ML20027D156
| ML20027D156 | |
| Person / Time | |
|---|---|
| Site: | Clinton  |
| Issue date: | 10/15/1982 |
| From: | Goddard R NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | Willman P ILLINOIS, STATE OF |
| References | |
| ISSUANCES-OL, NUDOCS 8210280340 | |
| Download: ML20027D156 (24) | |
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M October 15, 1982 Philip L. Willman, Esq.
Assistant Attorney General Environmental Control Division 188 West Randolph Street, Suite 2315 Chicago, Illinois 60601 In the Matter of Illinois Power Company, et al.
(Clinton Power Station, Uni F 1)
Docket No. 50-461 OL
Dear Mr. Willman:
Your letter of September 2,1982 raised two questions associated with the ECCS at the Clinton Power Station. The following responses were prepared by Messrs. Brad Hardin, the reviewer who has furnished you with information on this contention previously, and J. Herb Williams, the licensing project manager for the Clinton Power Station.
Question 1:
Has Illinois Power adequately addressed the Humphrey concerns associated with Mark III containments as applicable to the ECCS at the Clinton Power Station?
Response
Humphrey's concerns were raised in May 1982 in the OL review of Grand Gulf Station. A public meeting was held on May 27, 1982 to discuss these concerns. The meeting was transcribed and available to the public.
In June the NRC Staff requested, 4
by letter, that Illinois Power Company address these concerns for the Clinton Power Station. Additional questions were sent to Illinois Power Company in July. An ACRS Subcommittee met on the Humphrey concerns on July 28-29, 1982. At the end of the meeting each member and consultant was asked to give his view of the concerns raised.
I have attached a copy of this portion of the transcript.
It also includes Illinois Power Company's presentation. The Staff review of the infor-mation submitted by Illinois Power for Clinton will be reported in a Supplement to the Safety Evaluation Report.
Question 2:
How do recent events at the Kuo Sheng No. 1 plant affect the function of the ECCS at the Clinton Power Station?
8210280340 821015 PDR ADOCK 05000461 PDR Q
. Response:
The instrument line break recently experienced at Kuo Sheng No. I due to impingement by the Low Pressure Coolant Injection ECCS flow had no effect on the performance of the ECCS. Equip-ment modifications are being made to protect the instrument lines from impingement damage.
The NRC Staff believe that a fair reading of the ACRS transcript and the above responses would indicate that no further concern over the Kuo Sheng incident is warranted regarding Clinton Contention 10.
If you have any further inquiries, please let me know, as the Staff would like to eliminate as many non-meritorious contentions as possible from this proceeding prior to the commencement of evidentiary hearings.
Sincerely, Richard J. Goddard Counsel for NRC Staff
Enclosure:
As Stated cc: w/ enclosure Prairie Alliance Sheldon A. Zabel, Esq.
Mr. Herbert H. Livermore Jeff Urish, Vice President Reed Neuman, Esq.
Jan L. Kodner, Esq.
Gary N. Wright Distribution:
Goddard /Chron Gutierrez/Patterson Lessy/Reis Murray Christenbury/Scinto Lieberman OELD FF (2)
J. Miller-216 J. H. Williams-340 Docket Files /PDR/LPDR bSO}
OFC :0 ELD j /:0 ELD NAME:RGoddard/fb,[f)::EReis
_____:_________.g'____:_0/g[/8 DATE :10/15/82
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AEEEEEEEE EEEElEE 2
1:05 P.M.
DR. PLESSET:
Let's reconvene End the next 3
itemonouragendaisapresentatiob"bromIllinoisPower 4
5 so if they will proceed.
Are they ready?
Yes.
All right.
6 MR. KANT:
Good afternoon.
My name is Eric
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7 Kant and I'm representing Illinois Power in these proceeding s.
8 (Slide Presentation) 9 Please excuse the quality of my slides.
They're-10 not what you're used.to seeing but I think they'll help 11 in presenting what I have to say.
Our initial involvement 12 with the Humphrey Concerns started in the May 27th meeting in Bethesda during which John discussed some of his 13
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- 14 concerns with us'and MP&L presented their first response 15 to the issues and after that meeting, we received the 16 transcript of the proceedings and went to work reviewing 17 g
them and the applicability to our plant.
,j 18 dn' June 23rd, we received a letter from g
Mr. Bernard requesting submittal of'a program to address 19
,g 20 these issues for our plant.
