ML20062E294

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Transcript of 820728 Public Meeting Re Discussion & Possible Vote on Full Power OL for Facility in Washington,Dc. Pp 1-110.Viewgraphs Encl
ML20062E294
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Site: San Onofre Southern California Edison icon.png
Issue date: 07/28/1982
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REF-10CFR9.7 NUDOCS 8208090282
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t NUCLEAR RIGULATORY COMMISSICN k

W-f' COMMISSION MEETING In e.% " " Cf:

PUBLIC MEETING DISCUSSION OF AND POSSIBLE VOTE ON FULL POWER OPERATING LICENSE FOR SAN ONOFRE UNIT 2

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DATI:

July 28, 1982 PAGzs:

1 - 110 AT:

Washington, D. C.

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  1. - (. REPCRTLTG ALDEIL%.Y 400 vi_yd-+a Ave., S.W. Wmah4"g-9, D. C. 20024 l(

Ta.laphc=a : (202) 554-2345 8208090282 820728 PDR 10CFR FT9,7 PDR

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 3

4 DISCUSSION OF AND POSSIBLE VOTE ON FULL POWER OPERATING LICENSE FOR SAN ONOFRE UNIT 2 7

8 PUBLIC NEETING 10 Il Nuclear Regulatory Commission Room 1130 12 1717 H Street, S.

W.

Washington, D.

C.

13 Wednesday, July 28, 1982 34 I

The Commission set, pursuant to notice, at 3:00 p.m.

I BEFORE 18 NUNZIO PLALLADINO, Chairman of the Commission JOHN AHEARNE, Commissioner 18 l

THOMAS ROBERTS, Commissioner AMES ASSELSTINE, Commissioner 20 STAFF AND PRESENTERS SEATED AT COMMISSION TABLE:

21 S. CHILK 22 L.

BICKWIT F. REMICK 23 H. DENTON D.

EISENHUT 24 H. ROOD 25 ALDERSON REPo3 TING COMPANY,INC, l

400 VIRGINIA AVE., S.W., WAShlNGTON. D.C. 20024 (202) 554 2345

2 1

AUDIENCE SPEAKERSa 2

R. MATTSON B. GRIMES

/

3 C. KNIGHT L. NORDERHAUG 4

REGION Y SPEAKERS:

5 R. ENGELKEN 6

J. CREWS A. CHAFFEE 7

8 9

10 11 12 13 P

14 15 16 17 18 19 20 21 22 23 l

24 25 ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345

e DISCLAIMER This is an ' unofficial transcript of a meeting of the United States Nuclear Regulatory Commission held on July 28,1982 in the

'Commissi'on's offices at 1717 H Street, N. W., Wasnington, D. C.

The meeting was open to public attendance and observation.

This transcript has not been reviewed, corrected, or edited, and it may contain inaccuracies.

The transcript is intended solely for general informational purposes.

As provided by 10 CFR 9.103, it is not part of the formal or informal record-of decision of the matters discussed.

Expressions of opinion in

.this. transcript do not necess rily reflect final determinations or

.beliefs.

Ho pleading or other paper may be filed ~with the Commission in statement or argument any proceeding as the result of or addressed to any'orize.

contained herein, except as t.9e Commission may auth N

e

3 1

EE0CEEDIEEE 2

CHAIRMAN PALLADINO:

Good afternoon, ladies 3

and gentlemen.

4 The Commission meets this afternoon for 5

discussion and possible vote on full power operating 6

license for San Onofre Unit-2.

7 On February 16, 1982, the Director of the 8

Office of Nuclear Reactor Regula tion issued a license 9

limited to low power operation for San Onofre Unit 2.

10 Since that time, the licensee has loaded fuel and 11 conducted post-fuel load hot functional tests.

12 The San Onofre Unit 2 reactor achieved initial 13 criticality on July 26, 1982, and nov' the licensee vill 14 conduct lov power tests.

15 Dn Tuesday, July 27, the Court of Appeals for 18 the District of Columbia denied a request to stay the 17 San Onof re operating license, and I will ask the General 18 Counsel to highlight the outcome of that case.

19 MR. BICKWITs Very good, Mr. Chairman.

20 CHAIRMAN PALLADIN0s Let me finish a fev 21 procedural items.

22 We have with us from Region V, Leroy 23 Norderhaug -- Leroy, where are you?

Nice to have you 24 with us -- who is Chief of the Safeguards Branc in the 25 region.

We also have a telephone hook-up, at least so I ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W WASHINGTON, D.C. 20024 (202) 554 2345

4 1

am told, with Region V.

On the other end, we have with 2

us Robert Engelken, the Regional Administrator; Jesse 3

Crews, Director, Division of Resident, Reactor Projects 4

and Engineering Insper tion ; Daniel Sternberg, Branch 5

Chief, Reactor Operations Projects Branch; Gerald 6

Zwetzig, Section Chief, Beactor Operations Projects 7

Branch; and Alf red Chaf fee, Resident Inspector f or the 8

San Onofre Nuclear Generating Station.

9 Bob, could I confirm that all of you are on 10 the line?

11 MR. EN GELK EN s Yes, we are, Mr. Chairman.

12 CHAIRMAN PALLADIN0s Thank you.

13 I might indicate that this is a voice actuated 14 system, so if the people on the other end are talking, 15 you won't be heard until he stops talking and you 16 start.

I understand the telephone line vill be open 17 throughout the Easting.

18 At this time, unless there are comments by my 19 fellow Commissioners, I am going to turn the meeting l

20 over first to General Counsel, and then to Mr. Dircks, 21 Mr. Denton, and staff, to discuss the San Onofre Unit 2 22 licensing.

23 MR. BICKWIT:

Mr. Chairman, the end result of 24 that litigation is that it has no operational 25 significance for the Commission's actions today and ALDERSoN REPORTING COMPANY,INC.

400 VIRGINIA AVE., S.W., WASHINGTON. U.C. 20024 (202) 554-2345

5 hereaf ter in this matter.

It is as if the litigation 2

had not taken place.

3 The Petitioners, Carstons, Friends of the 4

Earth, et al., had asked for a stay of the low power 5

license, and had petitioned for review of the 6

Commission 's denial of a stay of tha t licen se.

The 7

panel of the Court has denied the stay, and has denied 8

the petition for review.

9 The Petitioners also initially asked for a 10 stay of the Commission's immediate effectiveness order 11 with respect to the full power license.

Throughout the 12 course of this litigation, it became clear that 13 Petitioners had misunderstood the meaning of the 14 immediate effectiveness order regarding the full power 15 license.

They had understood it to have authorized the 16 issuance of a license, whereas in fact it does not do 17 that.

It paves the var for the authorization of that 18 issuance, should the Commission decide to issue the 19 license.

20 The Court did not speak to the petition for l

21 review of that immediate effectiveness order.

The 22 meaning of the Court's failin'g to speak to it is 23 unclear.

What is clear is that the Commission can move i

24 forward today and consider the matter without regard to 25 any action the Court has yet taken.

ALDERSoN REPOR1?NG COMPANY,INC,

6 1

CHAIRMAN PALLADINO:

Thank you.

2 Are there any questions?

3 Then let me turn the meeting over to Mr.

4 Dircks or Mr. Denton.

5 HR. DENTON:

The action that we recommend 6

today is that you authorize issuance of a full power 7

license for this station.

It is the first Combustion 8

Engineering Plant to have a complete review by the staff 9

since Three Mile Island.

So what we will try to hit to today in our presentation are those unique features of 11 this plant.

There are several that I want to highlight 12 for you.

13 One is the issue with regard to the PORY.

The 14 Combustion Engineering plant does not have a PORV, and 15 there was a lot of emphasis during our review on the 16 PORY, and we will cover tha t one in more de tail.

17 Another is the independent design review.

An 18 effort was undertaken about a year ago to verify the 19 accuracy of the seismic design of the plant.

We will 20 report additionally on that.

21 Some of the seems which we devoted a lot of l

22 attention to, such as seismic design, were subject to 23 adjudication, and I will no t go into those.

24 The operating experience, since the issuance 25 of the low power license will be covered by Region V.

ALDERSON REPORTING COMPANY,INC.

MS VIRGINIA AVE., S.W., WASHINGTON D.C. 20024 (202) 554 2345

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He also will report on some safeguard aspects of this 2

review, and then we will cover the amendments to the 3

operating license that we would propose be a part of any 4

license to be issued.

5 I have Darrell Eisenhut and Harry Rood, the 6

project manager, who will walk us through each of these 7

issues.

8 Darrell or Harry.

9 MR. EISENHUTs Thank you, Harold.

10 We will try to go down through this.

If I 11 could have the first slide.

12 This is basically an outline, I think everyone 13 has this package of slides, it has slightly been revised 14 and there are some additional aspects in here since the 15 package we sent down to the Commission last week.

16 Harold just went down the agenda here.

We 17 will be walking through it with several different 18 speakers, and when we get to the end, there are a couple 19 of conditions that have been added, and there is at 20 least one outstanding issue that needs to be resolved 21 prior to the issuance of the full power license.

22 I will turn it over first to Harry Rood who 23 will go through the first several topics.in the agenda.

24 MB. BO3D:

Thank you, Darrell.

25 The first slide gives a little background ALDERSoN REPORTING COMPANY,INC,

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description.

2 The next slide gives a little background 3

description on the plant and the location.

The 4

principal Applicant is Southern California Ed iso n.

They 5

are acting as project managers for the facility.

There 8

are three other owners, San Diego Cas and Electric, and 7

the Cities of Anaheim and Riverside, but Southern 8

California Edison is managing the project, so we mainly 9

deal with tnem.

10 It is a pressurized water reactor of a C-E 11 design, as we have mentioned earlier, with a large dry 12 containment.

The architect-engineer-constructor is 13 Bechtel Power Corporation.

It is an i100 megawatt 14 electrical plant located in San Diego County, about five 15 miles south of the center of San Clemente, and the 18 population within five miles is estima ted f or 1980 to be 17 27,000 people.

It is the first plant licensed since 18 Arkansas Unit 2 roughly four years ago.

19 COMMISSIONER AHEARNE:

Is Unit 3 the same 20 kind?

t 21 MR. BOOD:

Unit 3 is essentially a duplicate l

22 of Unit 2.

23 COMMISSIONER ROBERTS:

What is the similarity 24 between this plant and the Palo Verde units?

l 25 NR. ROOD:

Palo Verde is a CSAR design, and I l

ALDERSCN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W WASHINGTON, D.C. 20024 (202) 554 2345

B 8

9 1

think that it is a little bigger.

They do share many of 2

the same features.

This is nat c System 80 plant, but 3

it does have a lot of the System 80 features on it.

4 Going to Slide 3, status schedule.

The 5

construction permit was issued in October of 1973.

The 6

OL application came in in 1 ate 1976, and van docketert 7

for review in March 1977.

We issued an operating 8

license for Unit 2 on February 16, 1982, which was 9

limited to operation at or below 5 percent power.

10 The construction schedule of Unit 2 was 11 completed in February 1982.

Unit 3 is, per the 12 applicant, going to be completed in November 1982.

We, 13 the staff, have a little concern that that won't quite 14 come out that way, but that is what we are working 15 toward on the licensing basis.

But there might be a few 16 months slip in that.

17 In terms of start-up schedule for Unit 2, 18 February 16 was the license, and they started loading l

l 19 fuel within a couple of days.

Within roughly a month,

[

20 they got the fuel loaded and the head tensioned.

They 21 just achieved criticality on the 26th of this month, a 22 couple of days ago.

They are currently critical, and 23 proceeding through their initial tests at criticality.

24 They are scheduled to be above 5 percent power the week 3

25 of August 16th.

ALDERSoN REPORTING COMPANY,INC,

10 1

The next slide is the first of several issues 2

selected for highlighting here.

This slida No. 4 talks 3

about the core protection calculator.

This is a 4

relatively new system.

It was installed on A rk a n sa s-2.

5 Basically, it uses a digital computer for two of the 14 6

trip ' functions in the plant protection system.

Perhaps 7

Roger Mattson could say a couple of words about this to 8

augment what I have said.

9 MR. MATISON:

It is worth talking about in the 10 sense that it is the second of a kind to go into 11 operation.

ANO-2 was the first one to go in with the 12 CPC in place.

He are now up to having approved the 1

13

=ycle two operation of the CPC at AN0 2, which is 14 essentially the same as the CPC software that goes into 15 San Onofre Unit 2.

The hardware is essentially 16 identical.

17 This is the first design that uses a computer 18 system to process normal control system information and 19 then make decisions for two of the several protection 20 systems functions.

In this case, it is low DEB ratio, 21 and high local power density that are the two protection 22 functions.

23 Down through the years there has always been a 24 concern in the regulatory staff with coupling control 25 with protection functions.

Remember that we have a lot ALDERSON REPORTING COMPANY,INC, RMJWFORTfMTtFfKX9

11 1

of buffering betWaen control systems and protection 2

systems.

Tying them together in a computer has always 3

raised the spectre of software errors or common mode 4

f ailures in the design making an error from the control 5

system propagate into the protection system.

So there 8

was quite a lot of review given to ANO-2.

7 A rough figure from the computers back home 8

says that 15 man-years of NRR staff work went into the 9

development and review of the criteris for ANO-2, about 10 eight man-years of that went into ANO-2 alone.

By 11 contrast there sta just seversi man-months to look at 12 the difference between what is in this Southern Cal 13 Edison nachine as opposed to what we have approved for 14 ANO-2.

15 We have had a lot of help from the people at 18 Oadkridge on the hardware parts of the machine, or the 17 CPC, and a lot of people at the Pacific Northwest 18 Laboratories in scrubbing the software.

19 We have used this as a model for how not to do l

(

20 computer protection systems in the future.

It was the i

21 genesis of our invention of third party VCV which you 22 have heard us speak of with the safety parameter display 1

23 system when we were down here in connection with 24 SECY-82-111.

It was from the experience of our having 25 to do the VEV on this design that we decided somebody l

l l

ALDERSoN REPORTING COMPANY,INC.

400 VIRGINIA AVE S.W.. WASHINGTON. D.C. 20024 (202) 554-2345

12 1

else ought to do that one because we couldn 't afford 2

it.

3 The system has worked well in ANO-2 cycle 4

one.

They had some software glitshes that they worked 5

out in the course of the first cycle.

We are kind of 6

please with the way it is operating, and we expect it to 7

operate well in this plant.

8 CHAIRMAN PALLADIN04 Roger you said something 9

that may I misunderstood, but at least it ought to be 10 clea red up for the record.

You said that this is how 11 not to do the job.

12 NR. MATTSON:

Yes.

13 CHAIRMAN PALLADINO What were you referring 14 to?

15 NR. MATISON:

Spending 15 man-years to look at 16 one component in the machine.

When we only spent about 17 20 man-years total looking at the whole reactor for an 18 operating license, and spending 15 on one little piece 19 of the protection system is too much.

20 CHAIRMAN PALLADINO:

It was not that you had 21 any concern about it.

22 NR. MATTSON:

No, we did a good job, it was 23 just too expens'ive.

24 CHAIRHAN PALLADINO:

Thank you.

25 COMMISSIONER AHEARNE:

Roger, do they have ALDERSoN REPORTING COMPANY,INC.

400 VIRGINIA AVE., S.W WASHINGTON, D.C. 20024 (202) 554-2345

13 1

plans to go beyond just those two functions?

2 MR. MATISON:

I am sorry.

3 COMMISSIONER AHEARNE:

Do they have plans to 4

expand the system beyond the two that are now 5

controlled?

6 MR. MATTSON:

To more protection functions, I 7

will have to ask Larry Philips, I don't know.

8 No, this design sticks with these two.

They 9

will continue to make software changes and continue, I 10 mm sure, to eat away a t a little of the margin that we 11 have reserved as we get our feet wet with this first of 12 a kind.

We will keep up with those reviews through 13 subsequent cycles, but no more functions will be added.

14 There are other designs by other 15 manuf acturers, and maybe even another design by 16 Combustion, for advanced control rooms that put 17 computers into many more protection functions.

18 Westinghouss has an offering that has all of them in the l

19 computer.

20 CHAIRMAN PALLADINO:

Roger, you said once that 21 this was previously used in ANO-2.

I got the feeling 22 that this was the sacond plant in which we are using 23 it.

Then you said that this is the first of a kind.

24 ER. MATTSON4 I meant that this core I

25 protection calculation, which is beino used in ANO-2 and ALDERSON REPORTING COMPANY. INC, e'G

14 1

San Onofre, and in other plants, is the first computer 2

based protection system in any nuclear plant in the 3

country.

That is what I meant.

This CPC is the first 4

of a kind.

This plant is the second one that it is 5

incorporated in.

6 CH AIRM AN P ALLADIN04 Thank you.

7 ER. ROOD:

Thank you, Roger.

8 Slide five introduces the PORV, or system 9

depressurization question, and I would like to turn that 10 over to Harold Denton to discuss.

11 ER. DENTON:

I wanted to give a little 12 background on the role PORVs in our review of this 13 plant.

The staff attention given to says to remove 14 decay heat right after TMI resulted in the adoption in i

l 15 our standard reviaw plan of raliability gosls for l

{

16 auxiliary feedwater systems.

17 So it was recognized that ways to remove decay 18 heat from a plant that had shut down were very 19 important, so we adopted in the standard review plan a 20 requirement that auxiliary feedwater systams be shown to 21 be reliable in the range of 10 to the minus 4 or ten to 22 the minus 5, and this plant was reviewed against that 23 criterion.

24 We also had initiated unresolved safety issue 25 A-45 to help address the question, should we have even ALDERSON REPORTING COMPANY,INC, l

400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554 2345

15 1

better means of removing decay heat.

We had a number of 2

things in sind that are being addressed by A-45, but th e 3

results of that will not be available for 18 months or 4

two years.

5 During the course of the review, we received a 6

meno from Research which pointed that they thought 7

perhaps the reliability goals would not be achieved 8

based on the type of experience that we were getting 9

COHNISSIONER AHEARNE:

On the aux feed?

10 MR. DENTON:

-- on the aux feed system.

So we 11 brought this to the attention of the ACRS.

We reviewed 12 the aux feed system again, taking into account the 13 experience we had gained over the past decade with 14 auxiliary feedvater systems.

15 If you look at aux feed systems and PORVs 16 against the safety goal of the Commission, it is sort of 17 interesting.

The precursor study shows that aux feed 18 systems are not achieving the desire reliability mainly 19 because of common mode failures, maintenance type 20 problems where the valves or bolts are tightened too 21 tight, or not properly maintained.

l 22 So there has been a suspicion on the staff i

23 that once the unresolved safety issue study was 24 complete, it sight show that san 11 break of coolant l

l l

25 accidents coupled with the actual in-place performance i

ALDERSON REPORTING COMPANY,INC,

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of auxiliary feedvater systems might prevent plants from 2

seeting the 10 to the minus 4 goal if they didn't have 3

other ways to provide core cooling, such as a PORY, a 4

high pressure RHR, or automatic depressurization system, 5

and there were a number of such schemes.

6 It is these kinds of concerns which led us to 7

make this area an unresolved safety issue.

It also led 8

us to conclude in the safety evaluation report that we 9

vanted further study of this area.

