combust ible gases, and we agreed 4 that they were items suitable for further study for possible S inclusion as USIs.
6 (At 11:14 a.m.,
Commissioner Bradf ord exited the 7 hearing roca.)
8 CHAIRM.AN AHEARNE:
Carl, were you saying that they ashould study them or were you suggesting they go on the list?
10 ER. F.ICHAELSON:
I was suggesting that they go on 3:che list, really, after looking to see whether they might 12already be covered by an item on the list.
If not, then I ethought they would belong there.
We probably did not
(
14 articulate adequately 'on the question of combustible gases.
15Unfortunately, I cited it only as an example of what was 16 really the unresolved safety issue, and that is how we treat 17nonsafety grade equipment relative to postulations of 18 failure, when the failure can occur, and finally, failure ig ef f e ct s.
20 For instance, the hydrogen piping is 21 nons eismically qualified generally.
It may or may not have 22saf ety grade isola tion.
It may not and probably does not 23have safety grade relief detection.
And, of course, the
/
24 pcssibility of hydrogen entering the building af ter a 25 seismic event sight lead o some serious challenge in safety k.
ALDERSoN REPORTING COMPANY,INC,
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400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554 2346
42 1 grade equipment.
2 So really, the issue is not just hydrogen per se 3but rather how you treat nonseismically-qualified equipment, 4 and it is a generic issue, in my opinion, the reasons being 5that we do not have regulatory guidance concerning how you 6 postulate how nonqualified equipment fails during an 7 earthquake.
8 For instance, do you postulate all of it fails, a 9 certain f raction of it f ails or none of it fails?
COMMISSIONNRGILINSKY:
When you say how you treat 10 11 1t in a safety analysis?
12 MR. MICHAELSON:
In a safety analysis we 13 concentrate on the mitigating equipment and make sure it
(
14 ride s through the earthquake. We do not look at the 15 no n q ualified equipment to see if it were to fail in 16 combin ation.
It could then lead to effects on safety grade 17 equi p m en t.
We do look at this equipment from the viewpoint 18cf postulating that at any point in time, any one device can 19 f ail, even nonsaf ety, and we look to some extent to be sure 20it cannot thereby affect safety-related equipment.
21 But we are dealing now with several of these 22 events occur ng simultaneously, the question is how many.
CHAIRMAN AHEARNE:
I am a little confused, Carl, 23
(
24 1n the sense that you had suggested that specific 25 description you had just mad e, a t least during an earthquake
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o ALDERSON REPORTING COMPANY. INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
D 43 1being incorporated into something else. Now are you saying 2 that in addition, that the failure of the 3nonseismically qualified equipment not during an earthquake 4ought to be then a separate 5
MR. MICHAELSON:
No, no.
Cnly the unresolved 6 aspect of the, nonqualified equipment, I believe, is only 7whe..
ammonly challenged, like during an earthquake.
Its 8 f ailure singly is generally considered, I think, in terms of 9 pipe treik analysis and this sort of thing. But if you were 10 to experience an earthquake, then you ask how many of these 11 postulated f ailures do I assume?
12 CHAIRMAN AHEARNE:
Didn't you say that that aspect 13 would be done under the seismic qualifications?
(
14 MR. ANEIL:
Yes, we said we would include that, 15yes.
16 MR. MICHAELSON:
You know, that is what I think.
17 If it is not there, then I think it is unresolved; if
.t i-18 there --
19 CHAIRMAN AHEARNE.
I think what they said is ther 20will make sure that the task is so written to make sure that 21 1s there.
22 MR. MICHAELSON:
That is correct.
COMMISSIONER GILINSKYs Are you saying this is 23 l
li 24 only a problem during seismic events?
It is not a problem 251n other cases?
k ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
- o un 1
MB. MICHAELSON:
It is, to my knowledge, one of 2 the few common challenges to all equipment simultaneously, 3and therefore how does it or does it even fail when shaken, 4 as opposed to challanging only a piece of equipment locally, Slike with a local explosion or local fire or wha tever?
The 6 earthquake challenges all equipment at the same time.
What 7 do you assume about the failure since it is not qualified 8 for the challenge?
That is the unresolved issue.
9 I think it can readily be covered by the present 10 1ssue. Our only effort here was to make sure it was, and 11 then rela tive to the hydrogen line, much of the problem is 12 the seismic, but not all of it.