On July 6, we resonded to (f
21 that letter indicating that we were pursuing forming an
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22 owner's group with the other Mark III people to address
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these concerns as generically as possible.
We would be
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l 24 participating in a meeting July 22nd with Mr. Humphrey to 25 further understand the issues and there have been some 4
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1 additional issues that we had a chance to look at at 2
that time also.
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3 The final item was that we were going to participat e 4
in this meeting to again get a better" understanding of 5
what some of the concerns were and be in a better position 6
to respond to them.
7 Dased on the participating in those activities, 8
we agreed to provide a complete program by mid-August.
9 We feel at this point the majority of the work to to address these concerns can be done generically and 11 we intend to do it in that manner.
Additional plant 12 specific analysis is to be done by Sargent and Lundy.
13 Current estimates indicate that we can complete this
- ~ 1 <4 work in the first quarter of 1983.
I 15 We'd like to improve on that but I'm not in l
16 a position to ma'ke that commitment at this time.
g A summary of the perspective that we have, 17 18 on these issues at this time is that the design margins g
are very large for Clinton and the other containment.
19 j
20 We have a 95 PSI ultimate containment pressure.
CPS is
' f 21 a smaller reactor than some of the others and essentially i
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22 the.same size containment and as a result of this, the l
23 analysis being.done will most likely bound us also.
t 24 We concur with the evaluation presented by 25 General Electric and MP&L that the affects are second order a
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3 effects, that these issues do not present a significant 2
safety impact to the Mark III' design.
1
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3 That concludes my discussion this afternoon.
4 Are there any questions or comments"thh I can address?
DR. SCHROCK:
Will Sargent and Lundy do pool 5
6 dynamic calculations for you or is that in the generic 7
group?
MR. KANT:
Sargent and Lundy will be doing the 8
g load applications, right.
The pool dynamics load calcula-tions.
That's absolutely correct.
10 DR. PLESSET:
Any other questions of Mr. Kant?
11 I guess not.
Thank you.
12 MR. KANT:
Thank you.
13 DR.- PLESSET: ' I think we're going to have a
--14 Presentation by Cleveland Electric Illuminating-Company.
15 Mr. Pender, I believe?
16 MR. PENDER:
Yes.
My'name is Richard Pender.
37 l
18 I am the lead engineer in charge of mechanical design on g
39 Perry.
C j
20 (Slide Presentation)
{
Instead of boring everyone with yet another 21 i
f 22 chronological history of the Humphrey Issues, I think 23.
i.t would suffi,ce to say that, Perry has been following the, 24 actively following the issues since they were first l
25 identified in a letter from MP&L -- from Mr. Humphrey to l
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MP&L dated May.8.
A meeting was held with the Staff on 2
June 17th to discuss Perry's preliminary evaluation of
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3 the issues.
We have categorized those issues into
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4 generic and non-generic issue.s.
Approximately 2/3rds of i
5 the issues are generic in nature and Perry will be working 6
'with the owners groups on these issues.
The remaining 7
one third are either plant specific or not applicable to 8
Perry.
For those issues that are applicable to Perry, 9
we are presently performing in-house evaluation and to analysis as necessary to.close them out.
11 With regards to our schedule, we will be 12 formally submitting our program to the Staff the first 13 week of September.
This program wiil be similar to the
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- - 14 format of the' program submitted by MP&L and will define i
15 the action to be taken by Perry in closing out both 16 generic and plant unique issues.
'knconclusion,wefeelthatourprogram1s 17 I
l 18 consistent *with our licensing sdhedule and we anticipate 19 a completion date during the first quarter of 1983.-
j 20 We fully expect that these issue: that are applicable to f
21 Perry will be closed out prior to our fuel load.
a l d 22 Are there any questions?
8 I
23
.DR. PLESSET:
Who yas the architect engineer.
24 on this plant?
25 MR. PENDER:
Gilbert and Associates.
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DR. PLESSET:
Yes, thank you.
Any questions 2
of Mr. Pender.
3 DR. SCHROCK:
MP&L re, lied almost exclusively 4
on G.E. analysis codes.
Are you goihg'Uo do the same 5
so that it will be essentially a carbon copy of their 6
answers to the resolution of the problem?
7 MR.
P. ENDER:
Those generic issues that are s
applicable to MP&L and us, we will be relying on the G.E.
9 analysis.