Even though we 10 thought the plant was adequate in the interim without a 11 PORY, we were obtaining f urther studies of this f rom 12 Combustion, and had in mind that they would complete 13 such a study within about a year.

14 Coming back to the safety goal, and the way we 15 propose to implement the safety goal is, if you are 16 above the ten to the minus 4 range, you look to see what 17 it means for health effects off-site.

The types of 18 accidents where the PORY plays an important role with 19 regard to sitigating core damage are not those in which 20 you would expect large off-site radiological 21 consequencas.

22 Let me say that another way.

If a PORY is to 23 be effective in the small break loss of coolant 24 accident, it must mean that you have got AC power to 25 power HIPSI, and if you have AC power, then you probably ALDERSON REPCRTING COMPANY. INC,

17 1

sta able to operate containment fan coolers, containment 2

sprays and these kinds of things, and therefore you tend 3

to mitigate.

4 So even though we might eventually conclude 5

that a plant with nothing more than a very reliable 6

auxiliary f eed water system would be above the ten to the 7

minus 4 safety goal, it probably will not make a great 8

deal of impact in terms of v'hether or not it meets the 9

off-site dose consequences.

In fact, I would speculate 10 that the absence of a PORY would not greatly affect the 11 off-site consequences.

12 What I am trying to say is, even though you 13 may be above ten to the minus 4, you may not be able to 14 see that in terms of what the acute or latent health 15 effects are off-site from a full spectrum of risk.

If 16 you were to use ALARA as the basis for backfitting of 17 the plant, I would speculate that you would not be able 18 to backfit very much into a plant that had a reliable

_19 auxiliary feedwater system.

20 It was these kinds of concerns within the 21 staff that resultad in this area getting an awful lot of 22 attention during the review.

These areas were discussed 23 with the ACRS.

We notified the Boards with regard to 24 some of these issues.

What I would like to do now is 25 have Roger Eattson summarize for you the conclusions in l

ALDERSON REPORTING COMPANY,INC,

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18 1

this particular case, and the license conditions that we 2

propose to add into this license to reflect some of the 3

interest of the Commission.

4 CHAIRMAN PALLADIN0s I wanted to ask you, 5

aren't there circumstances such as -- Let me ask it this 6

way.

If you have steam tube failures, will the systems 7

in place enable you to handle it with the ease, for 8

example, tha t it was handled at Ginna?

9 MR. DENION:

The cases in which you have steam 10 generator tube ruptures, and if you are only have two 11 steam generators in the plant, and the other one isn't 12 effective for some reason, then it is really desirable 13 to have an alternative way to cool the cora.

It is 14 because of the concern about cooling the core under 15 certain small break loss of coolant a =idents that we 16 have always tried to ascertain whether we have adequate 17 back-up means or not.

18 But I was trying to compare to the safety goal 19 of the Commission.

20 CHAIRMAN PALLADINO I was thinking from a l

21 depressurization as well as a heat removal standpoint, 22 to reduce leakage, that presumably you might want to 23 reduce the pressure in the primary system.

24 MR. DENTON:

Then you get into questions of 25 how good is the pressurizer spray system, how many pumps l

l ALDERSoN REPORTING COMPANY,INC, Ej) VIR$1NIA AR @.W., WTHINST6Ne @).@. 8584 G85$ GDO.M______ __ ___ _

19 1

feed the spray, and what other meanc you have for 2

rooling the core.

3 CHAIRMAN PALLADINO Will your study, or 4

whatever is being asked for, will it address both the 5

depressurization and the heat removal questions?

6 MR. DENION:

Yes, it will.

What I would 7

propose to do is to have Roger walk you through our 8

particular fi,ndingu on San Onofre and what we would 9

propose to add in the 11conse, to assured that when we to take a decision in this area, we have got as much 11 information as we can have.

12 CH AIRM \\N P ALL ADIN0a Commissioner Ahearne.

13 COMMISSIONER AHEARNE:

Befo're that, can you 14 give me a little background.

Have C-E plants never had 15 POR Ys?

16 MR. DENTON I think they have had them.

Let 17 me ask.

18 COMMISSIONER AHEARNE:

I am sure they have.

19 MR. DENTON:

This particular breed of plants 20 doesn't have it.

21 COMMISSIONER AHEARNE:

I am sure they did, but 22 not all of them.

23 MR. DENTON:

Not all.

24 COMMISSIONER AHEARNE:

I am sure that the 25 staff at some point must have addressed with C-E putting ALDERSoN REPORTING COMPANY,INC, di3) V1R$1ND_ AR$$( W@ HIC'@@5% @.@. SEiR)(Si8) 693-$%D

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in PORVs.

So there must be some arguments both for and 2

against.

I wondered, in this presentation that Roger is 3

about to give, whether he can also comment on what are 4

the arguments on the other side.

5 MR. DENTON:

I would propose that we discuss 6

this plant first.

We have never been able to settle the 7

pros and cons.

Remember, we have talked about, right 8

after THI, closing the block valve so that PORVs would 9

not be a potential cause of an accident.

We have looked 10 a lot more at this those days.

11 I would propose that we switch to the review 12 of this plant and discuss the generic issue for all 13 plants.

14 CON:fISSIONER AHEARNE:

If you just quickly i

i 15 sketch the arguments for and against.

I think I 16 understand the arguments for.

What are the arguments 17 against, just on a generic basis, then I think I can 18 better follow the argument that might be made on this 19 plant.

20 NR. DENTON Roger, do you want to hit both 21 sides of that?

22 HR. MATTSON:

A stuck open FORY was the cause 1

23 of the accident at Three Elle Island, and as a source of 24 a potential small break LOCA, it is a risk contributor.

25 That is the argument against.

That was the reason that l

ALDERSoN REPORTING COMPANY,INC.

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21 1

Combustion-Engineering took it out of the System 80 2

design, and in fact took it out of some designs in 3

advance of Systen 80, namely San Oncfre and ANO.

4 COMMISSIONER AHEARNE:

All right.

5 MR. MATTSON:

The reason the PORY is there in 6

all the other designs, and was ' originally there in the 1

7 Combustion Engineering design, was to avoid challenges 8

to the safaty relief valve, so that plants could ride 9

certain over-pressurization transients without opening 10 and challenging the safeties.

11 Given that the System 80 design, the evolving 12 C-E design, didn't propose to try to avoid those 13 challenge, it wasn't going to try to ride those 14 transients out, was in fact going to trip the reactor 15 for those transients, then it was a source of a small 16 break LOCA that they saw they could remove and they 17 decided to remove it.

That is the downside of adding a 18 PORV.

19 In fact, as you will see, when we get to the 20 license condition that we have proposed to add for this 21 plant, we have ceased calling it a PORY, it isn't what 22 ve are interested in for this plant, it is a 23 depressurizing capability that PORVs in some plant might 24 be good at, and at other plants may not be worth 25 anything as I have explained, I guess.

ALDERSoN HEPoRTNG COMPANY. INC.

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CHAIRMAN PALLADINO:

All right, do you want to 2

go ahead.

3 MR. MATISON:

Yes.

Let me start with your 4

question, Mr. Chairman, about the depressurization 5

capability at San Onofre in view of what we saw at Ginna 6

and the need to depressurize the primary system.

7 The way the San Onofre design works today, 8

there are two ways to depressurize the primary system, 9

either by heat removal from the steam generators, if you 10 had a steam generator tube rupture event like Ginna, 11 then you could depressurize using the inf aulted steam 12 generator, which is one way to depressurize.

13 Another way to depressurize'is to use the 14. spray in the pressurizer.

With off-site power, and 15 reactor coolant pumps operational, which you hope to 16 have be the situation for steam generator tube ruptures, 17 that spray works off of the reactor coolant pumps.

18 For the case where the reactor coolant pumps 19 are tripped, which would be the instance if you lost 20 off-site power, then San Onofre has a safety grade 21 a uxillia ry spray system, which is driven by make-up 22 pumps, or high pressure safety injection pumps in this 23 design.

That auxilliary spray system is partitglarly 24 effective for reducing the primary system pressure down 25 to the range of the secondary system pressure, that is ALDERSoN REPORTING COMPANY,INC, samrwyrwvxrwn an - rara scn agracn erwen

23 1

down to 1,000 to 1,200 p.s.i.

It is not very useful for 2

going below that pressure.

3 Further depressurization is impossible in this 4

design unless there were some addition of valves.

There 5

are no other valves that you could open up and 6

depressurize with.

There are small valves, drain lines 7

that are not remotely operable in all likelihood.

There 8

are the vent lines for the non-combustible gases that we 9

added as a result of lessons learned from,Three Mile to Island.

Those are all very small and not a controlled 11 way to depressurize the system.

12 Does that go to your question?

The question, 13 I take it to be one of reducing exposures off-site in 14 the event of a steam generator tube rupture, which this 15 plant can do either through the unfaulted steam 16 generator or through the spray system to the 17 pressurizer, with and without off-sita power.

It 18 doesn't need this capability.

19 CHAIRMAN PALLADINO:

Except, without off-site 20 power, you can only go down to 1,000 p.s.i.

21 MR. MATTSON:

That is right.

22 C05MISSIONER AHEARNE:

What would the Z3 significance of that would end up being?

24 MR. MATTSON:

I am scrry.

25 COMMISSIONER AHEARNE:

What would be the ALCERSoN REPORTING COMPANY,INC,

24 1

significance of that if you could only get down to 1,000 2

p.s.i.

3 MR. MATTSON:

The way we do calculations for 4

consequences, it would be man-tems.

It is not 5

insignificant numbers, significant fractions of the 6

off-site doses, for example, at Ginna.

It is not small 7

percentages, it is factors.

Cut it in half, cut it by a 8

factor of three or four.

9 COMMISSIONER AHEARNE:

Of the exposure at 10 Ginna?

11 MR. MATISON:

Yes.

12 CHAIRMAN PAlLADINO Does your proposed study 13 include looking at alternative ways of depressurizing or 14 perhaps even, whether or not it is needed, to 15 depressurize below this 1,000 p.s.i.

16 MR. MATTSON:

Why don't you let me go through 17 the next three slides, and I think you will see 'he t

18 progression of what we have done so far, and what we add 19 to that.

20 On this slide that is up, the first statement 21 is that those C-E plants do not have power operated 22 relief valves.

Let me try to be a little more specific 23 than that.

I know you are aware that there have been 24 some changes in this area in the last few days.

25 Of the plants yet to be licensed of Combustion ALDERSoN REPORTING COMPANY,INC,

25 1

Engineering design, St. Lucie has PORVs, they are 2

installed, and they will be wired up and ready to go 3

this fall.

Palo Verde has made a decision on its own to 4

add PORVs.

j 5

COMMISSIONER AHEARNE:

Could I ask a question 6

on that?

7 MR. MATTSON:

Yes.

8 COMMISSIONER AHEARNEa You add, on its own.

9 This was solely, then, Palo Yerde's decision?

10 MR. MATISON:

Yes.

11 COMMISSIONER.AHEARNE:

There was no 12 encouragement by the staff?

13 HR. MATTSON:

Palo Verde was involved in the 14 dialogue among the staff, the ACRS, and itself on 15 whether they should be added.

We didn't strong-arm them 16 into these PORVs, they made the decision themselves.

17 COMMISSIONER AHEARNEs Do you know what was j

l l

18 the tipping factor for them?

19 HR. MATISON:

Yes, I think operational 20 flexibility for events, complicated events that are 21 different than our stylized design basis events.

I have 22 that information second-hand.

I don 't have that 23 straight from Palo Verde but from Combustion 24 Engineering.

25 WNP-3 has a study underway by Abasco to decide ALDERSON REPORTING COMPANY,INC,

i 26 1

1 whether to add PORVs.

They may do it.

Waterford and 2

San Onofre have decided not to add PORVs.

3 Commissioner Roberts, I am sorry.

4 COMMISSIONER ROBERTS:

Yes.

Who would make 5

that decision?

6 MR. MATTSON:

The licensee in this case.

7 COMMISSIONER ROBERTS:

How much would they 8

rely on their architect-engineer?

I guess that would 9

vary.

10 MR. MATTSON:

They would rely on their 11 supplier to do the study, to tell them.

12 COMMISSIONER ROBERTS:

Bechtel is the 13 architect-engineer at San Onofre and they decided not to 14 opt f or the PORY.

Bechtel was the architect-engineer 15 for Palo Verde.

16 MR. MATTSON:

I am not certain the 17 architect-engineer made the decision.

18 COMMISSIONER ROBERTS:

Okay, I just wanted to 19 understand the process.

20 MR. MATTSON:

In the case of WNP-3, the 21 trehitect-engineer is doing the study.

I think that the 22 decision on Palo Verde was made between the license 23 applican t and Combustion-Engineering.

24 COMMISSIONER AHEARNE:

What is Combustion's 25 position?

ALDESSON REPORTING COMPANY,INC,

27 1

MR. MATISON:

Combustion's position is that 2

after WNP-3, they will add PORY to CSAR.

No, I am 3

sorry.

4 CHAIRMAN PALlADINO:

To who?

5 MR. MATISON:

I said it wrong, let me say it 6

again.

After WNP-3, they will add a depressurization 7

capability to CSAR.

8 COMMISSIONER AHEARNE:

Is that a to be 9

designed depressurization capability, or is that just a 10 euphemism for PORVs?

11 MR. MATISON:

We haven't seen it.

In fact, in 12 the licensing form, they have told us that it is 13 unnecessary for safety.

That continues to be th eir 14 official posture vis-a-vis licensing of the CSAR 15 design.

But they have underway internally design 16 studies.

17 COMMISSIONER AHEARNE:

You say that their 18 position is that it is unnecessary for safety, but ther 19 are going to add it?

20 MR. !ATTSONa They have told us on the CSAR 21 docket that it is net necessary for safety, or to meet 22 the Commission's regulations.

Off-the-docket, they have 23 told us that they have undervsy design studies for this 24 operational flexibility f or complicated events within or 25 beyond the design basis of their concern, where they are ALDERSON REPORTING COMPANY,INC,

28 1

undertaking to look at such a design.

2 MR. DENTON:

They know we have it under 3

consideration, and it is flagged for further study, and 4

I think some of them are coming to their own conclusions 5

about where they may come out.

But we have not required 6

it of Palo Verde or these others.

7 What we have required in this particular case 8

is that a study be done and provided on San Onofre.

9 That is where the SER leaves the case.

10 MB. MATTSON:

I will say more about that 11 second bullet on th e n e xt slide.

le t me skip to the 12 third one.

13 The basis for interim acceptability of San 14 Onofre has been that they have a reliablea aux feedwater 15 system, and a high quality way to go to cold shutdown, 18 and state-of-the-a'rt steam generators, and every 17 expectations that they can meet the reliability criteria 18 of the standard review plan, in addition to the 19 deterministic requirements of the Commission's 20 regulations.

They are fully in accord with our 21 regulations.

22 COMMISSIONER ASSELSTINE:

Was the reliability 23 of the auxilliary feedwater system upgraded in the case 24 of this plant?

25 MR. MATTSON:

This plant, yes, added a third ALDERSON REPORTING COMPANY,INC,

29 1

aux feedvater pump, and there may have been other 2

changes of a smaller scale.

But it was upgraded i'h 3

order the ten to the minus four/ ten to the minus fif th 4

criterion.

5 COMMISSIONER ASSELSTINE:

Was this done at our 6

direction or insistence.

7 MR. MATTSONa It was done under a review 8

pursuant to the lessons learned from TMI.

9 COMMISSIONER ASSELSTINE:

Was tha t done on the 10 theory that by upgrading the auxilliary feedwater 11 system, that then the PORY would not be necessary?

12 MR. MATISON:

No.

13 COMMISSIONER ASSELSTINE:

It was separate?

14 MR. MATTSON:

Having done what we did to 15 assure a reliable secondary system, our argument has 16 been that it was not necessary to do more than have a 17 reliable secondary system, which is the traditional 18 reading of the Commission's regulations.

19 It was subsequent to those decisions when 20 people began to pay at the ACRS and internal to the f%

21 staff that you may not be achieving the reliability of 22 aux feedwater that you say you are trying for on paper, 23 and in addition there may be other ways to defeat the 24 secondary system by failing two steam generators at once 25 in a two-steam generator plant, or by failing the A:.JERSoN REPORTING COMPANY,INC,

)

30 1

primary system through a steam generator tube rupture, 2

and then failing the faulted steam generator through a 3

stuck open relief valve and having an uncontained LOCA, 4

the pressure relieving capability is also useful there 5

as a backup to the secondary system.

6 As those arguments began to gel, and people 7

began to put a little more urgency into this decision 8

because of San Onofre and'Palo Verde coming on line, we 9

began to see the need to look at feed and bleed, 10 depressurization capability for these beyond design 11 basis, beyond curve requirements kinds of concerns, 12 which really brought me into the next slide, if you want 13 to switch that one.

l 14 CHAIRMAN PALLADINO Could you refresh my 15 memory, Roger, on the loops in steam generators on this 16 plant?

17 MR. MATTSON:

Two-loop, two by four plants.

18 CHAIRMAN PALLADINO Give me for a steam 19 generator.

20 MR. MATTSON:

Two steam generators, four 21 pumps, inverted tube steam generator.

22 MR. DENTONs I would like to go back just a 23 bit to pick up on one of your questions.

24 When we picked this ten to the minus four goal I

l 25 for auxilliary feedwater systems, I think it was in ALDERSON REPORTING COMPANY,INC.

31 1

recognition that the probability of a small break LOCA 2

where the system sight be called upon, either through a 3

steam generator tube rupture, or pump seal failure, was 4

more a ten to the minus two than what was in WASH-1400.

5 In WASH-1400, I think it was more like ten to the minus 6

three.

7 We were recognizing that the probability of a t

8 small break LOCA moved up a decade to ten to the minus 9

two, then you would ask yourself, what kind of 10 reliability should you have for removing heat for this, 11 and that is how we picked the ten to the minus four/ ten 12 to the minus five design goal for this system, so when 13 you couple those two together, you would not make small 14 break LOCA followed by a loss of feedwater a dominant 15 sequence.

16 What is beginning to.cause us the unease in 17 this area is the fact that studies like the precursor 18 study show that we are not being able to achieve in 19 actual practice the ten to the minus four goal, where 20 that would indicate more like ten to the minus three.

21 What we have done in this case, we went with 22 the precursor study, looked at all those events that led 23 to a loss of auxilliary ferdwater function during the 24 first decade in that study, and compared those causes to 25 the design at San Onofre.

ALDERSON REPORTING COMPANY,INC.

400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554-2345

32 1

We think that it has got additional protection 2

in there, so that those kinds of problems that cause 3

failures in the first decade are somewhat covered in the 4

design.

But nonetheless, we were sufficiently uneasy 5

about the natch-up between the reliability of the system 6

and the probability of loss of core, that we did require' 7

this utility to commit to doing further study on this.

8 That would come out at about the same time our 9

unresolved safety issue came out, and we could address 10 this issue generically.

11 COMMISSIONER ASSE1STINE:

I understand wha t 12 you are saying.

You are still not quite sure that even 13 with the upgrades, this system will meet the ten to the 14 sinus four reliability design goal that you set for the 15 system in this case.