In the case of combustible 13 cases, there is also the question of less of off-site power 14 1f you already have an existino hydrogen leak which you have 15not detected and the reason is that you have a large amount 16 of building ventilation which carries it away and rakes it 17 un de tectible.
18 If you suddenly lost off-site power, then the leak jgproceeds to accumulate'and precipitates an explosion in an 20 area where the vital equipment is located.
l 21 COMMISSIONER GILINShY:
Which hydrogen are you i
l 22 talking about?
l l
23 MR. MICHAELSON:
Sakeup tanks, this sort of
(
24 thing.
It is generally on the order of one-inch pipe, but t
25 1t is fed by a ltrge tank, hydrogen bottles out in the
(
ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE. S.W., WASHINGTON, D.C 20024 (202) 554 2345
45 1 field, and it has to deliver varying flows since it is 2 generally a batch process of filling tanks and so forth.
So 3you cannot put excess flow limitation on it or that sort of 4 thing very readily.
5 The best you can do is.put good detection in the 6 building to take care of possible leaks and put good 7 isolation, hopefully safety grade.Jolation.
The 8 difficulty, thoughe is that a leak little less than, say, sfull flow cannot be isolated by flow indication since it is 10 a normal condition.
It can only be. detected by leak 11 detection devices, and they may iso t even be powered during 12 the loss of off-site power, in which case you do not even 13 know that you should isolate until af ter, perhaps, it is too
(
14 1 ate.
15 (At 11:20 s.m., Commissioner Bradf ord entered the 16 hearing room.)
17 CHAIRMAN AHEARNE:
Ed?
18 MR. CASE:'
We will be looking at this further.
19 E. GEORGE:
If I might add to that, the reason we 20had tha t iten down on further study is because it is our 21 un derstand*. q that the fire protection reviewers have been 22 ooking at the combustible lines.
One item that was pointed 1
23 ou t in a meno from AEOD was that this concern with the
/
24 detection devices that they may not be qualified is 25somethi.s that we felt needed further looking into because ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
46 1 we understand that the fire protection reviewers were 2 considering this issue.
And maybe the criteria need a 311ttle refining, so we are not sure at this time that you 4 need to make it a separ ate issue.
5 MR. MICHAELSON:
In retrospect, if that were the Sonly issue, I would probably not make it unresolved.
It is 7 certainly resolvable. It is unresolved only in that 8 presently there are not requirements to do something.
9 CHAIRMAN AHEARNE:
It sounds like it is a problem 10 that could be solved, but we have to make sure that someone 11 1s looking at it and solving it.
12 MR. MICHAELSON:
Yes.
Therefore, the study period 13 1s a perfectly goed resolution.
r
(
COMMISSIONER GILINSKY:
Following on your earlier 14 15 1 tem on safety-related equipment, is there so.ne general 16 ef fo rt to redraw that boundary between safety-related and 17nonsafety-related in the wake of our experience?
18 MR. CASE:
Do you know, Hank?
3R. GEORGE:
There is an item in the TMI Action gg i
20 Plan which is to expand the QA list, and it is considering i
l 21 addressing just what additional items may neea be added to 22the Q list, or maybe certain functions for those items need 23 to be added to the Q list. But again, as it is indicated in
/
24 the Action Plan as to provide reasonable recuirements in 25 that area, it really needs to rely on some ongoing studies, ALDERSoN REPORTING COMP /NY,INC.
400 VIRGINIA AVE, S.W., WASHINGTON. D.C. 20024 (202) 554-2345
47 1 particula rly IREP, to identify what nonsafety systems you 2may wani to pick up in that category.
3 There is one area, however, which was this issue 4 we were considering adding, and that is -
proposing to add 5 safety implications of control systems because of existing 6 experience, that that is a nonsafety-related area that more 7 attention needs to-be given to them.
8 COMMISSIONER GILINSKY Let ne underctand more gclearly.
What is this effort on r0 defining the list of 10 items or equipment that is subject to OA, which is 11 equivalent to the saf ety-related designa tion, is that not 12 true?
13 MR. GEORGE:
That is correct.
(
14 COMMISSIONER GILINSKY What doet that effort 15 consist of ?
16 MR. GEORGE:
That offort is going to primarily 17 follow on after IREP.
18 C3MMIFSIONER GILIESKYs Is there anything 19 happening now?
20 MR. GEORGE:
Carl is shaking his head no. I 21 believed there were some ongoing ef f orts right now to 22 mprove some of the GA criteria, and with respect to that i
23 ma y pick up some nonsafety -- a t least wh-t have been u
24 considered nonsafety in the past that are actually parts of
\\.