10 DR. SCHROCK:
Yes, but even plant specific --
l 11 will they be analyzed --
12 MR. PENDER:
No our plant specific will be done 13 by Gilbert and Associates.
-- 14 DR.- PLESSET : ' Okay, any other questions?
15 DR. BUSH:
One that is not necessarily just 16 Perry.
I understand in some of,the hand-outs that there i
g was a joint meeting the 20th of July about or what was it?
17 l
18 MR. KUDRICK:
The 22nd.
g 19 DR. BUSH:
The 22nd of July and I have been t
j 20 listening to see if there was anything productive that 21 came out of that meeting.
I don't believe I've heard 2
,f 22 anything.
Was it just a kind of discussion of issues t
l 23 or what was the situation?
4 24 MR. PENDER:
I think that meeting, the one you're 25 referring to was just a meeting of all the utilities and b
w p
359 5
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Mr. Kudrick to discuss exactly what we planned on doing 2
with regards to an owner's group, forming an owner's group.
/
3 DR. BUSH:
So it was really just a sitting down
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4 of the --
5 MR. PENDER:
It was a kick-off meeting basically.
6 DR. BUSH:
That answers my question.
Thank you.
7 DR. PLESSET:
Since there are no other questions, a
thank you again.
g MR. PENDER:
Thank you.
10 -
DR. PLESSET:
Well, we're a little early but it we do have schedules of discussion and I would like to
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12 lead it off.
I'm going to call on'.the other members and 13 consultants to express an opinion here and I might say
. 14 that my remarks are directed primarily at Dr. Butler, 15 Jack Kudrick and Mel Fields because I think that's the P ace where they might best fit.
l 16 17 You may -- I'm sure they know, but the rest l
18 of you may*not appreciate that the.ACRS letter report to l g 19 the Commissioners on Grand Gulf talks about a low power s
l g 20 license and they gave approval for this, and for Clinton l Jj 21 and Perry they gave full power approval.
Now, the 2
l d 22 reason I think that Grand Gulf got the low power approval
- j 23, in our report, was primarily,it was the first plant th,at.
24 came in and there was still some concern on the part of 25 some of the members that the impact loads on the HCU floor
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had not been proven acceptable as far as the integrity 2
of that unit.
I think since that time there is a little 3
better understanding of this and I think-that now it 1
4 would be most likely accepted by ths:C5mmittee, so that 5
in a sense, those plants are all pretty much on an equal 6
footing.
a 7
Then of course now, we've had the concerns 8
raised by Mr. Humphrey and the question is, would this 9
change the view of the -- first the Grand Gulf subcommittee to and second, the view of the full committee?
And I think 11 that what this subcommittee can do is forward it's 12 views to both of those -- the Grand Gulf subcommittee 13 and to the full committee.
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14 Now-I'm going to call on the others for their 15 opinions but not to influence them, give my own-first.
16 My feeling is, that I, see no reason why these g
plants and Grand Gulf in partic'ular cannot go ahead and 17 j
18 receive a full power operating license.
There is nothing
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19 that's come forward since the reports that I mentioned have i
20' been prepared that would change my view on this question.
a l
21 Now, it's true that there were some concerns 8
22 raised by Mr. Humphrey that have occupied the Staff and l
23
.the applicant.
For example, things like encroachment.
24 I'm very optimistic about that.
I don't think it's going 25 to make any difference to the safety of the plant, but Y
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i that's just an optimistic forecast.
I'm sure that the 2
Staff will investigate th'is.
And in my view, recommending 3
that Grand Gulf in particular get a full power license
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4 doesn't pean that the Staff won't dc.stme more work.- I 5
am sure they~will but like other items in an application, thereareusuallyman[ points,someofthemgenericthat e
7 they have to straighten out to their own satisfaction, a
They have a responsibility in that direction and I don't g
see where there's anything new which really changes go this picture.
Maybe it's painted on a little broader n
horizon, but that to me is not a part.icularly essential item.
So that's'Ny' View.
I would. recommend that the 12 13 Grand Gulf sdbepmmittee and the full committee accept
(',t 34 this siguation.and proc,eed as usual with the licensing 15 of the plant. ' We've, alr'vady done that for Perry and Clinton 16 It's just a matter of Grand Gulf and that's a relatively
.,4 17 small step in my mind from the 4% approval to the full I.,
7l 18 power._ '
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Now, there's a spectrum of people up here ig 20 anel they may give you other views so let me go down the
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l 21 table.
