ML20024A455
| ML20024A455 | |
| Person / Time | |
|---|---|
| Issue date: | 06/10/1983 |
| From: | Advisory Committee on Reactor Safeguards |
| To: | |
| References | |
| ACRS-T-1221, NUDOCS 8306170322 | |
| Download: ML20024A455 (93) | |
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UNITED STATES OF AMERICA
-h NUCLEAR REGULATORY COMMISSION i'
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In the matter of:
ADVISORY CO+1ITIEE ON BF1CIOR SAFEGUARDS
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278th General Meetiny Docket No.
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256 - 349 Location: Washington, D.C.
Pages:
Date: Friday, June 10,1983 I.
3 TAYLOE ASSOCIATES Court Reporters 1625 i Street, N.W. Suite 1004 Washington, D.C. 20006 8306170322 830610 (202 293 3m PDR ACRS T-1221 PDR
Whitlock TA-228 1
UNITED STATES OF AMERICA 256 NUCLEAR REGULATORY COMMISSION tV 3
4 ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 5
278th General Meeting 6
7 8
Room 1046 1717 H Street, N.W.
9 Washington, D.C.
10 Friday, June 10, 1983 11 12 The 278th General Meeting of the Advisory 13 Committee on Reactor Safeguards convened at 9:00 a.m.
14 in open session, Jeremiah Ray, Chairman of the Full 15 Committee, presiding.
16 PRESENT'FOR THE ACRS:
g 17 J.
RAY 7
J.
EBERSOLE 18 J. MARK y
C.
SIESS j
19 R. AXTMANN g
D. MOELLER g
20 W. KERR j
M.
CARBON 21 H.
ETHERINGTON
.i F.
REMICK l
22 D. WARD D.
OKRENT 23 C. MICHELSON P.
SHEWMON
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24 H.
LEMIS I -
25 N. SCHWARTZ-Staff Engineer
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AUDIENCE PARTICIPANTS:
2-V. STELLO 3
H. DENTON
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R. MATTSON 5
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PROCEEDINGS 2
MR. RAY:
The next item on the agenda is a presenta-3 tion by Mr. Harold Denton, the Director of NRR.
4 MR. DENTON:
Good morning, Mr. Chairman.
I'm glad 5
to see you back.
8 I'd like to talk about four interrelated aspects, 7
four topics that have interrelation, the SEP program, the
~
8 IREP program, the NREP program, and PRAs in general.
8 And I think it is a topic in which it would be 10 useful for me to go back into history a little bit and summar-11 ize where these programs come from and discuss with you where 12 we think we ought to go in this area.
13 Let me start with the SEP program.
14 You know the general status of~the SEP program and 15 have seen a lot of every one of the plants that have come 16 through and made a lot of constructive and useful suggestions 17 on each of those.
l l
18 You may recall that the program began in 1977, and 19 the object was to review the 10 oldest operating reactors against current licensing criteria to see how well they com-(
21 plied with today's criteria.
22 It also provided the Staff a-basis for converting 23 those old provisional operating licenses to full-term M
licenses.
There were at least seven of those ten that only u./
26 had provisional operating licenses and, in fact, today are
259 BWjl 1:2 I
operating with provisional operating licenses.
t 2
The issues with regard to the SEP program are as follows:
We have completed the objective for Phase II, with 5
the exception of San Onofre.
San Onofre 1 is still -- we are 6
still deciding how to approach the seismic design of the plant.
7 Another issue to keep in mind is the FY '83 8
authorization bill, where the Commission and Congress are to 9
review the results of SEP Phase II before any decision is made 10 to continue with the program.
- 11 Two of the plants that we reviewed did go to PRAs.
12 Big Rock Point is doing an integrated assessment, which has
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( j expanded to involve all of the safety issues and all pending 14 actions between the company and NRC.
So, we can take an 15 integrated approach to reviewing that plan and deciding which 16 changes, if any, need to be made.
If you look at the results of the SEP program, what 18 you find are numerous safety improvements.
There have been 19 l
improvements -- plant-specific' improvements --
which have
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t 20 affected the entire industry.
I will just give you some l
21 examples.
22 In the hardware area, for example, you may recall
'xx improvements from the anchorage and structural integrity for 24
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electrical components, battery system status indication, k_)i 25 better safe shutdown systems, structural upgrading.
t
BWjl 1:3 260 1
There were a number of upgrading improvements in
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2 the procedural area --if you look across at the eight or nine 3
that you have seen so far that you have seen so far, improved 4
emergency procedures for safe shutdown, better testing of 5
reactor detector systems, AC systems, improved understanding 8
of the use of nonsafety systems for safety systems.
7 We also tightened up the tech specs in a number of 8
those plants.
There are a number of cngoing actions to be 8
done.
10 I am scheduled to give the EDO recommendations and
+ 11 views on this within the next 30 days or so.
And the 12 Commission is scheduled to make a decision about what to do
(
13 with the future of the SEP program in the last quarter of I
l 14 fiscal '83.
15
[
Now, let me go to the IREP program, which is closely l
16 tied in.
l 17 IREPs were conducted on five plants, Crystal River 18 3, Arkansas 1, Browns Ferry 1, Calvert Cliffs 1 and Millstone 19 1,
20 You may recall the purposes of that were to test 21 the development of the methodology, try out that methodology 22 against various plant systems and containments and train E
l the staff in how to conduct and review PRAs.
24 The current status of that program is there have C's 25 been four studies completed, Crystal River, Browns Ferry, i
e
s onjt 1:,
261 1
Browns Ferry and Arkansas 1.
They have been coordinated with 2
the Licensees, and a number of actions have been taken by the 3
Staff on the dominant accident contributors.
4 As a result of those, Calvert Cliffs'is the one 5
remaining study, and that is expected to be finished in the 6
fall of this year.
7 So, the issue there is to what extent should this 8
kind of an approach be continued in the future.
8 Let me go next to the NREP program.
The NREP pro-10 gram was devised as a result of TMI.
It was an extension of 11 IREP.
12 We did issue a draft Procedures Guide in September 13
)
of '82 for public comment that laid out how to do NREP type 14 reviews.
15 And we told the Commission the decision regarding 16 the initiation of NREP or continuation of some kind of program 17 would be made this fiscal year.
18 The present schedule for publishing a final proced-19 ures guide is targeted for -- September of
'83.
E Another issues you are well aware of is PRA in 21 general.
A number of plants have completed PRAs.
But let's 22 go back to WASH-1400.
There were two plants studied, Surry 1 23 and 2 and Peach Bottom 2 and 3 -- add iri the NREP plants for 24 another five.
25 Within the SEP program, there were three plants
BWjl 1:5 262 I
where the owner has elected to do PRAs, Yankee, Big Rock Point D)
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2 and Millstone.
3 And then I have ordered or.otherwise directed some 4
studies to be done at high population sites, such as Indian 5
Point's 2 and,3, Zion's 1 and 2, Limerick 1 and 2, and Millstone 3.
And those PRAs are underway.
7 There are some plants that have PRAs completed, also.
Take the RSSMAP program, Grand Gulf, Oconee 3, Sequoyah 1, and Calvert Cliffs 1.
10 And then there were a number of plants which elected,
- 11 on their own, to do PRAs, and they are underway at various 12 stages -- Shoreham, Midland, Seabrook, Browns Ferry, Oconee,
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3 Nine Mile, Susquehanna, Oyster Creek, TMI-1, all of the 14 Commonwealth plants -- includes Dresden, Quad Cities, Byron 15 and Braidwood.
16 And tied into this is our CP/ML rule, in which we 17 require PRAs to be done for new plants.
18 We moved on that rule'withethe floating plant, GESSAR, and Westinghouse.
20 If you look at these four programs, the question is 21 where do we go from here?
What would make sense to do to 22 integrate these programs?
23 The first question I think we need to answer 24 clearly -- and I think this is where the Committee can play g
1
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25 a big role -- is with regard to the usefulness and direction
BWjl 1:6 263 1
of PRA.
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2 I think the Committee has sent some conflicting 3
signals on how valuable PRA is and how it should be used.
4 Thereiis a lot going on.
5 We are moving, in many areas, to use PRA more and 6
more.
7 The general code
-- it has identfied strengths and 8
weaknesses of plant design.
It is very useful in supplement-8 ing judgments for need for corrective actions, it helps in 10 deciding priorities on generic issues, it is a good way to 11 a
educate utilities in the risk management program, and it is 12 very good for operator training purposes.
You get lots of
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13 good insights, even if you don't agree with the numbers that
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15 Bon 2?
The cons about big scales, PRAs, such as the NREP 16 program, are cost and time.
There are few trained specialists.
17 There is a lot of difficulty in handling external events --
18 for example, a lot of uncertainty in the '. nan program.
l 19 The SEP program has resulted in safer plants.
It r
20 j
has improved CFP in not only the plants we looked at but i
21 other plants.
i 22 The con of the program is that not all issues have i
23 been addressed.
We did not look at USIs, we did not look at 24 TMI. It is a common complaint that it took too long, and it
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25 is not cost-efficient.
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1 BWjl 1:7 264 j
1 So, the task before us then for the Staff is what
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2 do we do with these topics, and how do we proceed'from here?
3 What I would like to do is give you my preliminary 4
thoughts on this matter.and the basis for them.
5 Basically, I want to discontinue SEP Phase III and 6
NREP.
I want to do it a different way.
7 What I think I am going to propose to the Commission 8
is to integrate the best aspects of the lessons learned from 8
SEP, IREP, NREP, PRA2, into a new follow-on program.
And 10 this program would address all regulatory issues when we
- 11 look at a plant, and that would include all of the issues 12 flowing from TMI, all of the unresolved safety issues, all
()
13 of the SEP Phase II issues, and all of the outstanding 14 operator actions on that particular plant.
15 We would look at a plant not in isolation, but when 16 we look at where the changes are needed and if so, it would 17 end 1 be based by a team looking at the total view of that plant.
18 19 20 l-21 22 23 i
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26 l
265 bw21bl 1
We would use PRA and deterministic methods.
We f
i 2
are still bound today to use deterministic methods for the 3
first cut and then look at PRA to supplement our judgment.
4 I do not.want to get into posture, at'this time, of having 5
PRAs to dominate and have people say just because the PRA's 6
showing this there's no need to look.
I think we still need 7
to look using the deterministic method that the SEP program 8
started.
The product of this would be a prioritized schedule 9
'for the Licensee action after we have looked at a particular
[
10 plant, decided what changes -- if any -- need to be made,
- 11 conclude that it would meet today.'s standards provided the 12 following actions are taken, come up with an integrated schedule 13 where they do certain things during the first outage and the 14 second outage and third outage, and in effect wrap up and f
15 complete a review of that plant against all outstanding possible 3
l 16 issues that we know of.
In effect, we would have a completely 17 reviewed plant and put to bed the issues that we can.
This
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18 would resolve TMI Action Plan,. Item-II, C.2,.which is'still.
19 outstanding.
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g 20 The kind of program I see would be one where we would
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21 take a six or seven plant group, and do a group a year, and try l
22 to work through those.
That is the kind of level that I am 23 now budgeted for, for our own internal resources.
It is over 24 30 people a year to carry out this kind of*a program.
It would 26 cost industry something.
Those that have PRAs would probably m
m
bw21b2 266 1
spend on the order of $2 million per plant.
Those that don't 2
have PRAs', in this group, would spend 2 million plus, whatever 3
a PRA would cost them to do.
4 The SEPR's group generally supports this kind of 5
a broader integrated assessment.
I think it would result in 6
lower overall cost of the utility for us to take this total 7
integrated look, and it would resolve these safety issues that 8
have not been handled as an integrated concept.-
And I think 9
it would build up our Staff expertise and the utility expertise 10 and understanding of plant.
So, in a broad overview, that is
- 11 the kind of program that I think we are going to come up with 12 and propose to the EDO and the Commission.
I think it is a 13 very timely time for you to look at that kind of program.
14 I understand Bill Russell is coming down next month to brief 15 you on the details of it.
- j 16 The real key is what are the issues and how much O
l 17 should we put PRA in, how do we make decis_ ions?
I would like I
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18 to get a program that was well-defined and we knew what we h
19 were going to do and then allocate resources and go do it and 5
f 20 not turn it into a Christmas tree to try t'o have it developed
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21 and refined in technology that ought to be done on some other s
l 22 track.
There are a lot of safety issues that this kind of a 23 program cannot handle.
There are ones that it can handle that 24 I would like to approach.
G 26 MR. SIESS:
Harold, to clarify, can you explain a
+
i bw21b3 267 1
more how this will differ from SEP Phase II?
You said you O
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2 started off by saying that you did not want to continue SEP, 3
but --
4 MR. DENTON:
One of the main differences, SEP 5
was narrower.
6 MR. SIESS:
Completeness, but you have the Big Rock, 7
which is an odd ball.
8 MR. DENTON:
We did not require PRAs in the SEP 9
and it was catch as catch can using surrogates.
We did not 10 have plant specific SEPs.
- 11 MR.SIESS:
There were significant features of 12 SEP that I think became apparent to us, and certainly to the
-( )
13 utilities.
And I think some of the things they pointed out v
14 when the did endorse a continuation was one, the way in which 15 it was managed and the authority that was vested in the SEP
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16 people to make decisions at less than the strict regulatory 0l 17 level, make exceptions, and for the integration.
And the 1
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18 other was a familiarity with the particular plant that was 19
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gained by the SEP reviewers.
Now, would these be features of G
20 the extended program?
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21 MR. DENTON:
I think tha t observation was not 3
f 22 unique to industry.
We agree with those.
The SEP program 23 floundered for a long time and I think what we learned from 24 i
f"'s that was by having -- if you are able to dedicate resources t
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v 25 to a plant you can get a better resolution of issues that fit
268 bw21b4
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I that plant.
When we deal with issue by issue and not plant
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2 by plant, we put everyone on a procrustean bed and either 3
stretch or lob off to make them fit the scheme.
It is more 4
resource intensive to do it plant by plant.
You have to be 5
careful about not biting off more ambitious program than we 6
can actually manage when we do a plant by plant.
7 MR. SIESS:
It has been my impression that the 8
benefits certainly are commensurate with the additional cost.