25some currently recognized safety systems. So there may be l
ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE, S.W., WASHINGTON, D.C. 20024 (202) 554-2345
48 1some improvement there: as an example, perhaps, instrument 2 air systems.
3 But the longer-term effort in expanding tha t list,
4 we will wait on IREP.
5 COMMISSIONER GILINSKY:
When is IREP supposed to 6get to the point where you can get useful information for 7 this O A list? '
8 MR. GEORGE:
The schedule in the Action Plan for 9 starting work on this QA list was about two years.
10 COMMISSIONER GILINSKY:
Two years from now?
11 MR. GEORGE:
A year and a half from now.
12 COM5ISSIONER GILINSKY:
It seems like kind of a 13 1ong time.
CHA[RMAN AHEARNE:
I think that is what we ought 14 15 to cov?r toda y.
16 C3" MISSION ER GILIN SKYS I was raising it in 17 context of this list. I feel this is something that ought to 18 be on the list.
Go ahead.
19 CHAIRMAN AHEARNE:
I think the more important ones 20 are included.
21 COMMISSIONER GILINSKY:
When you draw the 22 boundaries, some things are included and some are excluded.
23 CHAIRMAN AHEARNE:
The approach we have been 24 taking is to try to identify what items ought to be 25 2ncluded.
I think IREP is aimed 7.t :;te explicit items.
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49 1
COMMISSIONER GILINSKYs I am not sure I 2 unde rsta n d, but why don't we go ahead.
3 CRAIRMAN AHEARNE:
Carl, your last item. Ccald you 4 explain to me what a differential expansion effect to th e 5 steam generator is?.
6 MR. MICHAELSON:
Yes, I certainly can.
I did not
'kn >w we started discussing that item yet.
7 1
1 8
CHAIRMAN AHEARNE:
That is the last item.
9 MR. MICHAELSONs No, but I mean had we talked 10 abou t the steam generator transients already?
11 CHAIRMAN AHEARNE:
This is embedded in that whole 12 --
13 MR. tICHAELSON:
The differential expansion
(
14 problem is that which results when having overfilled a 4
15once-through steam generator.
In the process of l
Severfilling, you cool the tubing much quicker than you cool 17 the shells, because the shell is a massive piece of metal, i
[
18and this all happens in about a minute. So the tubes cool i
19 very quickly.
The shell does not cool quickly.
So the 20 tubes end up a few inches shorter than the shell, so they 21 hve to stretch.
22 The question then is is that stretch uniform, 23which is the way. you usually analyze it, or is it 24 con cen tra ted where there is a defect in the tubing or 25 developing defect in the tubing.
That is one of the l
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ALDER $oN REPORTING COMPANY. INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
e 50 1 potential problems in worrying about steam generator 2 overfill.
3 CHAIRMAN AHEARNE:
Carl, you do not wish to e
4 include this steam generator transient on the unresolved 5 safety issue list.
6 MR. KNEIL:
Not at this time. '4e would add it to 7 the list f or f urther study.
8 CHAIRMAN AHEARNE:
Could you say why you don't gthink it is appropriate to add it now?
10 MR. KNEIL:
Okay.
I guess it is my view that he 11 really was not proposing to add it.
I guess I was confused 12as to what the proposal was.
13 MR. F.ICHAELSON:
I think I listed two items 2cr 14 addition and two items for thought.
This was one of the two 1 tem s fo r addition".
15 16 CHAIRMAN AHEARNE:
Yes.
17 MR. GEORGE:
I guess it was our understanding that 18 this was one of the two items fcr consideration. Mr.
19 0rnstein indicated that was correct.
He was not trying to 20 say how this fit in with overall risk contribution 21considering all the other issues.
He felt it was an l
22important issue.
It had not been considered before.
It 23should be thrown in tne hopper and consideration given as to 24 making it a USI.
25 MR. MICHAELSON:
I think that is a correct i t l
ALDERSoN REPORTING COMPANY,INC, I
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51 1 statement, the intention being that you people consider it 2and then decide is it or isn 't it, and you decided it wasn't.
3 MR. GEORGE:
Well, I think --
4 MR. CASE:
It needed further study, particularly 5 th e risk aspects, the risk-benefits, before we could decide.
6 MR. "ICHAELSON:
My one concern on this issue, of 7 course, is it is not a new one.