Spencc, would you like to -.
2
' DR. '30STI:
Sure.
Dr. Ple'sset knows that I don't
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+ influence t(taE easily so his prior comments haven't really 23 c; i-
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24 25 1 would Dope that the issues cotild be sesolved v, _.
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generically rather than case by case for a. variety of 2
reasons, certainly Staff load and I think also as you 3
see in the tenor of my remarks, I don't consider them
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4 as having that major an impact that we need to overload 5
the industry.
6 With regard to a degradation of safety, function 7
which I think is the important thing, I see no significant-8 losses in the Grand Gulf design and I suspect this to 9
be true for the STRIDE design but I would reserve final to judgement pending a little more information.
Quite 11 frankly, I'm not that familiar with the STRIDE design.
12 The preceding comments consider the effects 13 of loads rather than the subtleties and thermo-hydraulics 14 since I don't-consider' myself very expert in that area.
15 I have no reservations in permitting Grand Gulf 18 to go to full power on the basis of these issues that t
17 we've been discussing.
Obviously other issues may control g
j 18 this decision.
That's been the. case in other plants and i
19 I think that the decision of a 5% li* cense on the first c
l j 20 plant was a very logical one.
i i i 21 At'this. time I reserve judgament on the other s
i d 22 Mark III designs simply because of -- I haven't 1 i; 23,
had a chance t,o look at them,and there may be some 24 subtleties that would affect the plant specific areas, 25 though I suspect this may not be the case.
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With regard to Mark I's and II's, I feel that 2
most of the issues are either inapplicable or insignificant 3
with regard to safety margins.
There may be a few
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4 applicable issues that need further~ examination and I hope 5
again that these could be generic.
6
- I go back to my original plea and feel that some 7
level of instrumentations that measure a critical pressure a
temperature, stresses or strains could be valuable in g
a Mark III design and possibly in a Mark II to confirm jo the loads are comfortably within the design envelope.
11 which would hopefully. minimize the continuous discourse 12 on design margins in this particular area.
13 DR. PLESSET:
Thank you, Spence.
I didn't
,, 14 want to imply. that you would be at all malleable.
We 15 know otherwise.
A good metallurgical man.
16 Before I call on Dr. Schrock, I should mention 17 that Mr. Ray, a committee member, indicated his concurrence
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18 with the views that I've expressed,regarding this 19 situation and Dr. Zudans did likewise.
I'm going to make g
g 20 life easy for Virgil by letting him have the microphone.
l 21 DR. SCHROCK:
I'll keep-it only briefly.
g s.
f 22 With regard to the Humphrey Issues, my view is 23 that I heard nothing that would lead me to have any.
l 24 misgivings about proceeding with a full power license for 25 Grand Gulf.
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I think that many of the things that were 2
discussed here were certainly worth discussing.
'I have 3
some severe reservations about whether we have set an
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4 unreasonable precedence for raising "Issnes of this level 5
of importance in the way that they eventually evolved 6
in a meeting of the subcommittee of the ACRS.
I think 7
that there is some risk in our proceedings here in s
following this path.
9 With regard to the responses from the utilities 10 and from the General Electric Company and Bechtel, I l
11 think it appears to me that the answers that are being 12 sought will be obtained in a satisfactory way.
I have 13 no real concern that there will be serious questions
_ _ 14 remaining after all of the things that weve heard to be 15 done will be accomplished.
16 One point I would make with regard to the 17 assurance with re'spect to design margins is that I don't
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18 like to see design margins essentially misrepresented.
g 19 I don't mean to say that they were intentionally a
j 20 misrepresented but I don't like to see them carelessly a
l 21 misrepresented.
I. think the question of what a design 3
f 22 margin is-is a serious question and it should be dealt 23 with very carefully.
I Frequently, usually, I think we do not know 24 25 very well what our design margins are and to overstate them 1a
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i is not a good practice in general.
With regard to the 2
enc.oachments as a specific issue, it seems to me that 3
we have had a lot of controversy in the hydrodynamics of 4
the pool responses, and that it would Te very desirable.
5 to have some of,these calculations confirmed by other 6
than th'e designer of the system and for that reason, I 7
was pleased to hear that there will be some additional a
supporting calculations submitted to the staff that will e
be done by other AE's using different codes.
10 That concludes my comment.
11 DR. PLESSET:
Thank you, Virgil.
Mr. Etherington?