16 MR. DENTON:

Without some other additional 17 feature built into the plant.

This one does have the l

18 one feature we have mentioned, the special feature for 19 pressurized spray valves which tends to help this 20 problem.

21 COMMISSIONER AHEARNE:

You say that you did 22 have them put in a third aux feed train.

Is that what i

23 you said, Roger?

l 24 What modification did they make to the aux l

25 feed system, put in a third?

l ALDERSON REPORTING COMPANY,INC,

33 1

MR. MATTSON:

A third pump.

2 COMMISSIONER AHEARNE:

Now, is that also what 3

was done at Palo Verde?

4 MR. MATTSON:

Let me make certain.

Did they 5

add a third pump, or did they cross-connect?

6 MR. EISENHUT If I am not mistaken, at Palo 7

Verde, the third pump is a control grade pump.

I should 8

point out that at San Onofre, it is really a third pump 9

on a two train system.

10 MR. MATTSON:

Yes.

11 MR. EISENHUT It is not a three-train 12 system.

13 MR. MATTSON:

It is a third' pump at Palo 14 Verde, but it is the train.

15 MR. EISENHUTs It is a different arrangement 16 when you go through the overall reliability.

17 MR. MATTSON:

There is a spectrum of what

'S people do to meet this reliability criterion.

At Byron, l

19 they have cross-connected power supplies rather than add 20 a third pump, which gives a higher reliability and puts 21 them in the ten to the minus four/ ten to the minus 22 five.

23 CHAIRMAN PALLADINO:

What do you mean by 24 control grade pump?

25 MR. EISENHUT:

A better characterization would ALDERSoN REPORTING COMPANY,INC,

,_.M KR$DE M& @.LNTOM 8B33MF93-fFH~L__.__

34 1

be, it is not necessarily a safety grade.

2 COMMISSIONER AHEARNE:

It is a lower grade.

3 MR. MATISON:

For reliability performance, not 4

for function under severe conditions.

So in order to 5

get to the reliability, you can do it with less than 6

saf'et y grade equipment.

7 CHAIRMAN PALLADINO:

Could we find out how we 8

stand with our connection..

9 COMMISSIONER AHEARNE:

The red light went out, 10 so we will have to call back, I think.

11 MR. MAIESON:

Maybe I could plow ahead with 12 this second slide we had on the depressurization 13 capability minus Region V.

14 Let me just start from the top and get us back 15 on track.

We have concluded that for the current design 16 basis that a depressurization system was not necessary, 17 if there was not unacceptable challenge to safety relief 18 valves, and we had found the auxilliary feedwater system 19 to have a high reliability.

20 Nevertheless, we are confident that a reliable 21 depressurization system could be designed.

What that 22 seans is, you could put a depressurization system on 23 that would add more to safety than it would detract 24 Remember, we already said that it would detract from 25 safety by creatin7 the possibility of a small break LOCA ALDERSoN REPORTING COMPANY,INC,

&iWIRhTmo /11L EktL ECD 0lNMT@fA @.@. MAJK@A.LT D#M!a

35 1

-- but with the requirements to monitor the tailpipes of 2

relief valves and to have positive indication, and to 3

put a block valve on, and all of those things we have 4

lea rned to do in some of these non-safety relief valves 5

since TMI.

We are confident that it has is a design 6

basis that it be reliable, you could design one.

7 COMMISSIONER AHEARNE:

Should I infer, from 8

the way you have described that that a t the present time 9

you know of no such design?

10 MR. MATTSON:

I have not seen on paper such a 11 design submitted.

I have heard idea about such a design 12 that give me confidence that one could be built, yes.

13 COMMISSIONER AHEARNE4 I am~not talking about 14 the -- I would agree with you in having confidence that 15 you could do it.

I was just asking if there is one 16 existence.

l 17 MR. MATTSON:

No.

Neither Palo Verde nor

~

18 CSAR, both of whom we know to be looking at designs, 19 have said anything in particular about this design.

20 COMMISSIONER AHEARNE:

Nor any other PWR7 21 HR. DENTON4 I can tell you some of our l

22 thoughts.

I don't think we have to -- If you wanted a 23 real gold plated feed and bleed system l

24 COMMISSIONER AHEABNE:

I am not looking for a 25 gold plated system.

ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024.q202D 554 2345

36 1

MR. DENTON:

Let me give you a first class 2

feed and bleed system, it would not be a PORV, it would 3

be control valves.

PORVs are not the easiest things.

4 If you really want to have an ability to feed and bleed, 5

PORVs are not the desirable valves, you would have 6

control valves.

You would be more careful about where 7

the water goes when it comes out of the valve.

Instead 8

of just spraying in the containment, you would probably 9

pipe it down.

10 So we have thought about that kind of thing, 11 but we have decided that we would not make any 12 recommendations.in that area until we had the study on 13 the unresolved safety issue behind us.

14 COMMISSIONER AHEARNE:

But do any of the PWR 15 manufacturers have such a system that meet your criteria 16 in existence at the present time?

17 HR. DENTON:

Hany of them have PORVs.

18 COMMISSIONER AHEARNE:

I understand that.

l 19 NR. DENTON:

We don't have as a design 20 criteria that they be designed to feed and bleed 21 reliably, and so forth.

They have been considered a 22 back-up to the auxilliary feedvater system.

23 COMMISSIONER AREARNE:

I undarstand that.

24 HR. MATTSON:

They are better than we thought 25 a couple of years ago.

They have cone through EPRI ALDERSoN REPORTING COMPANY. INC.

400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (?O2) 554 2345

36-A 1

testing, and the block valves have better assurance and 2

that sort of thing.

But, again, they had as a design 3

basis the protection of the safety relief valves from 4

unnecessary challenges.

5 6

7 8

9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 ALDER $0N REPORTING COMPANY,INC.

NVIRGINlA AVE., S.W WAS_HINGTON. D;C. 20024 (202) 554-2345

37 1

We are talking about an ability to 2

depressurize to a particular head flow curve on a 3

high-pressure injection system in a particular time 4

frame with high reliability of not only opening but of 5

controlling and closing and blocking if the PORV, the 6

new valve, whatever it is called, were to stick open.

7 And those are different design bases than they 8

originally had.

9 COMMISSIONER AHEARNE4 I understand that, to Roger.

My question really is you had just finished 11 talking about CE was not yet ready with such a design, 12 and my question was very simply 13 MR. MATTSON:

No one else's either.

We have 14 not seen it from anyone.

15 Okay.

The third bullet here.

It is clear 16 tha t as a backup to the secondary system, it is 17 desirable to have this flexibility.

It is hard to 4

18 estimate what the likelihood is of losing the secondary 19 system.

We can give you assurance that the reliability 20 of the aux f eedvater, we are able to design it and

-4 5

21 review designs of it in the range of 10 10 Yet 22 operating experience continues to belle that.

23 Failure of two steam generators or one steam 24 generator plus operational error or one steam generator 25 plus a f ailure of a steam generator relief valve, those l

l ALDERSON REPORTING COMPANY,INC.

38 1

are complicated events without a lot of experience.

And 4

2 whether they meet the 10 is the subject of ongoing 3

study today.

4 So as a backup to that it would be desirable 5

to have the depressurizing capability.

In fact, most 6

operating PWRs today have a depressurizing capability by 7

virtue of their PORVs.

8 If I could digress on that for a moment.

We 9

have had a couple of questions from Commission staff on 10 what the status is for operating reactors.

11 They come in three classes.

The best class j

12 a re those seven or eight operating BEW plants that have 13 high-pressure injection capability al1 the way up to the 14 safety relief valve set-points and can either remove 15 decay heat via the safety relief valves or the PORVs and 16 need not have a secondary system if they have enough 17 high-pressure injection pumps operating.

So that is a I

18 pretty good capability.

That plus the EPRI tests of 19 PORY capability wi th two-phase flow gives you a fairly 20 high confidence in the feed-and-bleed capability of 21 those machines.

22 The next class of machines are the l

23 Westinghouse and Combustion Engineering designs, of l

l 24 which there are two subsets.

There is a subset tha t ha s l

25 a very high-head high-pressure injec tion ca pability, but i

j ALDERSON REPoPTlNG COMPANY,INC,

39 1

not as high as the BCW plants.

And there is another 2

subset that has a lower high-head injection capability.

3 For both subsets they have enough PORY 4

capability to remove the decay heat.

They depend on 5

aanual operation of the PORY to do that.

And the 6

discomfort with those operating plants is that they 7

haven't any procedures in place nor is there a high 8

degree of analytical or experimental verification of 9

cheir ability to cool by feed-and-bleed.

10 So although they have PORVs, they do not have 11 high assurance of an ability to cool by f ee d -a nd -bleed.

12 Let me give you two examples -- I will give you three 13 examples.

14 ANO-2 has no PORY, but we include it in this 15 second class because it has a 4-inch vent line.

That is 16 bigger than a PORY.

Your superficial judgment.would be,

17 that is good.

But when you look at the system, it is a 18 plumber's nightmare.

It was put there for flushing, 19 back-flushing the system of boron.

It was not put there 20 as a pressare-raliaving capability at all.

And we do 21 not even know whether the valve will open at full 22 reactor pressure.

23 So a superficial examination would tell you 24 that looks like a good depressurizing system.

It needs 25 an engineering ev31uation before you draw any comfort ALDERSCN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., W ASHINGTON, D.C. 20024 (202) 554 2345

40 I

that ANO-2 has a f eed-and-bleed ca pability.

2 Another example is another CE reactor, Calvert 3

Cliffs, which has a PORV, but whose operation depends 4

upon an operator going behind the console, opening up a 5

high-voltage cabinet, reaching by high-voltage 6

connections, manipulating a lever that the man on the 7

other side of the control console tells him whether he 8

is having the right effect or not.

So that is not very 9

vell human-engineered.

If you wanted to depend upon a 10 feed-and-bleed capability, again you would have to know 11 more than it has a PORY.

12 A third example is the Yankee plant, where it 13 is a close call between the high-pres'sure injection 14 capability and the depressurization capability of the 15 POBV.

16 The point I want to leave you with is:

do not i

17 jump to the conclusion that just because a plant has a 18 PORY it has a fed-and-bleed capability.

19 Finally, there is a third set of operating 20 plants, of which there is only one, Davis-Besse, which 21 does not have the capability to remove decay heat by 22 feed-and-bleed.

It has a low-pressure high-head 23 injection systes and an inadequately sized PORV to get 24 to the point where the high-head system could keep up 25 with decay heat.

ALDERSON REPORTING COMPANY,INC, T@A K696 QVRLEW-M

41 1

CHAIRMAN PALLADIN04 I did not get the meaning 2

of the whole last phrase.

3 MR. MATTSON:

Well, the Davis-Besse plant 4

cannot feed-and-bleed and remove decay heat without a 5

secondary system.

It needs at least a partial secondary 6

system.

7 CHAIRMAN PALLADINO But it has got other 8

means for decay heat removal?

9 MR. MATTSON:

Yes.

Yes.

The auxilary 10 feedwater system, the steam generators are its way of 11 removing decay heat.

12 CHAIRMAN PALLADINO:

Did I check to see if our 13 California f riends are on the line?

Bob, are you on?

14 MR. ENGELKEN:

We are here, Mr. Chairman.

Can 15 you hear me?

16 CHAIRMAN PALLADINO:

Yes.

Very well.

Thank 17 you.

18 MR. ENGELKEN:

Mr. Chairman.

19 CHAIRMAN PALLADINO Yes.

20 MR. EN GELK EN :

We can hear.

21 HR. MATTSON:

I think let me conclude this 22 slide by saying we had decided a t SER time for the San 23 Onofre units to require a study to examine the need for 24 a pressure-relieving capability on this design.

Some 14 25 questions were filed with Combustion and Southern Cal ALDERSON REPORTING COMPANY,INC, fM VIRGINIA AVE., S.W., WASHINGTON D.C. 20024 (202) 554-2345

42 l

1 Edison, due to be complete in the March 1983 time frame.

2 We are today recommending 3

CHAIRMAN PALLADINOa Focused on?

4 HR. MATTS,0Na The need for a 5

pressure-relieving capability.

6 For the 14 questions, if you were to read then 7

I have a copy here -- would cover the briefing you 8

have been getting on all of the interest in that 9

pressure-relieving capability, including the one I 10 jumped over on ATWS.

11 We are now recommending that we strengthen 12 that requirement by a license condition, which is on the 13 next slide, requiring this licensee to submit by July 1,

14 1983, a design of a pressure-relieving capability and 15 ancillary equipment for design obfectives that are 16 stated in this licensing condition that need not 17 necessarily meet the General Design Criterion.

18 The flavor we want to leave there is that we l

l 19 believe that the need for pressure-relieving capability 1

20 is beyond the current design basis.

Given that it is 21 beyond the design basis, we believe that the GDC need 22 not cecassarily apply and would encourage through this 23 license condition the use of cost-effectiveness analysis 24 and probabilistic risk assessment and the things that go 25 with it to justify the design that the licensee comes up ALDERSON REPORTING COMPANY. INC,

43 1

with.

2 COMMISSIONER ROBERTSa What is the reason for 3

the change in the staff position?

4 MR. MATISON:

Well, Harold, do you want to 5

start?

8 MR. DENTON:

Well, you could go on to the 7

second part of that.

The only thing we are requiring 8

here is that they provide a design so --

9 COMMISSIONER ROBERTS:

You initially in the to SER wanted a study.

11 HR. DENTON:

Yes.

12 CONNISSIONER ROBERTS:

Now you are going to go 13 a step farther and require a design.

14 MR. DENTON:

Yes.

15 COMMISSIONER ROBERTS:

I want to know the 16 basis.

17 HR. DENTON:

And tha basis for that is that we 18 have got Sandia studying about 12 plants which would 19 look at whether or not we ought to make some 20 improvements in this area.

And if we were to decide 21 that improvements were needed, we.3till would not have a 22 design for any particular plant.

We felt for this plant 23 that if va had a design and if we came to a conclusion 24 that something was needed, we would save some time in 25 putting one in.

ALDERSON REPORTING COMPANY,INC, 400 V.RGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345

6 44 1

We have not come to a judgment that we really 2

need a PORY in this plant.

And you will notice the last 3

block in --

4 COMMISSIONER ROBERTS:

I thought we were not 5

talking about a PORY.

I thought it was scrupulously 6

avoiding that.

7 MR. DENTON But the last part of this license 8

condition does not say that you put it in, it says that 9

you provide a design --

10 COMMISSIONER ROBERTS:

I understand.

11 NR. DENTON4

-- that we can review, and if we 12 come to a conclusion that improvements are needed, it is 13 a commitment from a licensee to put it in.

14 NR. M A'frSON:

Maybe I could help put a little 15 more light on that.

At the time we wrote the license 16 condition -- I am sorry -- at the time we required of 17 them that there be a study, we had insufficient 18 information of our own to make a racommendation 19 according to agency procedures that a new design 20 requirement be created.

21 We had indications from a number of sources 22 that people felt it was maybe necessary, but we did not l

23 have the information to support such a decision.

24 COMMISSIONER ROBERTS:

But you are telling me 25 that in between June 1982 and today you have additional ALCERSoN REPORTING COMPANY,INC, 6T@N, f@.@. FMR4M54 fE45

45 1

information?

2 MR. MATTSON:

We have several kinds of 3

additional information.

One is the knowledge that Palo 4

Verde made the decision on their own, which is an 5

important additional piece of information.

A second 6

piece of information are two Commission memoranda which 7

tell us that the Commission is interested in whether the 8

design requirements ought to be changed separate from 9

our putting together a formal recommendation to support 10 making a change.

11 Now, we are not proposing to abandon the study 12 of need for adding this requirement.

In fact, the 13 previous study that we have required of the licensee 14 stands because we need more information to understand 15 the risk reduction potential of this design change.

16 What we have added to that is more specifics about how 17 you go about doing it, trying to focus people on exactly i

18 what it is, the purpose, and the ends that could be 19 achieved by this design change.

20 MR. DENTON:

I think the provision of a 21 specific design would sharpen our ability to make a 22 decision.

We would be able to answer better what are 23 the pros and cons if we had one in front of us.

And 24 since we had already required the study to come due in 25 March of next year, it seemed to be reasonable to ALDERSoN REPORTING COMPANY,INC,

46 1

require that they provide a study.

2 But we have not come, we still have not come, 3

to a conclusion that we could say one is needed today.

4 COMMISSIONER AHEARNE:

Roger, or Harold, What 5

would be the criteria that this system would be designed 6

against?

7 MR. MATTSON:

Well, we have specified several 8

in this license condition.

Highly reliable is one 9

deterministic criterion.

Removal of decay heat without 10 any other system, using the existing makeup systems is 11 another criterion.

12 COMMISSIONER AHEARNE:

Highly reliable is very 13 subjective.

i 14 MR. MATTSON:

Well, we have issued 70 15 operating licenses and 100-some construction permits on 16 that basis.

17 COMMISSIONER AHEARNE:

Yes.

18 MR. DENTON:

Well, let me have a shot at 19 this.

20 COMMISSIONER AHEARNE:

In general, that is a 21 judgmental decision, and now you are saying you want 22 someone to design something.

23 MR. DENTON:

I think it will come down to 24 being a policy issue by the Commission.

We have talked 25 before about how do you implement a sa fety goal if you ALDERSoN REPORTING COMPANY,INC,

47 1

had one.

2 COMMISSIONER AHEARHE:

Harold, I am asking you 3

a much simpler question.

4 You are telling these people to design 5

something.

Now, you had a study under way in which they 6

were going to study whether it was needed.

Now, I 7

assume one of the products of that kind of a study is if 8

the answer is, no, it is not needed, that is one side.

9 But if the answer is, yes', it is needed, usually the 10 "it" is somewhat defined, what is needed.

But you are 11 here asking them to do design, in effect, in the absence 12 of having done the study of what is needed.

13 HR. DENTONs Right.

14 COHHISSIONER AHEARNE:

And I was really e.

15 asking, since you are not waiting for them to decide 16 what are the criteria, what criteria you were having 17 them design this to.

It has to be, ob v ious ly, that you 18 have reached the rough conclusion that is needed, and so 19 you have this.

20 NR. DENTON:

No, I have not.

No, I have not.

21 COMMISSIONER AHEARNEa Well, but you are 22 asking them to design something.

23 MR. DENTON:

Well, I am trying to be 24 responsive, and I think that two of the Commissioners 25 who said we should consider this, and I can best ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W WASHINGTON D.C. 20024 (202) 554 2345

48 1

censider it if I had a specific design at about the same 2

time the study was comiog to completion.

3 COMMISSIONER ASSELSTINE:

Yes, I understand 4

what you --

5 MR. DENT 0~:

That is where we are.

We 6

finished this review without any requirement other than 7

a study.

And we have seen the correspondence between 8

the Commissioners showing an interest in PORVs, and it 9

seemingly -- I thought a way to respond would be to get to a specific valve design so that in a year from now we 11 could advise you on whether one is needed or not and we 12 would not lose time.

Now, if that is not your desire,

~

13 that could be accommodated.

14 COMMISSIONER AHEARNE:

Why not have the 15 research staff then design it if you are responding to 16 our interest, then why do we not design it?