9 and resources for the public and the utilities.
10 MR. DENTON:
The plants are so different in
- 11 detail and design.
In other words, we often think up new 12 rules and guides and approaches assuming there is some nominal
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13 plant in mind.
When you really go out and look at the whole v
14 population they differ all over the map in detail.
The generic 15 solution that we come up with, often is not an ideal solution U
16 for any particular plant.
17 MR. EBERSOLE:
I have long been_ convinced that i
Ij 18 PRA, even though the answers come out funny, is the only way 8
19 to integrate the plant, the safety considerations, system I
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20 interactions, and a host of other things into an integral
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21 pickage that is manageable.
I, for one, would endorse your 3
fg 22 program with great enthusiasm.
23 MR. OKRENT:
What would be the division of labor if g-s one followed the proposal you have just outlined, Harold?
24 O
25 For example, would the Licensee have full responsibility for
269 bw21b5 1
the PRA?
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MR. DENTON:
Some of the details, I guess, I will 3
have to leave to Bill, assuming that this kind of a program 4
gets endorsed.
I am for getting more responsibility to the 5
Licensee rather than us doing it.
I think to have the 6
Licensee do the PRA, as Cordell Reed has said, has a lot 7
of benefits in itself.
It does not help in real space for us 8
to do a PRA on a plant if the Licensee does not put his heart 9
in it and really learn from it, and that kind of thing.
I 10 think the basic thrust of it would be that both the review
- 11 against the existing criteria, as was done in the SEP program, 12 and to do the PRA would be done by the Licensee.
Our job
}
13 would be to test it and make sure it was reliable and probative 14 MR. OKRENT:
That would be consistent with what 15 the ACRS has recommended concerning future PRAs.
We urge that 4
l 16 not only that the Licensee be responsible, but that he be 0
17 principal in the technical work and not just farm it out in 3
18 very large part to one or another, consulting firms.
I 18 MR. DENTON:
The first group of plants, in order
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I 20 r
to get this program moving and keep it moving, would be to pick 21 plants that already have PRAs.
So, the first group that we turn f
22 to would be the ones that have existing PRAs where this concept 23 would go.
I tipped off some types of people that would be 24
(~N included in that and, in fact, even in the. Group II proposal 25 we can get a large number of the Group II plants that would hav e end t 2 existing PRAs of different quality.
1 7_..,.
v_.-.... _ _. _., _.. _
bw31bl 270 1
MR. MARK:
You said to pick plants that already 2
have PRAs.
How many of them have been done, mainly by the s
3 plant organization itself, and how many have, as Dave pointed 4
out, been farmed out to SII or somebody or other?
5 MR. DENTON:
I don't know the answer to that.
A 6
lot of them have been farmed out.
I did find, in the Zion 7
one for example, toward the later stages you get the companies 8
more and more involved and some companies started them with 8
more involvement that others.
Maybe someone here might have 10 a guess at how much the companies were involved, I don't know
- 11 that right off the top.
I was told it was less than half, 12 probably, have had a really major involvement of the company.
13 MR. REMICK:
I agree with what Jesse said in support!--
ting the concept.
I guess I still don't quite understand,..
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4 15 l
what criteria you use for which plants.
Would the people who 4j 16 j
have been in SEP II, would they be forced to undergo this I
again or would it be just plants initiallywwho do have existing 18 PRAs?
And then I go on one step further, would this require I8 rulemaking?
If people did not volunteer and you wanted it to E
2 20 l
r be conducted this would be a new rule, with follow-on rulemaking.
21 to enable you to require PRAs?
MR. DENTON:
On the first question, we have got 23 to go back to the SEP Phase II plants, anyway, to pick up these 24 USIs and TMI items, so we would not have tb repeat the 2.
deterministic agreements that have already been reached.
But
bw31b2 271 3
1 in order to really integrate the plant together, we would have N_,
2 to do something on those.
I do not see this program going 3
back to those in any full scale sense, except Big Rock Point, where they already adopted this integrated approach.
<u 5
=I don't know whether it would require rulemaking or 6
not.
We did not issue any special rules when we kicked off 7
the SEP program, but in view of Congress' interest we would 8
certainly have to go back to them and explain the objective 9
of the program.
10 MR. KERR:
Certainly the intergrated approach you
- 11 suggest appeals to me, and it seems to appeal to you.
In what 12 you said, I gather you would plan to have every plant do a
)
PRA, fairly complete one, eventually if this were carried 14 through.
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MR. DENTON:
I would not go so far to say as every v
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16 plant in the U.S..
I kind of see a program of, over the next b
17 2
few years, of doing as I said, six or seven plants a year for 18 g
about three years and then reassess the situation.
At some a
p 19 g
point in time, we may learn enough about the actual status of 20 all plants to reconsider so I would not be, at this time, E
21 j
proposing every plant have a PRA.
22 f
MR. KERR:
In the course of the PRA, it seems to 23 me among other things, the results that one gets are likely to
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24
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depend very strongly on what assumption on'e makes about source 25 term.
Is it anticipated that this will be begun more or less
272 bw31b3 1
using existing approaches to source terms, and then as better O
D' 2
information becomes available, this might be factored into the 3
picture?
Or have you gone far enough in the detailed conside-4 ration to have looked at that?
5 MR. DENTON:
I think the source term is realized 6
by everyone to be important.
Since it is uncertain, we would 7
pose to kick it off by using the existing.
In fact, we have 8
considered doing it both ways.
You could do an analysis with 8
today's source term and you can make some assumption about 10 source term and see if it affected it.
In many of the
- 11 Commission's present rules, they are deterministic anyway.
12 The PRA allows you to judge on how important that issue is.
13 MR. OKRENT:
Actually, one or more of the PRAs v
14 have adjusted the source term using their own subjective 15 judgment, so not every one is used in what I would call the
- j 16 WASH 1400 source term in estimating their results.
f 17 MR. KERR:
One of the things that has been talked Ir 18 about has been our consideration of source term is what 18
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significant change in source term would do to emergency E
planning, and while the emergency planning rule is deterministm i
21 we are told, I think, that the basis for the deterministic f
22 requirements was results that came from a study like WASH 23 1400 in which one looked at the extent to which serious 24 consequences would occur.
p) 25 In that sense, it seems to me, a different source
273 Ew31b4 1
term could have an influence on a number of things which f~%
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2 presently appear to be deterministic but have have as a basis 3
a PRA type analysis.
4 MR. OKRENT:
I don't disagree with the comment, 5
but I myself would tend.to disassociate a study on emergency 6
planning and whether what is now required should be modified 7
in view of new knowledge from the program, that Harold outlined.
8 That would be my own approach.
As part of that, you are 9
going to start bringing some probabilistic questions into 10 your judgment.
At what probability do you decide that I do
- 11 not need to plan, and so forth.
12 MR. DENTON:
I think, to some extent, that problem 13 will be dealt with by the Commission through rulemaking.
In
)
14 other words, if, based on the new source term, they change h
15 their emergency planning requirements, that would be a change 2,
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16 that would affect all plants.
It would be tough to handle f
17 in the kind of program I envision.
E 18 MR. OKRENT:
If I could get to the question, it I
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19 was not clear, from your comment, whether you envisaged trying n
l 20 to get best effort, reasonably full scope, PRAs, or PRAs with
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21 only internal events, for example, which is what we have 22 in RSSMAP and IREP.
Do you have'any comment in that area?
23 MR. DENTON:
I do not know the answer to that, yet.
24 The Division of Engineering is still dubiq,us about their abiliQq to bound external events and keep telling me how difficult thel'
./
25
274 bw31b5 1
whole area is.
I think that is an issue we should settle
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2 before kicking off such a program.
And, in fact, we ought 3
to try to define what kind of PRAs would be done so that we 4
don't end up with products which are -- which were unacceptable.
5 We need to say, is it internal only, is it internal and erbumak,.,
6 how far does it go, what is in it?
So, if you kick a program 7
it requires something to come in a year and a half, people will 8
know exactly what to do.
This question needs to be settled 9
before we move into it, and I don't have a view today.
There 10 are strong feelings in the Staff both ways, that you just
- 11 cannot get reliable external indicators.
We have had disxmsiorm i
12 on that before.
Other people feel it is very useful to do.
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13 We got them in Indian Point, to some extent.
Because of the 14 results, we made certain changes at Indian Point.
You may 15 read the GAO report that came down and criticized the PRA k
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6 l
16 in general at Indian Point.
17 MR. OKRENT:
I have seen the GA_O report except a
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18 reference to it in one of the weekly newsletters, so I hope 2
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19 our. office is getting it out to the members.
I must confess, 5
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l 20 in case it is not clear, I certainly have an opinion and that 1
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21 is not to try to do, what I will call, a best effort.
That l
l 22 means, best effort at the present time.
It may be two years j
i 23 j
later you can do something considerably better, but if you 24 don't try to do something, let's say, along the lines of what f-sv N,)
25 was done inside at Indian Point on external events I think i
275 bw31b6 1
the basis for judgment on a variety of things may be not D
(V 2
only incomplete but biased, in an unfortunate way.
And 3
although I am the first one to argue that there will be very 4
big uncertainties in these studies, I still think they are 5
doable in a kind of way and the provide, frequently, a consider-6 able amount of insight.
7 I would urge that you not stay down the old road.
8 MR. DENTON:
In our thinking, if we go to the plants 9
with existing PRAs we would get a mixed bag.
If we include 10 Zion, for example, in that Group I they already have external
- 11 events.
Some other group might?not have it.
We have not had 12 it in most of the SEP plants that we have looked at, and have 13 had to rely on expert engineering judgment in a lot of those 14 areas.
15 MR. OKRENT:
It can be added at a fraction, let's
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16 say, of the cost of the full PRA if you wish to.
It is not o
17 that it is incompatible.
18 MR. DENTON:
I think that is a question of science.
18 If we can do it, and the results can be relied upon, we 1
20 l
probably should decide that in advance.
If it gets done and r
l 21 no one is going to use the results, then we probably should j
22 not kick it off until the methodology runs and improves.
That would be a good issue to try to decide before we got that l
23 24
)
specific with this program.
J y
MR. OKRENT:
I don't know what you mean by the word
276-bw31b7 l
1
" rely upon".
That is a word that is a little awkward to use
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on almost any part of PRA.
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277 bw41bl 1
MR. SIESS:
I am getting a little disturbed by a
()
discussion that suggests that the success of an SEP review will 2
3 depend 90 percent on having plant specific external event 4
complete PRAs.
I don't think the Phase II showed that the 5
SEP type thing is that fully dependent on having the PRA.
If 6
SEP Phase III is going deteriorate into a basis for getting 7
PRAs out of plants I do not think it is going to do what 8
you expect.
9 MR. DENTON:
There is obviously a difference of 10 opinion in the Committee in that area.
The Staff has several 11 views.
I think it would be a good one to --
12 MR. SIESS:
Having PRAs is a good idea for a number 13 of reasons.
I am not sure that they are that essential to
]
14 the SEP type of review for a great many of the decisions that h
15 have to be made.
There are some that were not made that would l
16 have been helpful.
Let me bring up another point.
I think f
17 it is interesting that we have gotten this_far in a decision 1
18 of an SEP type review without the word backfitting even being r
i g
19 heard.
That may be because SEP Phase II really did not get I
i i
l 20 into required backfits where the backfit rule had to be
{
21 invoked.
There was a lot of backfitting done without, let's 5
l 22 say, overt coercion by the Staff and certainly without any 23 action by the Commission under the backfit rule.
24 Now that, I think, is strictly a function of how t
M5 that SEP was carried out.
And can it be continued on that basis?
278 bw41b2 1
MR. DENTON:
I think both the Staff and the utili-
/%.
U 2
' ties credit it worked out that way.
They were able to 3
resolve the technical differences and came to a common view 4
on what needed to be done.
5 MR. SIESS:
My question is do we know why it 6
worked that well and can we be reasonably sure that the 7
extended program will have that same characteristic?
I think 8
it was very desirable, very important.
9 MR. DENTON:
I do not think you can be sure.
I 10 think reason was, over the six year history of that program,
- 11 people eventually came to see more or less eye to eye on the 12 major parts of the plan.
We did not see eye to eye for the 13 first couple of years.
%J 14 MR. SIESS:
I understand that program a lot better 15 if I forget about the first couple of years --
4j 16 (Laughter.)
o 17
-- except to figure out how not to do it._ That certainly was
{
18 wrong.
19 g
MR. EBERSOLE:
Harold, having endorsed the program i;
E overall, let me pull back now a little bit.
21 (Laughter.)
f 22 A lot of the work in the PRAs have to do with 23 hypothesizing cascades of different pipes which throw the 24 plant into duress of various forms, pipes break, etc., etc.
p) 25 I think we have a practince, in the PRAs, of using a sort of
279 bw41b3 1
average number for the reliability of equipment under ordinary d
2 circumstances, not under conditions of duress and overload such 3
as hydrodynamic loads, exposure to horrible environmental 4
conditions,.etc.
So.I think a great deal of qualification has 5
to be put in a study of some routine as to whether environ-6 mentally qualified piece of apparatus is, in fact, capable 7
under the circumstances that it faces.
I do not think 8
attention has been given to the probability of even non-opera-9 tion of certain equipment because of inability to test.
10 MR. DENTON:
I think we are getting into how you
- 11 do a PRA and what is a good one.
I think it would be important I had envisioned the NREP guid that we published in September 12/
13 would be,the basis.
I don't think you can expect a program like 14 this, which has got to be done by large numbers of people, to h
15 really be the cutting edge of technology.
It may be very n
Y!
16 important questions, and maybe they should be funded by f
17 research, or done by EPRI or somebody, but_I think what we 3
18 need to do here is define what a PRA, for this purpose, will I.
19 consist of and then have people go do it because of the time g
1 20 scale it takes to go do it.
Whereas, I think if you take the g
{
21 very first utility and expect'to make him a model you will 5
l 22 solve the difficulties of the PRAs once and for all.
You 23 would never get the program going.
I think to some extent I 24 see the best being the enemy of the good and we ought to say gb 25 what do we know how to do and where do you think it is
280
~bw41b4 1
reasonable to say them?