12 DR. ETHERINGTON:
I think everyone is addressing 13 these concerns in a responsible manner and I see nothing
_ _14 in the unresolved items that would warrant withholding 15 a license, full power operating license.
16
-DR. PLESSET:
Dr. Garlid?
17 DR. GARLID:
Well, I think the issues that g
l 18 were raised were real ones but were for the most part le second' order with respect to safety.
MP&L has been (j
20 responsive to the concerns that were raised, and that lf 21 the Staff has developed a reasonable plan, g
although if ld 22 anything it's on the conservative side of how to deal l 2 23 with them.
l 24 I don't think the issues should cause any. delay 25 and finally, 3 think the question of interface is whether C-t
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1 they are interfaces between organizations or interfaces 2
of problems between one discipline and another,'that 3
these are generic issues and not unique to these plants.
4 DR..PLESSET:
Thank you. "Neise?
5 DR. EBERSOLE:
Yes.
May I ask G.E. a question 6
about the containment structural design and the limitations 7
on it?
It's always concrete, I take it for N16 and other -
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shielding purposes.
Does it have a membrane liner on
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9 either side?
Do you give freedom to the AE's to put to liner skin on the structural wall?
Do you know?
11 MR. DAVIS:
This is Mac Davis from General l
12 Electric.
We place no requirements at all on the AE as 13 to whether he can or cannot put liners on.
_ _ 14 DR: -EBERSOLE:
Are any of these equipped with 15 liners?
Membranes on either side?
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16 MR. McGAUGHY:
We have what's -- well it's not 17 a O type liner.
We have concrete steel forms that are g
j 18 welded together.
In essence, a, liner but it's not a --
19 DR. EBERSOLE:
Is it on both sides?
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20
,'MR.' McGAUGHY:
It's on the inside.
ij 21 DR. EBERSOLE:
THen I would only ask one question.
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22 When that particular wall is subjected to negative l
23, pressure,and therefore gas in-leakage, how do you retain t
I 24 that liner in'the structural context?
How do you keep 25 it from peeling off?
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MR. McGAUGHY:
It's designed to 3PSID, to withstand that pressure.
2 DR. EBERSOLE:
In otherwords, it's anchored at 3
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4 sufficient intervals to --
MR. McGAUGHY:
Yes.
See, well, it's not Q, it's 5
6 got to be seismic.
We've got to show that it won't fall off 7
in an earthquake and it will withstand the amount of 3PSID.
DR. EBERSOLE:
I'm talking about due to in-leakage 8
from the high pressure side.
How do you keep it from g
peeling off and flying inward into the containment?
ja.
MR. McGAUGHY:
It has ancho,rs on the back of it, into the concrete.
12 DR. EBERSOLE:
So it's periodically anchored?
13 MR...Mc.GAUGHY:
That's correct.
_. 14 DR. EBERSOLE:
On the inner face.
15 j
MR. McGAUGHY:
Yes, sir.
16 DR. EBERSOLE:
Is it designed to permit 17 g
atmospheric penetrat' ion and to' carry the structural' load I
18 at the liner face?
On the inner face of the liner, next 19 g
to the concrete?
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I'm not sure I understand the MR.'McGAUGHY:
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question.
t, DR. EBERSOLE:
Okay.
The gas, the atmosphere h
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on a reverse pressure mode will be carried inward through 24 the leakage of the concrete and the pressure gradient will 25 l
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occur on the liner.- Are you with me?
2 MR. McGAUGHY:
Yes, I think so.
4 3
DR. EBERSOLE:
Okay, the pressure gradient k
4 being almost all contained on the lider, how do you 5
support it against the buckling load?
6 Somebody is holding their hand up.
7 MR. BROSE:
I'm Tom Brose from Bechtel in 8
Los Angeles.
The generic Bechtel design of a liner g
plate is not a structural member.
1o DR. EBERSOLE:
That's what I was afraid of.
11 So now what's going to keep it from flying all over the 12 place if you apply an external atmospheric load on it.
13 MR. BROSE:
It is anchored to the concrete
,. 7
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_ 14 containment by. three by two by quarter-inch channels ~
l 15 spaced every fifteen inches.
,It's designed as a membrane 16 only.
Okay, your question as to the differential 17 Pressure across the liner throu'h diffusion through g
-I l l 18 the concrete would not occur because the liner is i
19 continous to the outside surface, and by that the liner lj 20 is attached to the penetration -- you wouldn't -- I don't
,,f 21 foresee a differential pressure occurring across the
'f 22 liner.