This has been articulated 8since ACRS days. It has been going on for two years now, you sknow, and yet the progress seems to be going slowly.
There 10 has certainly been adequate time to consider it one way or 11 the other, and it is not like something out of the blue.
12There is considerable documentation behind the problem, 13 including ACRS letters.
(
14 COMMISSIONER HENDRIE:
What is the field 15 expe rience, first of all; and second of all, what does B.CW 16 sa y about it?
Obviously, it is an operating condition ther 17 :ad to consider in the design of the once-through 1
18 g e ne ra tors; and furthermore, it is a condition where in fact 19 we have carried out this experiment.
20 MR. MICHAELSON:
I think we are now talking about 21 the total problen of. a transient and not just the 22 differential expansion effects as only one nanifestation of the transient.
The transient as a whole, we have had two 23 24recent experiences in which they were both fortunately at 25 estinghouse plants, which do have a high level trip on the W
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ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
52 1 steam generator, even though it is not safety grade.
2 In both cases the feedwater system failed in the 3 wide open valve position, which filled the generator very 4 quickly and reached a high level trip.
The transient was 5 terminated and nothing bad happened. The problem, of course, Sis if you do not have a high level trip.
7 Now, how does this get terminated?
Well, it has 8 to be by operator action, and very quick operator action, at 9that.
Combustion plants, some have high level trips, some 10 don't, depending on customer preference.
11 BCW plants do not have high level trips. You fill 12the generator in about a minute.
If you do not terminate 13 1t, the water pours down the main steam lines.
It pours i
14 1nto the auxiliary feedwater turbines. It causes hydraulic 15 steam hammers.
It could be a very devastating event.
It is 16 mu ch worse, I think, for a once-through steam. generator.
17 So, we have had experiences but we have not yet 18had experiences wherein there was not a high level trip. I 19 have not searched all the ancient history to see what other 20close calls occurred. The one I do recall, though, is the i
21 Rancho Seco " light bulb" affair where one of the things they 22 thought was happening was they were close to overfillino 23 their steam generator, but they do not believe they actually 24 did, but the f ailure there was in running back the generator 25 and using auxiliary feedwater to overfill for a longer l
l ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024.(202) 554-2346
e 53 1 period of time.
2 The problem here is a direct filling by the full 3 valve wide open position of main feedwater, which is very 4 fast.
It involves a lot of complication.
There are a 5 somber of things you get into..besides steam hammers.
You 60et into the problem of the steam lines not being designed 7to accommodate the water, the weight of the water.
8 Normally when you want to fill a steam line you 9 pin the hangars first to take away the water. I do not think 10 that would necessarily knock the lines down, 'however, but in 11 conj unction, the weight in conjunction-with steam hammer 12 ef fects could.
The auxiliary feedwater system clearly would 13 be lost.
You cannot run water down the main auxiliary
(
14 feedwater system and expect the turbine to continue to 15 function.
16 The question of isolating the main steam lines 17 un de r this water condition, the main steam line isolation w.ignal may come later when the water is already running down 19 the main steam lines.
Now, what effect does that have on ability to 20 21 clos e main steam i'. olation valves?
There is a primary side 22cooldown ef f ect.
You are ra pidly cooling the primary side from filling the secondary side with cold water.
I 23
'here is a further problem, and that is if you get r
24 the water in the main steam lines and cpen the safeties as a 25 ALDERSoN REPORTING COMPANY,INC, i
400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
54
~
1 consequence, which is highly likely under these conditions, 2 you now start blowing down the secondary side just after you 3 cool down the primary side considerably already from the 4 cold water addition.
So it is a further nuclear transient.
5 These basically are unanalyzed events, and the 6 unresolved safety issue says, then, let's analyze them, 7 1et's find out which are real, which are imaginary; let's 8get on with fixing them.
9 There is a further consideration of what happens 10if a steam tube ruptures under the circumstance.
Again, we 11 have differential expansion, we have steam hammer effects 12 and so f orth. If you rupture a tube, now we have a combined 13 primary / secondary side blowdown.
Where is the analysis? How
(
14 do we know how to handle it?
15 Then you get into the question of, well, where are 16 the opera ting precedures?
What is the operator to do if 17 this ever happens?
What is next?
These are kind of 18 opera tin g procedures which might be classified as unresolved ggsafety issues. They are procedures for very unusual 20 circumstances.
