ML20132A387
| ML20132A387 | |
| Person / Time | |
|---|---|
| Issue date: | 09/17/1985 |
| From: | NRC COMMISSION (OCM) |
| To: | |
| References | |
| REF-10CFR9.7 NUDOCS 8509250327 | |
| Download: ML20132A387 (83) | |
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
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In the matter of:
- d COMMISSION MEETING
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Status of Progress on Environmental Qualification of Electrical Equipment (Public Meeting)
Docket No.
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E.
Location: Washington, D.
C.
Date: Tuesday, September 17, 1985 Pages: 1 - 65 ANN RILEY & ASSOCIATES l (.
Court Reporters 1
8509250 % 850917 Suite 921 PDR 10CFR l
PT9.7 PDR Washington, D.C.
20006 (202) 293-3950
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D I S C L 4 1 M ER 2
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This is an unofficial transcript of a meeting of the
- Tuesday, 7
. United States Nuclear Regulatory Commission held on i n the Commission's office at 1717 H Street, 8
Septster 17, 1985 9
N.W.,
Washington, D.C.
The meeting was open to public 10 attendance and observation.
This transcript has not been 11 reviewed, corrected, or edited, and it may contain k
12 inaccuracies.
13 The transcript is intended solely for general 14 informational purposes.
As provided by 10 CFR 9.103, it is 15 not part of the formal or informal record of decision of the 16 matters discussed.
Expressions of opinion in this transcript 17 do not necessarily reflect final determination or beliefs.
No 18 pleading or other paper may be' filed with the Commission in-19 any proceeding as the result of or. addressed to any s'atement t
20 or argument contained herein, except as the Commission may 21 authorire.
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UNITED STATES OF AMERICA 2
. NUCLEAR REGULATORY COMMISSION
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STATUS OF PROGRESS ON ENVIRONMENTAL QUALIFICATION 5
OF ELECTRICAL EQUIPMENT 6
7 PUBLIC MEETING 8
Room 1130 9
1717 H Street, N.W.
10 Washington, D.C.
11 Tuasday, September 17, 1985 12
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The Commission met, pu,rsuant to notice, at 2:05 p.m.
13 COMMISSIONERS PRESENT:
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14 NUNZIO J.
PALLADINO, Chairman 15 JAMES X.
ASSELSTINE,. Commissioner 16 THOMAS M.
ROBERTS, Commissioner 17 FREDERICK M.
BERNTHAL, Commissioner 18 LANDO W.
- ZECH, JR.,
Commissioner 19 STAFF AND PRESENTERS SEATED AT COMMISSION TABLE:
20 V.
Stello R.
LaGrange 21 D.
Eisenhut J.
Knight 22 R.
Vollmer 23 AUDIENCE SPEAKERS:
24 G.
Zech 25 s
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2 s
1 P ROC EED I NG S 2
(2:05 p.m.3
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3 CHAIRMAN PALLADINO:
Good afternoon, ladies and 4
gentlemen.
5 Commissioner Bernthal was detained and will be 6
joining us shortly.
7 Members of the NRR Staff are with us today to 8
discuss environmental qualification of electrical equipment 9
important to safety in nuclear power plants.
10 Section 50.49 of the Code of Federal Regulations 11 allows a Director of the Office of Nuclear Reactor Regulations
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12 to grant extensions for finalization of environmental 13 qualification to a date no later than November 30, 1985 if
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14 good cause is demonstrated.
Beyond November 30, 1985, the 15 Commission itself may grant extensions in exceptional cases.
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16 (Commissioner Bernthal joins the meeting.3 17 By generic letter in early August, licensees were 18 advised that the Commission's intentions that extensions will 19 granted only in rare circumstances and that enforcement action 20 will be taken against licensees that continue to operate their 21 plants with unqualified equipment beyond November 30,.1985 22 without extensions approved by the Commission.
23 Justification for continued operation will have to 24 be provided to the Staff by licensees, and extensions will 25 have to be approved by the Commission. Fines may be imposed; I
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i hcwover, the gonoric lottor indicated that soms mitigation of 2
any penalty may be considered based upon satisfaction of
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3 factors identified in the generic letter.
4 The objective of today's meeting is for the St.aff to 5
brief the Commission on the status of environmental 6
qualification.
Furthermore, it is possible the Commission 7
would like to explore with the Staff what the Commission may 8
expect between now and the November 30, 1985 deadline.
9 Do any of my fellow Commissioners have any it additional remarks?
11 CNo response.]
12 CHAIRMAN PALLADINO:
P should note also that Regions 13 III and IV will be listening via telephone hookup.
14 Let me turn the meeting over to Mr. Stello.
15 MR. STELLO:
Okay.
16 I had a brief comment I wanted to make at the 17 outset.
The purpose of the meeting is clearly to go over the 18 status of where were on the EO issue.
The concern is to what i
19 to do with those plants which will be asking the Commission to 20 extend the deadline beyond November 30 as set forth in the 21 rule, as you already mentioned.
22 It is our intention to take the submittals -- and I 23 believe we now have six plants, and I will get into that in a 24 minute, who have indicated they will be requesting the 25 Commission to beyond that November 30 deadline -- +he Staff
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1 will teko whatover the submittels aro as objectively as wo 2
'can, evaluate the reasons that are given by the licensees, and 3
determine after we have analyzed carefully those reasons what 4
recommendation we think is appropriate and bring that 5
recommendation to the Commission for the Commission to make 6
the policy judgment as to whether or not to extend it.
7 We believe that we will do the job as technically 8
and comprehensively as we know how, and then the Commission 9
can make the policy judgment of what to do, but we will have 10 our recommendation.
We do not have any recommendation on any 11 plant today, and we are proceeding and you will get the 12 status of where we are on those ' plants during the briefing.
13 With that I would ask Darrell 4
14 CHAIRMAN PALLADINO:
Could I ask you one 15 question? Do you have any idea of when you might have the 16 evaluations and recommendations of the six plants that have 17 already requested extensions?
18 MR. STELLO:
I believe Darrell will be going through 19 that in this briefing.
20 CHAIRMAN PALLADINO:
Thank you.
21 MR. EISENHUT:
Thanks, Vic.
22 You will recall the last briefing we had was on 23 April 2nd, and at that time we went through the overall status 24 of where the review has been and where we saw that it was 25 going.
That meeting, of course, led to the Commission l
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1 guidanoo and lod to the issuance of a gonoric lottor, and lod 2
to the Staff carrying on with the program as it i's now.
x 3
Just in the way of indexing as to where we were at 4
that time, you will recall that the Staff's view was that the 5
industry has come a long way over the last five, six, seven 6
years.
Clearly, the program has taken longer to get into 7
place than we would have liked for it to, but where we are 8
today was we projected that if you look at the actual pieces 9
of equipment that are out there to be qualified, it was the 10 Staff's view that something approaching 95 percent of all the 11 equipment is now qualified.
12 The pieces that have not been shown to be qualified 13 have not been evaluated to see whether or not there is an 14 adequate justification for continued operation or else that 15 the plant is not operating, and on all operating plants there 16 does exist justification to continue operation.
17 So, to some extent the program that we are looking 18 at at this time is we are-getting down to the last piece of 19 the program, the last perhaps 5 percent of the equipment, and 20 to that extent we are already discussing somewhat of the 21 exceptions to the overall program.
22 The documentation of the adequacy of the existing 23 environmental qualifications programs in utilities was also 24 discussed, and we estimated that about 30 or so plants had 25 been evaluated to see if there was inadequate documentation, 1
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6 5
1 most of those granted being the NTOL reviews that we woro 2
doing.
3 Today we are going to give you a specific update, as 4
Vic mentioned, discussing one of the principal items, being 5
the extension requests that could foresee that would be here 6
to go beyond November 30.
In April I projected there would be
'7 about 10 to 12 plants that we could foresee that would go 8
beyond. That still would be my estimate today as to where we 9
might see us go.
10 If I could have the next slide, please.
11
[ Slide.]
12 Much of this slide I reckon I have already covered 13 except since the April 2nd meeting, recall that we were 14 evaluating 95 total plants, t h'a t is, plants up through the 15 last plant to receive its license.
We have continued to 16 complete the evaluations as the Commission had put forth in 17 its guidance.
The actual number of extensions requested and 18 granted up to November has remained unchanged.
That is, we 19 acted on all those that were in house at the time in March, 20 and we have six plants that requested an extension beyond 21 November 30, either already in the door or they have told us 22 that they are on their way to being submitted.
23 CHAIRMAN PALLADINO:
You say eleven evaluations 24 completed total now 84.
That means 84 evaluations are 25 completed?.
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1 MR. EISENHUT:
That is correct. Wo havo olovon 2
evaluations to go, and I will be focusing on that in just a 3
moment.
4 COMMISSIONER ASSELSTINE:
But those do not include 5
actual inspections?
6 MR. EISENHUT:
Those do not include i n s p e c t-i on s.
7 And If I could defer on the inspections for a couple of 8
minutes, we do summarise that when Dick Vollmer will be making 9
his prese,ntation.
10
[ Slide.3 11 This breaks down the 95 plants up to where we are 12 today, and there are 95 plants ficensed to operate excluding 13 the three that are permanently or semipermanently shut down 14 with licenses, which included San Onofre, for example, Dresden 15 1,
for example.
16 There were 41 operating reactors that did not seek 17 extensions beyond March 31.
There were 45 that were granted 18 extensions up to the November 30 timeframe. We had issued 19 seven new OLs with the November 30 deadline, and you will 20 recall we discussed that in connection with a number of Obs, 21 and there.were actually two units that were l'icensed, full 22 power licenses, that met environmental qualification prior to 23 November 30.
24 Those were, as I recall, the Diablo Canyon. units. So 25 it should add up to 95.
9 8
1
[S11do.]
2 Th?s slide summarizes really the substance of where 3
we are today in the overall evaluation program.
There are six 4
units, as I ment.,oned, that have an extension either in house 5
or have told us that it is coming in house.
We expect a 6
couple more plants to be submitted, and I will speculate on a 7
few of those as we go down the page.
8 The extensions requested, as Vic has mentioned, are 9
going to be evaluated from a technical standpoint as 10 objectively as we can, and perhaps -- the first one that came 11 in is the Brunswick-2 unit, and I have a backup slide.
12
[ Slide.]
13 I would like to focus for just a moment on the kinds 14 of factors the Staff is evaluating.
This is a busy slide.
We 15 do have copies that we will be providing you.
16 These are the items that the utility basically 17 submitted as arguments in favor of an extension.
First, you 18 have get to keep in mind we would argue the plant is safe.
19 There is a justification for continued operation of the 20 equipment.
There has been a justification for the last number 21 of years, certainly to extend for another 120 days, which is 22 the Brunswick request. That same justification could almost 23 certainly be carried on.