17 HR. DENTON:

Because that is not normally done 13 by resea rch for specific designs.

19 COMMISSIONER AHEARNE:

We had set up a process 20 for establishing how you go about doing requirements.

21 MR. DENTON:

Yes.

22 COMMISSIONER AHEARNE:

And so has this gone 23 through the CHGR?

24 MR. DENTON:

No, it has not.

But what would 25 go through the CRGB is if when we get the design in and ALDERSoN REPORTING COMPANY,INC, 65WKf6EE lML RYlL Y?YJTMr!6fiitcRL R(EL RiMb GRM GFB4Yia

49 1

we look at the study at, say, at that time and it is 2

determined that we want to impose a requirement, that 3

would go through the CRGR.

I did not see that the 4

design of a vslve for one particular plant is the kind 5

of thing that you had CRGR in mind for.

6 COMMISSIONER AHEARNE:

Well,.it is not a 7

valve, is it?

8 CHAIRMAN PALLADINO We do not know if it is a 9

valve.

10 COMMISSIONER ROBERTS It could be a system.

11 COMMISSIONER AHEARNE:

It could be, but it is 12 a depressurization system.

~

13 MR. DENTONa Yes.

14 COMMISSIONER AHEARNE:

And I presume that if 15 we end up requiring it here, we would end up requiring 16 it on all CE plants, at least.

And I would imagine that 17 if we required it in all CE plants, we may end up 18 requiring it in all PWRs.

(

19 HR. DENTON:

Well, I think that decision was 20 not being made today.

It was to be made based on 21 information we got as a result of this proposed 22 requirement.

23 COMMISSIONER AHEARNE:

Okay.

Perhaps then I i

24 ought to ask, sinre I guess Joe as the chairman was one 25 of the people who --

i i

(

l ALDERSON REPORTING COMPANY,INC.

_ CERVIR$1NIA AS S.W, WGHIN$7$N. D.C. FEE 4 (2023 SDSD'O _ _

50 1

CHAIRMAN PALLADINO:

Yes, I was one of the 2

people, yes.

3 COMMISSIONER AHEARNE:

What criteria did you 4

have in mind that they should design to?

5 CHAIRMAN PALLADINO:

Hell, I did not ask for a 6

design.

I asked for them to look into whether or not or 7

to what extent we had depressurization system and decay 8

heat systes in this plant.

And then I also asked them 9

later, too, that I think they ought to look beyond this 10 plant.

And the chief problem I have is that 11 depressurization appears needed in the event of steam 12 tube ruptures.

And th a t I intuitively feel we need.

I 13 ild not try to indicate what criteria"we ought to meet.

14 As a matter of fact, I want to ask them some qrestions 15 about tha t criteria.

16 COMMISSIONER ROBERTS:

Yes.

Is it appropriate 17 to ask what the licensee thinks about this?

18 MR. DENTON:

I think it is appropriate to askh 19 his.

He does not think it is needed, obviously, and did 20 not propose it.

But he thinks he could design the type 21 of system that has been provided on other plants within 22 this time frame.

And we have talked to his about it.

23 COMMISSIONER AHEARNE:

I thought earlier you 24 said there was no 25 HR. DENTON4 But there are FORVs.

ALDERSoN REPORTING COMPANY. INC, 400 VIRLiNI A AVE 0.W., W$HINGT@N, @.C. 60024 $ $ 693 M G

51 1

COMMISSIONER AHEARNE:

Well, I guess I go back 2

to an earlier question.

Your statement, is this really 3

a euphemism for P3RV?

4 MR. DENTON:

Well, we are trying to be broader 5

than PORV.

6 CHAIRMAN PALLADINoa Yes, I think you need --

7 MR. DENTON:

I think there are other ways to 8

depressurize, and we did not want to limit it to PORVs.

9 So we were going to allow the designer flexibility in 10 proposing a depressurization system.

11 COMMISSIONER ROBERTS:

Is it appropriate to 12 ask for a representative of the licensee to address 13 this?

I do not know whether they have anybody in the 14 audience.

15 MR. DENTON:

Yes, there are people here who 18 could address it.

17 COMMISSIONER ROBERTS 4 I would like very much 18 to hear what the licensee has to say.

19 CHAIRMAN PALLADIN0s Do we have any problem 20 with that?

21 COMMISSIONER AHEARNE I guess we have to ask 22 our legal counsel.

23 CHAIRMAN PALLADIN0a Where is our legal 24 counsel.

25 MR. MALSCH:

I do not see any problem with ALDERSoN REPORTING COMPANY,INC, 400_ VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345

a 52 1

asking.

It is not a contested issue at this point.

2 MR. DENTON:

I think the vice president of the 3

company is here.

4 CHAIRMAN PALLADIN04 Who is it?

5 MR. DENTON:

Ken Baskin.

6 MR. BASKIN:

My name is Ken Baskin.

I am 7

manager of nuclear engineering from Southern California 8

Edison Company.

9 In regard to this matter, I think maybe Roger 10 summarized or Harold summarized it fairly well.

From a 11 safety standpoint, we do not think such a system is 12 required.

Cle a rl y, in o,ur mind, it is not required to 13 seet the Commission's regulations.

14 We think such a system can probably be 15 designed to provide more benefits or provide an overall 16 benefits in other words, has more advantages than 17 disad van tag e s.

Again, it has pluses and minuses.

We 18 think a system can be designed that strictly from that 19 standpoint has more positive aspects than negative.

20 From the standpoint of whether or not such a 21 system is cost-effective in any sense of the word, I 22 f ra nkly do not know.

We do not have any estimates for a 23 system like this.

I do not know what it would look 24 like.

So whether we would be spending, just to pick a 25 number out of the air, $10 million for a very minor ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554 2345

53 1

increment in safety, I just cannot speak to at this 2

point in time.

We do not have encugh information.

3 The staff asked us if we would agree to do 4

this sort of study, as Mr. Denton said.

We did not 5

propose it, but we agreed that if they felt it was 6

required to move ahead, we would proceed and do the 7

design as they have suggested.

8 COMMISSIONER ASSELSTINE:

You are talking 9

about the staff's new proposed license condition, or are to you talking about the --

11 MR. BASKIN Staff's new proposed license 12 condition.

13 Does that answer your question?

14 CHAIRMAN PALLADINO:

You mentioned $10 15 million.

I missei what the $10 million was.

16 MR. BASKINa Oh, I was just picking a number 17 out of the air.

My point is I do not know today whether 18 or not it would be, from our perspective at least, 19 justified on a cost-benefit analysis.

I do not knov 20 what the cost is.

I do not have any quantification of 21 the benefits.

22 CHAIRMAN PALLADINO:

Well, I have a strong 23 feeling that depressurization capability or some way to 24 control that pressure is a highly desirable feature of 25 these plants.

And I am one of the proponents of ALDERSoN REPORTING COMPANY,INC.

400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024.(202) 554 2345 _____._ _ _ _ _ _ _

l 54 1

avoiding all backfitting if we possibly can.

But I do 2

feel, based on the insight given by the Ginna incident, 3

that this is a worthwhile thing to do.

It was the basis 4

for my meno.

You notice I did not say PORV.

I spoke 5

about the depressurization system and decay heat 6

resoval.

7 COHNISSIONER ROBERTS:

I have one further 8

question.

Do you hava any feel for what the cost of 9

this design will be?

10 COHNISSIONER AHEARNEs The design study?

11 COMMISSIONER ROBERTS:

Yes.

12 HR. BASKIN:

No, I taally do not.

My 13 expectation -- and again recognize that I am giving you 14 something off the top of my head -- would be somewhere 15 between a half to thrae-qua rters of a million dollars.

16 COMMISSIONER ROBERTS:

Thank you.

17 HR. BASKIN:

For the study, not the system.

t 18 CHAIRMAN PALLADINO:

Okay.

Any other 19 question 07 20 (No response.)

21 CHAIRMAN PALLADINO:

Thank you, Hr. Baskin.

22 Could I ask a question?

What do you mean by 23 saying not necessarily meet General D.esign Criteria 1,

24 2, 3, a t caters ?

What do those relate to, Harold?

25 NR. DENION:

Roger, do you want to explain why ALDERSoN REPORTING COMPANY,INC,

_400 VIRGINIA AVE., S.W, WASHINGTON D.C. 20024 (202) 554 2346

55 1

we took tho se ?

2 MR. MATTSON:

1, 2,

3, and 4 are the 3

environmental qualifications, fire protection, 4

high quality equipment, the sort of general 5

requirements.

14 is the one concerning the quality of 6

the reactor coolant pressure boundary.

30 and 34 have-7 to do with heat removal, residual heat removal.

8 These are criteria that would apply, for 9

example, to the decay heat removal system or to the 10 emergency core cooling system and other systems within 11 the design basis of the plant that were required for 12 de:ay heat removal.

13 What we are saying in this case is, this is 14 something we think is pro. ably beyond the design basis 15 of the plant but it is a good backup, a desirable 16 quality of a design, and we are trying through these 17 approaches to learn how to use PBA and other reliability 18 techniques for speaking to those " nice to have, but

[

19 beyond design-basis" requirements.

20 The analogy we have been using in the staff --

21 and it has not come up here today; I am a little 22 surprised -- is the igniters in Sequoyah, MacGuire, D.C.

23 Cook, Grand Gulf.

It is the same concept that we are 24 dealing with.

They are desirable to have, they are not 25 within the design basis of the plant; if the ALDERSON REPORTING COMPANY. INC.

400 VIRGINI A AVE S.W., WASHINGTON, D.C. 20024 (202) 554 2345

56 l

1 design-basis equipment works the way it is licensed to 2

work, you would not call upon this system.

3 COMMISSIONER AHEARNE:

Can you explain the 4

process you have in mind by the last sentence?

5 (R. MAIfSON:

The list sentence?

6 COMMISSIONER AHEARNE:

Yes.

7 MR. DENTON What I had in sind in the last 8

sentence would be, they would send one in, a design, we 9

would consider that plus the results of the Sandia study to and other in-house studies; and if we came to the 11 conclusion that such a system was necessary, we would 12 propose that the bill have a review by the committee for 13 reviewing regulatory requirements, get their views, and 14 come down and get the Commission views, I would expect, 15 on this issue.

And then if everyone concurred that that 16 was a desirable action, have the licensee install it.

17 COMMISSIONER AHEARNEa So when you say staff 18 approval, staff approval includes going through the 19 CBGR?

20 MR. DENION:

I would envision the Commission 21 in this case.

22 COMMISSIONER AHEARNE:

I guess what was 23 concerning me is that we did have developed some kind of 24 a process to flow requirements through, and it just 25 seemed to be going around it.

ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE S.W., WASHINGTON D.C. 20024 (202) 554 2345

57 1

NR. DENTON:

I guess I did not see having the 2

study done as going around it, because I had intended 3

that any generic application certainly would go through 4

it.

5 COMMISSIONER AHEARNE:

Well, I just caution 6

rou that when you do something for one plant which has a 7

very high probability of then ending up being a 8

requirement for all plants of a class, like PWRs, it 9

probably is not really accurate to describe it as a 10 single-plant issua.

11 COMMISSIONER ASSELSTINE:

Yes, I must say I 12 agree with that.

I think that the pontential generic 13 implications of this are fairly significant, and I think 14 requiring a specific design for this particular plant 15 really does go a long way towards how we are going to 16 respond to the problem.

It does not make it a foregone 17 conclusion, but it sure goes in that direction.

And I 18 think the war this is being developed does tend to 19 short-circuit the process that we put in place to take 20 away those kinds of issues.

21 MR. DIRCKS Harold and I talked about it 22 earlier today, and it was moving along, I think, as a 23 result of this particular action.

And as we discussed 24 earlier today, we agreed it should be brought back into 25 the more formal channels and subjected to the reviews ALDERSoN REPORTING COMPANY,INC,

58 I

that yo u have establishad for this sort of thing.

2 COMMISSIONER AHEARNE:

I guess as just another 3

comment, va are in the midst of a budget review, and 4

part of this budget review is the $200 million that we 5

spend in rasearch.

6 I guess I as a little puzzled by if we spend 7

all that money in research plus there is some other 8

31zeable chunk of dollars in technical assistance, if we 9

f eel that something ought to be designed, I am not sure 10 why we should not then hire somebody to design it.

11 MR. DENTON:

Hell, mentioning research, I 12 think you should probably hear from Research on this 13 issue.

They did write us a meno on this during the 14 course of the review, and you might like to hear their 15 views on how the absence or presence affects safety.

16 COMMISSIONER AHEARNE:

Well, that is fine.

I 17 doubt if they are going to address this specific comment 18 I just made.

19 MR. DENTON:

No; that is right.

20 MR. MATTSON:

If I could interject one point, 21 Commissioner, you do get a different kind of design 22 study when you require a licensee to go to his 23 architect-engineer and his NSSS supplier than you would 24 get by going to a national laboratory or someone else 25 with whom we could contract under existing ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON D C. 20024 (202) $$4 2345

59 1

conflict-of-interest requirements.

2 COMMISSICFER AMEARNE:

You mean that we could 3

not transfer funds to EPRI to have EPRI have that done?

4 MR. MATTSON:

It might be a possibility, but 5

for generating a Commission requirement, we have had 6

some difficulty of that sort in the past.

7 HR. DIRCKSs I

nn see your point, though.

8 What you are talking about is this is a study to look at 9

the feasibility of the requirement as opposed to the 10 design of a piece of equipment to go in the plant 11 i tself.

12 COMMISSIONER AHEARNE:

Yes.

13 HR. DIRCKS:

I can see the difference.

14 COMMISSIONER AHEARNE:

And I think it was 15 clearly describad by Harold, it is because the 16 Commission vants it done.

It would seem to me that 17 COMMISSIONER ROBERTS:

I don't want it done.

18 CHAIRMAN PALLADINO At least two 19 consissioners want it done.

20 COMMISSIONER AHEARNE:

No.

I think I would 21 guess that we are probably all interested in addressing 22 the depressurization question.

I do oot think there is 23 any doubt about that.

I mean what I as just pointing 24 out is that we have a very sizeable budget which, in 25 theory,,is spent to answer the questions that we feel ALCERSoN REPORTING COMPANY. INC, F*LM&%).

60 1

have to get answered.

2 MR. DENTON One more comment, and then I 3

would like to ask Frank Rawson to give his views on 4

this.

5 But basically, I think the staff thought after 6

THI that our attack on auxiliary feedwater systems would 7

provida a13quita level of assurance, and we did this big 8

PRA study and we upgraded auxiliary feedwater systems to 9

what we thought was a high degree of reliability.

Our 10 confidence in the reliability now is being somewhat 11 undermined by continuing ope ra ting experience where they 12 are not performing as well.

13 And so it is the fact that they are not 14 performing as well as expected that is causing us to 15 look for alternative ways to depressurize.

And there 16 are other schemes, such as the high-pressure residual 17 heat removal system instead of the low-pressure system, 18 or a depressurization system such as boiling-water 19 reactors have as an easy way to get pressure down so 20 that pumps could work.

21 But Frank wrote a perceptive memo on this to 22 us which 111 play a role in our deliberations, and 23 perhaps he would like to discuss it.

24 MR. RAWSON:

My name is Frank Rawson.

I am 25 deputy director of the Division of Analysis and Research.

ALDERSoN REPoRTINo COMPANY. INC, M VIR71130 AML O.W MFD 3RF)TM @).@. K5F0 # rial em

1 69 1

The cassents I am going to make are on the 2

basis of the study I did for that memorandun and are not 3

necessarily the position of the Of fice of Research.

4 It is my feeling that what we have here is the 5

tip of the iceberg of the major policy problem that you 6

gentlemen have struggled with before in the safety goal 7

arena.

I see no incentive to add a depressurization 8

system on the basis of what we know today to protect 9

public health and safety.

10 I do see an incentive to add such a capability 11 to protect the plant f rom incidents like THI, f rom 12 incidents that do not threaten public health an: safety 13 directly, but which are immensely costly to the utility 14 suffering them.

15 What our role should be in making su c.1 16 accidents cara is a policy issue that you have struggled 17 with when you have considered whether or not to have the

-4 18 10 criterion for core damage in the safety goals.

19 And to what extent the Commission vants to step into the 20 arena of ragulating accident scenarios that pro 5mbly do 21 not touch off-site radiological risk very much is a 22 ticklish issue, as you gentlemen know.

23 CHAIRM AN P ALLADINO:

What was your. observation 24 with regard to steam tube ruptures so far as reducing 25 off-site doses?

ALDEMSoN REPORTING COMPANY..NC,

62 1

MR. BAWSON:

I have seen no evidence in the 2

calculations I have done or others I have read that a 3

depressurization system is necessary to pro tect public 4

health and safety.

The scenarios by which the steam 5

generator tube rupture evolves into something 6

pot en tially th re a tening to public health and safety look 7

to me to be so low in probability as not to warrant 8

attention under either the ALARA criterion or the health 9

effect-based sortality and morbidity criteria, though it 10 might be the operational flexibility it gives an owner 11 would be useful to him.

12 And in addition, there is a class of accidents 13 in which, as Harold has pointed out, hC power is 14 available, containment cooling systems are presumably 15 available, in which having a depressu:12ation system 16 could make the dif ference between core damage or core 17 nelt and no core damage.

18 CHAIRMAN PALLADINO:

May I ask one other 19 question?

You referred to studies in this area.

Are 20 they studies such as to be able to answer the need for 21 depressurization ander various circumstancas?

And when 22 vould that study be done?

23 MR. DENTON:

The major in-house study is an 24 unresolved safety issue.

I think it is A.45.

And I 25 believe that study is not to be completed in total for ALDERSON REPoATING ';0MPANY, INC,

63 1

18 months to 2 yesrs from now.

It is being done by 2

Sandia.

3 And it involves a look at several selected 4

representative types of plants that are presently in 5

operation or under review, to give us a firm base so we 6

fully understand the capabilities and the reliabilities 7

of the system, looking at the kinds of problems that 8

Roger saw and described in some of the systems.

So that 9

we look fully at the reliability of the auxiliary 10 feedwater system, the HPCIs, the procedures, and the 11 thermohydraulic analyses to support feed-and-bleed 12 operations.

13 So thst study, from my standpoint, was to 14 provide the answer to this question.

And I would say 15 tha t is, ss I said, a year and a half or 2 years away.

16 CHAIRMAN PALLADINO Very well.

This is an 17 issue I guess we will have to decide as an adjunct to 18 our basic decision.

19 COMMISSIONER ASSELSTINE:

Let me ask one other 20 question.

How much time woull be saved by requiring 21 this design, assuming the possibility that that design 22 aight not be what you would want or that it would be 23 what you want?

24 If the decision was ultimately made to go 25 ahead with this system?

How much time would you say it ALOEF40N REPORTING COMPANY,INC,

m 64 1

sight require in the development of the design at the 2

same time that the study is being done?

l 3

HR. DENTON:

Well, I think in the straight 4

sense of San Onofre, you would save a year, or ther 5

think it would take them about a year to save this.

So 6

if we were to come to a decision that one were necessary 7

before any design was done, then it would cost a year.

8 Actually, I think it will contribute to the 9

quality of the decision to have a real design to look at 10 when we make that decision.