21 Presently there are not procedures for these very 22 unusual combination of circumstances, and yet the 23 prob ability of that happening, I think, is quite high. The 24 eq uipmen t involved has already aven demonstrated to fail 25 this way, and it is only a question of when it will happen
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55 1 where. they do not have a high level t ri p.
2 CHAIRMAN AHEARNE:
I guess what I would like to 3do, unless I get significant opposition to this, is to first 4 ask NRR to come back shortly, in the next week, now that you 5 recognize Carl has really proposed adding that, give us your 6 comments on that.
I would like Hanrahan to go around to the 7 Commissioners to see if he cannot pull together positions.
8 At least for myself, I have to think through some gof the more fundamental questions which relate to the issues 10 we were talking about at the beginning, what is the whole 11 purpose of this document that goes out?
12 CO.*MISSIONER GIIINSKY:
Could I ask a question?
6 13 MR. MICHAElSON:
One other point that should be
(
14made on this whole transient situation on stean generators, 15 and that is much of the equipment that is causing all this 16 to happen is nonsafety grade equipment, of course.
This is 17 the main feedwater control system.
And also associated with 181t is the depressurization system of ten put offstream will 19be mainstream isolation valves, which is also nonqualified.
20 Now you cet into the question, well, what do you I
21 assume about all of this if there is an earthquake?
It is a l
22 ve ry valid question, the behavior of this system under l
23 seismic conditions.
You can create these feedwater 24 transients also during an earthquake at a time when you are 25really not prepared to handle this kind of an event.
(
l l
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56 1
MR. FRALEY4 Mr. Chairman.
2 COMMISSIONER GILINSKYs Go ahead, Ray.
3 MB. FRALEY:
Mr. Bender has arrived.
He is really 4 here for this af ternoon 's session,
Maybe if you would like Sa member, he could answer 2nur questions.
6 CHAIRMAN AHEARNE:
Mike?
7 MR. BENDER:
I had a quick briefing.
I don't 8 think I have anything to add, but if you would like to have ga Committee member's opinion on anything, I am here to 10 respond.
11 CHAIRMAN AHEARNE:
Okay.
12 COMMISSIONER GILINSKY:
Why isn't the question of 13 dealing with hydrogen in the containments an unresolved 14 safety issue or proposed to be an unresolved saf ety issue?
15 CHAIRMAN AREARNEs Ed.
16 MR. CASE:
In the sense it is included in degraded 17 co re.
18 COMMISSIONER GILINSKY:
I read that section. The 19 wo rd " hydrogen" does not appear.
20 MR. HANRAHAN:
My staff had prepared me for a 21 backup position.
The only one we had seen was hydrogen i
l 22 control in small containments.
l MR. GEORGE: I believe we did discuss this at the 23 1ast Commission meeting, and as we indicated, it was f
24 25 inadvertently omitted out of the SECY paper, the specific
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ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
i:
57 1 reference to it.
However, we do say that this item relates 2 to II.B.8 out of the TMI Action Plan.
3 COMMISSIONER GILINSKY4 The reference in there --
j 4
MR. GEORGE:
It does spefifically i
5 CHAIRMAN AHEARNE:
We are supposed to change that
^
6 1n the description.
7 MR. GEOR;E:
Yes.
Kell, what we committed to was athat in the Commission -- or in the report to Congress, we guill add those words.
10 CCMMISSIONER GIII;iSKY:
What words, George, that 11 this does include consideration of the adequacy of hydrogen 12 requirement, hydrogen control?
13 MR. CASE:
We will make it clear.
14 CHAIRf.AN AHEARNE:
As best I can recall, the issue 15 at the tin.e was they would propose those words to see 16whether or not that satisfied --
COMMISSIONER GILINSKY:
I just wanted to see if 17 18everybody remembered.
(Lauchter.)
19 CHAIRMAN AHEARNE:
All right.
20 21 Anything further?
All richt.
We will use that moment of silence, 22 23 then, to move this group away.
Thank you.
24 (Whereupon, at 11:27 a.m.,
the meeting was 25 concluded. )
k ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
4 6
i l
l MUCLEAR REGULATORY CNC4ISSION i
This is 00 certify tha; the a, ached proceecir.gs before the l
in the matter Of:
DISCUSSION OF SECY-80-325-UNRESOLVED SAFETY ISSUES l
Date of Proceeding:
October 16, 1980 Docket Nucber:
Place of Proceeding: Washington, D.
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