24 So you have got to put in the front end that the 25 plant is, in fact, safe.
The Brunswick facility finds itself
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1 in a situation whoro Brunswick No. 1 is, in fact, undorgoing 2
an extensive outage. They had been out and shut down for about 3
nine months. We have bullets about halfway down the page 4
here.
Unit 1 has been shut down.
They are doing quite a bit 5
of work, including the environmental qualification work, and 6
they are projecting return to service about mid-December.
7 The very next bullet, at about the middle of the 8
page, is the utilities arguments include the fact that if he 9
deferred his environmental qualification work on Unit 2 until 10 after he has completed the Unit 1 outage, it certainly is more 11 efficient and effective.
He has learned things from the Unit
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12 1 outage.
He has learned from a man rem exposure standpoint 13
.where he could or should more efficiently and effectively from 14 an ALARA standpoint be able to carry out the outage, so he 15 would argue that it would be prudent to wait until he has 16 completed the Unit 1 outage where he has his staff working 17 basically 60-hour weeks now for a number of months, give him a 18 breather, looked at the lessons learned, and start that 19 outage, I believe it is, March of next year.
20 Another item he put forth is that today, if you look 21 at his environmental qualification program, he has a very 22 diligent program.
We have, in fact, gone out and done an 23 inspection of his environmental program at the Brunswick Unit 24 1 and 2 site and feel that he does have a very fine program.
25 There were some glitches in it, but if you look at
10 1
the overall programs in tho industry, it is one of -- a solid 2
program that he has in place today.
3 COMMISSIONER-ASSELSTINE:
But that's today as has it been diligent since the environmental 4
opposed to 5
qualification rule was issued?
6 MR. EISENHUT:
That's right. That item is, in fact 7
the last item on the other side of the scale also, which is a 8
factor that needs to.be considered. On the one hand, you know 9
today that he has an adequate program; however, you know that 10 it has taken him a number of years to get there.
And how do 11 you weigh that considered against other utilities where we may
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12 think the program itself is marginal but it got there in a big 13 hurry?
-14 So those are the kinds of considerations that we are 15 going to have to evaluate.
16 CHAIRMAN PALLADINO:
Look at your Slide 5.
You can 17 see the number of items and the number of components.
That 18 plant certainly stands out among the others.
19 MR. EISENHUT:
That's right. In fact, sir, that's 20 why I'm using that one as the example, because while it talks 21 about something on the order of 179 items, or we call it 200 j
1 22 for the sake of argument, the plant has up to about 2000 23 individual pieces of equipment, so we may be talking something 24 on the order of 10 percent of the equipment is act'ually in 25 question as of today.
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1 CHAIRMAN PALLADINO:
But when you look and comparo 2
with others, it still stands out.
~3 MR. EISENHUT:
That is correct, and that was the 4
point I was making with respect to these are the licensees' 5
arguments in favor of the extension, and I am only focusing on 6
a few. Clearly, there is also an economic consideration. I 7
don't kncw whether we have actually a bullet on this or not.
8 The unit is due to come up on March 30 for a refueling 9
outage.
If we require him to go into a refueling outage on 10 November 30, or into an outage on November 30, he will 11 undoubtedly also turn that into a refueling outage because he 12 could not go through the environmental qualification work,
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. 13 operate for four months and then come back down for a 1.4 refueling outage.
He would state that he would want to run 15 the two in parallel.
If you don't run them in parallel 16 CHAIRMAN PALLADINO:
What do you mean, in parallel?
17 MR. EISENHUT:
That is, while he would be doing the 18 environmental qualification work, he would also be undergoing 19 a refueling outage.
20 CHAIRMAN PALLADINO:
Oh, I see.
21 COMMISSIONER BERNTHAL:
.What is the difference 22 between an item and a package in a component?
23 MR. EISENHUT:
You will recall from the last 24 briefing a particular kind of an item, a piece of equipment we 25 called an item. If*he has five of those, those are five
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individuct piocos of oquipmont or a component.
2 COMMISSIONER BERNTHAL:
What is a package?
i 3
MR. EISENHUT:
Where are you referring to?
4 COMMISSIONER BERNTHAL:
Thirty-three EQ packages.
5 MR. EISENHUT:
If I could defer on that a moment, I 6
'will get to the EO, and there is an explanation for t,5 a t.
7 If you look at the licensees' arguments, though, 8
there is the irreversible loss of four months of the nuclear 9
fuel by the approach that he is on.
10 CHAIRMAN PALLADINO:
Say that again?
11 MR. EISENHUT:
The utility's program would be that 12 he coukd not justify shutting down for an environmental 13 qualification outage on November 30th for a prolonged outage 14 and then coming back up.for the last four months of the fuel 15 cycle and then shut back down for a prolonged refueling 16 outage.
II, in fact, he is required to shut down on November 17 30, he stated that he would go into.his refueling outage at 18 that time and simply discharge the fuel without the authorized 19 burnup on the fuel.
20 COMMISSIONER ASSELSTINE:
Of course, he doesn't 21 necessarily have to do just that.
The other alternative would 22 be to pay the civil penalty.
23 MR. EISENHUT:
Well, that is another item on the I
24 list.
I wanted to point.out that in the utility's 25 believe it is their September -10 t h letter to the Commission, I
13 1
the utility has stated that for a number of reasons, ho could 2
not see justifying operating the plant and be facing a civil 3
penalty.
That is, he feels that is just not a viable. I think l
i 4
it is in his September 10th letter to the Commission that, if, 5
in fact, the option is face the civil penalty on November 30, 6
and if, in fact, you use the full $5000 per item per' day, I 7
think it comes out something on the order of $30 million to 8
$40 million by the time you get to the time you would shut 9
down the plant.
10 COMMISSIONER ASSELSTINE:
Because of the large 11 number of items?
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12 MR. EISENHUT:
Because of the'large number, but 13 independent of the large number --
14 CHAIRMAN PALLADINO:
Fifty-five times five is what?
$5000 15 MR. EISENHUT:
I don't know.
I am told by 16 per day per item for 120 days.
I 17 CHAIRMAN PALLADINO:
Well,'I was looking at it per 18 day.
If there is no mitigation, it would be 55 times 5,
or 19
$275,000 a day.
20 MR. EISENHUT:
Or 179 if you count it per piece of 21 equipment.
22 COMMISSIONER BERNTHAL:
It sounds like they are 23 still roughly $800,000 in the black.
4 24 MR. EISENHUT:
But even if they would argue that it I think the position is, even l' f it is any kind of a 25' is
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14 a
1 civil poncity, they fool that that is 2
COMMISSIONER ASSELSTINE:
They would rather not 3
operate than incur a civil penalty?
4 MR. EISENHUT:
That's my reading and understanding 5
of the September 10th letter.
6
' COMMISSIONER BERNTHAL:
Why is that?
You know, if 7
it were $50 a day --
8 MR. EISENHUT:
I think that is right because I.think 9
it is also -- my bottom line is going to be that I would 10 suggest that my recommendation would be that I think the 11 Commission hcs to really hear this from CP&L eventually to 12 understand the reasons.
As I recall, it was more the 13 situation where they just didn't feel it would be a good 14 public posture to be in, where they are operating in a mode 15 where they are in violation of an NRC requirement and 16 willfully taking a civil penalty per day, even if it's one 17 dollar per day.
18 COMMISSIONER ZECH:
It's a matter of principle.
19 MR. EISENHUT:
A matter of principle.
I only flag 20 these -- I just want to mention the ones at the bottom of the-21 slide also here on the arguments against the extension are 22 some of the items that you have mentioned.
The number does 23 stand out, and I will get to that in a moment.
24 CHAIRMAN PALLADINO:
Which slide are we on?
25 MR. EISENHUT:
I'm still at the bottom of backup
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-1 slido No.
1.
Tho EQ program has boon slow starting through 2
the early eighties, but I need to point out that it was ~ also 3
slow for the industry as a whole. It's not something that you 4
can really stand out on, necessarily, at Brunswick.
So we 5
will be weighing those factors to come to a technical 6
recommendation for the Commission to make a policy call on how-7 to factor these things together.
8 CHAIRMAN PALLADINO:
Do they have any special 9
circumstance that said even though they started slow, they 10 couldn't accelerate like all the others?
11 MR. EISENHUT:
Yes.
There are a couple of items 12 which we certainly have not eval ~uated yet.
One is there are 13 some unique design features in terms of a harsh environment.
14 There is also a consideration with respect to -- recall, the 15 rule.was quite complex and it was tied to the second refueling 16 outage after a specified date or November 30.
To replace the 17 equipment, you must be in a refueling outage.
18 Their first refueling outage occurred a month after 19 the date the clock was turned on for the second refueling 20 outage, which puts them, actually, from a practical standpoint 21 in the worst possible situation.
So those are the kinds of
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22 factors that we are going to be evaluating.
i 23 To answer.your other question, Mr. Chairman, we 24 would hope that over the next couple of weeks you will start 25 seeing the evaluation packages coming down on the six plants c
r e
r m--
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that havo new roquestod an oxtonsion, so the Commission will 2
he seeing our recommendation on the items 3
COMMISSIONER ZECH:
We will get them in the next 4
couple of weeks?
5 MR. EISENHUT:
You will start to get them in the 6
next couple of weeks, yes, sir.
Brunswick is obviously a
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7 little bit more complicated, and that one will take a little 8
bit longer, but the first one that I believe we are procecsing 9
is Nine Mile Point 1,
which I would expect to come down even 10 in the next week.
11 MR. ZECH:
But Brunswick, as I recall, the paperwork I know yod have done other things since 12 that was submitted 13 then, but it seems to me that last July they put in a request.
14 MR. EISENHUT:
They put-in their request.
We had 15 been meeting with'them, and in fact, I think it has been in 16 the last week they have supplemented it twice.
17 MR. ZECH:
Right.
I understand.
18 MR. EISENHUT:
In fact, a number of these items on 19 this list come out of the more recent submittals because their 20 previous submittal really didn't lay out all the factors 21 MR, ZECH:
I appreciate the fact that it's 22 complicated, but I know they made adjustments to it, and you 23 people have looked at the plant and gone over it, but it seems 24 to me that we ought to try to get on it as soon as we can, and 25 I presume that is what you are doing.
I l
17 1
MR. EISENHUT:
Our targot is to havo it to you by 2
October 1.
3 COMMISSIONER BERNTHAL.
I guess I don't quite 4
understand what'the utility would propose, and I won't ask you 5
to explain what they would propose in lieu of a civil 6
penalty.
What sort of enforcement mechanism would they like L
7 the NRC to use?
We can't put the CEO on a rack for 8
lengthening periods of time once a week or something like 9
that.
10-Finally this agency has to have enforcement 11 measures, and although I have long argued and fully appreciate 12 the limited value of many of thi small fines we levy 13 because a utility really gets hit three times.