So in that sense, it 11 probably goes more to our making an adequate, reliable i

12 decision.

But at le 1st a year would be saved by that.

13 COMMISSIONER ASSELSTINE But you did say that 14 the reasons wh2 you came up with this license condition 15 were essentially two-folds one, that at least two 16 members of the Commission had expressed an interest in 17 requiring the depressurization system as a license 18 conditions and second, that another licensee had 19 voluntarily decided to install one.

20 HR. DENION Yes.

21 COMMISSIONER ASSElSTINEa And that those were 22 the two bases.

23 MR. M A TTSO N.a Well, there was a third reason, 24 and I think I got interrupted and I did not get to 25 mention it.

ALDERSON REPORTING COMPANY,INC,

65 1

And that is, when we called the licensee and 2

asked this licensee of the status of the study we had 3

asked for before and the da te by which it would be 4

complete and the involvement of other Combustion 5

Engineering plants and the relation among Combustion 6

Engineering and its clients, we did not have the feeling 7

it was moving aggressively forward and that a firmer 8

condition with a specified end date that got serious 9

about considering real design possibilities would add to 10 the state of knowledge.

11 COMMISSIONER ASSELSTINE:

But the original 12 condition h as a specified end da te, does it not?

13 c3. MATISONs No.

14 COMMISSIONER ASSELSTINE:

It does not?

15

!.R. MATTSON:

There was, by some oversight, no 16 specified and data.

17 CONNISSIONER ASSELSTINE:

Okay.

18 MR. MATISON:

The only commitment we have made 19 on the record is we told the ACRS we would do it in 20 about 12 menths, and the ACES letter said that the study 21 we had described sounded good to them, words to that 22 effect.

23 MR. DENION:

We had not turned that into a 24 license requirement.

March was the date that had been 25 understood formally.

ALDERSON REPORTING COMPANY, INC,

66 1

COHHISSIONER ASSELSTINE:

Okay.

i 2

COMMISSIONER ROBERTS:

Well, I have a 3

question.

There is some implied criticism of the 4

licensee, and I would like to hear their response.

5 ER. BASKIN.

Ken Baskin again.

8 Let me saybe make something clear, because I 7

think when I was here a moment ago, the term " study" was 8

being used maybe synonymously by Roger and maybe 9

differently by me.

As I look at it, there are two 10 things happening.

One is answers to a' series of 11 questions that were sent to Combustion Engineering and 12 to ourselves regarding the overall what I will call PORY 13 situation.

14 Ihe second thing is this specific study for 15 the design of the system, in my mind, those are distinct 16

-- overlap quita s bit, but distinct -- things.

17 I believe what Roger -- apparently, fror. what 18 you were just talking about, Roger -- was your letter 19 asking these broader questions about the need for 20 PC9Vs.

That was sent to Combustion and to us.

I am not 21 sure about any other licensees.

22 The agreement we had with the staff was that 23 we would work with the Combustion Engineering and Owners 24 Group to try or to prepare answers in a timely manner.

25 We were not going at it on any kind of crash basis.

We ALDER $oN REPORTING COMPANY,INC.

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67 1

told them, and were under the impression that it was 2

satisfactory, that we would'have the answers in about 3

March of naxt yatt.

4 So from the standpoint of, you know,.this 5

license condition being required to get us to take 6

action on that letter, I guess I would take exception 7

with that statement.

We felt we were pursuing it in a 8

diligent manner consistent with the naads of averybody 9

inv olv ed.

10 COMMISSIONER ROBERTS:

Thank you.

11 CHAIRMAN PALLADINO:

While you are there, 12 could I ask you a question?

13 COMMISSIONER ROBERTSs Thehuestionincluded 14 the three bases for this would not drive us to do this.

15 CHAIRMAN PALLADINO:

Well, I do not want to 16 debate it ye t.

17 Could I ask you, do you know what to do with 18 this, with the words stated here ?

19 Ihe question was raised, are the requirements 20 set forth here definitive enough so that you could know 21 what to do?

22 5R. BASKIN:

Well, one of the first things we 23 will do is to fini what va beliave the proper 24 requirements for such a system are.

I mean certainly I 25 do not know what they are today, and I do not think ALDERSON REPORTING COMPANY,INC,

68 1

anyone knows.

But that would be one of the first things 2

we would do as a part of this effort and the effort for 3

an swe ring the other questions.

4 CHAIRMAN PALLADINO:

Okay.

Thank you.

5 I might also note tha t CSAR is going to add 6

some depressurization capability after WNP-3, is it not?

7 COMMISSIONER AHEARNE Yes, that was the point.

8 But I gather what you said, Roger, is that 9

they are in the process of going through a study to 10 conclude what kind of depressurization capability to 11 add?

12 MR. MATISON:

Yes.

13 CHAIRMAN PALLADIN0s And I gather even the 14 requirement here would entail looking at what kind of 15 systems are available?

16 COMMISSIONER AHEARNE:

Well, as far as I can 17 see, what you have got is you have got the licensee 18 working with tha Owners Group to answer a set of 19 questions which are focused on the need for this kind of 20 a system; you have got Combustion working on their 21 system and trying to design a depressurization system; 22 and now what the Commission would do is task the 23 licensee to design a depressurization system, and, I 24 gather, in the same time frame as certainly it is 25 answering on the previous set of questions focused on ALDERSoN REPoRTINo COMPANY,INC,

69 1

the need.

2 CHAIRMAN PALLADIN0s Okay.

3 MR. DENTON:

This concludes our presentation 4

on this topic.

5 (Laughter.)

6 MR. DENTON:

Any questions?

7 (No response.)

8 3R. S*J0D:

If there are no more questions on 9

that topic, I would like to suggest a change in the 10 order of presentation of one of our slides out of 11 order.

We have a spokesman for the Federal Emergency 12 Management Agency, FEMA, here with us today for a 13 limited period of time.

14 So if we could jump out of order to the 15 emergency preparedness, which is slide 11 16 CHAIRMAN PALLADIN0s Okay.

l 17 MR. R00D4 we would like to cover that at this 18 point.

19 This issue is a contested issue, and I think 20 we have to be careful that we do not wander into 21 territory that we should not.

I do not know if there is 22 anybody who would like to spesk to thst, but 23 MR. CHANDLER:

I agree with that statement.

24 Okay.

25 (Laughter.)

ALDERSON REPORTING COMPANY,INC,

i e

e 70 1

MR. ROOD.:

What I plan to do is simply 2

summarize the status of what has transpired in terms of 3

the hearing dates and so on, and get into the technical 4

details on an is' sue which is not in contention and which 5

I think the FEMA people can address, and Brian Grimes 6

also will lead off on that.

7 Just starting out, though, going through this, t

8 the hearing in this area was held Au gust-Septem ber 9

1981.

A partial initial dacision was reached in 10 January, a complete initial decision in May.

We have 11 license conditions which we plan to include in the t

12 license per the Board's requirements.

13 All of the issues that woul'd stand in the var 14 of issuing a full-power amendmen t have been resolved, 15 with one exception.

And that exception is an area of 16 off-site emergency planning relating to the ingestion 17 pathway emergency preparedness.

This was not an issue 18 under litigation at the hearing.

19 MR. CHANDLERa For purposes of clarity, the 20 issue was initially contested.

The Licensing Board 21 ultimately found that it was no longer contested by 22 virtue of the intervenor's failure to file findings on 23 that.

That is -- and to that extent, is a matter which 24 may be subject to appeal -- in fact, is involved in the 25 appeal.

But the Licensing Board had found in there that ALDERSoN REPORTING COMP ANY, INC,

71 1

it was no longer a contested issue.

2

58. BOOD:

Okay.

And I think at this point we 3

would like to auk Brian Grimes of the staff to summarize 4

the situation with this one area.

5 MR. BICKWITs While you are coming to the 6

microphone, we have faced this question before.

It is 7

not an absolutely clear question, but our advice has 8

been that even a denied contention that is subject to 9

appeal is one that can be dealt with in the course of 10 these discussions.

Otherwise, you would not have 11 anything on which to base your immediate effectiveness 12 decisions.

13 14 15 16 17 18 l

19 20 21 22 23 24 25 ALDERSON REPORTING COMPANY,INC,

72 1

If you have no record, you have got to learn about the 2

subject matter some other way, and the way you learn 3

about it is during the course of these briefings.

4 MR. GRIMES.

If I can characterize the matter, 5

it is a fairly minor clean-up item that we need to take 6

care of.

The existing state of preparedness is such 7

that there is some capability for the ingestion 8

pathway.

9 The State of California and the counties have N

10 had some capability to monitor the pool pathways f or 11 sometime after the accident, and to take agricultural 12 interdictions measures if they needed to.

California 13 has f requently done that in other areas, so there is not 14 auch doubt as to the general capability.

15 There are not detailed plans in place which 16 all parties have integrated yet in this matter, and over' 17 the next few months those final touches will be put on 18 the plans.

There has already been one ingestion pathway 19 exercise in Orange County, and the State of California 20 had observers at that coordinating with the county.

21 FEMA has given us a status report of the state of 22 development of those plans.

The region has also given 23 us an overall finding of adequacy because we do have an 24 item in our regulations that specifically calls for 25 ALDERSoN REPORTING COMPANY,INC, Ci$ VIR@lNIA AML @.% WC@HIN@T@N 0.C. EiO4 $52$ 554 2909 2

73 1

ingestion pa thway plans, we will want to make sure that 2

there is something in place when we give a final 3

authorization for the license.

However, based on my own 4

personal knowledge today, I would say that we have good 5

assurance in that area.

6 I would like Vern Adler of FEMA to perhaps 7

speak to just the overall conclusions of FEMA in this 8

area.

9 MR. ADLERa I would say that Brian 10 characterized it accurately.

There was a drill in March 11 in Orange County of the ingestion pa thway zones.

As 12 FEMA observed it, the State Office of Emergency Services 13 and the State Rad Health were represented as observers.

14 They learned from the positive demonstration by Orange 15 County, and they are integrating what they learned from 16 that into what is now an advance status of their own 17 plans development.

The schedule for the development of 18 those plans was documented this date to Mr. Grimes and i

19 FEMA.

2'O CHAIRMAN PALLADINO:

Do you have any l

21 questions?

22 COHHISSIONER AHEARNE:

Does FEMA have any 23 remnant major concerns?

24 MR. ADLER:

Certainly not.

We do not.

25 CHAIRMAN PALLADINO:

Thank you,'Mr. Adler.

ALDERSON REPORTING COMPANY,INC,

74 1

Do you want to continue?

2 Are you trying to dacide what to present to 3

us, or how long it is going to take, or who is going to 4

do it?

5 MB. ROODS We decided to go back to the 6

presentation and just go back where we had left off 7

before.

8 CHAIRMAN PALLADINO:

I am just wondering.

I 9

have a feeling that we are going to spend at least 10 another half-hour on this.

11 COMMISSIONER AHEABNE I would think so.

12 CHAIRMAN PALLADINO:

I would suggest a

~

13 five-minute break.

14 (A short break was taken.)

15 CHAIRMAN PALLADIN0s I wonder if we might 16 reconvene.

17 Do you want to go ahead, Harold?

18 MR. DENION:

We will try to move ahead quickly 19 here.

The next topic was independent design review.

We 20 have sent down the results of the study that was done by 1

21 the General Atomic Company of the adequacy of the l

22 seismic design of San Onofre.

23 We felt that was a very worthwhile endeavor.

24 It did verify the adequacy of the design, which if we 25 can go through the slide.

Jim Knight is here to ALDERSON REPORTING COMPANY,INC.

75 1

summarize that review, if you would like.

2 CHAIRMAN PALLADINO:

Is there a desire to have 3

it revie wed ?

4 NR. DENTON:

It is slide No.

8.

5 COMMISSIONER AHEARNE:

Could I just ask a 6

question on the conclusions?

7 CHAIRMAN PALLADINO:

Yes.

8 COMMISSIONES AHEARNE:

What type of conclusion 9

did they reach as far as the existing numerical to calculations that had been done in contrast with any 11 independent numerical calculations that were done?

Did 12 they find that they were generally consistent.

13 HR. KNIGHTa Jim Knight of the staff.

14 Torrey Pines performed two independent 15 calculations, and in one instance they found, as one 16 aight expect I would argue in this type of situation, 17 results on the original calculation that were quite a 18 bit more conservative than they got, and one facet of 19 the design, that is the buckling through the sloshing in 20 the tank, that was less conservative than they would 21 calculate, still concluding that the overall design 22 approach for the tank was a valid one.

23 In the other, they looked at the frequency 24 calculation for pump support.

In that instance, they 25 calculated quite a different number.

They would 1

ALDERSoN REPORTING COMPANY,INC, S WlEGWfD

76 I

calculate a frequency in the range of 20 to 30 Herz, 2

whereas the original calculation was something like 3

100-some odd Herz.

The question here was one of whether 4

or not that represented a significant difference, one 5

might say, in a large picture, certainly, if you can 6 ' characterize it as a 400 percent difference or 500 7

percent.

8 In standing back and looking at this 9

particular findin7 in relation to the overall program, 10 they concluded that the designer had set about here to 11 designed are rigid support, and in fact he had 12 accomplished that.

An experienced engineer looking at 13 this type of support would say, yes, that you have met 14 the design objectives.

15 There was, in fact, a numerical error made.

I 16 would characterize it as the most difficult of the 17 judgments that had to be made in this process, since the 18 vast majority of all of the investigations here show 19 that there was in effect a design control process, that 20 it was implemented, tha t the people doing the design 21 were qualified.

22 The whole picture indicated a whole process 23 under control and effective, if you didn't have this 24 one, unfortunately, large sample, one out of two, that 25 seemed to show a large numerical error.

They said that ALDERSoN REPoRTINC COMPANY. INC,

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77 l

1 they viewed that in the broader perspective, and after 2

reflecting upon it, the staff felt that in that broader 3

perspective their conclusion was a sound one.

4 COMMISSIONER AHEARNE:

When you esy, for 5

example, that the staff viewed it in a broader 6

perspective, could you say a few more words about that, 7

what you meant about the broader perspective.

8 MR. KNIGHT:

The broader perspective being the 9

overview that is gained from all of the other activities 10 that went on.

As I said there was very substantial 11 evidence that an effective design control program did 12 exist.

There was very good evidence that that program 13 was implemented, and implemented well'.

14 COMMISSIONER AHEARNE:

Okay.

15 MR. KNIGHT:

That is what I mean by the 16 broader.

17 COMMISSIONER AHEARNE:

What was the 18 significance as f ar as the actual design went of that 19 frequency difference?

20 MR. KNIGHT:

None whatsoever.

There was a 21 rigid support intended, and a rigid support was 22 obtained, and the impact on equipment was negligible.

23 COMMISSIONER _AHEARNEs Thank you.

24 CHAIRMAN PALLADINO:

Any other questions?

25 MR. EISENHUT:

If I could press on, let's go ALDERSON REPORTING COMPANY,INC, MilYiffGW"D Mft EEL PD~tilmiliK@l Fc0fL V6/0 (IRTF41 RPG FEE 4

78 1

to slide 9.

There are a couple of other issues here I 2

vill just summarized before we switch over to the 3

region.

4 Shift staffing, the plant is somewhat limited 5

by the number of SR0s.

They currently have been 8

operating with four shifts, that is two SR0s on each 7

shift for i total of eight.

They do, however, have 8

other SB0s in reserve, in training, and they have other 9

SRos assigned to different functions.

They have a group 10 of SBos presently who have undergone testing, and we are 11 examining the exam results, and they have another group 12 coming in the pipeline in December.

13 We recently have discussed 'this matter with 14 the licensee, who has committed that prior to exceeding 15 5 percent power, he vill be staffed with five scheduled 18 operating shif ts along th e lines of the discussions that 17 vere held with the Commission over the last couple of 18 weeks.

Four shifts on regularly working, with the fifth 19 shift in the training program, and all evolved to a 20 training program such as that.

21 COMMISSIONER AHEAR3E:

That is a commitment, 22 then.

23 MR. EISENHUTs That is a commitment.

24 The next slide, if I could, or. seismic 25 design.

This is meant here only to summarize and t

i 1

l ALDERSON REPORTING COMPANY,INC,

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highlight a key area and a unique consideration of this 2

plant.

It does have a seismic design bacis at.67 Gs 3

which is somavhat higher than, of course, most plants in 4

the United States.

5 COMEISSIONER AHEABNE It is built in an area 6

7 HR. EISENHUT It is built in an area of very 8

high seismicity relative to the rest of the country.

9 The design basis was reexamined during the 10 review process.

The plant has a seiswie trip at 60 11 percent of the SSE, which was largely based on 12 discussions with the ACBS who has pushed in the 13 direction of a seismic trip for a number of years.

14 This was a hearing issue.

That is, the 15 accuracy of the seismic design basis was, in fact, a 18 hearing issue.

The decision was appealed, and as 17 mentioned earlier there was a request for a restraining 18 order filed with the Court of Appeals, which was denied 19 very recently.

We don't plan on q?ing in any depth here 20 because it was a contested issue, but just to highlight i

l 21 the fact that it was an unusual feature.

22 At this time, we basically have two items left 23 in the overall agenda, that is, the Region V report, and 24 the special conditions we have added to the license 25 amendment of which there are a couple.

i l

l i

l ALDERSoN REPoaTING COMPANY,INC, l

400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (SiG $54-29'9

00 1

At this time, I would like to turn it over to 2

Region V to summarize a number of features, including 3

operating experience and delays in operation.

4 CHAIRMAN PALLADINO Bob, are you still 5

there?

8 HH. ENGELKEN Mr. Chairman, this is Robert 7

Engelken.

Can you hear me?

8 CHAIRMAN PALLADINO Yes, indeed.

9 MR. ENGELKEN :

Can you hear me, Mr. Chairman.

10 CHAIRMAN PALLADIN0s Yes, we can, clearly.

11 HR. ENGELKENs At this time, we are going to 12 have a brief presentation covering five principal 13 topics.

The first four will be presented by 3r. Jesse 14 Crews and will cover the operating experience of San 15 Onofre Unit 2.

The second topic covers the delays in 18 th e test program and in achieving ?riticali ty, and the 17

suses of those dalsys.

The third will be the readiness 18 for full power operation.

The fourth an assessment of l

19 licensee 's performance.

The fif th will be presented by l

20 Nr. Norderhaus who is present in the audience in 21 Washington, and he will briefly discuss the results of 22 Region Y's safety / security interface task force review.

l i

23 At this point, I would like to turn the 24 zi rophone over to Jesse Crews who will present the four l

25 first topics, using some slides that have been sent in, ALDERSoN REPORTING COMPANY,INC,

01 1

and which will be operated by comeone in the audience.

2 MR. CREWS:

This is Jess Craws.

We would like 3

to have viewgraph 12.

4 CHAIRMAN PALLADINO:

It is on.

5 MR. CREWS 4 Assuming that this viewgraph is 6

before you, it is, as the title indicates, the operating 7

experience.

We have attempted on this slide to 8

highlight some of the events and milestones during the 9

period from issuance of the license on February 16 10 through tha inititi criticality on Monday of this week, 11 July 26.

12 I don't intend to go through each of these 13 events.

We will field questions you "may have.