And that would be used in the program 2
and then save the question areas --
3
.MR. ' EBERSOLE :
I would pick a case in point, to 4
use average valve reliabilities when that is obtained by 5
simply exercising valves from one point to another, without 6
loads on them.
Under normal circumstances it is hardly a 7
database.
8 MR. DENTON:
I think some Committee attention to j
9 what PRA should and should not have -- when I say rely upon, 10 that is the wrong word -- I am still not regulating relying 11 on PRAs.
I am relying on the Commission's rules and determini-12 stic regulations.
I used PRA results to help make judgments
()
13 and I would propose this integrated program, that it still 14 be the same way that up until some revolution takes place -
9 E
15 in the field, we will follow the Commission's' regulations k
el 16 as the base line.
h 17 I don't propose today to know how to answer what ij 18 the data -- the right database -- is.
It would seem like we 19 should agree on the composition of the PRA for these plants and g
h N
tell the utilities that we have elected to participate in this y
f
{
21 program.
Here are the elements of your PRA, go do it and l
22 come back, and you come back in one year, come back in eighteen 23 months, come back in two years kind of thing.
24 MR. RAY:
Dr. Remick?
25 MR. REMICK:
Chet raised an interesting point when l
l l
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281 bw41b5 1
raised the question about backfitting.
It is my understanding 2
the Commission is in the last stages o'f word engineering a 3
Staff Requirement Memo on how the Staff should implement 4
51.09, and if that would go out near the form _it is in now it 5
would encourage Licensees to dig in their heels and differ 6
with the Staff from time to time on questions of backfitting.
7 It seems to me it would be extremely important when you 8
develop this plan and take it to the Commission that you 9
address how you would handle the Staff Requirements Memo 10 and 51.09.
I think it would be very important to let
- 11 Licensees know.
Otherwise, there would be tremendous 12 confusion if you go out with a Staff Requirements Memo that h
13 is currently going to be sent to Licensees and it says one
%J 14 thing,.and then you come along with an integrated program like f
15 this and do not address the backfitting issue.
I think it
?
{
16 will lead to a lot of confusion out in the field.
[
f 17 MR. DENTON:
As a result of thi_s program we would l
5 18 be in better shape, when it came time to decide the backfit, l
{
i 19 whereas here we hve all of the data available, all of the l
5 l
20 information.
The kind of approach the Commission has, I think,
{
21 on a plant specific backfit that the Staff wants to do is l
I 22 that we would propose, to the utility, that we want to make 23 this change and here are the reasons why.
He would have a l
24 chance to indicate back to the Staff why i$ was not the proper 25 thing or was not required and there would be appeals, meetings, l
282 bw41b6 1
1 and we would eventually do a cost effect study and use all
\\
2 of the tools we have got before final decision.
3 I think in a' sense, this. program.would provide a 4
basis for making those decisions at the end, under the kind 5'
of backfitting approach that the Commission takes, namely 6
that before you do it be sure that you have a thoroughly 7
documented and had given all parties a chance to participate 8
in the decision.
9 MR. REMICK:
I agree.
Th'e point I was trying to 10 make is that I think it is important that you stress whatever 11 you propose that that new means'of implementing S1.09 would 12 be in effect'so people knew, so there would not be a misunder-13 standing that this is something outside of 51.09.
The only 14 other way I can see you can do it would be you would have 15 to have a specific rulemaking to enable you to enforce those 16 backfittings.
I might be wrong on that.
f 17 MR. RAY:
Dr. Okrent?
i 18 MR. OKRENT:
I wonder if I could shift the subject 18 slightly, since Vic Stello and Harold Denton are both here.
D l
20 I am trying to understand the status of the Systems Interaction 21 Prograrh,. and the extent to which CRGR is involved in whether e
l 22 there is a pr gram and what its form should be, and what its 23 pay should be.
There are some memos that were written from 2
Stello to Denton, January 26th, 1982 and then August 19, 1982 V
25 from Denton to Stello, s
,w,-
283 bw41b7 1
As I read them, they suggest there was sort of a l_
( /
2 hiatus, perhaps, introduced for some extended period of time, m-3 and whatever the St'ff had in mind, with regard to systems a
4 interactions.
I wonder if anybody could educate me on, first, 5
what was going on and where things stand.
6 MR. DENTON:
First off, there was a professional 7
differing opinion on the system interaction.
We had a 8
witness in Shoreham who withdrew his testimony and provided 9
other testimony.
It is being handled within the Staff as a 10 differing professional opinion and I have sat down, named
- 11 someone to do a review and report back to me on his conclusions.
12 It does not involve CRGR at all.
I have never proposed a
,.~
(O) 13 resolution of system interaction to that group.
14 Basically, the reason the program is not moving, h
15 we have not been able to decide what a good system interaction 16 approach is.
I recounted to the Commission, a couple of months ol 17 the interaction we had with the Committee over the years
- ago, 3j 18 about the early 4-A in Watts Bar.
They found that technology ea 19
[
was not good enough.
Then we moved into Indian Point.
Indian EO g
20 Point is doing one.
I have authorized the Staff to try the 21 other two methods using the same database as we have got at 3
l 22 Indian Point.
If I ever get an indication of what system 23 interactions worth may be, is it going to find anything for 24 (3
all of the money it costs, and what kind of methodology can
~
25 you use.
I will be prepared to move forward with a program.
284 bw41b8 1
It has been my decision and not one of CRGR, the systems (3
g,/
2 interaction people.
At least one person wanted to move forward 3
on all. plants, right now, and I just could not understand 4
what the program was and what its benefits would be and 5
what would be.
t 6
We are now funding two laboratores to use the same 7
27 volumes of information, or so, that Indian Point has 8
collected up, and use the other two techniques identified.
9 And when the results become available, I will look at the 10 results of three different ways to go and if some of them 11 make good technical sense I will propose to move along.
12 MR. OKRENT:
I guess when I read this memo from
(}
13 Stello to Denton -- and let me just quote from it to give the 14 flavor.
It says "I believe the CRGR should be involved in h
15 determining the future course of action on the System Interac-2yj 16 tion Program.
Please prepare a briefing for the CRGR and f
17 the Systems Interaction Program to address _at least the 9
18 following:
the definition of a need for systems interaction, r
i g
19 as distinct from other reliability and risk assessment programs i
l 20 such as IREP, NREP and the Reliability Engineering Programs
{
21 articulated in NUREG 0660, a brief description of each step l
22 in a typical system interaction analysis, the final product, 23 and how that product will be used, whether plant specific 24 system interaction analysis could be used to focus direct or a
26 otherwise help to manage the scope of the detailed quantitative i
285 bw41b9 1
PRA on that same plant, the need to pursue system interaction 2
as a separate program level activity rather than as a systematic 3
first step in the conduct of each plant specific PRA that 4
might be undertaken, whether a thorough system interaction 5
analysis could identify a method of plant specific residual 6
risk and the necessity on a a risk reduction versus cost 7
basis for further detailed PRA on that plant."
8 I could read, there are a few more.
I think that 8
is enough to give the flavor.
I must say my first reaction 10 to this was that is the kind of set of questions I would write 11 if I wanted to style something from really reappearing.
- Also, 12 I think some of the questions are not very sound technically, 13 in the sense that to expect that system interaction could 14 obviate the necessity for further detailed PRA, to me does f
15 not make sense.
So, I have problems in two different ways 18 with this memo.
But then later, you know August, you said o
17 I decided not to pursue the systems interaction pilot program 2
18 and things were then presumably, waiting for whatever you 18 were going to do in your NREP proposal, that we are talking E
ar7ut now.
21 The system interaction program began back in '74, 22 at least from the point of view of the ACRS.
When we wrote 23 end t 4 the Staff, after about three years, the Staff began to respond 24 and to identify some action in here.
V 25
BW5 rgl 286 1
I really do not understand a question concerning whether or 2
not there have been what I will call ' interesting
- things" 3
found via the system's interaction process.
I think Mr.
4 Ebersole could cite from his own experience things that he 5
has found on points that he has looked at.
6 And, in fact, as you and I well know, Diablo Can-7 yon, they found seismic types of things and other plants have 8
found things.
I am just disturbed, partly by, I would say, 8
what seems to be an inappropriate delay in the program by --
10 for any reason.
- 11 As Itsaid before;.I think this set of questions is 12 not the kind of set of questions to ask for, I think what has Q
13 already been a USI.
I guess I am trying to understand what D
14 is going on.
15 MR. DENTON:
Vic can speak for himself about the 16 memo, but let me tell you what is going on from my standpoint.
17 I review the USIs and try to move them all and get t
18 technical resolution, and it has been very difficult to pin 19 down how to resolve this USI question on system interaction.
It is a lofty goal, and if someone could come up with a 21 methodology that they could tell me would work so I could l
22 know what I am imposing on somebody when I am imposing a':
23 system interaction study., It appears that the only one that 24 has gotten ACRS acceptance is Indian Point.
That is about
'%)
26 one million dollars.they have gone through, as I understand i
BWS rg2 287 1
it, and have compiled 27 volumes of some such information.
3 They are finding very little with regard to the 3
interaction of systems that was not known. They have reported, 4
I think, one finding with the dependency of one system on 5
another.
6 They are finding spa tial relationships, because in 7
each room they look at things that might impinge on something 8
else.
9 I did not think it was -- the system was well 10 enough developed to impose that study on everybody until I
- 11 could at least see the results from this, which is reputed l
12 to be the best system interaction study done.
I was also 18 told there were at least two other approaches to system inter-14 action.
Nobody could produce a scholarly study or publication 15 in the ANS or any technical report that said this-is~how"the5 16 system works und has been found to work.
17 I do not disagree with the ob{ective.
It is trying 18 to get something comparable to a NREP handbook, so that we 19 can agree on what it is on how do we find thihgs that:we do 30 not otherwise know about.
21 So the present state is, we are spending consider-22 able NRC money to supplement the Indian Point study using the l
l 23 same database, and I would hope then that out of that maybe l
24 one of these three techniques might really be worthwhile.
-s V
36 Otherwise, I do not know how to go tell someone to go off and I
-e
, - - ~ - -.
.y__
288 3WS rg3 2
1 do good.
)
And if ~it comes back, the only approach I know that 2
a you and the Staff have endorsed has been the Indian Point one, 4
which is incomplete to date.
I think it is premature to a
launch that on -- until we know its payoff and how practical 6
and how revealing it might be. It it finds a lot of things 7
very good, iE will show it is practical.
But for myself I e
just did not think -- it is also very hard to distinguish-s that from PRA when a good PRA in my view should have identi-10 fied the interactions between systems.
Not spat ial inter-
- 11 action but system dependencies.
12 So, we have had these kinds of discussions in-house 13 and I would think that some time in the near future when the
)
,f 14 Indian Point system interaction study is complete, the 15 Livermore method is complete, and the Brookhaven. method, that l
to way we will have spent maybe three million dollars on one j
17 plant.
And then maybe we can decide from that which of those 18 three methods we ought to go forward with.
19 MR. RAY:
I would like to wind up the discussion.
30 MR. OKRENT:
Just one or two more minutes, please.
21 I guess -- I doubt'in my own mind that there is a perfect 22 method and so I have a feeling like the Staff is hunting for 23 something that is not there when it says we are going to se study these three different methods and see which is the right SS one.
~.. -
BW5 rg4 289 1
Let me continue a minute.
And furthermore, it is 2
not at all clear to me that the choice is either to pursue 3
a perfect method or to do no looking.for~systemsLinteractions.
4 Now, to my knowledge the bulk of the PRAs that have 5
been published did not include spatial interactions.
They 6
included a limited look at other kinds of systems interactions 7
certainly not to the extent that, let's see, it was suggested 8
in the ACRS letter suggesting something for Indian Point.
9 I think the thing that Indian Point, in fact, on 10 which the Staff help has gone beyond what the ACRS recommended,
- 11 we cannot control that.
Now that is really between what you 12 and the applicant have been working on.
[)
13 You can ask Mr. Ebersole to give you a range of N
14 examples of things that have been found.
I am just troubled 16 by something that is sort of like another ATWS in: this case-16 of being attacked by the Staff.
17 MR. DENTON:
There have been 4. lot of operating-18 experience which has been very useful in showing system inter-19 actions.
As you know, we tbnd to act on those one by one by 20 one.
Now, the question would be, how do you design your pro-21 gram to find this needle in the haystack or the various 22 needles.
- That has been the difficulty.
23 We can go off and look.
The ppople who devise 24 these programs tend to devise very extensive _ expensive ones.
,s 25 Maybe if we had 10 Mr. Ebersoles at each plant, we might be l
-i gp
BW5 rg5 290 1
.able to spot them with just experience.
But these programs 2
have to be done by ordinary people, so you need to write down 3
what a system ihteraction program 1is. And that is why I 4
thought a sci 6ntific approach to it would be to get three 5
different people to look at the same plant, and that might 6
sned a little light on the dispute.
7 There has not been a reluctance on my part to pur-8 sue.
It has been inability to define the program so that 9
I would know how to tell someone to go do it.
10 MR. EBERSOLE: The letter we wrote on this topic
- 11 to Indian Point, I thought it was a reasonable two or three 12 page comprehensive set of instructions as to how to do this
()
13 sort of thing.
I regard a really comprehensive PRA as in-V.
14 clusive of system interaction studies.
15 On the other hand, a non-comprehensive PRA may 16 just be a bunch of mathematicians and numbers -- workers who 17 do not understand the vehicle' interrelationships of the 18 plant not merely dmmugh* 1ines but through space. 'That would 19 be a void in the PRA program.
20 MR. DENTON:
I'm looking to see what the result 21 of this is at Indian Point.
They made a commitment that they 22 would notify us of any finding which perturbed the PRA on 23 which we are relying in the Indian Point proceedings.
I 24 think the only finding they hotified us about so far was one fs (G'
25 in the feedwater system that had a negligible effect on the
BW5 rg6 291 1
overall risk of that system running.
<m (Q
2 So the program -- you may have spelled out a pro-3 gram.
I guess I'm waiting to see what the program turns up 4
in that plant, where Ehey did do a good PRA we think before 5
requiring it across the board.
6 MR. STELLO:
I ought to speak to the criticism 7
that Dave had of the letter that I wrote.