They. get hit 14 when the proposal-is made and then they get hi t -lat er for 15 something else, and finally it's a year later, and once again 16 the fine is levied and they get three raps in the media when, 17 in fact, they deserved only one.
So I am sympathetic, but 18 unfortunately, I don't know what alternative we have.
19 1 don't need t,
preach this sermon to you, but what 20 I would like to hear from Staff is how the argument has 21 affected your point of view up to this time and what kind of 22 mitigation you might be willing to recommend, assuming all the 23 arguments are good.
But we do have deadlines, and this has 24 been around for, what, five years or so.
25 MR. STELLO:
Let me try to answer-the first part of 1
18 1
your quontion first-Why do utilition fool the way they do 2
about civil penalties?
I think you really need to-talk to 3
them. They have some strong feelings about the impact that 4
civil penalties'have in the communities they serve.
5 COMMISSIONER BERNTHAL:
Well, so do I.
As I just l
6 said, I have never agreed with this policy of many, many small 1
7 fines.
Maybe we ought to rethink the issue of a point system 8
or something, and I have always favored that.
9 MR. STELLO:
But that is the environment they are 10 in, and they are a product of the history they have had up 4
11 until now, and some of them have very, very strong feelings l
12 about doing anything that they'6an to the best of their 13 ability to avoid being penalized, be it civil penalties or 14 almost any enforcement mechanism, if they have a choice.
15 Now, I think in this particular case you need to 16 talk to the licensee and hear from them why they feel that s
i 17
'way.
I have heard it from a lot-of them.
I can understand 18 that they would rather not, certainly, have to deal with civil l
I 19 penalties. It's a way of life.
They have had a lot of it and 20 it has affected-them pretty badly even in the financial 21 market.
22 What other alternative or what other views we might i
i 23 have, I don't believe that's a fair question until we have 24 finished our evaluation.
When we are finished, then I think 25 that would be part of what we would recommend, and until you 1
h 4
7
- -. ~
..e-.,
_._,--_.m._w,-._
19 1
havo really fininhod all of it, I think it would be prematuro 2
to try to deal with that, f
3 The general question, I think, is one that, to the 4
extent you can, you certainly can get a reaction from the 5
industry, and there is a fairly strong feeling in all who I 6
have talked to about that particular issue for a long of 7
reasons.
8 COMMISSIONER BERNTHAL:
Well, okay.
I don't.think 9
we can solve that problem here, but I have been listening to l
10 this, not as long as you and Commissioner Roberts have, 11 Mr. Chairman, but I would like to suggest again that we take a 12 look at that policy, and I stilr am inclined to urge that we l
13 look at a point system here rather carefully at some point.
14 COMMISSIONER ASSELSTINE:
I thought'that the last 15 time we worked on the enforcement policy, we did make an 16 effort to cut down on large numbers of small penalties and 17 that we were fairly successful in doing just that.
And I 18 would also say, you know, we have got to review the 19 enforcement policy that is going to be coming to us fairly 20 soon. We can talk about that in that context.
e 21 But I think for purposes of this meeting, we have to 22 recognize that it appears that thero may well be three I
23 situations.
There may well be the group of utilities that 24 made diligent good faith efforts to comply with this rule and 25 did a Dood job, and I hope that is the majority.
{
20 1
Thoro may also bo a group that may havo mot the 2
deadline, arguably, but they didn't do a good job, and when we 3
do the inspections, we find out that they just didn't do what 4
they were supposed to do, and I think in generic letter we 5
have dealt with that group by saying if we find that is the 6
situation, we are going to go back and we are going to impose 7
civil penalties and take enforcement actions against that 8
group.
9 And then there is a third group that just 10 dilly-dallied around and didn't conscientiously deal with the i
11 problem and now they are in saying, hey, now we need some 12 relief for that.
I think the ge'neric letter is fairly clear 13 on that group, too.
14 CHAIRMAN PAILADINO:
And it made a-substantial fine 15 for those plants that have large numbers of items.
16 COMMISSIONER ASSELSTINE:
That's right, and I think 17 we all had difficulty in excusing that group, and I think that 18 was the purpose of the generic letter, was to send a m?ssage 19 to the licensees that we are serious sbout this, the deadline 20 does mean something, and for those that have not made diligent 21 goed faith efforts to get the job done and to do the job 22 right, that they are not going to get off scott free.
23 COMMISSIONER BERNTHAL:
Yes, I agree with everything 24 you said.
I was really asking a more generic question.
25 COMMISSIONER ASSELSTINE:
Yes.
The broader one we l
21 1
should look at, I agroo.
2 COMMISSIONER BERNTHAL:
Specifically here I would 3
have that -- my only dissatisfaction was that we didn't start 4
this sooner because now it occurred to us, I think, rather 4
5 late in the game that it is a pretty hefty penalty now, and I 6
think if we had started maybe a year or two ago with an 7
escalating financial penalty, that may have been one way.
8 COMMISSIONER ASSELSTINE:
But in essence we have 9
already given them until November, recognizing the original 10 deadline was in March, and basically we gave them until 11 November.
12 MR. EISENHUT:
dell, Tet's see.
On Slide 4 13 CHAIRMAN PALLADINO:
That's a subject I think we 14 have to take up at another meeting.
15 COMMISSIONER BERNTHAL:
Yes.
16 MR. EISENHUT:
If I could go back to Slide-4, I 17 won't discuss the other extension plants until the next slide, 18 but there is one plant that is due to shut down November 19 30th.
That was a license condition, a commitment from the 20 licensee, I believe, when we issued the plant, and that was 21 Byron 1.
22 There are several plants who have stated, in a I
23 meeting we had about a week or so ago on TVA, where Hugh Paris 24 stated it is their intention that the TVA plants, which are 25 all shut down today, will not restart until environmental i
I
~,
_-r_.
- .2 1
qualification is, in fact, roco1vod.
2 There are only two of them that it res11, j
3 immediately hits, and that is the Sequoyah 1 and units.
4 They stated in that same meeting that it was their intention 5
to hope to restart each of the Sequoyah stnits later this 6
year.
We have been meeting with ther. In fact, we met with 7
them in an all-day meeting yesterday. It is not entir6ly clear
~
8 that they may not come back and ask for relief on certain 9
aspects of certain equipment.
10 Recall that TVA voluntarily shut down both the 11 Sequoyah units because of environmental qualification
~
12 problems.
13 COMMISSIONER ASSLI.S;INE.
Darrell, what position had 14 they taken on the two Sequoyah units back in Apr41 in terms of 15 where they stood on e nv i r onroe n t a l qualification?
16 MR. EISENHUT:
Let's see.
We, in fact, in the April 17 meeting flagged Sequoyah 1 as one of the only units that had 18 not completed its detailed review of environmental 19 qualification, as I recall.
I think that is what we said in 20 the April 2nd Commission 21 MR. LA GRANGE:
Yes. We were still evaluating both 22 Sequoyah units, and in fact, we were continuing that 23 evaluation when they elected to shut down.
24 COMMISSIONER ASSELSTINE:
I take it you have not 25 done an inspection yet for Sequoyah.
23 1
MR. LA GRANGE:
Not yet, I'm sure wo will before 2
they restart.
3 COMMISSIONER ASSELSTINE:
Okay, good.
4 MR. EISENHUT:
There are a couple of other plants we 4
5 also mentioned in April that I want to flag here again: Fort 5
St. Vrain, Hatch 2,
Oyster Creek and Pilgrim.
We discussed 7
some of those plants in the April 2nd briefing. I only want to 8
really focus on one today again, and that is Fort St. Vrain, 9
where first the utility thought its equipment was qualified, 10 and he was in that posture for a considerably long period of 11 time.
12 As we pointed out, in April the Staff had really not 1 -
13 devoted much attention to Fort St. Vrain because of its unique 14 nature and the different environment.
We were putting our 15 resources where they were certainly more effective from the 16 broad standpoint. So the Staff really had not looked much at 17 the unique environment and qualification of equipment at Fort 18 St. Vrain. In fact, it was in January of this year they were 19 actually sent detailed questions.
When Bob LaGrange and the 20 environmental qualification group started doing their review, i
21 they sent detailed questions to Fort St. Vrain.
22 They right now have a rather major program under way 23 looking at the qualification of their equipment.
It is very 24 likely, at least in my mind, that they will be coming in with 25 a request to go beyond November 30th, largely because of the i
i
24 4
1 lato hour wo aro in the process and largoly because of the 2
unique environment that they are facing.
All of the 3
requirements in the environment and profiles where we have 4
devoted our real attention up to this point in time were on 5
light-water reactors.
6 CHAIRMAN PALLADINO:
Are they coming in for an 7
extension because they have found that they are not in 8
compliance or 9
MR. EISENHUT:
They have not as of today requested 10 an extension, and they have not stated they are going to.
It 11 is my opinion, though, based on our review, that since they 12 are now to the point where they"are recognizing that they have 13 to do quite a bit of work, they are now to the point where 14 they have a number of consultants whom we have quite a bit of 15 confidence in, I believe, and who are quite experienced on the 16 EQ problem working the issue.
17 CHAIRMAN PALLADINO:
But they only got started after 18 you started asking questions?
19 MR. EISENHUT:
Tha t -i s correct.
They up to that officially I believe their 20 point in time and up to today 21 position is they think they are qualified and meet the intent 22 of the rule.
23 CHAIRMAN PALLADINO:
But now you say they have hired 24 a consultant to help them.
Did they do that before?
25 MR. LA GRANGE:
Yes, In response to generic letter 3
l
25 1
84-24, it was their position, tho bottom lino position that as 2
it applied to Fort St. Vrain, they comply with the 3
requirements of 50.49.
They subsequently came in with 4
responses to the questions we had sent to them back in January 5
which indicate they had open items remaining to be resolved.
6 7
We met with them a couple of times. They hired 8
several consultants to start really looking into the problems 9
that we were raising that we didn't feel had been adequately 10 addressed and had discovered they have a significant amount of 11 work to do on that plant to actually bring them into 12 compliance with 50.49.
It is going to be sometime, probably, 13 in my opinion, mid next year before they are complete with 14 that effort.
15 COMMISSIONER ASSELSTINE:
And that is largely 16 because they did not look at the characteristics of the 17 environment for that particular plant?
18 MR. LA GRANGE:
They are finding quite a few 19 problems, installed equipment not what they thought it was, i
20 equipment that is in a harsh environment now that they looked
- l 21 and they did not think was in a harsh environment previously, 22 and the problems go on and on and on and on.
23 MR. EISENHUT:
It is a number of different 24 things. You can't really generalize.
It is hard to 25 characterize.
It is not that they didn't recognize that they l
1
-.m-.
,m_
.,r,
,_....,.-,_s..
26 1
had a difforont onvironmont.