I think 14 there are a couple of events that constituted unusual 15 events in reporting to us.

I sm going to ask Al 16 Chaffee, who is the senior resident at San Onofre, to go 17 through those, starting with the event of March 14, loss 18 of shutdown cooling.

19 ER. CHAFFEE:

This is Al Chaffee, can you hear 20 me?

21 CHAIRMAN PALLADINO:

Yes.

Can you hear us?

22 MR. CHAFFEFt The loss of s'hutdown cooling 23 event occurred due to air binding of the shudown cooling 24 pump.

This occurred when they were doing a normal 25 evolution of backflushing of filter at 20 with hydrogen,

At.DERSoN REPORTING COMPANY. INC,

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1 which hasn't been clearly determined, either due to 2

equipcent salfunction or operator error, resulted in the 3

.'.njection of a large quantity of nitrogen into the 4

shutdown cooling systes, and that resulted in a loss of 5

the shutdown cooling trains, both trains and both 6

pumps.

7 In the process of mitigating this, the 8

operators attempted to purge the shutdown cooling pump 9

of its nitrogen by recircing from the refueling water 10 storage tank, recircing to get rid of the gas.

In the 11 process of doing that, they lined up or opened the valve 12 which was then parallel with another valve, such that 13 they established a flow path from th e' ref ueling water 14 storage to the reactor coolant system, which resulted in 15 two things.

One, it resulted in a dilution, a small 16 dilution.

Secondly, it resulted in overflowing the 17 reactor coolant vessel, the borated water then going out 18 through an instrument signal from the top of the vessel 19 head, and overflowing the closure head, and resulted in 20 having to clean that area up.

21 This o::urred, one, because the procedure did 22 not have a caution statement, although it in fact did 23 have a sequence that the operators did not follow.

So 24 in addition to the procedure being probably weak, also 25 the operators failed to follow the procedure precisely.

ALDERSON REPORTING COMPANY,INC,

83 1

1 This resulted in the flow path being established.

2 It also occurred because the plan t was in the 3

unique line in that only during initial criticality does 4

the situation occur where the refueling water storage 5

tank when full was at a level of up to three feet higher 6

than the lavel in the rasetor coolant system where the 7

level was roughly at the plan's level.

So you, 8

therefore, had an edge, so th a t when this flow path was 9

established, it would get full of water from the 10 refueling water storage tank into the reactor coolant 11 system.

12 In addition, it became a problem as far as the 13 dilution occurring, because unknown to the licensee, 14 they also had a problem that the boron concentration in 15 the refueling water storage tank was less than that in 16 the reactor coolant system, and that occurred because of 17 stratification in the refueling water storage tank, and 18 that occurred due to two reasons.

19 One, the sampling systes that they used only l

l 20 sampled the boron concentration in the bottom of the 21 tank; and second of all, the recirc system they had for 22 recircing one of these tanks did not result in a mixing 23 of the borated water within that tank, in that when you 24 recirc the tank, the water going into the tank came in 25 at the bottom, and the water flowing out of the tank ALDERSoN REPORTING COMPANY,INC,

84 1

also came out of the bottom.

So there is no effective 2

amount of recire.

3 The licensee has corrected that on an interim 4

basis by providing a hose to the top of the tank so that 5

now they do get proper mixing.

The licensee has also, 6

as a result of this, further corrected their procedures 7

and further emphasized procedure compliance.

8 Are there any questions on this event?

9 CHAIRMAN PALLADINO:

No, but may I ask if you 10 can hear us?

11 3R. CHAFFEE:

Yes, I can hear you.

12 CHAIRMAN PALLADINO:

We weren't sure.

13 Are there questions?

14 (No response.)

15 CHAIRMAN PALLADINO:

There appear to be none.

18 Would you proceed.

17 MR. CREWS:

The second event I would nov like 18 to address involves the reactor coolant system leakage 19 and their response to that in the latter part of April.

20 MB. CHAFFEEa With this communication system 21 ve have, as long as I continue to talk, I can't hear you 22 asking questions.

So if you do ask a question, if I 23 don't stop it is for that reason.

Let me go ahead and 24 start.

25 The licensee, following going into Mode 4, had ALCERSoN REPORTING COMPANY, INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345

85 1

to do a reactor coolant system leakage test, and he also 2

had to do an emergency core cooling system check valve 3

verification to determine that the 'askage rate through 4

its check valves was less than a gallon per minute.

5 On April 27, when he went into Eode 4, he had 6

pressurized up to 2200 pounds in preparation for doing 7

the emergency core cooling system check valve leakage 8

test, and in conjunction, while doing that, he was also 9

doing reactor coolant leakage calculations which looks 10 for leakage from all various sources from the reactor 11 coolant system.

12 In the process of doing this reactor coolant 13 leakage chack in conjunction with als5 doing ECCS check 14 valve leakage, and doing several other evolutions, they 15 determined that they had an unidentified leakage rate 16 that was in excess of the one gallon per minute tech 17 spec limit.

18 They then did repeated calculations to try to 19 get a firm handle on the exact value of the leakage, but 20 the issue became a little bit confused because they were 21 having some problems, unless they had time ahead of 22 samples being taken and the ECCS calculations being 23 done, where they were charging water into the RCS, which i

l 24 at times made the results they were getting seem t

1 25 confusing.

ALDERSoN REPORTING COMPANY,INC,

_ _, C$$ ME@lNIA AVE,9.W, WASHINGTON, D.C. 20024 (8 21) 554-2345

86 1

So probably due to the several evolutions 2

going on, also due to the fact tha t the procedure they 3

were using was being used for the first time and did not 4

take them directly to identifying the location of the 5

leak, as far as just focusing on the fact that the had a 6

leak and calling it unidentified, they proceeded tc 7

declare it an unusual event.

8 They continued to follow up on it, and 9

eventually were able to identify that the majority of 10 the leakage was due to two drain valves in the reactor 11 coolant system, which were interior test valves that 12 were leaking.

They in effect accounted for the majority 13 of it.

They were able, six to ten hohrs after the event 14 was declared, to identify where the leakage was.

At 15 that point they were able to come out of the unusual 16 event.

So the identified leakage tech spec requirement 17 was 10 gallons per minute, and they were within tha t 18 once they had focused in and identified where the 19 leakage was.

20 So due in part new procedures, and being 21 somewhat unfamiliar with them, they were in a situation 22 where they declared an unusual event.

They were able to 23 identify where the leakage was.

They have since refined 24 their procedure and refined their technique for doing 25 this type of calculation.

ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345

87 l

1 In addition, while this was occurring, ther 2

also found that they did haveun acceptable leakage on 3

the emergency core cooling system check valves due to 4

the greateste extent to misalignment of the check valve 5

itself between the peak and th e di p.

6 They corrected that, and subsequently further 7

testing proved that they were able to meet the one 8

gallon per minute emergency core cooling check valve 9

requirements for all their ECCS check valves.

10 Are there any questions on that event?

11 CHAIRMAN PALLADINO:

There are no questions on 12 that point.

13 MR. CREWSt Before leaving this slide -- this 14 is Jess Crews again -- I just would point out two 15 occasions indicated here on May 28, when the reactor 16 coolant pump seals were replaced, and again in the 17 middle of June, June 17th.

They have replaced the seals 18 on all four pumps, and in two of the pumps, twice ther 19 have replaced seals.

20 They have pretty much concluded that the cause 21 of the degradation of the seals being misalignment 22 between ta a reactor pump motor shaf t and the pump l

23 shaft.

That has been corrected and, hopefully, that l

24 will correct the problems that they have been 25 experiencing.

l 1

ALDERSON REPORTING COMPANY,INC, Ci$ 6 % @%% WIN 8T@N, @L@. EiEA q@ E93-@CO

88 1

I would just quickly point out that the 2

problem has been excessive leakage, but one of 3

degradation of one of the seals in each of the reactor 4

coolant pumps.

5 Hoving on to the next slide, we have put 6

together.

7 COMMISSIONER AHEARNE:

Jesse, can I ask you a 8

question on the previous slide?

9 HR. CREWSa Okay.

10 COMMISSIONER AHEARNE:

Could you explain the 11 event of March 19?

12 HR. CREWS:

This was an occasion when they 13 were using a metal rule'to make some measurements on 14 instrumentation penetration.

This penetration, they had 15 look at prior to this accident, and this is penetration 16 where there is a height within the penetration, so that 17 it is leaving an annulus area.

l 18 They had done some measurements to determine

(

19 that, they inadvertently dropped the rule on what they l

20 had not considered as the non-concentrix orientation of 21 the instrument penetration in the inner-tubes.

After a 22 number of measurements had been made, the metal rule 23 fell into the reactor vessel.

That required the removal 24 of the vessel head to retrieve it.

25 COMMISSIONER AHEARNE:

That is what it sounded ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE S.W., WASHINGTON. D.C. 200_24 (202) 554-2345

89 1

like.

2 COHHISSIONER ROBERTS:

Question on the slide 3

12, the event of 5/17, what do you mean by vent line 4

failed?

Specifically what happened?

5 MR. CREWS:

One of the vent lines actually 6

failed, broke off.

This is about a three quarter inch 7

line, which is connected to a two-inch cross-tied line 8

between the two trains of feedvater.

9 They had experienced earlier excessive 10 vibration.

In fact, Al Tracy had observed what appeared 11 to be excessive vibration in that particular section of 12 the feedwater piping.

He brought it to their

~

13 attention.

14 They re pe a te d the plant condition to try to 15 reproduce the vibration.

They did make the seasurements 16 which served as part of their evaluation and analysis of 17 any degradation to piping.

But on two occasions, a 18 three-quarter inch vent line failed due to fatigue from 19 vib ra tio n.

20 CHAIRHAN PALLADINO Any other questions?

21 Will you proceed.

22 ER. CREWS We are going to the next slide, 23 slide 13, please.

24 On this slide, we have indicated the principal l

l 25 delays brought by events after issuance of the license.

I ALCERSoN REPORTING COMPANY. INC.

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I would state ons corre: tion to this slide, the last 2

bullet entitled " Reactor Coolant RCT Seal Repair," the 3

time to be corrected to 19 days rather than the 10 as 4

indicated.

That then results in a cumulative delay 5

represented on this slide of approximately two months.

6 We included this slide because there has been 7

some concern of the period of time since issuance of the 8

license and initial criticality, at the base of which 9

the testing program has progressed.

10 CHAIRHAN PALLADINO:

Commissioner Roberts has 11 a question.

12 COHNISSIONER ROBERTS Your foreign material 13 in vessel required head removal, impa'ct five days, is 14 tha t the same thing on the previous slide as the 3/19 15 event?

16 3R. CREWSa It is.

17 CONFISSIONER ROBERTS:

Is there any 18 inconsistency between the dates.

This says, reinstalled 19 vessel head 3/20.

Slide 12 indicates a one day passage 20 of time, and this indicates a five-day delay.

I don't 21 understand.

22 MR. CREES:

I think on the 19th, it indicates 23 when the vessel head had been removed, and then the 24 retrieval of the metal rule.

25 COHHISSIONER ROBERTS:

The next line says, ALDERSoN REPORTING COMPANY,INC.

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3/20, rainstallad the vasrel head.

2 HR. CREWSs The 19th is when they retrieved 3

the metsi rule.

They actually dropped it in there 4

several days prior to that.

Af ter removal the rule, the 5

next day they actually reinstalled the vessel head.

It 6

aust have been like on March 14 when they a ctu ally 7

dropped th e metal rule into the vessel, and then it took 8

several days to cool down, remove the material above the 9

head, and then remove the head, and finally removed the to rule on the 19 th.

The total lost time was five days.

11 COMMISSIONER ROBERTS:

Thank you.

12 CHAIRMAN PALLADINO:

Any other questions?

~

13 Will you proceed.

14 MR. CREWSa I would point out, again, the 15 reactor coolant pump seal replaced were an appreciable 16 part of tha cumula tive dela y.

17 I would just try to give by way of comparisons 18 of performance by others that we have looked, they have 19 ranged from something slightly more than a month between 20 issuance of the lower power license and initial 21 Oriticality up to four months, and San Onof re, it was 22 exactly five months.

23 CHAIRMAN PALLADINO:

Iou can continue.

24 MR. CREWS May I have slide 14, please.

25 This slide summarizas the status of our i

ALDERSoN REPORTING COMPANY,INC, M EMIMD NTL R% CC9XXM8M @$fMAG W E93-SD29

92 1

program.

The TMI action items, their implementation, 2

and the licensee conformance are indicated on this 3

slide.

Our program is current.

The TMI action items 4

either are complete, and there is sufficient assurance 5

that, looking at their schedule,.they will be done by 6

the time required, and the same is true of conformance 7

with the license conditions.

8 We haya used these areas of licensee 9

performance in the presentation here, the licensee event 10 reports, unusual events, and enforcement actions.

11 During the period of the last five months, as 12 indicated on this slide, there have been approximately 13 60 licensen event reports.

Those are' conditions 14 requiring a report by the licensee in writing to the 15 Regional Office.

12 By way of comparison to previous facilities, 17 they fall somewhere in the middle of performance of the 18 other facilities.

The number of LERs has ranged from on l

19 the order of 20 on the low side, to as many as 140 in a l

20 six-month period of time, and at San Onofre, they have 21 had 60 in a period of time of about five months.

l 22 COMMISSIONER AHEARNE:

With respect to that, l

23 you say that it falls right about the middle, and you l

24 give a 20 to 140 range.

Is this 20 to 1u0 range for l

l 25 plants in a similar situation, that is plants going t

ALDERSoN REPORTING CoWPANY,INC, CDD VIR$1NIA AVL @.Wm W@HIN@T@Ne @.@. SDE4 (EES) O-33-EEYG

93 1

through their start-up?

2 MR. CREWSs The period is comparable for all 3

the plants, the first six months of operation and 4

issuance of the license, and all plants are closely 5

aligned.

6 COHNISSIONER AHEARNE:

Thank you.

7 NR. CREWS:

The next category is unusual B

events.

Al has described the two occasions when there 9

vere unusual events reported.

We don't consider that to 10 be an excessive number.

11 Moving to enforcement actions, we have to 12 update this slide to make it current.

There are 13 presently seven notices of violation 'that have been 14 issued by the region, all of those in the level four or 15 five category.

We have a couple currently under 16 considarstion.

Again, by compa rison, other f acilities 17 that we have looked at have ranged from as few as two to l

18 as many as 23 violations.

Amon g them, San Onof re with 19 seven is not out of line in comparison to the other to 20 the other facilities.

21 CHAIRMAN PALLADINO Any questions?

22 Will you proceed.

23 MR. CREWSs At this time, we are ready for l

24 Leroy Norderhaug, if he would, to present a statement 25 regarding the safeguards ma tters.

l l

ALDERSON REPORTING COMPANY,INC, dim FAffeYPTa /ML 9tt"L NTK6frL f0R friWO GF6H1 ERS-fELTi

94 1

58. NORDERHAUGs Chairman, Palladino, 2

Cosmissioners, I have prepared a written statement 3

concerning the program at San Onofre Nuclear Generating 4

Station, particularly as it applies to the Unit 2 5

licensing action being discussed today.

6 If you agree, I will be pleased to read that 7

five-minuta statament, which has been revie wed f or 8

national security information and safeguards 9

information, as well as for proprietary interests, and to is suitable for disclosure in a public forum such as 11 this.

If you have any specific questions, I will answer 12 them to the extent I can.

13 CHAIRMAN PALLADINO:

Can you summarize it in 14 one minute?

15 MR. NORDERHAUGs Yes.

s 16 CHAIRMAN PALLADINOs Would you please.

17 HR. NORDERHAUG4 Okay, summarizing it in one 18 minute.

(

19 CHAIRMAN PALLADINO:

Or less.

20 MR. NORDERHAUG:

The task force study looking 21 at the interface between security concerns and safety 22 needs did identify some problem areas that look like 23 they could potentially present a problem.

24 We discussed each of those items with the 25 licensee in a meeting at the regional office.

They ALDERSoN REPORTING COMPANY. INC.

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95 1

prepared and submitted to us proposed corrective action 2

for each one of those.

We reviewed them.

3 We have a team of inspectors on sfte this 4

week.

I tslked to the lead inspector this morning.

All 5

the items that were to have been completed, most of 6

which are to be done by August 1, have been.

Those that 7

have not been finished, we feel that we will be able to 8

accomplish on the time scale given.

The interim 9

sensures in place until they are ef f ective, we feel 10 compensate for those.

He don't think that there is any 11 problem.

12 CHAIRMAN PALLADINO:

Any questions?

13 COMMISSIONER ASSELSTINEa I'just have one on 14 tha t.

Does that leave in place the basic structure of 15 the present physical security arrangement a t the plant?

16 3R. N3RDERHAUG Yes.

The main changes are in 17 some cases redefining certain areas, rertain access 18 control points, some clarification of procedures, some 19 training con sidera tions.

A little additional 20 21 22 23 24 25 ALDERSON REPORTING COMPANY,INC, M0 NNfC'lY3 / Elk 9tD CCCinfMR5tdL1 f@#L M R8W MM

)

96 1

preplanning on just who needs to go where under certain 2

types of emergency conditions so that those 3

considerations are taken care of and accommodated by the 4

security program.

5 COMMISSIONER ASSELSTINE:

But you are 6

confident that that will assure that the present access 7

limitations that apply out there are not going to unduly 8

restrict the ability of plant personnel or our people to 9

be able to move about the plant in responding to an 10 emergency situation?

11 MR. NORDERHAUGs That is correct.

12 COMMISSIONER ASSELSTINE:

Okay.

13 CHAIRMAN PALLADIN0s Any other questions?

14 (No response.)

15 CHAIRMAN PALLADINO:

Okay, Bob, who is going 18 tc present the conclusion?

17 (No response.)

18 CHAIRMAN PALLADINO:

Can you hear us?

19 (No response.)

20 CHAIRMAN PALLADINO:

Are we reconnected?

21 MR. ENGELKEN:

Please?

22 CHAIRMAN PALLADINO:

Can you hear us, Bob?

l 23 MR. ENGELKEN:

We can hear you.

Can you hear j

24 us?

t 25 CHAIRMAN PALLADINO:

Yes.

Now we can.

ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345

97 1

Who is going to present the conclusion?

2 MR. ENGELKENs Bob Engelken.

3 Although the licensee has encountered a number 4

of operational problems since the issuance of the 5

operating license, such experience appears to be 6

normal.

And in addition, the licensee appears to be 7

taking aggressive corrective action.

8 Based on its observations and assessments, 9

Region V =ancludes there is reasonable assurance that 10 the licensee can safely operate San Onofre Unit 2.

11 CHAIRMAN PALLADINO:

Are there any questions?

12 ER. ENGELKENs That concludes our 13 p resen ta tion, Mr. Chairman.

14 CHAIRMAN PALLADINO:

All right.

Thank you, 15 Bob.

I gather there are no questions.

So we vill turn 16 back to the staff here.

Thank you very much.

17 HR. EISENHUTs All right.

If I could have the l

i6 r=:t slide, entitled " Amendments to the OL," this is 19 just meant to be here for completeness.

There are five l

l 20 amendments that have been issued to date.

There is 21 actually one that will be going out this week.