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You do not put any pressure in,
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DR. EBERSOLE:
l l' your design against the exterior face of the liner, that 24 l
25 is the face between'the the concrete and the steel?
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MR. BROSE:
No.
2 DR. EBERSOLE:
You don't look at the permeation 3
of atmospheric pressure against that face?
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MR. BROSE:
No, but the lideT'itself is designed 5
for a negative load due to the other new loads which create 6
such loads on the liner and it has the capability en 7
Grand Gulf -- I can't give a specific number, but 8
whatever the negative pressure is from SRV.
g MR. McGAUGHY:
He's not -- we're talking about to -
inside the drywell.
11 MR. BROSE:
No, no, he's talking about containment 12 MR. McGAUGHY:
I'm sorry.
13 MR. BROSE:
He's talking about the containment
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liner and the containment liner is capable of withstanding
_ _ 14 15 the negative pressure from an SRV discharge which would 16-suck on the liner in the order of magnitude --
17 MR. McGAUGHY:
At least SPSI.
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18 DR. EBERSOLE:
You follow me -- I'm just looking 19 at the anchor mode to the concrete and hoping it won't g
j 20 scallop and come off.
i aj 21
.NR. BROSE:- It's designed'for a suction load, a
d 22 DR. EBERSOLE: In otherwords, you do then.put n
23 a.tmospheric pressure on the back face?
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24 MR. BROSE:
Yes.
25 DR. EBERSOLE:- You have to.
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MR. McGAUGHY:
That's the only way you can
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2 get it, I guess.
3 DR. EBERSOLE:
And you put what, 5 PSI?
4 MR. BROSE:
Whatever Gran3 Gulf's design criteria 5
are.
6 MR. McGAUGHY:
The negative loads from the SRV 7
actuation are at least five.,
8 DR. EBERSOLE:
So you're anchored at sufficient 9
intervals per square foot to hold it together.
10 MR. BROSE:
Yes.
11 DR. EBERSOLE:
Okay, that's one question I had.
12 Other than that, I have no reservations, Dr. Plesset 13 about this containment.
If I have any reservations about n-
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_ 14 thermo-hydraulic loads in other contexts such as the
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15 drive, controller drive units -- sorry, not the-CRU's but to the tubes and instrumentation and other thermo-hydraulic loads that may be imposed on sa'fety equipment which we 17 1
l 18 haven't pinpointed here as we have the HCU's on this floor.
fg 19 But those will come up in another context rather than c
g 20 a containment context.
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, i 21 DR. PLESSET:
Thank you, Je.ese.
Arthur?
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22 DR. CATTON:
I've been involved, I guess, with 23 the Mark I,.II and III in th.e suppression pool loads and l ('
24 so forth.
And it's my view that the Humphrey Issues are receiving 'far more attention than they deserve by NRC, 25
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1 G.E., and MP&L.
I.have no reservations regarding the 2
Mark III containment scheme.
I have some residual 3
questions that I've raised through the two day period.
4 I've had some promises with respect"to experimental data
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5 and answers and I'll just await receiving them.
6 DR. PLESSET:
Thank'you.
Let me -- do you want to 7
make another comment?
I think we've heard from the wise 8
men at this table and I'm not including myself in that 9
category, but you see there's kind of.a consensus here.
to I'd like to follow up on a couple of points that were 11 made by Dr. Bush, Dr. Catton that one has only a certa,in 12 amount of resource at one's disposal and one has to use 13 this wisely.
The question is, are you using these
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_ 14 resources for-the most' efficiency for safety?
And it's 15 been indicated or hinted at that maybe you aren't by paying 16 so much attention to these particular issues that we.'ve been 17 talking about the past two days.
And this disturbs me g
l 18 as well as the other members up here, that you may be 19 not helping safety by disregarding other items and lj
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20 concentrating on these and this I think, you have to think lJ l
21 about and I think along this same line, the kind of a cost aj 22 benefit approach to safety.-
2 23 Dr. Bush mentioned.his distress at Mark I an.d II
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being drawn into this and this seemed to me particularly 24 25 non-productive.
We indicated it was not productive for 9
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Mark III's but to get the Mark I's and II's in it is
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2 really a little bit well, more than unfortunate and I 3
wanted to stress those points to you, Jack in this
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4 connection.