In fact, they recognizod that 2
quite a bit, to the point where --
3 COMMISSIONER ASSELSTINE:
Well, when it is to their 1
4 benefit, they have argued that fairly consistently.
5 MR. LA GRANGE:
It is not just a problem with the 6
environment.
They are trying to do something about Lhat by 7
putting in some automatic accident mitigation systems, but 8
it's not the environment.
Their problem is much, much larger.
9 COMMISSIONER ASSELSTINE:
It sounds like they just 10 didn't do a good job, huh?
11 MR. LA GRANGE:
Well, they probably didn't do 12 anything much before this year.~
13 CHAIRMAN PALLADINO:
What do you mean, it's not the 14 environment?
I thought this was environmental qualification.
15 Is it 16 MR. LA GRANGE:
No, I thought Commissioner 17 Asselstine's question was was the environment the problem.
18 COMMISSIONER ASSELSTINE:
The fact that it is a 19 gas-cooled reactor as opposed to a light-water reactor, and 20 they just didn't understand the characteristics 21 MR. EISENHUT:
We don't think that that itself is 22 the cause of the problem..It's much broader than that.
They 23 have a program in place now, I think, that is taking shape, I mean it's going to take quite some time 24 but we don't see 25 to work it out.
But again, we are going to do an honest, you
27 1
knew, objectivo ovoluntion of it.
I think it's too early t o-2 speculate that they didn't do it or'they dropped the ball or 3
whatever.
We are going to take a hard look at it.
4 COMMISSIONER ASSELSTINE:
In view of the widespread 5
nature of the problems there, have you taken a fresh look at 6-the JCO for that plant?
7 MR. LA GRANGE:
Well, since their position was they 8
were in compliance with 50.49, there weren't any JCOs for that 9
plant.
10 COMMISSIONER ASSELSTINE:
So now there has to be 11 one?
12 MR. LA GRANGE:
Well,'in all honesty, they are 13 looking for relief to operate up to 8 percent power right now 14 to dry out the core while they are still doing their EO 15 review, and the Staff is evaluating that right now, and if it 16 is granted, that would only allow them to operate up to the 17 end of November up to 8 percent.
18 MR. EISENHUT:
Yes, we have the plant today shut 19 down, and the plant will remain shut down until there is an 20 adequate JCO, but even if they would start up, the request is 21 to go up to -- I think it is 8 percent now to stay at a 22 constant level for some time.
23 So the Staff will not let them start up until we are 24 confident there is an adequate justification.
25 CHAIRMAN PALLADINO:
Can I ask you about the other
/
28 1
throo plants?
Aro thoso plants whoro wo might faco possiblo 2
extension requests?
3 MR. EISENHUT:
Yes.
In fact, we discussed 4
CHAIRMAN PALLADINO:
That is the only connotation-I l
5 could put to "other."
Maybe I wasn't imaginative enough.
6 MR. EISENHUT:
Okay.
When we briefed you in April 7
of this year, we had flagged those to some degree, and in fact 8
we discussed the rationale behind it. For example, Oygter
~
9 Creek, as I recall, was undergoing a major improvement program 10 in the plant for many, many months.
They had stated that they 11 expect to have everything qualified by November 30, but it may 12 be as late as March 1986, I think is what the letter stated.
13 So we are rolling along, and we may very well get a 14 request from --
15 COMMISSIONER ASSELSTINE:
But didn't their letter 16 say they would shut down, either they would have it qualified 17 by November 30th or shut down or something?
18 MR. EISENHUT:
Well, you recall there were a number 19 of people who said that.
In fact, their view came about, !
20 guess, because of our view wherein we said it is our intention 21 not to support any requests past November 30, and we are past 22 that situation, so I think that commitment is sort of null and 23 void, to some degree, because it was predicated on the fact 24 that we weren't going to support operation past November 30, 25 and now we are in a mode where we are going to do this L
29 1
detailed evaluation of whether or not to roccamond supporting 2
it.
-3 COMMISSIONER ASSELSTINE:
Okay.
4 MR. LA GRANGE:
Hatch 2 is on the docket as saying 5
that they are having a problem with their hydrogen.and oxygen 6
analyzer, and they haven't officially requested an extension, 7
but if their problems continue, they would request an 8
extension.
That is why they are listed there.
9 Pilgrim.
I have heard that they may have a possible I
10 strike at the plant, and they still have quite a bit of work i
11 to do before November, and that would cause them to not be j
~
12 able to complete the job by Nove'mber.
l 13-This Slide 4,
I expect, with the exception of the 14 plants that are down now and they won't restart until they are 15 complete or until after November 3Jth, each of these groups is 16 probably going to -- more than likely, this is a snapshot in 17 time, and the EQ is changing significantly from day to day --
18 so these groups are going to increase, I am sure, before the 19 end of this year.
20 COMMISSIONER ASSELSTINE:
As I recall, our generic 21 letter said that if you are going to ask for an extension, you 22 had better do it by September 30th.
23 MR. E!SENHUT:
That is correct. So we would expect 24 any requests received to be by September 30 in order to be 25 considered a timely request. That is what the generic letter I
l l
9 30 1
said, and wo cro cortainly going to be rominding tho utilitios 2
about that aspect.
3 CHAIRMAN PALLADINO:
Did I hear correctly?
I'm not 4
sure of what y et said about the groups.
It was my impression 5
that these four were possible candidates for requests.
6 MR. EISENHUT:
That's correct. As I said before, I 7
would suspect that those four may very well move up to the top 8
category where an extension request is, in fact, received.
9 CHAIRMAN PALLADINO:
And also possibly may exist for 10 one of the Sequoyah plants, or both?
11 MR. EISENHUT:
There is certainly that possibility, 12 although a week and a half ago when we had the rather detailed 13 meeting with TVA, and I believe, in fact, Commissioner 14 Asselstine was there, Hugh Paris' commitment was very, very 1
15 clean; he did not intend to request an extension beyond 16 November 30 and would not operate the plant until then, 17 although in fairness to him, I don't think they had really 18 proceeded into their detailed evaluation at that point in time 19 also.
20 MR. LA GRANGE:
During the meeting yesterday, they 21 indicated that they plan or hope to return one of the Sequoyah 22 units to operation by late October, realizing they have a i
23 qualification problem with cables, in which case they would 24 have to request an extension unless they shut back down in 25 November.
i
31 1
COMMISSIONER BERNTHAL:
I still want to know tho 2
difference between a package and an item.
3 MR. EISENHUT:
Good point.
TVA has a documentation 4
package. I didn't know we used that terminology in the 5
briefing. It's a documentation package.
6 MR. LA GRANGE:
We'll, you are looking at backup 7
slide 2 on TVA plants.
That is what this review team that was the team consisting of TVA personnel and 8
assembled by TVA 9
- Westec,
- a. consultant, personnel from Westec -- was put 10 together to review the TVA program, the EQ program, and 11 several what they call or refer to as EQ packages.
Other 12 people refer to them as EQ filer. It's the same thing.
People they may have a package that consists of 13 lump different 14 three or four different cable manufacturers and maybe a cable 4
15 package.
Somebody else may have five different files, with 16 each file addressing individual cable manufacturers. So it is 17 really an EQ file with documentation supporting EQ.
18 COMMISSIONER ASSELSTINE:
And that package could 19 then translate into literally hundreds or thousands of actual 20 individual cables in the plant.
t 21 MR. LA GRANGE:
Well, it could translate into maybe 4
22 seven or eight cable vendors and thousands of miles of cable.
23 COMMISSIONER BERNTHAL:
What I am really trying to 24 get a sense'for is what would the numbers be for TVA. Pick a 25 plant.
I guess I am interested particularly in Brown's
32 1
Forry.
Soquoyoh is rathor difforont, but what would tho 2
numbers be on Slide 57 Just take Brown's Ferry.
3 MR. EISENHUT:
Well, I went back and read the last 4
Commission meeting in April, and there was a Slide C which 5
listed Brown's Ferry 1 as having 90 items with 262 components, 6
Brown's Ferry 3 having 83 items with 211 components.
7 MR. LA GRANGE:
That was for the extensions.
As I 8
recall, Brown's Ferry had around 1500 or 1600 pieces of 9
equipment.
10 MR. EISENHUT:
Total pieces.
11 COMMISSIONER BERNTHAL:
All three plants?
12 MR. LA GRANGE:
No, each plant.
~
13 COMMISSIONER BERNTHAL:
Each plant had 1500 14 components in it?
Is that what you are saying?
15 MR. LA GRANGE:
Yes.
Not unusual 16 MR. EISENHUT:
No, this is the number of pieces of 17 equipment where they had to have an extension to November 30.
I 18 You start with an inventory of something like 1500 to 1800 19 individual widgets, pieces of equipment in the plant.
The 20 extension request on Brown's Ferry 1,
where they had extended 21 and requested relief up to November 30, was for 90 items which 22 comprised 262 individual components, which is, you can see, a 23 certain percentage of the 1500 or 1800 that didn't apply.
24 Now, that has evolved since our last Commission 25 briefing, but it gives you an indication of the kinds of
(
33 1
numbors that wo aro talking of 2
COMMISSIONER BERNTHAL:
So, what is the answer to my 3
question?
4 MR. EISENHUT:
A large number.
Would you accept "a
5 large number"?
6 COMMISSIONER BERNTHAL:
Are we talking of the order give me the numbers. Brown's Ferry, all 7
of 100 items with 8
three -- what are the numbers?
What I want is'a comparison 9
with other utilities and other plants.
10 MR. EISENHUT:
I don't know the specific numbers 11 today.
The latest thing I can give you on the comparison is 12 what was called Slide C in the Kpril 2nd briefing, which 13 listed about 25 plants.
There were three plants that had over I
14 50 items.
In fact, there were only five in double digits.
15 Brown's Ferry 1 had 90, Brown's Ferry 3 had 83.
16 CHAIRMAN PALLADINO:
But I don't understand what 17 those 90 were.
You said those are the ones that they wanted 18 an extension till November 30.
19 MR. EISENHUT:
Those are the ones where they needed 20 more time to qualify the equipment.
That is, they had not 21 shown them to be qualified at that time.
22 CHAIRMAN PALLADINO:
But they only asked for an 23 extension until November 30?
24 MR. EISENHUT:
Because we had led them to believe the only thing they could request of the Staff 25 that was the l
34 1
is, in fact, until November 30.
i 2
CHAIRMAN PALLADINO:
So we don't know what the 3
number would be comparable to the Brunswick or the other 4
numbers on this page?
5 COMMISSIONER ASSELSTINE:
You could provide a Slide l
6 5 for the five TVA units, couldn't you?
7 MR. EISENHUT:
Certainly.
8 CHAIRMAN PALLADINO:
As a matter of fact, it would 1
9 he int'eresting to do it for Fort St. Vrain, Hatch 2 and Oyster 1
10 Creek.
As a matter of fact I have that written, how many 11 items and components?