The 22 first four were minor revisions to tech spec numbers 23 that are in the attached tech specs.

The one going out 24 this week is a minor change to a license condition 25 changing a completion date from August 1st to November l

ALDERSON REPORTING COMPANY,INC, cU) tiTJen N11342mI%2IIggdra M AUR3 F&MTD-fava

98 1

1st.

It had to be done before the August 1st deadline.

2 The proposed smandment 6 that was handed out 3

at the beginning of the meeting is an amendment to the 4

license which would authorize f ull-power operation.

It 5

puts in the emergency preparedness conelitions that flow 6

out of the ASLB decision.

It also is making a number of 7

minor tech spec changes at the same time associated with 8

this amendment.

9 There is an environmental qualification 10 condition date that is here.

Recall what happened 11 recently was that there were three conditions on 12 environmental qualifications one was having records; 13 one was having everything complete; ahd the third one is 14 the maintenance and surveillance program.

15 All three of those were by June 30, 1982.

The 16 Commission smended that date by rule.

We asked the 17 utility what would be an appropriate date for those 18 three items.

He states he has completed the first two 19 items; that is, everything is, in fact, qualified, the 20 E-2 conditions, and he does have a file.

21 However, he pro' posed that the last item be 22 completed by the first refueling outage.

We therefore 23 propose that in the license condition.

24 COMMISSIONER AHEARNE:

The last item being the 25 surveillance and maintenance?

ALDERSoN REPORTING COMPANY,INC,

99 1

HR. EISENHUT Yes, it is.

Hence, the license 2

condition that you see in the amendment is only a change 3

to item C.

Just 5.C.

4 We already discussed the reactor pressure 5

depressurization system conditions.

I will not mention 6

those.

7 There vss one other condition that, was not in 8

the package that was submitted downtown.

If I could 9

have the last slide, please.

10 COMMISSIONER AHEARSE:

Before you do, on that 11 last item you were just talking about, Darrell, I 12 remember the first two items.

I did not recall what we 13 had ended up doing in the recent addressal on the 14 surveillance and maintenance.

15 3R. EISENHUT Ihey had all three been June 16 30, 1982.

And I believe the rule erased essentially all 17 three of the June 30, 1982, dates.

It, in effect, 18 erased all dates.

19 COMMISSIONER AHEARNE:

Yes, but it left open 20 the possibility the dates might 21 ER. EISENHUT:

Might be put back in.

22 COMMISSIONER AHEARNE:

Yes.

23 3R. EISENHUT So, in effect, what we have 24 done, both on LaS111e and on San Onofre -- and we 25 proposed continuing the OLs -- is rather than completely ALDERSoN REPORTING COMPANY,INC,

100 1

drop the condition --

2 COMMISSIONER AHEARNE:

Right.

3 ER. EISENHUT

-- we have asked the utility to 4

propose a date that he can meet.

And on the LaSalle 5

license, you will recall there were two dates.

6 COMMISSIONER AHEARNE:

Yes.

7 ER. EISENHUTa And here he did not need to 8

propose a new date for items A and B.

9 COMMISSIONER AHEARNEa I did not understand 10 then.

It was C that I was wanting 11 HR. EISENHUTs And item C he proposed the 12 first refueling outage.

13 COMMISSIONER AHEARNEa And 'what was the 14 staff's position with respect to that?

Does that seem a 15 reasonable date?

16 NR. EISENHUT:

It seemed reasonable, yes, it 17 did.

18 COMMISSIONER AHEARNE:

The surveillance

(

19 program in question is what?

20 MR. EISENHUT:

In fact, I believe it is one of i

21 the two.

The surveillance has been accomplished, and 22 the maintenance is --

23 ER. ROCD:

No, it is the other way around.

l 24 MR. EISENHUT:

Oh, okay.

25 NR. BOOD:

The maintenance procedure is f

I i

ALDERSoN REPORTING COMPANY,INC, J

101 l

i 1

installed and in place.

But the surveillance, they need 2

some time to develop their surveillance criteria and 3

acceptance carves and things like that.

They are not 4

ready to put it in at this time.

5 COETISSIONER AHEARNE:

But the maintenance 6

procedures are all ready?

7 MR. ROODa But the maintenance program is 8

ready.

9 MR. EISENHUT4 in fact, we kept the license 10 condition intact, basically.

11 COMMISSIONER ROBERTS:

Questions Is there any i

12 inconsistency between this slide, which says it requires 13 the RCS depressurization system -- requires 14 installation?

l 15 MR. EISENHUT:

No, it was not meant to be 18 it was in the edification of the slides, is it evolved 17

-- it was meant to be -- this slide was meant to be a 18 summary.

It is certainly no change was meant, "if 19 required."

20 COMMISSIONER ROBERTS:

If required.

21 MR. EISENHUT Yes.

22 COMMISSIONER ROBERTS.

There is a difference.

23 MR. EISENHUT The last slide is an item that 24 actually csme about as part of a continuing review.

25 There is one license condition we have proposed to be ALDERSoN REPORTING COMPANY,INC, S M MM

102 1

added relating to a modification to implementation 2

relating to the auxiliary feedvater pump room.

There is 3

s piece of high-energy line that goes through the room, 4

and there will be some action taken by October of this 5

year to' accommodate breaks in that small segment of line 6

up in the first isolation valve.

7 That basically completes the presentation we 8

had planned.

I guess one other item, the last slide.

9 This is a 30-year license.

The utility in this case has 10 not requested a 40-year license.

It is really a 32-year 11 license.

40 years from the date of the CP.

12 CHAIRMAN PALLADINO:

All right.

Thank you.

13 Are there any questions?

14 (No response.)

15 CHAIRMAN PALLADINO:

Well, let me ask the 16 Commission a question so that we see how to proceed.

17 Aside from the question of depressurization and decay 18 heat, are there any other issues that the Commissioners 19 feel we will have to address?

All right.

20 COMMISSIONER AHEA RNE:

No.

21 CHAIRMAN PALLADINO:

Okay.

Then let me 22 propose that we address the depressurization/ decay heat 23 question.

And I am going to suggest that we take up to 24 1 minute to say what the position is, and then I suggest 25 ve vote whether we want to support the staff's ALDERSoN f,EPORTING COMPANY,INC,

_ 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345 _

103 1

recommendation or not.

And then, depending on what 2

happens to tha t, we vote on the license.

Is that a 3

reasonable way?

4 (No response.)

5 CHAIRMAN PALLADINO All right.

Well, let me 6

take the prerogative of the Chair, since I also support 7

the staff.

8 (Laughter.)

9 CHAIRHAN PALLADINO:

It appears to me that 10 this will be the first CE plant after Three Mile Island 11 to be built without some means of depressurization.

If 12 I understand correctly, St. Lucie 2 has a PORV.

Palo 13 Yerde vill install a PORV.

WNP-3 -- I think it is 3 --

14 is having a study.

And San Onofre will not have a 15 system or a PORY.

16 So while one might say this.is a generic 17 issue, it is the first one out of the pattern.

And I 18 should also note that after the WNP-3, the others will 19 add some depressurization.

20 And since I feel that depressurization is a 21 very important item, particularly when we come to steam 22 tube rupture, I think it is appropriate to ask San 23 Onofre to at least look into what is involved in the 24 design and in the process establish what we 25 sc omplished.

l ALDERSCN PEPoRTING COMPANY. INC.

400 VIRGINIA AVE., S.W, WCOMINGTON, D.@. 20024 G8BBj) @54-5%G

104 1

That is my one minute.

All right.

2 C05MISSIONER ROBERTS:

While I am addressirq 3

the merits, I disagree with it procedurally, with this 4

method.

5 CHAIRMAN PALLADINO Well, if this were -- I 6

am sorry, I was going to give each person a minute, and 7

then I interrupted.

8 (Laughter.)

9 CONNISSIONER AHEARNE:

Yes, I think that that 10 is slightly misleading presentation, Joe, on where the 11 status is, in the sense that WNP-3 is studying it, 12 Baterford has said, no, they were not going to put it 13 in, as did San Gnofre, and Combustion", as we have heard, 14 has said that they are also studying it and will, I 15 gather, eventually go to a depressurization aspect.

And 16 I would not be surprised, to some extent, because we are 17 convinced that it ought to be there.

18 Myself, I would tend to agree with you on just 19 an intuitive feeling that it is probably a sound ites to 20 put in.

However, we have spent a long time trying to 21 addressing let us get the procedures of putting in place 22 changes in such a way that we can have confidence that 23 this is the way it ought to go.

24 It seems to be the first out of the box in 25 that sense, that instead, we are going to decide ALDERSoN REPORTING COMPANY,INC,

105 1

intuitively it is a good thing, we ought to require the 2

licensee to design it.

3 I have no problem with requiring a design by 4

someone, and I have no problem with saying, well, let us 5

have the utility industry do it because they have a 6

different perspective, and I would have no problem with 7

taking some of our money that we have and transferring 8

it to EPRI to do that design.

9 I do have a problem with using the fact that 10 the licensee needs a license to require it.

11 COMMISSIONER ROBERTS:

Absolutely.

12 CHAIRMAN PALLADINO:

I was not trying to hold 13 up the license in any way.

As a matter of fact, the 14 proposal does recognize that there is time in which to 15 design and study.

But WNP at least is having a study, 16 and here we do not have a study required, nor do we have 17 a design.

18 It will still be the first one out of the 19 pattern, so in that regard, it is a change.

But I think 20 we can vote on it, after we have had everybody had a 21 chance to talk, vote on whether or not 22 (Laughter.)

23 CHAIRMAN PALLADINO:

By everybody, I mean the 24 four Commissioners.

25 (Laughter.)

ALDERSON REPORTING COMPANY,INC,

106 1

CHAIBMAN PALLADINO:

And then we will address 2

it on a different basis.

3 Jim?

4 COMMISSIONER ASSELSTINE:

My feeling is that I 5

think this is -- I agree with what John said and with 6

what you have said -- I think this is an area, the 7

depressurization area, is an area that needs to be 8

looked at.

9 My feeling is we should not impose this 10 condition, the staff 's proposed condition specifically, 11 and we should not require the development of a design, 12 for much the same reasons that John has mentioned.

^

13 I do think that we ought to adhere to the 14 process that we have set up now for looking at these 15 design changes.

I think we already have the CE Owners 16 Group study with Southern California Edison 17 participating, and we already have our own study on the 18 unresolved safety issue.

19 If there is a real concern about whether SCE 20 is pursuing that study, then I would not have a problem 21 with putting in the requirament that they do the study 22 by a certain date as a license condition, but I do not 1

23 support th e requirement to develop the design.

24 It was unclear to me in the exchange we had 25 with the applicant and with the staff how much of a ALDERSON REPORTING COMPANY,INC, A>TFAl#NFUPl#Y14

107 1

problem that is, whether we need to impose a condition 2

to require that they do go forward and study this and 3

get back to us in the time f rame tha t was discussed 4

earlier.

But I would not support this condition.

5 CHAIRMAN PALLADIN04 Let me ask a question.

6 This study that is in the SER, is that a requirement, or 7

has there been a commitment made to it?

8 MR. DENION:

Let me ask Darrell.

I do not 9

think -- we have not put that in the license as a 10 requirement, I think it is more informal.

But it could 11 be changed into a requirement that it be submitted by 12 some given date.

13 CHAIRMAN PALLADINO:

Is there a commitment on 14 the part of the applicant to do it?

15 HR. EISENHUT There is a commitment.

More 16 formally, we had sent a letter to the applicant.

The 17 applicant has agreed to participate and do it as part of 18 the CE Owners Group.

He sent us a letter, and the only 19 thing that is missing is, in fact, a firm date, number l

20 one, as to sort of a drop-dead date for the end of the l

21 study; and number two, is not a formal license 22 condition.

It could be made into such a condition.

23 CHAIRMAN PALLADINO:

Well, I just lost the 24 other vote.

25 (Laughter.)

i ALDERSoN REPORTING COMPANY,INC.

108 1

COMMISSIONER ROBERTS:

I would not make it a 2

license condition.

3 CHAIRMAN PALLADINO:

I understand, as I say.

4 But the other vote on whether or not we would hate this 5

proposal of the staff as part of the license is lost by 6

3-1.

Okay.

7 Now do we want to consider about making this a 8

license condition?

9 COMMISSIONER ASSELSTINE:

I have no problem 10 with formslizing the requirement that they do the study 11 and to put a date certain so that we know that we are 12 going to get the results back by a certain time.

13 Cil AIR M AN PALLADINO:

Fine.

"I would vote for 14 that, too.

And the date that you would propose vculd 15 be?

16 COMNISSIONER AHEARNE:

It could be something 17 like, say, March.

i 18 MR. DENTON:

We had talked about March, but I i

19 think if it is to be a license condition, we would want 20 to check with the company to be sure it is an achievable 21 date to get product in that time frame.

22 MR. EISENHUT And generally, I ask him to 23 send me a letter as to when he can really commit to do 24 it, put it back as a license condition.

25 CHAIRMAN PALLADINO:

Well, does it ALDERSON REPORTING COMPANY INC, 400 VIRGINIA AVE, S.W, WASHINGTON, D.C. 20024 (2023 554-2345

109 1

COMMISSIONER AHEARNE:

But I tnink you also 2

put some -- I mean if he comes back and says he 3

absolutely can do it by 1985, I do not think it would be 4

a good idas.

5 (Laughter.)

l 6

HR. EISENHUT Well, we do exercise a little 7

judgment.

8 COMMISSIONER AHEARNE:

Hake sure it is really 9

10 CHAIRMAN PALLADINO:

But with the 11 understanding that the time frame in which the 12 Commission is thinking is March to Juna or July --

13 COMMISSIONER AHEARNE Righi 14 CHAIRMAN PALLADIN0a

-- of that year, of next 15 year.

16 COMMISSIONER AHEARNE:

Yes.

17 CHAIRMAN PALLADINO:

All right.

I gather, 18 Tom, you vote against that?

19 COMMISSIONER ROBERTS:

Yes.

20 CHAIRMAN PALLADINO:

You vote for?

21 COHNISSIO N ER AREARNE:

Yes.

22 CHAIRMAN PALLADINO I vote for it.

You vote 23 for it.

24 COMMISSIONER ASSELSTINE:

Right.

25 CHAIRMAN PALLADINO:

All right.

ALDERSON REPCRTING OOMPANY,INC,

_ MRMTirEFmomLMt FPctarKAEr5TR 61f197com oT.Fa coMEvo

110 1

Well, now, are we ready to vote on granting 2

the license?

3 COMMISSIONER AHEARNE:

Yes.

4 CHAIRMAN PALLADINO:

With all the conditions.

5 Right?

6 All those in favor indicate by saying aye.

7 (Chorus of ayes.)

8 CHAIRMAN PALLADINO:

Opposed?

9 (No response.)

10 CHAIRMAN PALLADINO:

All right, I think we 11 have accomplished toda y's task.

A re there any other 12 points that should come up in this?

13 (No response.)

14 CHAIRMAN PALLADINO:

Thank you all for your 15 participation.

16 Thank you, Bob.

We have not forgotten you all

(

17 out there.

~~

1 18 We will stand adjourned.

l 19 (Thereupon, at 5:40 p.m.,

the Commission wa s l

l 20 adjourned.)

l 21 22 23 l

24 l

25 ALDERSON REPORTING COMF'ANY, INC, 400 VIRGINIA AVE., S.W., WASHINGTON. 0.C. 20024 (202) 554 2345

N NUCLEAR REGULATORE COMMISSICN This is to certify that the attached proceedings before the COMMISSION MEETING in the :: atter of:

PUBLIC MEETING - Disucssion of and Possible Vote on Full Power Operating License for San Onofre Unit 2 Date of Froceeding:

. ri31,7 79-1992 Docket !! umber:

Place cf Proceed.ing: Washington, D. C.

were held as hereia appears, and that this is the criginal transcript therect for the file of the Cc::: mission.

Patricia A. Minson Official Eeporter (Typed)

W Official Reporter (Signature)

  • .,e' M

-._~

CONTACT 8 H. ROOD

~

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. STATUS / SCHEDULE e SELECTED REVIEW ITEMS

-CORE PROTECTION CALCULATOR

-RCS DEPRESSURIZATION SYSTEM (PORVs)

-INDEPENDENT DESIGN VERIFICATION

-SHIFT' STAFFING e ASLB HEARING ISSUES

-SEISMIC DEEIGN

-EMERGENCY PREPAREDNESS

. REGION V REPORT

-0PERATING EXPERIENCE SINCE LICENSING

-DELAYS AND CAUSES

-SAFEGUARDS CONSIDERATIONS

-READINESS FOR FULL POWER OPERATION

-ASSESSMENT OF LICENSEE PERFORMANCE e AMENDMENTS TO 0?ERATING LICENSE e PROPOSED FULL POWER AMENDMENT

-CONDITIONS /0UTSTANDING ISSUES r

GL PLANT DESCRIPTION / LOCATION e UTILITY:

SOUTHERN CALIFORNIA EDISON e REACTOR TYPE:

PWR e NSSS VENDOR:

CE e CONTAINMENT TYPE:

LARGE, DRY

  • ENGINEER / CONSTRUCTOR:

BECHTEL e POWER:

1100 MWE/3390 MWT e LOCATION:

SAN DIEGO COUNTY, CALIFORNIA

- 5 MILES SOUTH OF SAN CLEMENTE

- POPULATION WITHIN 5 MILES:

27,000

  • FIRST CE PLANT LICENSED SINCE TMI j

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STATUS / SCHEDULE LICENSING MILESTONES e

-CONSTRUCTION PERMIT ISSUED:

OCTOBER 18, 1973

-0L APPLICATION DOCKETED:

MARCH 23, 1977

-0L ISSUED:

FEBRUARY 16, 1982 CONSTRUCTION SCHEDULE e

-UNIT 2:

COMPLETE FEBRUARY 1982

-UNIT 3:

NOVEMBER 1982 PER APPLICANT UNIT 2 STARTUP SCHEDULE ISSUE LOW POWER LICENSE

-FEBRUARY 16, 1982 BEGIN LOADING FilEL

-FEBRUARY 19, 1982 FUEL LOADED & HEAD TENSIONED

-MARCH 13, 1982

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INITIAL CRITICALITY

-JULY 26, 1982 EXCEED 5% POWER

-WEEK OF AUGUST 16, 1982 l

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4 CORE PROTECTION CALCULATOR USES DIGITAL COMPUTER GENERATED SIGNAL TO TRIP REACTOR e

FIRST USED ON ANO-2

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eWILi_BEUSEDONFUTURECEPLANTS

  • STAFF REVIEWED CHANGES FROM ANO-2 CPC i

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Tl PORVS e

MOST NEW CE PLANTS DO NOT HAVE POWER OPERATED RELIEF VALVES (PORVs) e GENERIC STUDY UNDERWAY BASIS FOR INTERIM ACCEPTABILITY RELIABLE AFWS:

2 100% CAPABILITY MOTOR DRIVEN PUMPS PLUS 100% CAPACITY STEAM DRIVEN PUMP PLUS LOW HEAD (NON-SAFETY) BACKUP PUMPS, PLANT CAN SHUT DOWN (COLD) USING SAFETY GRADE SYSTEMS, WITHOUT OFFSITE POWER, WITH SINGLE FAILURE 0

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G DEPRESSURIZATION CAPABILITY FOR PLANTS OF CE DESIGN 4

0 DEPRESSURIZATION SYSTEM NOT NEEDED FOR CURRENT DESIGN BASIS EVENTS NO UNACCEPTABLE CHALLENGE TO SRV AFW SYSTEM RELIABILITY IS HIGH I

A DEPRESSURIZATION CAPABILITY COULD BE DESIGNED TO BE SUFFICIENTLY RELIABLE 8

IT IS DESIRABLE AS BACKUP TO THE SECONDARY SYSTEM e

IT COULD IMPROVE ATWS CAPABILITY O

MOST OPERATING PWRs HAVE SOME DEPRESSURAIZATION CAPABILITY USING PORVs O

CE AND OWNERS REQUIRED TO STUDY THE NEED FOR A SYSTEM AND REPORT BY ABOUT MARCH 1983 0

WE NON RECOMMEND ADDING A CONDITION TO SAN ONOFRE LICENSE TO REQUIRE A DESIGN OF A DEPRESSURIZATION SYSTEM AND, INSTALLATION, IF REQUIRED.