I am not so sure 8
he missed the thrust of it, which was to try to get this 9
issue resolved, to find a way to bring it to a head, and 10 decide where we are doing and then move on.
Part of the 11 reason for having this meeting we hre having today, what we 12 have asked the ACRS to do -- I think the purpose of this is 13 to try to understand where we do have problems that we need 14 to focus on that the RCRS feels is important.
15 If the system interaction issue is one for which 16 the ACRS feels we need to give more attention than we have 17 given, then clearly it is an issue we ought t6 be talking 18 more about to understand.
It is disappointing to hear Dave 19 is criticizing what we are doing at a meeting like this.
20 If we have those kinds of problemn we ought to get them out.
21 I happen to believe, as Jesse does, that if you h
i 22 do a good PRA, you are doing an awful lot of systems inter-l 23 action.
If you do good systems interaction, you're doing 24 quite a bit of PRA.
There is a relationship.
The PRAs that O
l 25 are done that start looking what happens when a pipe breaks l
l I,..
BWS rg7 292 1
and where the water goes and what other systenp are affected, (p) 2 that is systems interaction.
3 I think the examples I have heard Jesse cite are 4
the kinds of things I had in mind in writing the comment I 5
wrote.
I think if we talked about it enough, I think Dave 6
would probably agree.
7 Now, if we need to do more in this area, what I 8
would suggest, rather than trying to decide how to do that 8
more today that all we ought to do is decide we need a meet-10 ing, perhaps a Subcommittee meeting pointing out where we
+ 11 are and where we ought to go.
That seems to be indicated 12 by the discretion we have had thus far.
13 (d
I would suggest that maybe to the Committee that 14 you might want to do that.
15 MR. OKRENT:
I am disappointed that in fact the 16 way I learned of this hiatus is really only after one of the 17 Staff members chose to make it an issue._Afterwards I saw 18 these memoranda, which seems to me contributed in part to the 19 hiatus.
Again, the statement that a very good PRA would in-20 clude systems of interaction, of course it is truewbut show 21 me the PRAs that have done it, that is the real issue, that 22 have really taken into account all of the kinds of things.
23 MR. STELLO:
Let me say again, so it is clear to 24 fx you, what the CRGR has done.
I think if you listen to what 4
26 Mr. Denton said did not create a hiatus.
293 BW5 rg8 1
NRR is not yet ready to decide what it wants to recommend
)
2
.be done.
I think suggesting where the hiatus occurs or does 3
not occur is not the issue.
The issue' is, it has been around 4
a long time.
It has been a very difficult issue to deal with, 5
for which it is not yet, I think, clear how to proceed.
6 And to the extent that the Committee cdn help, I 7
think I would urge that a subcommittee be put together for 8
that purpose and provide whatever advice and counsel the End five.
9 wisdom of the Committee can provide to us in that regard.
10
+ 11 1
12
/g 13 4
%)
14 15 16 17 18 19 20 21 23 24 N-sl' gs
294 BW jl 6:1 1
MR. OKRENT:
It seems to me CRGR might have two (VD i
2 roles.
One is to delay things it thinks should be delayed.
3 And another is to expedite things that it thinks are important 4
and are not really moving.
5 MR. RAY:
I would like to wind up the discussion 6
now with Dr. Kerr's question.
7 MR. KERR:
I must say that I sympathsize with 8
Mr. Denton'e approach to this problem.
8 I think the systems interaction business -- I have 10 listened to it carefully over the years -- is still extremely
- 11 tenuous if you try to separate it from a good PRA.
- Indeed, 12 I do not see how one does.
13 It seems, to me, to impose a study of this kind on 14 plants, without being able to define what it is you want 15 them to do on top of all of the other requirements that are 16 being imposed on plants is a mistake.
It seems, to me, the approach that he has taken 18 sounds reasonable.
I would certainly encourage him to con-18 tinue in that direction.
MR. RAY:
I have to reflect the same thought.
I l
21 agree with your comment.
22 I would like to say, too, Harold, that your l
23 appearance here today and the manner in which you came, the o
subject with which you came, to tell us in advance of the U
facts, the development itself of your intent is very
BW jl 6:2 295 1
constructive.
I think it is constructive to a better exchange O
V 2
of viewpoint and indoctrination, if you will, between the 3
Staff -- particularly the senior management levels -- where I 4
think these things, these inputs, should go -- and the commit-5 tee.
6 And I think you can see, by the detail of interest, 7
that was shown here today that it is productive of our 8
responsivene ss.
8 I think the exchanges that take place here are in 10 the best interests of the public in every sense that one can 11 evaluate it.
I endorese the idea, and I certainly hope it 12 is continued.
And, in fact, we would like to see something 13 like this;every month.
14 Thank you very much.
15 MR. STELLO:
Let me make it clear that that was my 16 proposal that Bill and I had.
When I talked to Ray, we 17 intended to schedule one hour each meeting with the ACRS for 18 this purpose.
19 MR. RAY:
Good.
Very good.
8 Thank you very much for coming.
21 I would like to have a 10-minute break at this time.
22 We will resume at 10:20 -- that's more than 10 minutes.
23 (Recess.)
fS MR. RAY:
The meeting will come to order.
3 Tbe next subject on the agenda is Generic
BW jl 6:3 296 I
Implications of Salem Nuclear Station Circuit Breaker Failure.
d 2
I would like to turn the meeting over to Dr. Kerr.
3 MR. KERR:
The Electrical Systems Subcommittee met 4
on May 26th, 1983, in Washington.
5 You have, in tab 9, a description of the highlights 6
of the meeting, which includes comments by a number of con-sultants that participated in the meeting.
8 The committee had, before the meeting -- and even I
had it in time enough to read it -- NUREG-1000, Volume 1, 10 which is, I think, a very complete and good description of
- 11 the generic implications of this Salem event.
12 It, of course, describes the event itself.
()
I would simply turn things over to Mr. Mattson at 14 this point and say that, from what he will say and what you 15 will find in NUREG-1000, I think you will get a good idea of 16 what the Staff considers to be and what seems to me to be at 17 least a reasonable set of generic implications.
It does 18 exist in preparation now, in Volume 2, which I believe will 19 be recommendations that come out of what the Staff judges to 20 be generic implications.
21 And I expect Mr. Mattson will tell us when that will 22 be available.
23 Mr. Mattson.
24
N MR. MATTSON:
You should have a set of charts that m/
25 were handed around a few moments ago.
BW:jl 6:4 297 1
I apologize for my voice today.
I chose to take O
t(,,)
2 last night for my first professional baseball game.
I went 3
out to see Baltimore and Milwaukee, an exciting game, and it 4
gave me an opportunity to vent my frustration.
5 And since there were six in the first five innings, 6
I became hoarse with booing, and I discovered it was a very 7
effective outlet for sitting on the sidelines and watching 8
people in the midst of the action screw it up.
9 MR. RAY:
You were acting like a member of ACRS.
10 (Laughter.)
+ 11 MR. MATTSON:
I began to appreciate, from your point 12 of view, how you must feel.
And I would, from my point of
(~
13 view, say that the players were completely were unaffected by
(
14 my booing.
15 (Laughter.)
16 MR. EBERSOLE:
That's also typical.
17 (Laughter.)
18 MR. MATTSON:
You have had, at this time, as is 19 unusual in many occasions, the report that I am here to 20 describe sufficiently in advance that,if you had an abiding 21 interest, you could read it and, if a casual interest, you 22 could leaf through it.
So, I'm not going to go into two much 23 detail in this briefing today.
24 One, you can't undue it in an hour.
And two, I 25 want to, at the end, indicate a way for us to interact and get J
298 BW:jl 6:5 1
your advice on some of the things that flow from the events 2
at Salem, because some of the Staff actions that are being 3
recommended and presently being considered will be implemented 4
over a fairly long period of time and involve some fairly 5
fundamental aspects of regulation.
And I would think you 6
would want to be involved, and we certainly would value your 7
advice.
8 I will try to save some time for where we are on 8
those actions at the end of this.
10 Let me quickly go through these charts and summarize
- 11 for you what NUREG-1000 tries to say.
12 First of all, let me say it was one of several 13 pieces I worked that gotadone on the'decident.
The first was 14 the Factfinding Report by Region I.
Bill-Raymond, a. senior 15 resident at Vermont Yankee, headed that work.
16 Although there were some facts that changed subse-17 quent to it, given that it was produced in the first two weeks 18 after the accident, that was noteworthy, it was a good piece 19 of work.
The Salem Restart Safety Evaluation Report, SECY 21 98, I encourage you not to wade through A, B,
C, D,
and E versions.
But if you are interested in more of the details 23 about what specifically the Commission did with Salem manage-ment in the Salem facility, Version E of the Commission paper 25 will suffice.
BW jl 6:6 299 1
You will tell that by that point, since there had O
V 2
been A through E editions, the Commission really hung up on 3
the management questions at Salem, the overall management 4
capability.
We will talk about that some more.
5 And, in fact, I think we told you some of that 6
while it was going on at an earlier briefing I gave you in the 7
midst of all of that activity.
8 There were two I&E bulletins and an information 8
notice that were issued shortly after the Salem event.
So, 10 one pertaining to the AK-2 breakers that failed at San Onofrc; 11 the other,.the DB-50 breakers of Westinghouse.
1 12 And then the information-notice summarizing the 13 results of testing conducted in conjunction with the earlier 14 bulletins.
15 The Task Force to Review the Generic Implications 16 is what I am here to report on today.
I headed that, and we 17 reported in NUREG-1000 in April.
18 And then the generic requirements that started with 19 the task force were turned over to the program offices, under-t went three CRGR meetings, have now cleared CRGR and are being 21 refined in the form of a Commission paper that I will return 22 to when we finish.
23 Page 2 summarizes what we were charged with doing 24 and who we were, as a task force.
O 26 Page 3 outlines the method of operation that we I
BW:jl 6:7 300 1
used and the method of reporting that we followed.
,m 2
If you look in NUREG-1000, you will see that we 3
generally wrote our report in this order, identified the 4
problems at Salem, analyzed the cause, to make sure that our 5
independent view of the cause of the problem was the same 6
view that had been arrived at in the course of the Salem 7
restart review conducted by a separate group of people.
8 And then the hard part of our work, which was to 8
examine the generic occurrence of the problems that we found, 10 it is hard to extrapolate what you see at one plant to other 11 plants.
There are design differences, people differences, 12 age differences.
We took several routes to that extrapolation, 13 one being both the reports and informal discussions with 14 senior representatives of INPO.
15 We worked with the regulatory response groups that 16 were set up several years ago, after TMI, to give us prompt 17 feedback on fast-breaking regulatory issues.
We looked at 18 SALP reports, which are a principal ingredient of NRC's I'
interaction on overall management questions with utilities.
I will say more about that in a few minutes.
21 We made some effort to get regtional input to our 1
22 deliberations, both at a management and a technical level.
We 23 had several opportunities to interact with people in charge of the ATWS rulemaking that led us, in turn, to the Rulemaking p) t'.
8 Owners Group for ATWS to discuss such things as what did we all l
l
BW:jl 6:8 301 1
mean by " diversity" -- as we had been saying to one another
()
2 over the last couple of years that we wanted diverse trip 3
systems.
We did that with breakers -- and to what extent, 4
what else did " diversity" mean?
5 Those were principally the areas we talked about.
6 We also talked about an area called reliability 7
j end 6 assurance, which I will say some more about later.
8 9
10 11 a
12
'N 13 14 15 i
16 s
17 18 19 20 21 22 23 u
k/
25
bw71bl 302 1
Page four just summarizes the two bulletins and r
\\',
2 the information notice.
Let me just say one thing about 3
a difference between bulletin number 1 and bulletin number 2, 4
actually 83-01 and 83-04.
There were a couple of other 5
bulletins with different subjects in between.
In 83-01 6
because a DB-50 breaker had failed at Salem, I&E chose to 7
go, with NRR's concurrence, to all Westinghouse plants with 8
DB-50 breakers and ask them to review their maintenance procedures and test them quickly, a very narrow response.
10 One of the things the task force say early in its
- 11 work was that a similar bulletin had been sent, in 1979, to 12 the people who used AK-2 breakers, manufactured by General I
)
Electric, used in combustion engineering and B&W plants.
To 14 a certain extent, in GE plants, but not in the trip system.
M E
15 That bulletin, in '79, had been just as narrow as 83-01 had 3
l 16 been following a Salem event.
It said if you have a breaker 8
17 2
of this model number check and make sure you are handling it 18 l
correctly.
If the AK-2 breaker bulletin, in 1979, had gone h
19 g
to the DB-50 breaker people for action simultaneously, being 2
20 8
breakers that you on first glance and on paper cannot tell the K
21 j
difference between.
The source of the problem of the AK-2 was l
n the same problem that caused Salem to have the double ATWS.
23 So one can, with not very many "what-ifs", say if 24 the bulletin in '79 had been a little bit Broader we might 2.
have avoided Salem altogether.
Therein is a small lesson for
bw71b2 303 1
NRC and something that we are paying attention to, in the b
(,,/
2 Staff actions that are ongoing.
That, in fact -- a lesson was 3
learned by the fact we issued 83-04.when the AK-2's failed.
4 The bulletin that went out in response to the San Onofre 5
failures went to all PWRs with any kind of breakers in their 6
reactor trip system and said now that we have had two kinds 7
fail, whatever kind you have got now, make sure you are maintai-8 ning them correctly, test them.
Tell us if you get any failures.
9 Sure enough, the DS-416 breaker, the more advanced model being 10 used by Westinghouse turned up with problems in the Farley
- 11 and McGuire and Summer plants, in which it had been utilized.
12 A little lesson right there at the start.
()
Let me go to page five and go through the seven 13 14 areas that the task force focused on that had implications h
15 for utility management.
The one we start off in the presen-3 l
16 tation is the one we start off with in the report and it was ol 17 one that was given the priority attention,_by the Commission, 5
{
18 in the restart of Salem, and that is the overall management 2
19 l
[
capability and performance of the utility.
4 l
20 What the Chairman and INPO, and others, have 21 expressed dissatisfaction with, the attention to detail, the 3
l M
lack of an intuitively questioning attitude, the failure to 23 j
clearly have accouhtabiIityif6r execution of the details l
24 7 w, important to safety at all levels of the organization.