12 MR. LA GRANGE:
Are we~looking for the total number i
13 of pieces of equipment in these plants?
14 COMMISSIONER'ASSELSTINE:
Items and components for 15 which qualification has'not yet been demonstrated.
16 MR. LA GRANGE:
On TVA.you are probably talking all 17 of them.
With the findings they had there, they didn't have 18 documentation to support qualification on but three or so.
19 CHAIRMAN PALLADINO:
But for these plants, and 20 especially the four at the bottom, I think it would be very 21 instructive to have them with the number on Slide 5,
with the 22 appropriate number.
23 MR. LA GRANGE:
Well, we would have, but they have 24 not yet requested an extension and identified the specific 25 numbers that they want relief on.
35 1
MR. EISENHUT:
Wo haven't gono bcck to TVA and 2
requested it; however, TVA's answer undoubtedly is they 3
haven't completed their evaluation.
So since they have stated 4
that they are still performing the evaluation 5
MR. STELLO; Why don't we come in and give you 6
whatever we have based on the documents we have, and to the 7
extent we can construct this table for those plants, we will 8
do it, and if not, then we will just simply inform you.
9 COMMISSIONER BERNTHAL:
Yes.
I am just trying to 10 get a sense; are they twice as far behind or three times as 11 far behind? I don't really want every bean counted.
12 MR. STELLO:
The statement was made a moment ago 13 that the equipment is unqualified, and that is not correct.
14 It doesn't mean the equipment-i s unqualified.
It means there 15 are questions in finding documents, and that is a completely 16 different issue.
17 COMMISSIONER BERNTHAL:
I understand for Sequoyah, 18 or is that true for all of them?
19 MR. STELLO:
For all the plants.
The components 20 used in these plants are the same identical components used in 21 other plants for which the documents do exist, and we will 22 have to determine whether they are or are not appropriate.
23 Don't let's start taking the next step and calling it 24 unqualified equipment.
That is not just a fair thing to do.
25 We are getting a little too far ahead of what we know.
36 1
MR. EISENHUT:
I hope I have boon stating it 2
correctly each time. In fact, it's a question of whether or 3
not they have been shown to be qualified.
It has not been 4
found that they^are " unqualified."
5 COMMISSIONER ASSELSTINE:
Right, but that's the only l
6 way we know whether it is or it isn't, is a demons,tretion that 7
in fact the equipment is qualified.
And I think in the l
f 8
Sequoyah_ situation, Bob is probably right because several i
I 9
months ago they thought they had the information to 10 demonstrate that it was,-and it turns out on the basis of the
}
11 questions that were raised it is uncertain, and so at the 4
12 present time TVA would probably'say, gee, we can't tell you i
a 13 that we have demonstrated that any of this equipment is 14 qualified.
We are trying to finish our evaluation'to decide
]
1 15 where there are questions, where we need te do more work or 16 where we have pulled together the documentation.
17 So if you want a snapshot now, it may not be real i
18 meaningful.
19 MR. VOLLMER:
While we are on the issue of 20 unqualified equipment, just to clarify, for the purpose of 21 enforcement, the Footnote 1 in the generic letter said for the 22 purposes of enforcement, unqualified equipment means that for i
23 which there is not adequate documentation, and so on and so 24 forth.
But in the Commission briefings that we have had 25 heretofore, what we have said is exactly as described-by f
37 1
Da r ro11 and Dob, that that dotormination is not mado in the 2
absence of documentation.
3 COMMISSIONER BERNTHAL:
At 1000 items it adds up 4
pret ty f as t.
i 5
MR. EISENHUT:
Yes, but it.is only if they want to 6
operate pas t November 30th, and it is their ccamitment that 7
they will not operate the TVA units until they have 8
CHAIRMAN PALLADINO:
But the item is not the same as 9
c omponen t s.
You may have 1000 components, but it may be a 10 l es ser numbe r 11 MR. VOLLMER:
Right. That is also Footnote 2 of the 12 generic letter.
It is defined.'
13 MR. EISENHUT:
We had to define t h'e nomenclature.
l l
14 If I could skip past Slide 5,
since we have all 15 looked at it and talked about it, and go on to Slide 6,
if I 16 could, on the IE inspection program, Dick Vollmer will be 17-discussing the next two slides.
18 MR. VOLLMER:
This past April we did discuss with 19 you the pilot inspection program, so I won't go into the 4
20 de tail we did there.
As the slide indicates, up until now we I
21 have completed nine inspections.
Several of these were for 22 plants that, at the time they were inspected, did not need to 23 be in compli ance with 50.49 because of the time of the 24 inspection and the time that the 50.49 deadline fell in the 25 scheme of things.
But now we have both those that are under
38 l
1 1
and thoso that woro not under the 50.49 doadlino.
In 2
particular, Zion, Point Beach 1 and 2,
Brunswick 1 and 2,
Nine 3
Mile 1,
and Calvert Cliffs 2 were inspected at a time which 4
they should have been in compliance because they were under 5
the 50.49 deadline.
6 CHAIRMAN PALLADINO:
What about the plants that just 7
got licenses?
Do you count those as inspected if one were 8
given a license?
9 MR. VOLLMER:
I think Darrell mentioned that. We do 10 go out on an EQ audit before the NTOL is inspected.
It is an 11 audit review, and the results of that review are written up in 12 the SERs. For example
~
13 CHAIRMAN PALLADINO:
Are those in addition to the 14 eleven, I mean to the nine?
15 MR. VOLLMER:
Well, those would be in addition 16 because these represent the pilot inspection program to look 17 at detail in compliance with 50.49.
They are broader 18 inspections. They are more intensive.
The NTOL inspections 19 are not that intensive.
For example, Byron was cited here to 20 shut down for EQ by November 30th,'so they could not meet 21 compliance with 50.49, so they indicated they would shut down.
22 CHAIRMAN PALLADINO:
But they were different.
There 23 are some of them, though, that had no condition.
24 MR. VOLLMER:
Many of them did have conditions.
25 Some did not.
Those that did not, we presume that they were I
39 1
in ccmplianco as best we can toll, and they will be factored I
2 into the inspection such that all operating plants will have 3
an EQ inspection when we are all through, and when we are all 4
through, we are' talking about probably the end of fiscal year 5
1987 to complete all plants.
6 MR. EISENHUT:
But Dick, I think it is fair to say 7
that the new OL would be certainly a lower priority on the 8
scheme because we have at least done an audit inspection.
~
9 Recall it was the same situation we had with fire protection, when the new OL gets its license, 10 where we had been doing 4
~
11 we go out and do a field inspection of the documentation to 12 give us the requisite amount.of ~ confidence before we go 13 forth.
i 14
.In this case I think the principal thrust of the 15 inspections, at least to this point in time, is the operating 16 plants that have been out there.
17 COMMISSIONER BERNTHAL:
What happened to Pilgrim?
18 Did you already tell us that?
19 MR. STELLO:
They have a strike.
20 COMMISSIONER ROBERTS:
They have one or they 21 anticipate one?
Did it start or is it anticipated?
22 MR. LA GRANGE:
There was talk about a strike, and 23 the licensee is quite worried that it would hold up his EQ 24 work, but I am not sure if it has actually occurred or not.
I 1
25 COMMISSIONER BERNTHAL:
Is that why they have
+
i
40 1
dropped off your scopo horo?
You know, they woro one of the 2-woret off as of last April, and I don't even see their name 3
mentioned.
4 MR. EISENHUT:
Their name is listed down under the 5
"Other" category.
6 COMMISSIONER ASSELSTINE:
They are one of the four 7
they said might come in for extensions.
8 MR. EISENHUT:
Because we still cre not sure they 9
are going to make November 30th.
The same reasons we had 10 before.
11 COMMISSIONER BERNTHAL:
But there is a good reason
~
12 that t ey are 100 items out of compliance or whatever it was 13 as of last spring?
1 4
MR. EISENHUT:
That is correct 15 MR. LA GRANGE:
I am sure there will be other plants 16 that are not listed on this slide that will request 17 extensions.
18 MR. STELLO:
Somebody can correct me if I am wrong, 19 but I think the plant has been in an outage doing EQ work now.
20 COMMISSIONER BERNTHAL:
Pilgrim?
21 MR. STELLO:
Yes, and I think the problem is whether 22 they are going to be able to get it finished.
I will check 23 that when I'get back, but that is my recollection.
24 MR. VOLLMER:
Okay.
Going on to Slide 7.
25
[ Slide.]
i
41 1
Tho inspoction approach has boon a roview of the 2
Licensee's program for implementing 50.49 as one element of 3
the inspection.
What we are looking at there is how do they 4
determine what equipment is on the EO list, and what 5
procedures do they have that identify how the EQ activity is 6
carried out, development of surveillance of ma i n t e n si.c o t
'7 procedures and things like that to carry out the programmatic
~
8 aspects.
9 Then review Licensee's surveillance procedures for 10 qualifying equipment to see that the equipment is properly 11 tended to for the life of the plant And for example, if the 12 equipment is cited in the EQ doc ~umentation as being good for 13 five or ten years, does the maintenance program have a way of 14 coming up and making sure that the equipment is changed out at 15 the appropriate time?
16 We also take a look at the safety evaluation 1
17 reports, which is generated by NRR, and see that the 18 corrective action commitments are taken. These are, for 19 example, moving equipment out of areas to a less harsh 20 environment area or changing orientation of equipment which 21 perhaps needs to have drain holes or things like that, but 22 whatever they have committed to do, we take a look at that.
23 We also review on the 15 to 25 percent sample the EQ 24 document files to see how a licensee has made its 25 determination based on test reports, similarity analyses and l
l l
l l
42 1
ccmparisen with other EQ analysos that the inspectors cro 2
familiar with to see that basically we think he is doing an j
3 adequate job in his analysis, and support that the equipment 4
is qualified will carry the day, and where we don't find that
'nto in the next slide, but that is i
5 is the case I will get 6
where most of the arguments are going to take place, and most 7
of the things are in the gray area.
8 For example, he has made &-similarity analysis 9
saying.that this seal on this type of equipment is close 10 enough to that type of seal which has already been qualified 11 in which you have radiation demonstration data available 12 There are areas where reasonable engineers can differ, and we 13 anticipate and have already seen a number of arguments that we 14 are going to have to get into with the Licensee where we say 15 we are not persuaded that you have adequate justification, you
-16 will have to go out and get additional information.
j 17 That could be in some cases more analysis, that 18 could be in some cases where they can't persuade us additional 19 tests.
Until then, the licensee is advised that he should be 20 aware that equipment is in a not-demonstrated qualification j
21 status, and if there were something that we felt very.strongly 22 about, and I will get into the next slide, then the licensee 23 might have to go by tech specs, declared inoperable or take 24 other action.