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7 LICENSE CONDITION FOR SAN ON0FRE UNIT 2 BY JULY 1, 1983, THE LICENSEE SHALL PROVIDE A DESIGN AND SUPPORTING ENGINEERING STUDY FOR VALVES, AND ASSOCIATED HARDWARE, CONTROLS AND PROCEDURES, THAT COULD BE ADDED TO THE REACTOR COOLANT SYSTEM TO PROVIDE FOR ITS CONTROLLED, RAPID DEPRESSURIZATION.

THE DEPRESSURIZ-ATION SYSTEM SHALL HAVE HIGH RELIABILITY AND BE SIZED TO PERMIT SUFFICIENT REMOVAL 0F DECAY HEAT BY PRIMARY COOLANT MAKEUP SYSTEMS TO PREVENT UNACCEPTABLE CORE DAMAGE AFTER A REACTOR SCRAM FROM FULL PONER WITHOUT RELIANCE ON HEAT TRANSFER TO THE STEAM GENERATORS AND THEIR FEEDWATER SYSTEMS.

THE STUDY SHALL CONSIDER, BUT THE DESIGN NEED NOT NECESSARILY MEET, GENERAL DESIGN CRITERIA 1, 2, 3, 4, 14, 30 AND 34 0F APPENDIX A TO 10 CFR PART 50." THE STUDY SHALL INCLUDE COST / BENEFIT ANALYSES OF DESIGN VARIATIONS THAT WOULD CONFORM COMPLETELY AND TO VARYING DEGREES WITH THESE GENERAL DESIGN CRITERIA TO DEMONSTRATE H0F THE LICENSEE'S RECOMMENDED DESIGN COST EFFECTIVELY SATISFIES ITS DESIGN OBJECTIVES.

IF REQUIRED, THE LICENSEE SHALL INSTALL THE DEPRESSURIZATION SYSTEM BEFORE STARTUP FOLLOWING THE NEXT REFUELING OUTAGE OR OTHER OUTAGE OF SUFFICIENT DURATION WHICH COMMENCES 24 MONTHS AFTER STAFF APPROVAL OF THE DESIGN.

Y INDEPENDENT DESIGN VERIFICATION e REVIEW 0F SEISMIC DESIGN AND QA PROGRAM CONDUCTED BY GENERAL ATOMIC COMPANY (GA) e MAJOR TASKS CONDUCTED BY GA

-DESIGN PROCEDURE REVIEW

-DESIGN PROCEDURE IMPLEMENTATION REVIEW

-TECHNICAL ASPECTS OF SEISMIC DESIGN

-AUDIT PLAN REVIEW

-PIPE SEGMENT WALKDOWN

-INDEPENDENT CALCULATIONS o

STAFF REVIEW 0F GA PROGRAM

-INDEPENDENCE OF GA

-TECHNICAL QUALIFICATIONS OF GA REVIEWERS

-QA USED BY GA DURING ITS REVIEW

-GA PROGRAM PLAN

-IMPLEMENTATION OF GA PROGRAM

-RESULTS OF GA PROGRAM e

CONCLUSIONS

9 SAN ONOFRE UNIT 2 SHIFT STAFFING e SHIFT STAFFING NOW LIMITED BY NUMBER OF SR0s e CURRENTLY OPERATING WITH 4 SHIFTS PLUS 2 SR0s IN TRAINING OR IN RESERVE e ADDITIONAL SR0s TESTED IN JUNE - RESULTS OF EXAMS EXPECTED IN AUGUST p MORE SR0 CANDIDATES SCHEDULED TO BE TESTED.IN DECEMBER, 1982, e THE LICENSEE HAS COMMITTED, PRIOR TO EXCEEDING FIVE PERCENT POWER, THAT SAN ON0FRE UNIT 2 SHALL BE STAFFED

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WITH 5 SCHEDULED OPERATING SHIFTS.

1 SEISMIC DESIGN e SEISMIC DESIGN BASIS - 0.67 G'S e DESIGN BASIS RE-EVALUATED DURING OL REVIEW e

PLANT HAS SEISMIC TRIP SET AT 60% OF SSE e

HEARING ISSUE:

ADEQUACY OF SEISMIC DESIGN BASIS e

ASLB HEARING HELD JUNE - AUGUST 1981 e

PARTIAL INITIAL DECISION OF JANUARY 11, 1982 DECISION APPEALED - STAY OF LOW POWER TESTING DENIED BY ASLAB AND COMMISSION TEMPORARY RESTRAINING ORDER STAYING LOW POWER TESTING DENIED BY THE U. S. COURT OF APPEALS FOR D. C.

e

I.

EMERGENCY PREPAREDNESS e HEARING ISSUES:

ADEQUACY OF EMERGENCY PLANS AND THEIR IMPLEMENTAION e REARING HELD:

AUGUST - SEPTEMBER 1981 o PARTIAL INITIAL DECISION:

JANUARY 11, 1982 (LOW POWER) e INITIAL DECISION:

MAY 14, 1982 (FULL POWER)

-ISSUES GENERALLY DECIDED IN LICENSEE'S FAVOR

-SEVERAL CONDITIONS IMPOSED BY BOARD

-DECISION APPEALED, STAY DENIED BY ASLAB -

e EMERGENCY PLAN EXERCISES

-FULL SCALE:

MAY 13,1981

-SMALL SCALE: APRIL 15,1982

OPERATING EXPERIENCE DATE EVENT 2/16/82 OL ISSbED 2/19/82 COMMENCED FUEL LOADING 2/28/82 COMPLETED FUEL LOADING - COMMENCED ASSEMBLY AND CLOSURE OF REACTOR, REWORK 0F CEDM VENTILATION, AND CONDUCT OF PRECRITICAL SYSTEM TESTS 3/14/82 LOST SHUTDOWN COOLING FOR ABOUT ONE HOUR DUE TO NITROGEN IN SYSTEM -

CONCURRENT MINOR BORON DILUTION (TANK STRATIFICATION) (UNUSUAL EVENT) i 3/19/82 REMOVED REACTOR VESSEL HEAD TO RETRIEVE METAL RULE 3/20/82 REINSTALLED REACTOR VESSEL HEAD - RESUMED SYSTEM PRECRITICAL TESTS 4/19/82 BEGAN SYSTEM HEATUP (MODE 4: 200F - 350F) - CONDUCTED SYSTEM TESTS 4/25/82 ENTERED MODE 5 (<t200F) TO CORRECT EXCESSIVE CHECK VALVE LEAKAGE 4/27/82 REENTERED MODE 4 TO TEST CHECK VALVE LEAKAGE 4/28-30/82 EXCESSIVE RCS LEAKAGE (UNUSUAL EVENT) - C00LDOWN TO MODE 5 TO REPAIR LEAKAGE 5/09/82 RESUME HOT SYSTEM TESTS 5/14/82 ENTER MODE 3 (;m 350F) FOR FURTHER SYSTEM TESTS 5/28/82 COMMENCE C00LDOWN TO REPAIR RCP SEALS - SUBSTANTIAL VIBRATION ALSO NOTED IN MAIN AND AFW LINES 6/07/82 RETURNED TO MODE 3 (Et 350F) FOR ADDITIONAL SYSTEM TESTS 6/11/82 WHILE INVESTIGATING CAUSE OF AFW PIPE VIBRATIONS, ONE-INCH VENT LINE IN AFW SYSTEM FAILED 6/17/82 COMMENCED C00LDOWN TO REPAIR RCP SEALS AND INVESTIGATE CAUSE OF FAILURES -

DURING C00LDOWN, VENT LINE ON AFW SYSTEM AGAIN FAILED - THIS TIME IN ABSENCE OF SIGNIFICANT VIBRATION

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7/06/82 R5 TURNED TO MODE 4 FOLLOWING REPAIR OF RCP SEALS 7/15/82 RETURNED TO MODE 3 FOLLOWING REPAIR OF CONTAINMENT SPRAY PUMP MOTOR BEARING

DELAYS AND CAUSES.

FUEL SET HEAD INIT LOAD CEDM REWORK POST CORE HOT FUNCTIONAL CRIT LOW PWR O

0-TESTS PREP TESTS O

-C 0-0-

0 BORIC ACID FOREIGN MATERIAL CHECK VLV/RCS LEAKAGE CLEANUP IN VESSEL REQUIRED C00LDOWN REQUIRED REQUIRED HEAD IMPACT - 7 DAYS HEAD RETENSION REMOVAL IMPACT - 7 DAYS IMPACT - 5 DAYS AUXILIARY FEEDWATER MOTOR REPAIR EXTENDED C00LDOWN DURATION IMPACT - 6 DAYS INSTRUMENT NOISE PROBLEMS EXTENDED SURVEILLANCE DURATION IMPACT - 5 DAYS RCP SEAL REPAIR (#2 a 3)

REQUIRED C00LDOWN IMPACT - 12 DAYS RCP SEAL REPAIR (1, 2, 4)

REQUIRED C00LDOWN IMPACT - 10 DAYS REPLACE CONTAINMENT SPRAY PUMP MOTOR BEARING - 4 DAYS CUMULATIVE DELAY APPROXIMATELY 1.5 MONTHS h-

s.

READINESS FOR FULL POWER OPERATION 1.

INSPECTION PROGRAM - CURRENT 2.

VERIFICATION OF TMI ACTION ITEMS (ASSIGNED TO A)

REGIONS)

- CURRENT 3.

CONFORMANCE WITH LICENSE CONDITIONS - CURRENT A)

A) VERIFICATION COMPLETE OR THERE IS REASONABLE AS REQUIREMENT WILL BE SATISFIED BY THE REQUIRED MILESTONE.

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ASSESSMENT OF LICENSEE PERFORMANCE TO DATE I.

A.

LICENSEE EVENT REPORTS 25 ISSUED SINCE OL

    • 12 - PERSONNEL ERROR 3 - INADEQUATE PROCEDURE 4 - COMPONENT FAILURE 6 - DESIGN / CONSTRUCTION ERROR
    • UP TO 33 OTHER POTENTIALLY REPORTABLE

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HAVE BEEN IDENTIFIED AND ARE BEING EVALUATED B.

UNUSUAL EVENTS I

2 UNUSUAL EVENTS DECLARED I

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LOSS OF SHUTDOWN COOLING FLOW EXCESSIVE REACTOR COOLANT SYSTEM LEAKAGE RATE C.

ENFORCEMENT ACTIONS l

6 NOTICES OF VIOLATION ISSUED (5 LEVEL IV AND 1 2 - FAILURE TO FOLLOW PROCEDURES 3 - FAILURE TO COMPLY WITH TECHNICAL SPE OR LICENSE CONDITIONS 1 - INADEQUATE DOCUMENTATION OF PLANT DESIG u

1 NOTICE OF VIOLATION UNDER CONSIDERATION h

FAILURE TO FOLLOW PROCEDURES 5

1

i I

1 CONCLUSION ALTHOUGH THE LICENSEE HAS ENC 0UNTERED A

NUMBER OF OPERATIONAL PROBLEMS SINCE OL ISSUANCE, SUCH EXP APPEARS TO BE NORMAL. IN ADDITION, THE LICENSEE APP TO BE TAKING AGRESSIVE CORRECTIVE ACTION.

BASED ON ITS OBSERVATIONS AND ASSESSMENTS, REGION V CONCLUDES THERE IS REASONABLE ASSURANCE THAT THE LICENSEE CAN SAFELY OPERATE SAN ON0FRE UNIT 2.

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5A

17 AMENDMENTS TO OPERATING LICENSE 8

AMENDMENTS 1-5 ISSUED TO DATE - MADE MINOR CHANGES TO THE TECHNICAL SPECIFICATIONS AND LICENSE CONDITIONS 0

PROPOSED AMENDMENT 6 MAKES THE FOLLOWING CHANGES:

ALLOWS FULL POWER OPERATION IMPOSES CONDITIONS REQUIRED BY ALSB ORDER - ALL ARE EMERGENCY PREPAREDNESS ITEMS CHANGES TECHNICAL SPECIFICATIONS REQUIRES E. 9. MAINTENANCE AND SURVEILLANCE PROGRAM AFTER FIRST REFUELING REQUIRES RCS DEPRESSURIZATION SYSTEM:

DESIGN BY JULY 1, 3983 INSTALLATION BY FIRST REFUELING THAT OCCURS

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24 MONTHS OR MORE AFTER STAFF APPROVAL OF DESIGN REQUIRES DESIGN OF AFW MOTOR BEARING PROTECTION HARDNARE BY OCTOBER 30, 1982.

y-LICENSE CONDITION REGARDING QUALIFICATION OF AFW MOTOR BEARINGS BY OCTOBER 30, 1982, SCE SHALL SUBMIT A PROPOSED HARDWARE MODIFICATION AND SCHEDULE FOR IMPLEMENTATION THAT WILL INCREASE THE RELIABILITY OF THE AFW MOTOR-DRIVEN PUMPS IN THE EVENT OF A BREAK IN THE HIGH ENERGY LINE FEEDING THE STEAM-DRIVEN PUMP.

IN THE INTERIM, SCE WILL PERFORM AN AUGMENTED IN-SERVICE INSPECTION OF THE STEAM LINE.

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o UNITED STATES E\\

w/' g NUCLEAR REGULATORY COMMISSION k 3..<'- V ) n WASHING TON, D. C. 205L5 w p SOUTHERN CALIFORNIA EDISON COMPANY SAN DIEGO GAS AND ELECTRIC COMPANY THE CITY OF RIVERSIDE CALIFORNIA THE CITY OF ANAHEIM, CALIFORNIA DOCKET N0. 50-361 SAN ON0FRE NUCLEAR GENERATING STATION, UNIT 2 AMENDMENT TO FACILITY OPERATING LICENSE Amendment No. 6 License No. NPF-10 1.

The Nuclear Regulatory Commission (the Commission) has found that:

A.

The application for license for the San Onofre Nuclear Generating Station, Unit 2 (the facility) filed by the Southern California Edison Company on behalf of itself and San Diego Gas and Electric Company, The City of Riverside and The City of Anaheim, California (licensees) complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act) and the Commission's regulations as set forth in 10 CFR Chapter I; B.

The facility will operate in conformity with the application, as amended, the provisions of the Act, and the regulations of the Commission; C.

There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations set forth in 10 CFR Chapter I; D.

The issuance of this license anendment will not be inimical to the common defense and security or to the health and safety of the public; E.

The issuance of this amendment is in accordance with 10 CFR Part 51 I

of the Commission's regulations and all applicable requirements have been satisfied.

I

. 2.

Accordingly, the license is amended by changes to the Technical Specifi-Cations as indicated in the attachement to this license amendment, and paragraphs 2.C(1), 2.C(2), and 2.C(5)c, of Facility Operating License No. NPF-10 are hereby amended to read as follows:

(1) Maximum Power Level Southern California Edison Company (SCE) is authorized to operate the facility at reactor core power levels not in excess of full power (3390 megawatts thermal).

(2) Technial Specifications The Technical Specification contained in Appendix A and the Environ-nental Protection Plan contained in Appendix B, as revised through Amendment No. 6, are hereby incorporated in the license. SCE shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

(5) Environmental Qualification (Section 3.11 SER, SSER#3, SSER*4)

Prior to startup following the fir 5t refueling outage, SCE shall provide c.

affirmation of implementation of tL1 surveillance and maintenance program procedures.

In addition, paragraphs 2.C(23) and 2.C(24) to Operating License No. NPF-10 are hereby added, to read as follows:

(23) Conditions of ASLB Initial Decision of May 14, 1982 Within five (5) nonths of initially exceeding five (5) percent power, SCE shall:

a.

Demonstrate that both meterological towers and the Health Physics Computer system are fully installed and operational.

SCE shall maintain offsite assessment and monitoring capabilities, essentially as described in the hearing (see Initial Decision,Section IV, Paragraph D.1-12, pp. 136-140), at no less than that level of readiness, pending development of satisfactory capability of offsite response organizations (see Initial Decision,Section IV, Paragraph 0.27, pp. 145-146, and Section V, Paragraph B, pp.

213-214).

._..._ _~.

. b.

Provide an assessment of whether public information regarding emergency planning should also be presented in Spanish (see Initial Decision,Section IV, Paragraph F.32, pp.168, and Section V, Paragraph c.2, pp. 215).

Provide plans demonstrating that SCE and offsite jurisdictions c.

have developed and stand ready to implement arrangements for medical services for members of the offsite public. Documentation of the arrangements and provisions made shall be provided to the Atomic Safety and Licensing Board as well as to the NRC staff (see Initial Decision, Section 111, pp. 43-47, and Section V, Paragraph D, pp. 216-217).

d.

Provide revised plans demonstrating that the " extended" Emergency Planning Zone (EPZ) concept has been deleted from the San Onofre onsite and offsite plans and the Plume Exposure EPZ boundary has been extended, along with siren coverage, to Dana Point and all of San Juan Capistrano (see Initial Decision,Section IV, Paragraph D.25, pp. 98, and Section V.C.5, pp. 216; See also Order (making clarifying change in Initial Decision) dated liay 25, 1982).

(24) RCS Depressurization System By July 1,1983, the Licensee shall provide a design and supporting engineering study for valves, and associated hardware, controls and procedures, that could be added to the reactor coolant system to provide for its controlled, rapid depressurization. The depressurization system shall have high reliability and be sized to permit sufficient removal of decay heat by primary coolant makeup systems to prevent unacceptable core damage after a reactor scram fron full power without reliance on heat transfer to steam generators and their feedwater systems.

The study shall consider, but the design need not necessarily meet, general design criteria 1, 2, 3, 4, 14, 30 and 34 of Appendix A to 10 CFR Part 50. The study shall include cost / benefit analyses of design variations that would conform completely and to varying degrees with these general design criteria to demonstrate how the licensee's recommended design cost effectively satisfies its design objectives. The licensece shall install the depressurization system before startup following the next refueling outage or other outage of sufficient duration which commences 24 months after staff approval of the design.

i

. 3.

This license amendment is effective as of the date of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION Darrell G. Eisenhut, Director Division of Licensing Date of Issuance:

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