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5 Now, unless the people up here at the table 6
want to make more comments, I'd be glad to have you respondtowhatwe'vejust$eensaying.
Jack or Dr. Butler, 7
a either one.
Both maybe.
g MR. KUDRICE:
We appreciate your frankness in f
to your positive comments relative to the concerns that 11 have been raised.
Since we have been informed'of the 12 Humphrey concerns, we have taken about trying to resolve 13 those as quickly as possible and hopefully we have.
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__ 14 given the subcommittee ~the impression that we do not 15 feel that the majority of the concerns are significant is safety issues, and I hope that we have made that point 17 earlier yesterday.
We have, however, believed that there 1
l 18 are one.cn two items that deserve our attention and to that based on the information that we've gotten, we believe j
20 that we will be getting a satisfactory response.
- However, 21 we will be awaiting judgement until we get those responses.
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22 In a similar fashion, we are waiting final acceptance t
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0,f the response.
Until we get the necessary background.
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24 on which the judgements were made, that these loads were 25 indeed secondary, I don't believe that we are that
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1 significantly differing from tho' subcommittee.
We have 2
asked the various elements of th'e industry to respond i
3 to those comments.
The magnitude of effort that that k'
4 industry responds to would be indic5tiFe of the magnitude 5
of safety concerns that they feel those concerns justify.
6 We are perfectly -- in fact we have' indicated rather 7
strongly that generic efforts be established wherever l
8 possible, so I' don't believe that we are inconsistent 9
in that manner.
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10 DR. PLESSET:
Thank you, Jack.
I don't want 11 to appear to abrasive in discussing the staff's work 12 but evidently we do have a fair amount of agreement 13 which is unusual between us and you.
Dr. Butler?
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_. 14 DR.- -BUTLER:
Let me just add a little bit more.
15 I agree with Jack.
We have pretty strong consensus with 16 the views expressed by the subcommittee.
g On the matter of margins that Dr. Schrock 17 l
18 hit on, I agree with that, that many of the margins g
depicted during the' presentation were relying on what 19 j
20 I'll call margins generally looked at for degraded core f
21 consider'ations.
When we're dealing with design basis a
f 22 accidents, these different margins have a specific. function s
l 23,, and we do,n't want to lean to,o heavily on them for these.
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24 new areas.
25 The other point that I wanted to make is that many r
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of these new areas are really design questions rather than
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2 safety questions.
And if you delegate the responsibility 3
to do a good engineering job, you would expect that these k~.
4 issues would be suitably dealt with."- There are no
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5 real technological questions at hand associated with 6
these issues.
To reinforce Jack's earlier statement, we 7
l 8
intend to moderate the amount of resources obligated to 9
resolving these issues.
To the extent practical, 10 we will push for generic treatment of them so as to 11 minimize the utilization of resources.
Thank you very 12 much.
13 DR. PLESSET:
Thank you, Dr. Butler.
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-- 14 appreciate that and I might say that all the members of 15 the subcommittee received a lot of literature, reports, 16 from meetings of the NRC and ma.ybe we got a little bit g
of an exaggerated idea of what effort went into this.
17 ll 18 Jack nods his head indicating c.oncurrence.
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19 MR. KUDRICK:
No, I believe that I will be w
l j 20 supporte_d by MP&L by'saying that there has been si'gnificant 21 effort to date on these particular issues.
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22 DR. PLESSET:
Yes, and they seem to be getting 2j 23, e little,out of hand if I may say so in the amount of
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24 effort and report writing and communications and so on 25 and I know you've got a lot of other things you have to IY..
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work on, some of which you know, the ACRS thinks are x
2 very important that the Staff isn't pushing very hard.
3 I don't need to mention them.
You can think of them k~
4 yourself.
5 Well,.anyway, are there any other commentc?
6 Jesse, do you want to. comment?
7 DR.,EBERSOLE:
No, I rest.
8 DR. PLESSET:
Ivan, Virgil?
Well, there's no g
use keeping you here any longer.
We've found it very to interesting.
I was going to say profitable.
I wouldn't 33 go that far.
And I presume that you will be meeting with l
the Grand Gulf subcommittee and with the full commif. tee 12 week after next, is that correct?
Well, until then, 13 l
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let's let the. subject'go.
We are adjourned.
_ _14 15 (Whereupon, at 1:40 p.m.,
the meeting was 16 adjourned.)
17
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