25 But in any event, they should be aware the JCO l
l l
l
43 1
for further operation of the facility is an important part of 2
his evaluation of how to deal with our inspection.results.
3 We also perform a physical inspection of selected 4
equipment, things like if a piece of equipment is qualified in i
5 a certain physical configuration, seeing it is not installed 6
upside down, if there are drain holes and things like that, to 7
see that the nameplate data is correct, to see that the 8
ambient temperature in the place where he has this equipment 9
installed meets the nameplate data, and also does the piece 10 that is there actually correspond to the piece that is 11 asserted to be qualified in the documentation file.
12 CS11de.]
13 COMMISSIONER ASSELSTINE:
On those last two items, 14 do you have a sliding scale?.That is, if you go do an 15 inspection and begin to find problems in the document files, 16 or you begin to find problems when you go out and do your 17 walkthrough through the plant, do you dig deeper and begin to 18 look at a larger sample size on those kinds of things or not?
19 MR. VOLLMER:
I think the sample size has been 20 somewhat constrained.
We certainly dig deeper into what is 21 behind that particular area, but sample size has been fairly 22 constant. It is fairly constant in terms of the size of the 23 sample, that being 10 to 25 percent, and we try to apportion 24 the thing.
25 1 think if there was an area where it looked like
44 1
tho liconsoo had a spocific programmatic wacknoss that would 2
-.we would benefit by a generic looking at the broader 3
program.
We have done that.
We have made broad 4
recommendations to the licensee in those areas.
5 CHAIRMAN PALLADINO:
Do you plan to follow up 6
inspections with some frequency?
7 MR. VOLLMER:
Well, we have indeed done a follow-up 8
inspection of Calvert Cliffs.
We have done a follow-up 9
inspection of Calvert. Cliffs.
10 CHAIRMAN PALLADINO:
Well, suppose a plant passes 11 with flying colors: do you plan to come back in five years?
12 MR. VOLLMER:
We don' t have any periodic inspection 13 for reevaluation. We ought to evaluate that when we get 14 through'our first round,.which is still a couple.of years 15 away.
16 CHAIRMAN PALLADINO:
But you have had a follow-up 17 visit?
That's when you had something that you wanted to go 18 back and 19 MR. VOLLMER:
That's when we had some very specific 20 things we felt we needed to go back on.
And that would hold 21 true, I think, with any plant.
22 But also the results of the inspection, in the 23 general sense, it would be up to the Region to evaluate the 24 Licensee's performance in taking care of those inspection 25 items, so they wouldn't be really left out, drifting too long, u
1 45 1
MR. STELLO:
Tho Chairman, I think, was interostod l
2 that when you went and found a plant was okay, did you ever 3
inspect this area again, and the answer was, yes, through the 4
routine program, but not thro 1gh some comprehensive program 5
like this.
It would fall into the routine inspection program.
6 COMMISSIONER ASSELSTINE:
Well, maintenance aspects, 7
you want to make sure the equipment is maintained, so it 8
continues to be qualified.
9 MR. VOLLMER:
Yes.
The next slide is inspection 10 results.
11
[ Slide.]
12 We still have not'iden'tified equipment that in the 13 judgment of the inspectors would fail or malfunction in an 14 anticipated environment, and as we get down a little bit you may question me on how we 15 later, you can question me 16 come to that judgment, and I'll be happy to try to answer 17 that.
18 But we did, for example, find one case where an item 19 was not the item the Licensee thought was there.
Indeed, it 1
20 had a different serial number and manufacturer type, I think, 21 than he though was there.
On further looking, it appears that 22 that particular item did have adequate qualification data 23 behind it, but again, we have not found anything that we 24 clearly know would malfunction or fail in the environment that 25 we expected to see.
I i
I
46
+
1 The progrcmmatic deficiencios wo havo soon aro those 2
indicated.
The fact that the Licensee is not able to come up 3
with his documentation in a very auditable form and things 4
like that, the fact that 5
CHAIRMAN PALLADINO:
You say they couldn't come up 6
with the documentation in an auditable form.
How could you 7
draw the first conclusion?
8 MR. VOLLMER:
Okay.
If he doesn't, that's a 9
programmatic deficiency.
Now when the inspectors dig deeper 10 into that, again it's discussion with the Licensee.
He will 11 bring up additional data.
It's a week inspection, so he will 12 scurry around.
He has his consultants there.
So he will try, 13 where we find this to be the case, to find backup 14 information.
Our inspectors are also very knowledgeable about 15 a broad data base of EQ that's out in the whole industry, and or as part of 16 they certainly use that knowledge to justify 17 the basis for their decisions when they're doing inspections.
18 So what the first part is here is that 19 programmatically he's not very well put together.
- Secondly, 20 in the area of retrieving information, secondly perhaps in the 21 area of the equipment maintenance and surveillance procedures 22 have not been fully developed.
In some cases, this doesn't 23 make a lot of difference, because in many cases the 24 maintenance and surveillance procedures are those things which 25 quill require equipment to be changed out over a period of i
l
47 1-timo.
The Liconsoo has, porhaps, somo load timo for that 2
But still, you look programmatically at how he's 3
CHAIRMAN PALLADINO:
If you look at the bottom 4
statement on that slide, it says that 20 to 60 percent of EO 5
document files reviewed did not fully support qualification, 6
and that seems to contradict the first statement, that no 7
equipment was identified that would be. expected to fail or 8
malfunction in the anticipated environment.
9 I guess what I'm asking is, if you don't know up to 10 60 percent or you don't have documentation for up to 60 11 percent of the items, it would be difficult to make the first 12 statement.
13 MR. VOLLMER:
I think perhaps the 20 to 60 percent is a little bit misleading.
let me jump down to that 14 15 What we say is, 20 to 60 percent did not fully support 16 qualification in the plant.that we looked at.
Now if you go 17 through a documentation file, which may cover at some plants a it may cover a broad 18 number of pieces of equipment now if for a certain type 19 category, for example, all cables 20 of cable, for example, one of the items of qualification --
21 for example, radiation or temperature or pressure -- was not 22 adequate, then you would say that that particular I
23 documentation file did not fully support qualification.
24 So in each file, there is a number of environmental 25 issues addressed.
l
48 1
Ton?
Is that how many wo look at?
2 MR. LaGRANGE:
Anywhere from ten to twenty.
3 MR. VOLLMER:
Anywhere from ten to twenty different 4
types of issues, and there's a large number of components, so 5
if you fall off on one item where you're not fully convinced, 6
then it sort of drops into this particular hopper.
7 So it's a fairly significant victory when t he-8 Licensee can fully support qualification for all the items in 9
any given file, to the degree that the inspection looks at it.
10 MR. LaGRANGE:
This Bullet No.
1 is really a 11 judgment call Absent the documentation, does it appear that 12 based on the knowledge of the i ns p e c t o r s and the use of the 13 similar equipment at other plants, there's no evidence that it 14 will fail, and, in fact, there is evidence existing elsewhere 15 that shows it will probably work.
16 MR. VOLLMER:
We're getting into the discussion that 17 we had before.
Is the equipment unqualified or does it fail 18 to be demonstrated to be qualified?
19 Item 1 is, if we run across something that we feel 20 is clearly unqualified in the inspector's judgment, based on 21 his experience and what he has seen out in the field, the 22 bottom there is that the Licensee hasn't given us adequate 23 demonstration, paper demonstration, that he can support his 24 qualification assertion, and that is why the discrepancy
)
25 exists.
49 1
COMMISSIONER ASSELSTINE:
Dick, can you give mo a
)
2 sense for the range of'what you found?
You have done five 3
inspections since we.had the April meeting.
Take the best and 4
the worst of'those five plants, and tell us what you found 5
in terms of these deficiencies.
6 CHAIRMAN PALLADINO:
Which plants?
7 COMMISSIONER ASSELSTINE:
Well, they did five plants 8
since we met in April.
Rancho Seco, Point Beach, Brunswick, 9
Nine Mile Point, and Calvert Cliffs, Calvert Cliffs being a 10 reinspection.
11 If you could go through and sort of highlight the 12 range of what you found, because you've talked about 13 deficiencies occurred at some or most, but sort of the range 14 of either, on the one hand, the best performance you found in 15 any of those five inspections, and on the other end, the worst 16 you found.
17 Slide 6 shows the plants for which inspections have 18 been done and the dates, and the last five were done since we 19 met in April 20 CHAIRMAN PALLADINO:
Okay.
Thank you.
21 MR. VOLLMER:
Okay.
One plant, particularly Zion-2, 22 we reviewed thirteen files, and only two files did not 23 adequately support the qualification.
Those wers on 24 Limitorque MO, motor-operated, valves and a certain type of maintenance 25 terminal blocks.
There were other open stems
50 1
procoduros, training, documentation orrors that we found,
)
2 Those are procedural, programmatic things.
We felt that there 3
were other items, for example, that we weren't sure that we 4
could agree with their 50.49 master list whish identified 5
every piece of equipment that should be under the EQ program, 6
including maintenance program.
That's also programmatic.
7 If you go on to what looks to be about the worst, 8
there were nineteen files looked at, and eleven of those files 9
did not adequately support documentation.
10 CHAIRMAN PALLADINO:
I ccn't hear you.
11 MR. VOLLMER:
01 nineteen files reviewed, eleven did 12 not adequately' support qualifica' tion, and that was Calvert 13 Cliffs Unit-1.
14 COMMISSIONER =ASSELSTINE:
This is the first 15 inspection?
16 MR. VOLLMER:
T?ll, --
17 COMMISSIONER ASSELSTINE:
Or is this the second 16 inspection?
19 MR. VOLLMER:
First inspection.
But the second 20 inspection, we were disappointed.
There were improvements, 21 but not to the extent that we had hoped.
And if you want any 22 details, I could ask one of the inspection personnel to brief
.23 you.
24 But in that particular case, we, you know, had 25 target rock valves, Rockbestos cable, motors, certain types of i
51 1
6 j
1 motors, terminal blocks and so on.
So wo had a number of i
~
2 things where they did not demonstrate by their documentation 1
3 that qualification had been achieved.
4 Now in some o'
these, the inspector was aware of he was aware of information that perhaps the 5
extenuating 6
Licensee wasn't, but in no cases did the inspector fuel that 7
that equipment clearly would be expected to fail in the case 8-of an adverse environment.
9 MR. EISENHUT:
Dick, do you have the date on the 10 Brunswick inspection?
11 MR. VOLLMER:
The-data on the Brunswick inspection?
- 12 MR. EISENHUT:
It's orie of the later post-April 13 MR. VOLLMER:
Yes.
Fourteen files were reviewed on 14 Brunswick, and four of these did not adequately support 15 qualification.