The 25 symptoms that we saw at Salem were indicative that this kind t
l I
l l
304 bw71b3 1
of a problem existed there.
And then the conversations we (A) 2 had with Regional people, with INPO people, with utility 3
People, either by their direct!admiisi6nnor their indirect 4
indication, led us to believe that those symptoms could be 5
found in other plants.
Not all, but others.
And they were 6
symptoms of a problem that occured at such a fundamental
/
7 level that you could only attribute them to questions of 8
attitude and philosophy.
9 When the Commission got into these discussions with 10 Salem, and with the Staff in reviewing Salem, one of the
- 11 first things they turned to was how does the Staff guage these 12 things, why didn't we see this before?
Salem is a plant we
{}
13 just licensed Unit 2 a year ago.
Why are we failing to detect 14 these fundamental questions in utility management, these h
15 fundamental problems?
The answer Mr. Dircks gave to.the v
[
16 Commission was we do not really have any tools at that level.
ol 17 There are not any yardsticks.
Attitude wa_s something that 1
18 had been brought up by the Kemeny Commission, something that c
19 this Staff had talked to the Commission about after the E
l 20 accident in the context of the TMI Action Plan, what were
{
21 going to do about that problem?
It is one on which we have 5
l 22 apparently failed to make much progress.
23 I
That does ndt:say thatt.there are not activities 24 at that area.
There are two, one is the NRC's program to 26 encourage and follow the results of the INPO program in overall
305 bw71b4 1
management performance.
The second is the SALP program,
(_)
2 Systematic Assessment Licensing Performance.
I do not know 3
of your familiarity with SALP.
If it is like mine before the 4
job of looking into Salem, it is not very deep.
Maybe you 5
had an opportunity to hear of its somewhat checkered past.
6 This was at one time going to rank all of the utilities in 7
America and folks who ended down near the bottom of that ranking 8
did not like it.
It was difficult, when protest occured, 9
for a Staff to explain clearly how they had ranked people, a 10 lot of selective judgment in that process.
It then came to
- 11 the state that it has today, where Licensees are all compared 12 against uniform criteria and put in three categories, good,
(~)
13 bad -- okay, not so bad, or whatever those three categories C/
14 are, high, medium and low.
But still, not a major program i
15 of the Staff.
4.
l 16 If you talk to the I&E people, they say that is f
17 the regional program.
If you talk to the NRR people, well that 1
{
18 is something that the Project Manager takes care of but he 19 does not get much input from the technical people.
And if you j
5 l
g 20 talk to the human factors folks, Licensee qualifications branch
{
21 you remember has some responsibilities in this area, not 3j 22 much intertie with those people who are putting new plants into i
I t
j 23 operation where you worry about these things and the SALP l
l 24 program, which is dealing with plants in operation to see how b
25 they are doing.
l l
l
306 bw71b5 1
So, it is a program that if it is getting a major
(
2 reliance from the Commission in addressing the overall manage-3 ment capability of performance issue, it needs more attention.
4 It is not really achieving.
It presents an interesting 5
opportunity on an annual basis for senior NRR, I&E, and 6
Regional people to interact with senior licensing management, 7
if they would choose to do so.
That is the subject of one 8
of the Staff actions in response to what we saw at Salem, 9
given that this kind of performance is going unobserved before 10 things go wrong.
Is there a way to better anticipate it,
- 11 better detect it, and do something about it in advance?
12 The actions in that area are what we have come up 13 with as a Staff, still working on, and something that will be
' (}
(/
14 briefed to the Commission in early July, following which there 15 will be an opportunity for yo u to interact with us in what 4
0 16 we have come up with in saying whether you think it is good, O;
17 not the right approach, or more of the same, whatever your 3
18 reaction might be.
I h
19 As I finish each of these areas, rather than have I
20 you have to come back to all of them simultaneously, if you f
(
21 want to stop me.
I am prepared to go on to the next one 3
22 unless there is something in this area that triggers a 23 response.
24 MR. OKRENT:
Has anybody used spme kind of incentive 25 approach?
If you have a good record, you do not have maintenar ce
307 sw71b6 1
errors, or whatever it is, your group is reported unfairly
)
2 and vice versa?
3 MR. WARD:
That is built into the SALP program, I 4
think.
The SALP program, as I understood it, was originally 5
to give an I&E guide in allocating resources.
6 MR. OKRENT:
I mean the utility.
7 MR. WARD:
If a utility gets a good SALP rating, 8
they have fewer I&E people on their case the next year.
End t7 9
10
- 11 12 14 15 16 17 I
18 l
19 20 l
21 l
22 l
23 24 s_/
l l
bw81bl 308 1
MR. MATTSON:
There have been discussions on that i(m) 2 kind of thing.
The difficulty is understanding what the 3
incentive might be.
What can we offer them?
4 MR. LEWIS:
You can offer them a flag to fly for 5
a month.
No joke, public relations-wise.
6 MR. ETHERINGTON:
The flags were excellent during 7
ithe war.
8 MR. LEWIS:
It is a tremendous incentive.
The 9
only risk you run is that if there is an accident.
10 (Laughter.)
- 11 MR. WARD:
Then you put the flag at half mast.
12 (Laughter.)
13 MR. LEWIS:
It is a serious gesture.
Something 14 like that is worth more than money.
15 MR. ETHERINGTON:
Not having it is a big disgrace.
16 MR. EBERSOLE:
Availability, have you done anything 17 with that?
18 MR. MATTSON:
That one did not work at Salem.
One 19 of Mr. Eckart's statement to the Commission was not satisfying 20 to them at all at one of their earlier meetings.
It was --
]
21 we have an excess of 90 percent availability and these units 22 are doing fine.
He had that at a year when he had an excess 23 of 20-trips of the two units in a 12 month period.
Those were 24 the things that were the challenge to the safety system, the
\\/
25 Japanese saying two trips a year, the Commission just heard
309 bw81b2 1
that and Mr. Eckart stood up and said that he was blinking b
k_/
2 20 trips a year and still getting in excess of 90 percent.
3 MR. EBERSOLE:
A yardstick is trips per year.
4 MR. MATTSON:
There are people discussing that.
5 MR. EBERSOLE:
I think that is --
6 MR. MATTSON:
As a measure to give -- that works 7
with the incentive thing.
If you have less than five trips 8
per year you are a good guy and then you come to the question 8
of what do you do for the good guy, maybe you fly a flag, maybe 10 you keep I&E away from him for six months.
I don't know.
- 11 MR. EBERSOLE:
I have been working with our 12 consultant, based on this kind of plan, reducing challenge 13 frequencies and significance per challenge.
I think it is 14 an interesting integrated plan.
It is based on reducing 15 challenge frequency.
16 MR. MATTSON:
There was another reaction to this 17 kind of talk generically, when we met witiv the Commission.
18 Both times, in fact.
I will name 'the Commissioners, because 19 you can then get a flavor for the interchange.
It was a 20 question of whether these experiences told you to get more 21 prescriptive in what you require in this area and others.
Or 22 whether these experiences told you that being Prescriptive does 23 not work and that somehow you had to reach people at a funda-24 mental level, challenge them to do well, and to figure out L) 25 what that meant on their own, and provide an incentive through
310 bw81b3 1
, stiff penalties if they did not achieve it.
2 The two Commissioners that d,ebated were the 3
Chairman and Mr.nGilinsky.
It seemed to be Mr. Gilinsky was 4
pushing more for*the more prescriptive things, get us involved s
5 more and more, while simultaneously saying -- and.this is 6
of coursd'Eeing discussed with legislation on the Hill --
7 saying 65. operating companies is too many, too diverse, too 8
many opportunities for bad ones to be in that group.
There 9
ought to be a smaller set, somehow.
The Chairman is saying hedidnotunderstandwhythingaas.fundabentalaspreventive 10
's,
- 11 maintenance -- you do it for you'r, car, for goodness sakes, why 12 can't you realize that you have to do it to a nuclear power (mv) plant -- he could not understand how those things fell into
./
13 14 the crack and NRC could not be responsible for all of the 15 details.
The only way to get it right was to have good people 16 understanding the penalties to themselves or through us that 17-owed to those kinds of mistakes, leave'the_ details to them.
18 And yet, when you find 'ereas that are so obviously done-poorly, i
19 you have to have some presbription issued by NRC to try to 20 straighten it out.
g
' s,'
I l
2 Both gentlemen were> talking of a mix of approaches, l
22 both general and prescriptive and specific.
23 MR. OKRENT:
When you castigate people for not doing 24 preventive maintenance -- I am using the "you" generically, not J
you -- does one run a risk that goes this way:
I have heard l
s
s 311 bw81b4 1
1 station managers say the time you get the most problems in
[)
2 the plant, the most things incorrectly assembled or aligned 3
or so forth, is after you have done systematic preventive s s 4
maintenance.
In other words, if it is running okay, let it 5
alone.
I have heard this philosophy.
6 MR. SHEWMON:
Are you saying we should never change
=,
7 the oil in our car because someone might leave the plug unscrewed?
s
,s
- i..
~8 n
MR. OKRENT:
No, but I am saying theresis a human f
9 error associated with the act of doing preventive maintenance.
s.
10 Just ask yourself about 3 0 rings on a 1011.
s 11 MR. MATTSON:
Th'at is something we will turn to 12 in a few minutes.
It is a real effect.
13 MR. SHEWMON:
To what extent is a maintenance U) 14 program -- apparently it is not part of a tech spec.
It 15 is sometimes part of a warranty, or recommended, yet I am 16 sure for other equipment it is not.
This is entirely left
' 17 up to the utility, except for Class IE or,what?
18 MR. MATTSON:
The only place you will find 19 maintenance mentioned, in regulations, is in Appendix B.
20 The only place you will find it reviewed, in the Licensing 21 process, is in the context of Appendix B.
The extent to which 22 it has been addressed in the past --
23 MR. SHEWMON:
Tell me what Appendix B is.
24 MR. MATTSON:
Qualit assurance regulation, Appendix M
B to Part 50.
The only review that has occured by a licensing
~
312 bw81b5 1
in any of the operating plants is for QA engineer, quality q
2 assurance engineer, in looking at the quality assurance 3
program to be sure that it includes the preventive maintenance 4
program, period.
That's it, there's no other review.
5 MR. SHEWMON:
So we make sure it is on the books 6
and whether they follow it or not is up to local management, 7
is that --
2 8
MR. MATTSON:
And what it contains :is up to them.
9 Now, the theory is that you take a component that is safety-10 related, and therefore more important than some other component
- 11 you look at what the manufacturer of that component said you 12 should do for preventive maintenance, probably a commercial
[}
13 product you just adapted to use in a nuclear plant like DB-50 V'
14 breakers, look at what the manufacturer says to do, and then 15 you think in theory, if you are a utility about what else 16 you might want to do because of this special reliance you 17 are placing on that piece of equipment, being in a safety-18 related system.
And then you develop a preventive maintenance 19 program for that piece of equipment that is embedded in a 20 l
larger preventive maintenance program that then gets executed i
l 21 l
routinely by a maintenance department in the utility, l
M In theory, that is what Salem did.
They made some 2
mistakes along the way.
They forgot to list breakers in 24 j
-~g safety-related equipment.
The maintenance > manual on those I
\\~)
25 breakers apparently never reached the utility.
Even then, l
313 bw81b6 1
some were done on the breakers in operation, was treated as
()
2 safety-related work because the people doing the work evidently,
3 were smart enough, even though the list did not include the 4
breakers, to know that it was in a very important safety-5 related system.
6 Yet, some critical maintenance and some replacement 7
of parts did not get done as safety-related stuff.
Therefore, 8
the wrong part of Westinghouse was contacted and the wrong 9
procedures and such were followed.
That, in some measure, 10 contributed to the failures that occured.
/
- 11 MR. SIESS:
Is there any relation between the fact 12 that they did a lot of' maintenance in January and had the
{}
13 double failure in February.
v 14 MR. MATTSON:
Yes, there is.
It is unclear what 15 the relationship is.
Early after the event it was thought 16 that it was improper lubricant that was the source of the 17 difficulty.
That turned out to be wrong. _There was a misunder-18 standing on the part of the utility people who told NRC what 19 had been done in something they had been told by the Westing-l 20 house site rep.
The Westinghouse had used lubricant that looked l
21 the right lubricant.
He used the right stuff, according to 22 him.
M If you look at the breakers that failed, you look 24 at the springs on the breakers and the way.they were adjusted -
g g!
[
t 25 this is something Westinghouse did and Franklin Research did
kw81b7 314 1
independently for the Staff -- you find a bunch of screw 13
(_,)
2 marks, screw driver marks, on springs -- bent springs.
You 3
find adjustment screws at the far end of their adjustment 4
where they were not supposed to be adjusted at all in practice.
5 And you-find tripping forces and -
cn1 the trip bar and forces 6
delivered by the tripping mechanisms that are out of spec.
7
.When wee say' it: was :a: maihtenance problem we mean 8
maintenance generally.
We do not really know what specific' 9
things went wrong in the two specific breakers that failed.
10 It appears it was a combination of those things, causing both
- 11 to go bad simultaneously.
Some have said ah, that was not 12 a common mode failure.
Those are two random failures that 13 overlapped.
If you are thinking down.at some really small 14 subdivision of common mode failures, I suppose that is true.
15 It is too theoretical for me.
It was maintenance that screwed l
is those two things up, either the people, the screwdrivers, the i
17 lubricant, or something, because they will_ operate if you treat 18 them right and keep testing them.
And they will go hundreds 19 and thousands of times without failing.
20 Apparently there was dirt in the cabinets.
And 21 that dirt, as one NRC observer pointed out, when you trip 22 the breakers it caused a little cloud of dust inside the 23 cabinet.
It would settle down and then you would trip the 24 breakers again.
They'd go -- they make a pretty good pop
~S O
25 when they go and the dust would go up.
There was wear from
'bw81b8 315 1
that kind of thing that was observed by Franklin and Westing-2 house in the post-mortem.
3 MR. EBERSOLE:
These are open ventilated enclosures 4
and there was no criteria?