Accelerometers, pressure transmitters, some 16 more Rockbestos cable, and I can't read the other one --
17 Westinghouse -- oh, the penetration assemblies, electrical 18 penetration assemblies.
19 So that's the range of things.
I've looked this 20 over, and with the exception of a few things such as the l
21 Rockbestos cable and Limitorque MOVs, there don't seem to be 22 any that jump out at you as being clearly across the board.
23 We haven't got that many inspections under our belt, however.
24 COMMISSIONER ASSELSTINE:
Have inspection reports 25 been written on each of those inspections that are listed on
52 1
Slido 6?
2 MR. VOLLMER:
I think we have four reports written.
3 COMMISSIONER ASSELSTINE:
Which ones are written, 4
and which ones aren't in?
5 MR. VOLLMER:
Gary Zech will indicate which ones are 6
complete.
7 MR. ZECH:
Gary Zech from the Staff.
8
.We have written reports since the April inspection 9
on Fort Cal'houn, Rancho Seco.
The other ones remaining are 10 Point Beach, Brunswick, and Nine Mile Point and are in various 11 stages of preparation, and we just finished Calvert Cliffs 12 last shek.
~
13 MR. VOLLMER:
But we had the Zion and Crystal River 14 already done.
~
15 MR. ZECH:
That's right.
And Fort Calhoun was the 16 next week after that April inspection, and that has been
)
17 issued.
18 COMMISSIONER ASSELSTINE:
Did you find programmatic I
19 deficiencies in every one of.the inspections or not?
Did 20 anyone come through clean in terms of their program?
21 MR. VOLLMER:
No.
There was always something we can not large in terms of 22 find.
Some of them were rather 23
. programmatic inspections.
Some, I think, in a couple of 24 cases, the Staff felt that they had really pretty good 25 programs underway, but there were some open items.
l
i 53 1
COMMISSIONER ASSELSTINE:
Which one of that group do 4
)
2 you think had the best program?
3 MR. VOLLMER:
I would turn to the inspectors.
4 COMMISSIONER ASSELSTINE:
Where you have done 5
inspections, which one looks the best in terms of having a 6
good EQ program?
7 MR. ZECH:
It is difficult to really make an 8
absolute comparison.
But of all those we have inspected, I 9
guess programmatically is how we really l o'o k at it, we could 10 probably say Zion Unit-2 had one of the better programs, in 11 that they looked at all the aspects of it -- the maintenance to make sure 12 requirements, the organizational procedures 13 that the different parts of the organisation are involved in 14 the EQ effort.
And there are a couple of others that would 15 probably be close behind Zion.
16
[ Commissioner Bernthal leaves the hearing room.3 17 CHAIRMAN PALLADINO:
Okay.
Continue.
18 MR. VOLLMER:
Okay.
I am through with Slide 8.
19 MR. EISENHUT:
Let's go to Slide 9,
which is the 20 conclusions.
21 CSlide.]
22 Most plants, where we are today, are well along, as 23 we said.
We are probably well into the 90-something percent 24 of the equipment is now through the program.
We do have the 25 six extension requests, as we pointed out, that have been i
1
e -
54 1
submittod, and we might oxpect a few moro.
2 The inspections are going to continue.
The Staff's 3
reviews will continue, focusing on the extension requests.
We 4
will rehighlight that the deadline for requests for extensson 5
to the Commission is September 30th, and we are hopeful that 6
we can send down our recommendations on the ones that we have 7
by about October 1.
8 That is, in a capsule summary, where we are today.
9 That's all we really planned to cover, unless there are any 10 other' specific questions.
11 CHAIRMAN PALLADINO:
You make a statement on Slide 12 9, quote, "Not aware of any plants proposing to operate 13 without approved extension and qualification not completed."
?
14-MR. EISENHUT:
A simpler way to say that would be 15 that we are not aware -- nobody is going to go forth -- we are i
16 not aware of anyone who is going to go forth and take the 17 civil penalty.
'f it is only one item?
I 18 CHAIRMAN PALLADINO:
Even i
)
i 19 MR. EISENHUT:
I'm not aware of any.
20 MR. STELLO:
Mr. Chairman, the question was asked 21 earlier of how the industry feels regarding accepting a civil 22 penalty, and I think that is that broad general question that 23 we really need to deal with in a different context.
l 24 COMMISSIONER ASSELSTINE:
When are your next 25 inspections, say, for the balance of the year, coming to what
5G 1
plants end which onos aro you going to be looking att 2
MR. ZECH:
What we are trying to do is evaluate the 3
results of the pilot program, and what we are doing now is 4
looking at turning it over in a phased approach to the 5
Regions.
But we estimate it would take about one inspection 6
per month for each of the larger regions over the next several 7
months to get the program going.
But right now, our schedule 8
doesn't go much beyond the next month.
9 Next week is San Onofre Units 1,
2, and 3.
And as 10 Bob L'aGrange mentioned, we probably will be doing some sort of 11 inspection at the Sequoyah plants sometime in October, the 12 latter part of October.
That's all we have right now.
13 COMMISSIONER ASSELSTINE:
All right.
So the idea 14 would be,'do those, finish your inspection reports on the ones 15 that you have done as well as those, and then basically 16 transfer it to the Regions starting the beginning of next 17 year?
18 MR. VOLLMER:
Well, that was our original 19 anticipation, but in order to do that, we would have to 20 evaluate the results of the inspections and how well the 21 training program -- we may institute a specific Regional 22 training program to'do that.
And I think also part ~of it was 23 to take a look at the inspection results with an enforcement 24 eye and see whether or not we have a reasonable approach to 25 turn it over to the Region.
56 1
So it's not exactly clear.
Our original goal, I 2
think, that we indicated in April, was to do ten inspections, 3
two per Region,. and then turn it over to the Regions.
j 4
COMMISSIONER ASSELSTINE:
The training program would 5
be for our Regional people?
6 MR. VOLLMER:
Well, they have been involved in t h'e s e 7
inspections, and we would anticipate probably before we turn 8
it over to have a conference of some sort to get everybody on 9
board with not only the results, but also how they should 10 interpret various actions and'EQ situations that they run 11 into.
And again, it's been difficult -- a difficult growing 12 period here for us in the inspection program, and I think
~
13 we're just going to have to sit down and decide how we go from 14 here.
15 COMMISSIONER ASSELSTINE:
How are you getting these 16 inspection results, the ones that you outlined in Slide 8,
in 17 terms of the deficiencies you found, both in terms of programs 18 and in terms of individual qualification efforts?
l 19 How are you communicating that information back to 20 the industry, not just to the utility that you did'the 21 inspection on, but also throughout the industry, so that those 22 people that are still completing their EQ work can take a look 23 at that experience and make sure, for example, that when you 24 come by, that they have got a maintenance program to keep the 4
l 25 equipment qualified, that they do have their performance r
57 1
requiremonts wall dofinod for particular pieces of equipmont, 2
that they are not making very bad judgments, at least in terms 3
.of relying on similarity of equipment?
4 How are you getting that?
5 MR. VOLLMER:
I know that a number of utilities have 6
requested the inspection reports.
I don't know if there is an 7
organized effort.
8 MR. STELLO:
I think it's a good point.
Maybe what 9
we ought to do is just bundle them all up and write a letter 10 and send them to the Licensees that we haven't inspected.
11 COMMISSIONER ASSELSTINE:
Yes.
And say, "Look, 12 here's one finding" -,
13 MR. STELLO:
That's a good idea.
We ought to just 14 bundle them up and send them out.
15 COMMISSIONER ASSELSTINE:
In fact, I would even 16 suggest, if the problems are widespread enough and generic 17 enough in their applicability, maybe even something beyond 18 that -- meetings with Licensees on a Regional basis and say, 19 "Here's the stuff we're finding," at least getting an 20 information notice out saying, "These are the kinds of 21 problems we're finding."
22 MR. STELLO:
That we can do quickly.
23 MR. ZECH:
We issued one in May of
'85, in fact two 24 of them.
One was on auditability of files, and the other was 25 on the qualification process.
58 1
But I might also add that in almost all of the 2
inspections, an Owners Group representative has been with us 1
3 at the utility, at the invitation of the utility, and is, I'm l
4 sure, feeding back that information.
5 MR. STELLO:
We will do that.
I think it's a good 6
idea.
7 CHAIRMAN PALLADINO:
I have one question.
Getting 8
back to the schedule, you indicated that the first plant 9
evaluation of those that requested exemption would probably 10 come within a week or two.
But we have all of these on which 11 to make decisions well before the 30th.
12 Do you think you will get the six, or at least the 13 six you have now, completed by mid-October?
14 MR. EISENHUT:
Oh, certainly.
We're planning to 15 have those complete by mid-October.
I'm not sure that two of 16 them are even in the door yet physically, but as soon as they 17 get in, certainly we would be targeting --
18 MR. STELLO:
Well, you indicated that you at least 19 thought that by next week, some simpler ones would be sent to 20 the Commission with -- I think you indicated CP&L's might be 21
-- October 1 was the target.
We will make every effort to I
l 22 make sure that we get them down here on about the 15th.
73 CHAIRMAM PALLADINO:
We are going to have to make 24 decisions, and I would like to avoid last-minute crises, if we 25 can possibly do so.
l
59 1
Now lot mo ask you, with regard to roquests that 2
might come after September 30th --
3 MR. STELLO:
Your letter -- or our letter has 4
specific language in it that deals with that issue.
5 MR. EISENHUT:
It says that requests received after 6
September 30th --
7 MR. STELLO:
'May be denied on that basis.
8 MR. EISENHUT:
It says they will be considered 9
untimely, and they may be denied on that basis.
10 MR. STELLO:
So you have added the element that says 11 we are going to consider them untimely, and on just the basis 12 of them being filed late, may be' denied only on that basis.
13 And the Commission will need to be sensitive to what's 14 happening between now and then in terms of making t h a t-15 judgment.
I don't think we can say much about it right now 16 until we see how things unfold in the next week or two.
17 MR. EISENHUT:
I.think 18 CHAIRMAN PALLADINO:
I just wanted to follow up.
So 19 if we d e. n y it, then what?
They have to shut down?
20 MR. STELLO:
On November 30th, they would have to 21 shut down.
22 MR. VOLLMER:
Or suffer a penalty.
23 MR. STELLO:
No.
That's a second issue.
24 CHAIRMAN PALLADINO:
Yes, that's a different one.
25 Ycu can't go beyond the 30th of November without a f
60 1
Commission-cpprovod oxtonsion.
2 COMMISSIONER ASSELSTINE:
No, no.
3 MR. VOLLMER:
No.
The letter gives them the option 4
of doing that.
5
[ Commissioner Bernthal returns to the hearing room.3 6
MR. VOLLMER:
Facing the enforcement action, that 7
was specifically an either/or for the Licensee.
He may shut 8
down, or he may continue to operate, subject to enforcement 9
action.
10 CHAIRMAN PALLADINO:
Oh, yes, you're right.