5 MR. MATTSON:
There was an instrument rack, I 6
understand there was some circulation back there to keep the 7
temperature under control.
8 MR. EBERSOLE:
A couple of months ago we were looking g
at the Turkey Point pressurized thermal shock in the cold 10 condition.
At the time we thought maybe maintenance procedures
- 11 and matrices of performance conditions and degress of disable-12 ment would well be a computer assisted process.
In last 13 Nuclear News McEvoy opened up the subject but did not talk 14 about it in the safety context.
In the safety context it 15 would be an invaluable aid --
16 MR. MATTSON:
That is interaction.
When we met 17 with the response groups -- let me back up.
Salem had the 18 master equipment list.
The maintenance folks could turn and 19 find the component and all of the red flags, the background 20 information, do the right thing, but they left the breakers 21 off the MEL.
They had good intent, but the execution was 22 poor.
They did not control the document.
They did not QA 23 the document.
It just did not get done well. The3 document fron.
l 24 which it was derived treated the breakers properly.
You could end t8 25 see the breakdown.
316 BW:jl 9:1 1
Other utilities are moving to computer-assisted A
k_,)
2 programs.
They were doing QA and doing good programs.
We 3
met several in the course of the RRG meetings, and there are 4
others out there who apparently make decisions -- some like 5
the following:
6 They were licensed, say, 10 years ago, it was an 7
agreed-upon list of safety-related systems, there has never 8
been generated a list of safety-related components either on 8
paper or in a computer, and the maintenance foreman says, 10
" Gee, I think I'd better do something to that breaker."
- II Let's say it is a DB-50, of'which :there are some in 12 safety-related systems and some in nonsafety-related systems.
[d T
He cannot remember for that particular system, so he goes to the operation staff.
He asks the station superintendent, who 15 was hassled that day, because we knocked him down a couple of 16 times -- dispatcher is on the phone, and he says, "I have to II do a DB-50.
Is it safety-related or not?"
i I
Whether he remembers the town, what system it is 18 in, whether the superintendent chooses to ask him or not, or 0
whether the superintendent, even if he gets that information, 21 whether he remembers, or whether he has to go to the list of 22 safety-related systems which is in his FSAR and has never 23 been translated anywhere else and it is carried around in the l
24 back pocket, is the impression you have,that is not very good.
n\\~/
2 It is too subject to human error.
317 BW jl 9:2 1
Without trying to be too proscriptive, we are 2
strongly encouraging folks to move to more modern and sophis-3 ticated information handling tools.
4 If you can have a computer in your home to manage 5
your budget, for goodness sakes, there must be cheap enough to 6
put in a reactor and help you manage your maintenance program.
7 This is a way to see that things, in theory, get implemented 8
in detail.
8 Let me keep moving on.
10 The second thing on page 5 is this post-trip review.
11 I do not think I need to spend too much time.
They did not 12 do a good one on February 22nd at Salem.
They had an ATWS.
13 (j
They went back to power and had another one three days later 14 We have looked at what our requirements are.
There 15 are not many.
16 If you look in Reg Guide 1.33, it is one of the 17
-- in Appendix A, it is one of the procedgres that that QA --
18 that you ought to have that list.
19 And if you look at what is in plants, the restart procedure, which is the normal startup procedure, start this 21 pump, turn that valve, there is not anything in the vast bulk 22 of plants that says, " Thoroughly understand what went wrong 23 before you start up, or throughly look at the response of the 24 p
safety systems that might have been activated before you start i
1 25 up" -- with one exception, and that was Oconee.
I
318 BW jl 9:3 1
At Oconee, they had a checklist that would require
(
2 v.
you to look at how the thing was caused and how the plant 3
responded.
4 There is some uncertainty about this, but there 5
seemed to be a philosophy at the Oconee Station if, in eight 6
hours, you do not satisfy yourself that you have correctly 7
answered the questions in this checklist, take the plant to 8
cold shutdown.
You need to study it further.
8 If you cannot do it in eight hours, it is serious, 10 and you'd better think about it, as opposed to procedures
- 11 with our other plants, where they seem to say if, after four 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, you have not figured it out, you have wasted enough 13 time, for goodness sakes.
Call the station superintendent 14 at home, and he will let you start this turkey up.
15 I am overstating it on purpose, because we will 16 see I'm overstating it.
17 If I juxtaposed those two points -- and we are going l
I0 to try to say to do better in this area.
19 MR. OKRENT:
Send it out to three national labora-20 tories.
1 (Laughter.)
22 MR. MATTSON:
Touche'.
23 We are going to try to say you ought to look,after l
M l
a trip, at'what caused the trip, how the plant responded, and 25 be conservative, for safety, in deciding your restart.
l
BW:jl 9:4 319 1
This is not an unimportant area.
O
(\\_)
2 There is fair evidence that utilities are treating 3
this subject too callously.
They have gotten too accustomed 4
to 20 trips a year.
5 MR. SIESS:
How many trips a year does Oconee have?
6 MR. MATTSON:
Not a small number.
They have seen 7
years where they have seen large numbers.
8 MR. SIESS:
This procedure does not really -- does 8
not necessarily cut down; the number of trips.
10 MR. MATTSON:
No.
I don't think they have the poor 11 trip performance of some other plants.
So, it may be that 12 some of the difference owes to this kind of thing.
13 There is some confusion.
People have said that we 14 have said Oconee is the standard that we want to meet.
That 15 is not true.
16 I will be frank with you.-
There is some disagree-l 17 ment among the sources from Oconee as to what they actually 18 do.
1 One representative from Oconee said one thing about a procedure we were looking at.
Some other representative 21 l
said another thing.
22 We looked at McGuire.
They did not have the same 23 j
thing, and they told the Commission they had the same thing, 8
and there are subtle differences in attitude, that even when 25 it is the same utility and a good utility, the execution is a
BW;JL 9:5 320 little different.
/~}
-/
Don't take from what I am saying that we will 3
promulgate a standard.
It is not good enough.
4 One thing I should mention, we looked at the NRC 6
role in restart and decided not to change it.
You get a 6
flavor for that in NUREG-1000.
Unless it trips somebody, I 7
will not talk about it here.
8
" Equipment Classification," on the next page, is 9
an interesting topic.
I have already said they had misclassi-10 fied the breaker.
It turns out some other people had done 11 the same thing with the same breaker.
12 In talking to the RRGs, we lost confidence that they
)
were doing these things in a way that was reliable.
14 Referring to the list-in-the-hip-pocket scenario 15 I referred to a few minutes ago, there is too much suscepti-16 4
bility to error in classifying things at the component level.
17 You know there has been some controversy in the 18 j
Staff in at the hearing boards in the last year and getting 19 us involved in the list of safety-related equipment and the 20 list of equipment important to safety, the former being a 21 subset of the latter.
22 We are not proposing at this time to jump into an t
23 l
NRC review of components in either of these categories.
We 24 are jumping off into a review of the program and the informa-tion handling system, or how these things are accomplished in l
BW:jl 9:6 321 1
operating plants.
2 If that sounds like there may be another shoe later, 3
there may be As we try to handle it at the programmatic, 4
management level and not get prescriptive, down into details, 5
that people get the message and execute well down into details, 6
they will keep us out of the details.
7 If problems continue to occur, you can see a spread-8 ing of regulatory oversight, into a finer mesh.
Equipment 8
classification is just one example of that.
10 Maintenance, as I will say in a minute, is another 11 example of vendor-licensee relations.
This refers to the 12 interface between Westinghouse and Public Service Electric &
13 Gas, not being sufficient somehow to get the maintenance 14 information from Westinghouse to PSE&G and execute it without 15 placing blame -- and I'm not sure we can -- as to where that 16 broke down, it is clear you cannot allow such breakdown to 17 affect safety-related equipment.
It is too big of a source 18 of unreliability to that equipment.
It is not just Westing-19 house that has that problem.
E Although the other NSSS vendors look better as to 21 what they do in this area, they have systems for doublecheck-22 ing the information they thought was important to send to a 23 utility was, in fact, received.
Some doublechecked to see 24 if was implemented -- and report back to utilities to show (w
1 25 them who implemented it and who didn't.
Sort of subtle peer
BW:ji 9:7 322 1
pressure.
2 There are other suppliers of major components with 3
whom licensees apparently have no ongoing relationship -- for 4
example, suppliers of diesel generators.
5 So, let's say that General Motors decides the diesel 6
it has built out to be maintained in some fundamentally 7
different way than they told a utility that the sold it to 8
20 years ago.
That utility has no guarantee that they have 8
kept -- that they have received that information and acted 10 upon it generally.
11 There may be utilities who will scream and yell that 12 they do.
But generally there is no assurance that they do.
I h 13 MR. SHEWMON:
When they drove it out of the showroom, v
14 it was theirs.
I 15 MR. MATTSON:
That's right.
And not recognizing 16 somehow the importance of preventive maintenance and the 17 fact that operating experience may have been reaching that 18 manufacturer through a route other than nuclear, they have not 19 maintained any contact.
l 8
So, the requirement that we will issue I believe in 21 the next few weeks is one that they establish a relationship 22 under the aegis of a program for handling safety-related 23 equipment, they establish a relationship with all suppliers of safety-related components.
If somebody is going out of 26 business or refuses to have such a relationship, then the
BW:jl 9 8 323 1
utility must accommodate that somehow in its own thinking for 2
backup and establish that tie.
3 Preventive maintenance -- we have already talked 4
about it a couple of times.
They were not doing any apparent-5 ly at Salem.
They had a program.
We reviewed it.
It looked not too bad according to standards that are available in Reg Guide 1.33 and ANSI N18.17, that did endorse this.
But 1
8 they were not implementing it.
INPO told them 18 months 9
before the event they were not implementing it.
They said 10 they would implement it in 18 months, and they didn't.
11 Other plants have the same problem.
Sometimes it 12 is a resource problem; sometimes it is a philosophy problem.
()
But there are plants that are not getting preventive mainten-14 ance.
15 EPRI did a study of it.
The Staff has done a study 16 at PNL to confirm the EPRI.
Everybody knows preventive l
maintenance is in sad array in the nuclear industry today.
What we do about it and how fast we can move to 19 effect change is still up in the air.
20 There are no licensee actions of any far-reaching 21 impact that are being considered in this first wave of licensee actions as a result of Salem.
There are Staff r
23 programmatic changes that are being considered, and you will 24
(~')
hear about and see in Volume 2.
And you will have a change kM 25 end 10 to interact with them.
/
324 bwl0lbl 1
Frankly, I expect the Commission to be disappointed (O/
2 in what we described.
There are not many good ideas in where 3
to move.
There are down size.
You do a lot more preventive 4
maintenance, at the same time you do not do any post maintenance, 5
functional checking to make sure that some dummy did not 6
misalign a valve, then you may be hurting safety instead of 7
helping.
It is not all straightforward, a difficult area.
8 MR. CARBON:
I am puzzled on one thing here.
9 Philosophically I would think this is the kind of thing that 10 INPO ought to push very hard and I assume from what you are
- 11 saying that they are just not doing it.
12 MR. MATTSON:
They are with only limited success.
('N 13 They told us, at a management level at INPO, that they intended 14 to develop better standards of excellence.
They have been 15 telling utilities to improve in this area for several years 16 and that they are not pleased with the progress.
Part of my 17 generic conclusion of this array is based _on information 18 received from INPO.
It is primarily the more thorough 19 going looks by EPRI, and specific Northwest laboratory, and 20 out own experience in Salem in talking to a few utilities.
21 MR. CARBON:
This says to me that INPO is not 22 fulfilling its mission.
Do you get that impression on other 23 things that INPO does?
24 MR. MATTSON:
We say some fairly good things about N
INPO in this report.
First, INPO is a good idea.
INPO has 1
bwi lb2 325 1
excellent people.
I'm very impressed with the people we b
V 2
interacted with.
INPO has some good standards.
INPO is 3
using those standards.
INPO is not. pulling punches.
You 4
read their reports, they are telling people where they are 5
finding difficulties.
They tell them in a more gentlemanly 6
way sometimes than regulators do.
You have to read between 7
the lines a little, I will agree to that.
8 But in some areas the proof is in.the pudding and 9
the pudding is not there.
Maintenance is one.
INPO says they 10 have been working in this area for a couple of years, Salem
- 11 attests to that, and the change is not there.
The INPO people 12 are as disappointed as we are.
13 MR. SIESS:
INPO has no clout.
They cannot force 14 somebody to improve their maintenance, can they?
15 MR. MATTSON:
This is not the proper place to test 16 INPO.
I do not intend to do that.
There are some positive 17 signs there.
18 MR. SIESS:
Am I right?
They can only recommend?
19 MR. MATTSON:
That is my understanding.
MR. WARD:
They can jaw bone.
That is their 21 chief weapon.
22 MR. SHEWMON:
Do we st ill have the Director of 23 INPO here, next month?
I think that would be a fine time 24 to bring up some of these things.
NJ 25 MR. KERR:
There is peer pressure.
The utility i
326 bwl0lb3 1
executives serve cn the INPO board.
And if -- obviously it
)
2 is not as effective as one would like -- if your utility is 3
looking bad then INPO has some pressure.
4 MR. MATTSON:
Let me change the subject just slightl r 5
to one very important idea that has come out of the Commission
/
6 meetings on the subject.
It occurs right at this juncture, 7
in the two times we have talked to the Ccmmission.
It is 8
a concept that the Chairman suggested.
I don't know where 9
he got the idea, perhaps himself, of general operating 10 criteria.
I will paraphrase what I' think he is saying.
We 11 have had general design criteria.
We have concentrated, 12 in the design area, in getting9the plants safely into operation.
(}
13 We are now beginning to collect a significant body of operating
%J 14 information, operating events, and as we look at what the 15 causes are there are some areas that are not being treated well 16 They are generally not being treated well.
17 It suggest that we should have _some general 18 operating criteria, of which maintenance would be a subset.
19 The Commission has asked the Staff to look into that idea, to M
embellish it, work with it a little, and report back on whether 21 there is anything productive there.
I think there is.
We are 22 not going to be able to do much other than say yes, we think it J
23 is a good idea.
We will be working with people in industry 24 and the ACRS to try to flesh out that idea over the coming 7S i
t
~
M months and report back to the Commission.
327 bwl0lb4 1
Th'is is a primary area, I think, that you might be (3
x,!
2 able to help us in.
I am not even sure yet, what those words 4
3 mean and I don't want to confuse them with rhetoric, general 4
operating criteria.
5 MR. EBERSOLE:
Would you include certification of 6
mechanics?
7 MR. MATTSON:
That is something that would be in 8
there. Another subset of things would be what do you do with 9
people in operations.
10 MR. SHEWMON:
Look what that has done for the FAA.
- 11 MR. EBERSOLE:
I know, it makes them put O rhigs on ---
12 MR. MATTSON:
Don't jump to those homilies too
(
13 quickly.
It is easy to say well, we are not so bad, look at L
14 FAA screw up O rings.
The Commission did that to me in the 15 second briefing.
If you look at FAA,:they do a much better 16 job in this area than we do.
17 MR. LEWIS:
They do.
18 MR. MATTSON:
There are things we could learn from 19 FAA.
They are going to make mistakes.
We are going to make 20 mistakes no matter how much we improve.
It will probably be 21 in o rings.
22 MR. SIESS:
There are a lot more airplanes than 23 there are reactors.
24 MR. MATTSON:
If you look at the engineering that n
M they have done in maintenance, and the human factors that they
bwl0lb5 328 1
have got to bear in maintenance, their programs are much
)
2 better than what we do and there are people looking.
3 MR. LEWIS:
They ought to regionalize.
Think of 4
how much better they would be.
5 MR. OKRENT:
I'm going to take my own fire extingui-6 sher home tomorrow night.
7 (Laughter.)
8 MR. MATTSON:
The last two items, on page seven, 9
post maintenance and quality assurance.
There are places in 10 tech specs where you are not really testing the functions.
- 11 Salem was testing these breakers even seven days by pushing 12 a button on the shot.
And by that mechanism apparently
('")
13 satisfying a tech spec that we meant for the UE trip attach-w&L) 14 ment to be tested if it had not been tested within seven days.
15 They were returning to power.
It was a loophole in the way 16 we had written the tech spec.
There are others and we will 17 go to post maintenance operability testing _as an area where i
l 18 Licensees will be required to look and see if they see 19 similar things.
l The quality assurance -- it is tempting whenever
'O J
i 21 you see one of these things to blame quality assurance.
We 22 started out,.as a ta'sk force, doing that.
And then, if you 23 look you find out that that is too general an attack.
It is 24 more elements of quality assurance like preventive maintenance t',/
25 and then a question of is that a sufficient treatment of
329
[ bwl0lb6 1
preventive maintenance.
An answer we came to, no that is (O
(m,)
2 not sufficient.
It ought to be treated on its own discreetly, 3
not as just an element of quality assurance.
4 If you read the report, you do not get a satisfying 5
feeling that quality assurance is particularly the way to go 6
fix this.
We did uncover and correct one deficiency in that 7
area as we were going along.
The QA standards, to which 8
most people have committed, are the '72 version.
The one that we inspect against, no matter what people have committed 10 to, is the '76 version.
The question arises can you enforce
- 11 well enough for the plants that have committed to the '72 to 12 get them up to the '76, which is a fairly significantly higher 13
()
level of detail.
One region, they said no, you can't do that.
14 You ought to upgrade everybody's commitments.
Two other 15 regions said we do it all the time and do not get any backtalk 16 and it works well.
The third region -- the first region 17 talked to the other two and apparently, ad-justed the way it 18
(
intends to inspect and enforce on QA operations findings.
They l
l 19 seem satisfied that for now that is all that needs to be done.
I n
There is a 1982 version of the same standard that 21
-- some consideration should be given to backfitting that to 22 clear up the fact of people being committed to the best we know 23 how to do in operational QA today.
I do not know of much 24 excuse not to commit to that.
It is not affecting people to
{^])
\\_
25 go back and fundamentally change the design, or even change
330 bwl0lb7 1
the design.
It is how you treat it.
If they are not treating 2
it the way we know how to treat it as a science then backfitting 3
the current best statement, from a national standard as to 4
how to do that I think would improve things.
5 Page eight is an area that has received attention, 6
a lot of rhetoric, and not much of idea of what to do.
The 7
vendor did not do very good in this case of the breaker.
They 8
looked at what some other vendors had done in similar equipment 8
and they had not done so good.
Life cycle theitesting of the 10 component like a breaker in a reactor trip system.
When is
- 11 it going to wear out?
How soon should you replace it?
12 Very mushy, you read the report I think you will m
[v}
13 be as dissatisfied as we were.
Some QA in the manufacturing 14 process, things that you thought you could rely on better from 15 an NSSS vendor or major equipment. supplier.
16 Let me just wrap it up and hen go to a question.
17 So far, the only idea for treating that is to get 18 tougher in vendor inspection, to make it more than seeing 19 if people are following the QA procedures they have set down 20 for themselves but to go more at are the things they have 21 set down for themselves sufficient to assure high reliable --
22 highly reliable equipment -- and to start with some of the more 23 fundamental safety systems, like reactor trip systems.
MR. SHEWMON:
Outside of a poem once about a carriage
'O 25 called a "one hoss shay", I have never heard of anybody that
331 bwl0lb8 1
talked about how long things last in terms of equipment.
I (O/
2 am not sure that it is a useful concept.
I think it is more 3-something, you know, how long you drive your car is a state 4
of mind and how much do you want to pay for repairs and have 5
fuss at that sort of thing.
6 I just wonder if you can talk about how you may, 7
in a procedure, say we will throw away all light bulbs after 8
600 hundred hours because we find it easier to do it once 9
a month.
10 MR. MATTSON:
Let me test that.
I remember a course
- 11 at the University of Michigan -- a fine school -- where somehow 12 I ended up taking a machine design high level course taught 13
)
by a person who worked in the automobile industry.
And I came 14 to understand there was fairly sophisticated theory, testing, 15 application of science in this area and then tying that to 16 maintenance prescribed in the owner's manuals for automobiles, 17 when do you check the bearings and when do_you check the axles?
18 MR. SHEWMON:
No question of that.
I thought you j
19 were talking about the life of a whole piece of machinery.
20 MR. MATTSON:
I'm talking about the fact there 21 has not been life cycle testing,t-of any significant engineering 22 sort, on breakers in any trip system in the United States.
Or l
l 23 that the breakers were chosen with no quantitative basis in 24 reliability, just some judgment that says they've been around
~s
\\/
2 since 1946 in a lot of places, they must be okay or somebody I
332
'bwl0lb9 I
would have changed them.
2 MR. SHEWMON:
It is your use of the word "of life 3
cycle" for something that is a composite of many parts that 4
is bothering me.
It is like asking what the life cycle of 5
a car is.
The life cycle of a car is much different than that 6
of the oil or the tires, and so forth.
MR. MATTSON:
I understand.
8 MR. RAY:
This question of reliability of service, 9
in the early days of the industry some hard bitten profanity 10 users, tough superintendents, had personnel radically different 11 from what it is today in the. utility industry.
And you wonder, 12 sometimes when you hear recitations such as Roger's today O(_,f 13 as to whether or not it would not be timely to resurrect some 14 of those guys from their graves and put them back into their
.j 15 g
positions.
v 8
16 For instance, cable splicers in the old days --
0-17
?
I am revealing my age when I say some of those things I 2
18 g
realize -- but in the old days, if a cable failed, a splice 19 j
usually was the trouble.
It was particularly true if it was 20 a cable and a splice was involved that had been recently
=
21 end t10 implemented.
[
22 24 s
i k-25
BWil rgl 333 1
An investigatory task force would be appointed and then O(,)
2 specifications on how to make a splice would be on the task 3
force as well as operating supervision.
That would be dis-4 sected in a company laboratbry and a decision would be maae, 5
and if workmanship responsible for the failure, the man got 6
two weeks off without pay, Bang!
Just like that.
7 They would not do that today because personnel 8
relations -- it is the most effective incentive you can de-9 vise.
Today personnel relations would enter into the picture 10 and you absolutely cannot get away with that.
- 11 If it were material, the supplier of that material, 12 depending on what the statistical evidence of occurrences in-(~'T 13 dicated, do you think he would be taken off the suppliers' t,
/
v 14 list?
15 MR. KERE:
You just do not understand positive 16 reinforcement.
17 (Laughter.)
18 MR. RAY:
It sv. ems to me we have gone so far in I
19 giving way, if you will, to the concept of enforcement, both fror 20 the viewpoint of procurement, when something -- when a bid is 21 given today or made or requested on supplying material or 22 equipment, the price tco frequently is the rule who gets 23 the order rather than price and quality.
24 In the old days, the performance entered into the O)
'N-25 award.
Penalties entered into the personnel situation when
334 BWil rg2 1
they misperformed or did not perform.
I still think some of
(,)/
f' 2
that should be reinstituted in the present management indoc-3 trination.
4 MR. MATTSON:
That was a problem at Salem. They 5
have hhd some union difficulties at that plant.
Part of 6
what I & E saw, the region saw in looking at the reasons for 7
the disarray of some of these programs.
A lack of implement-8 ation was an attitude by first and second. level. supervisors of 9
"Let's not rock the boat on the union negotiation.
The boys 10 will be boys.
Whht are a few broken windows?"
And where
- 11 screw-ups occurred, they did not get rid of the people, they 12 did not punish the psople and they let it go. That breakdown
())
13 in discipline had occurred of some degree at Salem.
14 MR. SIESS:
What Rind of breakers do the Japanese 15 use?
i 16 MR. MATTSON:
I am embarrassed.
The Chairman asked 17 this question. I.was. supposed to get an_ answer,'
I have asked 18 someone to look.
On the Japanese,I know-the Japanese use 19 a breaker in PWRs that is not differential bolt from the 20 DB-50.
Not different from the DB-50.
I'm not quite sure --
21 MR. SIESS: In appearance or reliability?
22 MR. MATTSON:
It is apparently treated different 23 in maintenance and surveillance and inspections.
And its re-24 liability has apparently been higher.
But I do not have the
\\-
25 details. When Mr. Denton and some of our people were over
BW11'rg3 335 1
there, they looked into this.
O
(._,
2 Bill, maybe you remember better what I said at the 3
Subcommittee.
I did not bring those folks with me.
As I 4
understand the Japanese breakers are essentially the same.
5 It-has been treated better and the performance is better.
6 MR. EBERSOLE:
I learned in the hall at the last 7
meeting we had that these breakers and these circuits carry 8
about 1600 amperes, 480 volts, which is an astodishingly high 9
number.
It may well be outside the motor start or a contactor 10 type rating, but it brings up the notion of breaking these 11 habinta~ circuits. In other words, more than one, like 800 12 apiece, and. then' using motor starter because' of its improved 13 capability for cyclic duty.
14 Has anybody looked at this?
15 MR. MATTSON:
You brought this up in concept in 16 the Subcommittee meeting.
I thought about it afterwards and 17 tried to understand why we did not move more aggressively in 18 that kind of thing.
19 I think the answer is, we have a reluctance to make 20 such fundamental change in something as important as the 21 "by God. reactor protection system."
22 MR. EBERSOLE:
You do not ask them to bring you 23 the brick house instead of the straw house?
24 MR. MATTSON:
That is a good question in my mind LJ 8
for new designs.
Unfortunately, the one we are looking at
.._,m
BWil rg4 336 1
in any detail is GESSAR, and it does not seem to have this OQ 2
particular problem.
But it has the discharge volume problem 3
that you plead that we should be looking at on the GESSAR II.
4 Maybe when we get a chance to talk to Westinghouse about this 5
aspect of the advanced PWR, we can talk about it there.
6 I would be afraid, frankly, to take an operating 7
plant, go to such a fundamental change in the SCRAM system, 8
talk about doing it in a refueling outage where the incentive 8
is to get back up and produce electricity.
Long delays -- it 10 is hhman, it is there.
When the reliability of the existing
- 11 SCRAM systems can be improved, it basically?is down there..
12 around one in 1000y, where we-thought it should be for these 13 kind of components, the failure rates for these kinds of 14 components.
It-7*i-15 MR. RAYL -Roger',' I'wish you1would summarize'your 16 story shortly.
While you started late, I have been keeping 17 track of time, and we have given the allocated time.
18 MR. MATTSON:
Good.
Let me fihish with slides 10 19 and 11 just to make the tie to some intermediate term actions 8
that will be recommended to the Commission in about a week 21 to 10 days.in the form of a Commission paper that I suspect 22 will have the title, NUREG-1000, Volume II.
23 Although I am not responsible for that paper, M
Vic Stello has the lead for that, I am supplying or coordina-n)
!v 2s ting the NRR input that will be briefed to the Commission
BW11 rg5 aa/
1 on the Shh'of July.
/*)
(_,
2 It will contain as an Enclosure 1 or A, four 3
licensee actions of an, intermediate term nature, that is, 4
get some post-trip reviews, get some assurances that s&fety 5
grade equipment is properly classified, get going on what is 6
your program for handling information and doing a good job 7
on safety-related equipment, and modify your breakers if 8
you're Westinghouse or B & W.by wiring in the shunt just as 9
CE has the shunt wired in as one part of the automatic. scram 10 system.
- 11 You can see these are fairly narrow -- limited 12 changes.
They will be in the form of a 50.54F letter giving f~'
13 licensees like 60 days to respond with their schedules and k
14 plans for implementing.
15 Westinghouse and B & W owners groups have already 16 talked to us in some depth.
Their designs for wiring in the 17 shunt are fairly straight-forward.
We have them under review.
18 They are not waiting for the 50.54F letter to effect this l
19 fairly important reliability addition to the acram,. to the 20 breaker.
21 The paper will also include program changes in l
l 22 SALP, in maintenance, in quality assurance, in these other l
23 areas I have already mentioned.
l l
24 I would propose that when we have talked to the f_#)
25 Commission about those things and they have given us the
't BWil rg6 338 i
1 go-ahead on the 50.54 letter, we send the volume to you,
()
2 ask you to read it, and then set up, ways to interact.
'I do 3
not know whether it is -- no offense to Bill'-- I do not 4
think some of these things are ri91t for the ATWS sd6commi tee 5
where we have talRed so'far~,but more for> operations-ot>iented 1
8 or human factors 4orieniedor management oriented subcommittees.
7 I would,let the Staff elements resp'onsible for the 8
pieces like SALP an'd the I'& E people who have overall res-3 9
ponsibility for it come down.and-tell you why that is an ac-10 ceptable way for us to gage overall management performance.
+ 11 And to do that soon.
Not to let Salem get too cold before 12 the ACRS has an interaction.
13 Maybe we could tie itiall toge her with some 14 further meeting th'at Ilcould come to in' August, or September l
15 even, after there has'been a chance fon some various. sub-16 committees to, interact with it.
n 17
'One oeher thing.
Id did 1cok.at the ATWS rule
~
s 18 as a task force-ts'get kind of another perspective on whether
\\
19 that thing had the right stuff.
And I changed -- you heard 20 me say it already,TI will say it again -- I changed My view l
l l
21 on ATWS.
Dave, you pointed out yesterday I'm not pushing l
I want to see an ATWS rule that goesmto 23 something now on a decision.
The task force had the same 3
24 view.
I do not think I shaped it all though.,
I sp6ke out.
l s
-}
s 25 We have waited too long ahd'done nothing.
There'are some t
/
BW11 rg7 339 1
prevention things that should be done, should be done soon.
()
2 And diversit'y of trip systems is a help.
3 We are convinced that divera..y will improve the 4
reliability of these trip systems.
I think now it ought to 5
include Westinghouse, despite the fact that they have a 6
better mitigative capability.
Legally, in order to do that.
7 there has to be an addition to the rule in a proposed form.
8 That should not hold back the rest of the rule.
A final 9
rule should go forth requiring diverse reactor trip systems 10 on the other three manufacturers.
11 MR. SIESS:
What do you mean by " diverse"?
12 MR. MATTSON:
We have a NOAA that says what
(~T 13 we mean and says what is required of that diverse system.'If
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~
14 you have not seen it, let me get it to you, Chet. Faust. and 15 his people have with meetings with the ATWS owners group and
-16 some general discussions come to a fairly specific list fgt tt
_ ~17 me of what that Means.
In a nutshell, it i.s not another
-3
-1
-2 18 10 system, it is more like 10 or 10 It is not going
(
19 to be fully gold-plated.
It does not have to be seismic.
20 It is not the seismic event we are headed for.
It is the s
1 21D reliability for the frequently-recurring trip demand that we y'
22 are looking for.
P 23 E
I think people have listened.
We have been trying N
i 24 to finally come up with what is the best we can do to say O,
b- /
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Mi generally how to achieve reliability Of the sort you want for
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BWil rg8 340 1
the event you are predicting against.
2 There is a discrete list of things that we think a
is the right stuff for those diverse trips.
t 4
MR. CARBON:
I would like a copy of that too.
6 MR. MATTSON:
Can you make sure that gets down a
here.
End o'./en 7
VOICE:
Yes.
8 9
10 11 12 13 14 16 16 l
17 18 l
19 20 21 l
22 28 24 O
l
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--.. _ _ =.
341 BW:jl 12:1 l
1 MR. OKRENT:
If I can ask a naive question, I sus-2 pect if I were to do the kind of risk-impact studies that are 3
being done in other areas by the Staff for ATWS on the 4
Westinghouse reactor, taking the kinds of assumptions the 5
Staff has made concerning its ability to write out ATWS, the 6
consequences, and the current thinking on how good a large 7
dry containment is and so forth, I might have a hard time 8
justifying -- requesting them to do one thing different --
8 since the calculated risk, the change would be so small, since you already would estimate so small a risk.
11 If I am wrong in my estimation of this risk change, 12 tell me.
If I am not wrong, then help me.
13 MR. MATTSON:
There are two areas like that which I4 are hot right now.
You could reach that conclusion and 15 generally people will agree with it.
16 If you look! at PRA, if you look at realistic analy-II sis, you come to the conclusion that what-you get in risk I8 reduction does not justify taking an action.
The others is igniters in small containments.
20 Without belaboring it, you will see it is not justified if I
you look for yourself.
But on other grounds, you can come to l
a conclusion that is the right thing to do.
For igniters, it happened at TMI.
If'it happehed..in the small containment 24 again, it would have much more consequence.
Not being able i O.
25 l
to face those consequences for something that is already l
l 1
3
- - ~,
.----y-,
BW:31 12:2 i
342 1
happened, design a system to prevent it.
2 Now, in the case of the reactor -- the Westinghous'e 3
reactor trip system, you can come to the conclusion that they 4
can live with Service Level C for the -- not design basis, but 5
what, as somebody calls it, the garden variety ATWS and ride 6
the event.
7 But if they have one PORV blocked, they raise the 8
pressure by 150 pounds.
If they have two PORVs blocked, they 8
raise by 300.
Half of'the Westinghouse plants in America 10 operate with all PORVs blocked, because they modified them 11 for a low-temperature,over-pressure protection, and they 12 leak at high pressure.
They are not there.
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13 The garden variety ATWS gets 300 pounds added to it.
)
14 It is 300 pounds over Service Level C, the 3200 pounds was 15 calculated for no human error and no equipment failure.
16 One cognitive error, one additional piece of equip-17 ment failed of the wrong sort, and you are going to raise 18 the pressure some more.
l 19 So, you write an ATWS, but with some small margin for the uncertainties that you are involved with in making i
21 such calculations.
You come back to are you willing to 22 challenge a system, the overall system, with that kind of 23 event, where other people have been able to achieve higher reliability in reactor trip systems without significant v
=
additional cost.
BWHijl 12:3 343 1
And having thought about those things, my conclusion 2
is no.
And you should increase the diver'sity of the Westing-3 house reactor trip system.
4 MR. OKRENT:
If you were to look at utility 5
submission on PRA, they would claim the reduction in risk is 6
very modest, indeed.
And even with the things you have pro-7 posed, I think you would not estimate a very large likelihood 8
of coremelt, let alone a large release.
8 Let me make it clear.
I am not arguing against 10 improving the reliability of the Westinghouse scram system.
11 You should do it, even though you said they had all of this 12 capability.
ps 13 What I am getting at is the following:
You do this b
14 PRA stuff.
You can come out with a conclusion that this is 15 not worth doing.
16 MR. KERR:
His point is not let PRA stand in the 17 way of strong convictions.
l 18 (Laughter.)
i 19 MR. MATTSON:
Or conversely --
l (Laughter.)
l 21 MR. MATTSON:
-- don't let wrong decisions stand 22 in the way of --
l MR. OKRENT:
You only have strong convictions after the event apparently.
The hydrogen occurs.
The scram 26 breakers did not work.
I have a problem with that logic,
344 BW jl 12:4 1
because one of these times it ain't going to stop quife so (Q
2 short.
3 MR. MATTSON:
I hope you're not suggesting that 4
my strong conviction came after the ATWS event.
5 MR. RAY:
I will allow two more questions.
Dave 6
has been very patient.
7 MR. WARD:
Roger, I realize the chairman is trying 8
to move you along, but you skipped over your page number 9.
8 I want to hear a little bit about the operator 10 response.
- 11 Maybe we can go fast, but I will just ask a few 12 questions.
13
)
One is:
What is the 40 to 100 seconds time avail-14 able?
What does that mean?
15 MR. MATTSON:
Depending on whether you are 'a B&W, CE, 16 or Westinghouse plant, you have between 40 and 100 seconds to 17 execute successfully a manual scram if the automatic scram 18 function fails at power when it is demanded -- 40 to 100 18 seconds, the pressure goes up, and you cannot arrest it short of the peak that it is going to reach due to the inherent 21 capabilities of the machine.
22 MR. WARD:
That must be dependent on what is demanding the scram.
MR. MATTSON:
This is for the the loss of feedwater p
'%Y g
type of event in the PWR.
1
345 BW jl 12 5 1
MR. WARD:
What about the situation of ambiguous 2
indications of a scram and the situation with procedures, 3
whether or not the operator is required to initiate a manual 4
5 Is there going to be some new requirement coming out 6
of this?
7 MR. MATTSON:
Yes.
And there is disagreement within 8
the Staff as to what is ought to be.
9 If I understand correctly today, the Division of 10 Human Factors has changed its position since Salem was 11 restarted, wherein a position.was taken "when in doubt, punch 12 it out.
If you get a demand for an automatic scram, go 13 immediately to manual and confirm it manually."
14 In a boiler that is done, but not with scram buttons, 15 It is done with a mode switch, because they like what the mode 16 switch does to auxiliary systems better than what the scram 17 switch does.
18 Westinghouse owners, B&W owners, and CE owners, the 19 utility groups that are involved in:the emergency procedure guidelines, have protested mightily. The basis of the protest 21 is it teaches operators not to believe their instruments.
It 22 is a philosophical sort of an agreement.
23 Human Factors has waffled a little.
They would not 24 appreciate me calling them wafflers.
They changed a little.
V 26 They said they would allow a little investigation by the
BW:jl 12:6 346 1
operators as to whether the scram occurred upon demand before 2
the operator is to confirm it manually.
3 Mr. Eisenhut and I are in disagreement with them, 4
and they are trying to work it out.
I presume within some 5
short time they will.
That is something you will get to interact with us on.
7 Subject of Volume 2, going forward:
That is a O
staff action, rather than a licensee action.
8 Ray, you are the last.
10 MR. EBERSOLE:
I cannot think of a batter time to
+ 11 say this here.
12 One of our veteran consultants and I live in the 13 same town, and I have listened to him.
In fact, there may be 14 some new insights that have come from his thinking about this 16
-- E. P. Eppler.
16 I am just going to quickly run through some elements, 17 i
j sort of a program of study, of which one part is his own 18
(
concept of what might be done to improve this problem area.
I' The main theme in the front end of it is to reduce I
20 scram frequency for the use of coincident trip requirements l
21 on control grade equipment out in the plant, which now initi-22 ates scram on central channel failures and a host of other 23 things.
24 The general theme is to reduce scram frequency.
-s g
\\s 25 GE is offering main feedwater controls, which ought
BW jl 12: 7 347 1
to assist.
/%
2 The second thing is to upgrade the normal heat sink
~,
3 capacities and reliabilities so we do not fall back on our 4
safety-limiting safety final heat sink requirements.
This is 5
the condensor capacity bypass valve reliability and the con-6 trol reliability of those functions.
7 And then finally getting to the scram function or 8
setback function itself, he perceived that these new steps 8
that you are talking to improve that ATWS will not really 10 buy a great deal of improvement in the the reliability of the
- 11 systems.
It is hard to discern and almost impossible to test.
12 If you can go forward on reducing scram frequency,
[)}
it is something that you can see, you can measure it, and it 13 14 will make money for the companies,just to increase availabil-5 ity.
16 But finally, getting to the scram functions, his 17 concept is since we seem to believe the mechanical operation 18 of these rods is good enough, I think that little division of 19 one-thirds and two-thirds is arbitrary, that the real way to 20 go for increasing simplicity and reliability is to break the 21 rods into subgroups, the first of which will give you what 22 we used to call -- and it is nothing new -- a setback function 23 or a hot standby, with a diverse integral change, including 24 the sensors, which would have a system called " distributing
-w 25 coincidence."
It brings a little problem.
If you have a
BW jl 12:8 348 1
failure of a thermocouple on a pressure device, there would
?
2 have to be some problem worked out.
It would only give you a 3
setback from which you could quickly recover.
4 And then if you go to a parametric level, which 5
you could pick on any set of parameters, wherein you need 6
something better than halfs the rods, you would execute the 7
final trip with totally dif ferent trip chains,' which woul~d 8
t,2 separate within'those' chains.
9 MR. MATTSON:
Those'are in the B&W design now --
10 maybe not as far as would go, but control rectifiers with 11 regulating rod groups and breakers with safety rod group and 12 broken up into a number of groups with cross-batching.and m
13 things.
14 MR. EBERSOLE:
Buried in here is fixing the B&W 15 hydraulics?
16 MR. MATTSON:
Yes.
17 MR. EBERSOLE:
Those are the general elements of 18 the program.
19 What can be done about adopting -- coordinating a program like that7 l
21 MR. MATTSON:
How do you fit it into the institution 22 is the question.
I don't know.
I will think about it.
23 MR. RAY:
Thank you, Jesse, M
MR. MATTSON:
Could I take one more minute just to p
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gs j
mention something personally?
1*
l BW831 1
On the last page, I would encourage you to pick up 2
on this and do something about it.
3 Salem is another example of where the nuclear family, 4
you, the regulators, the designers, the users, are not coming 5
to grips with what I want to call reliability assurance, ther 6
thing that Hendrie tried to say in his version of the ATWS 7
rule, the thing that my task force tried to say in its report 8
and has now been taken out of the ATWS rule by the CRGR.
It 8
may be that its time has not quite come.
But sooner or later 10 this family is going to have to listen to what has been 11 achieved in reliability in the defense and aerospace industry 12 through formal reliability assurance programs and design, 13 construction, and operation, because they are better than us, 14 they are applying tools that we could apply.
And we are 15 moving too slowly.
16 So, we have lost, again, on the reactor protection 17 system with this good way to move, in my judgment.
And I am 18 going to keep speaking on it.
Maybe we will find some event 19 or some trigger to get us to do it.
We said it after Three Mile Island; it got forget-21 ten.
We said it after Salem; it is being turned aside again.
22 And I think the only two voices left are Frank 23 Rossman and I, so I hope someone is listening.
MR. RAY:
Thank you, Roger.
O 25 (Whereupon, at 11:42 p.m., the meeting was adjourned.)
END T 12 w. _........
CERTIFICATE OF PROCEEDI'GS k
This is to certify that the attached proceedings before the 3
NRC cot @lISSION 4
In the matter of:
ACRS General Meeting s
a e of hoceeMng: hMay, hem, W3 6
Place of Proceeding:
Washington, D.C.
were held as herein appears, and that this is the original transcript for the file of the Commission.
10 Barbara Whitlock si Official Reporter - Typed 12
'13
${
officiad Reporter - Signature 15 16 17 l
[
is 19 20 21 22 23
(
23 TAYLOE ASSOCIATES REGISTERED PROFESSIONAL REPORTERS NORFOLK, VIRGINIA