11 MR. VOLLMER:
Which can be mitigated on the factors 12 indicated at the top of page
- 2. ~
13 COMMISSIONER ASSELSTINE:
That's right.
14 CHAIRMAN PALLADINO:
No, wait a minute.
It says 15 here -- let me read the sentence to you.
Maybe I don't read 16 it correctly.
17 "The purpose of this letter is to advise Licensees 18 that it is the Commission's intention that extensions will be 19 granted only in rare circumstances, and that enforcement 20 action will b,e taken against Licensees that continue to 21 operate their plants with unqualified equipment beyond 22 November 30 without extension approved by the Commission."
23 COMMISSIONER ASSELSTINE:
That's right.
That's 24 enforcement action.
That is defined.
25 CHAIRMAN PALLADINO:
Not necessarily.
If you had
61 1
said finos, I would understand it.
2 MR. VOLLMER:
Well, the next sentence --
3 CHAIRMAN PALLADINO:
The next sentence says --
4 MR. VOLLMER:
"It is the Commission's intention that 5
Licensees that are not in compliance on November 30th and 6
which have not been given extensions either will havesto shut 7
down or, if they have valid Staff-approved JCOs, select to 8
operate and face civil penalties.
9 CHAIRMAN PALLADINO:
Okay, that's right.
So then 10 they would have to take that up.
11 COMMISSIONER ASSELSTINE:
They have to make the 12 choice 13 MR. STELLO:
I was trying to make the point that if 14 something happened that is late, and they have an untimely 15 filing, you can decide that they can't get an extension.
But 16 there's the second part of it that has to be done,.and that 17 is, if it's a new piece of equipment, it may or may not have 18 the JCO.
That will require Staff action, and we may or may 19-not decide we agree with them.
20 If we don't agree with them, they shut down.
If we 21 do agree with them, then they have the option.
22 COMMISSIONER ASSELSTINE:
That's right.
And under 23 no circumstances can a plant operate without a valid JCO.
24 MR. STELLO:
That's right.
So you have to evaluate 25 the safety issue.
62 1
COMMISSIONER ASSELSTINE:
Including Fort St. Vrain.
2 MR. EISENHUT:
Right, including Fort St. Vrain.
And 3
I was going to say, because of the timing, we will be calling 4
each utility and alerting the senior managsment that there is 5
a request, if it's after September 30th, it's not a timely 6
filing, just reminding them what the letter says.
7 CHAIRMAN PALLADINO:
Okay.
Any other items to cover 8
on this matter.
9
[No response.)
10 CHAIRMAN PALLADINO:
Okay.
Now I haven't adjourned 11 this meeting yet, but we have affirmation at 3:30, and I guess 12 we will just, have to wait for it.
1 13 COMMISSIONER ZECH:
Mr. Chairman, I would like to 14 make a point before we go on.
15 First of all, we were talking about equipm3nt 16 qualification, which is a very importsat matter, and I think 17 it's important, you made some important statements, and I 18 think it is important to recognize that so far in all the 19-years we've been looking at it, we haven't found any equipment 20 which would be expected to fail in a harsh environment.
I 21 think that's an important point, and I guess that's what you 22 have told us, right?
23 MR. LaGRANGE:
Well, that's the recent inspections, 24 and as a result of several years of work, there has been quite 25 a bit of hardware replaced that would not have functioned, in
63 1
cur opinion, up to this point.
2 COMMISSIONER ZECH:
Also, we are talking about a s
3 problem that is a documentation problem, and it's obvious to 4
me that the utilities, perhaps at least a number of them j
5 anyway, have not done the job in documentation that they 6
should have.
7 On the other hand, we have put out what I believe is r
8 a pretty tough policy that does require complianoe, and I 9
think it's appropriate that we have done that.
10 I think now, though, that we have come to the time 11 of asking for the Staff's good work on helping us to come to 12 decisi[ns and analyze whether ths utilities.have, indeed, 13 taken a reasonable approach, have they taken a comprehensive 14 approach, have they scheduled t h e.i r business properly, and 15 that's what I'm looking for when you come to us, so we can 16 make a judgment call as to whether exemptions should be 17 granted or not.
18 I think it's appropriate, though, that we do 19 recognize that it is-a documentation problem that we have, 20 more than anything, as I understand it, but there is certain 21 documentation, there is certain paperwork that's important.
22 And this kind of paperwork, as far as I'm concerned, is indeed 23 important.
It should be documented properly, and it's 24 appropriate that we have a good, tough policy out that.we 25 follow through.on.
l l
64 1
But it doos roquiro scmo judgmont calls on our part, or certainly I feel at my level that I need the 2
and we are 3
Staff's analysis and your good, cool thoughts on what has 4
happened in this whole program, in order to help us make a 5
judgment call.
6 MR. STELLO:
That's what we do provide.
7 CHAIRMAN PALLADINO:
I think those are very good 8
comments, although I don't want to give the impression that we 9
are not interested.in the actual qualification-of equipment.
10 I'm sure that's not 11 COltMISSIONER ZECH:
Oh, no, not at all.
I think 12 that's the most important thing"of all.
It's encouraging, at q
13 least.
I.think it's important to note that we haven't.found 14 anything really significant that wouldn't perform.
If we do t
15 find something, then I think that's the important thing.
16 The documentation is important, but it only verifies 17 what we are trying to find out in the first place:
Will the 18 equipment operate in a harsh environment?
19 So I think the whole program is very important, and 20 that's why I agree, Mr. Chairman, we should focus on the 21 equipment -- that's what we're trying to do and safety.
22 That's what it's al1 about.
23 CHAIRMAN PALLADINO:
Let me make one other comment.
24 If you run into difficult / on evaluations, s u cia that thers is 25 going to be a significant delay, would you let us know, so
i 65 i
1 that at locat we can soo how to resolvo the problems?
MR. STELLO:
We will do our best so that is not, in 2
3 fact, the case.
But if we do run into problems, we will let 1
4 you know.
5 CHAIRMAN PALLADINO:
All right.
Any other comments?
6
[No response.]
7 CHAIRMAN PALLADINO:
All right.
Now I am going to 8
ask the audience to bear with us for another three minutes.
I 9
am going to adjourn this meeting and convene another meeting 10 that is called affirmation and discussion.
There are two 11 i t ems on the agenda, and it should take us not over three
~
12 mi nu t e s to handle it.
13
[Whereupon,.at 3:30 o' clock, p.m.,
the Commission
\\.~
14 meeting was concluded.3 15 16 17 18 19 20 21 22 23 24 25
1 CERTIFICATE OF OFFICIAL REPORTER 2
3 4
5 This is to certify that the attached proceedings 6
before the United States Nuclear Regulatory Commission in the 7
matter of. COMMISSION MEETING e
9 Name of proceeding:
Status of Progress on Environmental Qualification of Electrical Equipment to (Public Meeting) 11 Docket No.?
12 Place: Washington, D. C.
13 Date:
Tuesday, September 17, 1985 14 15 were held as herein appears and that this is the original 16 transcript thereof for the file of the United States Nuclear 17 Regulatory Commission.
I's (Signature)
(TypedName'ofReprter) [Su'za$e B. G ng 20 21 22 23 Ann Riley & Associates, Ltd.
24 25
i L
UNITED STATES NUCLEAR REGULATORY COMMISSION COMMISSION-MEETING SEPTEMBER 17, 1985 STATUS OF PROGRESS ON ENVIRONMENTAL QUALIFICATION 0F ELECTRICAL EQUIPMENT J
0
,n--
-SLIDE 2 OVERVIEW LAST BRIEFED COMMISSION ON STATUS OF ENVIRONMENTAL Q o
FICATION (EQ) ON APRIL 2, 1985 o
SINCE APRIL 2, 1985 MEETING:
TWO PLANTS LICENSED (TOTAL NOW 95) 11 EVALUATIONS COMPLETED (TOTAL NOW 84)
STATUS OF EXTENSIONS GRANTED / REQUESTED UP TO NO 30, 1985 UNCHANGED EXTENSIONS BEYOND NOVEMBER 30, 1985 REQUESTED FOR SIX PLANTS
~ E0INSECTIONSOFEIGHTPLANTSANDONEFOLLOW-UPINSPEC STAFF REQUIREMENTS MEMORANDUM (SRM) DATED APRIL 26, 1985 o
STAFF RESPONDED BY SECY-85-220
- GENERIC LETTER 85-15 (COMPLIANCE DEADLINE)
.o o
SRM DATED AUGUST 27, 1985 o
EQ INSPECTION PROGRAM i
4 l
SLIDE 3 STATUS
SUMMARY
o TOTAL NUMBER OF OPERATING REACTORS:
95 OPERATING REACTORS WITHOUT EXTENSIONS BEYOND MARCH 31, 1985:
41 OPERATING REACTORS GRANTED EXTENSIONS UP TO NOVEMBER 30, 1985:
45 NEW OPERhTING LICENSES ISSUED WITH A NOVEMBER 30, 1985 COMPLETION DEADLINE:
7 NEW OPERATING LICENSES ISSUED WITH QUALIFICATION COMPLETED:
2 1
O
SLIDE 4 PLANTS THAT WILL NOT OR MAY NOT COMPLETE QUALIFICATION BY NOVEMBER 30, 1985 EXTENSION REQUESTED i
- BRUNSWICK 2 HADDAM NECK MILLSTONE I NINE MILE POINT 1 POINT BEACH 1 P0 INT BEACH 2 TO SHUTDOWN FOR'EQ~BY NOVEMBER 30,'1985 BYRON 1 DO NOT PLAN TO RESTART-UNTIL AFTER NOVEMBER 30, 1985 OR UNTIL EQ COMPLETE BROWNS FERRY 1 BROWNS FERRY 2 BROWNS FERRY 3 SEQUOYAH 1 SEQUOYAH 2 1
OTHER FORT ST. VRAIN HATCH 2 OYSTER CREEK PILGRIM
,~
O-SLIDE 5 30, 1985 PLANTS FOR WHICH AN EXTENSION TO THE NOVEMBER
-DEADLINE HAS BEEN REQUESTED NUMBER OF ITEMS (COMPONENTS) 1 (4) o NINE MILE POINT 1 53
(*179) o BRUNSWICK 2 1
(2)
O POINT B.ACH 1 E
1 (2) o POINT BEACH 2 5
(34) o HADDAM NECK 6
(11) o MILLSTONE 1 l
i l
SLIDE 6 IE EQ INSPECTION PROGRAM INSPECTION MODULE / GUIDANCE COMPLETED AND PROVIDED T 0
OFFICES NINE INSPECTIONS (INCLUDING ONE FOLLOWUP) COMPLETED - IE LEAD, 0
NRR, REGIONAL PARTICIPATION CALVERT CLIFFS 1 OCTOBER 1984 ZION 2 JANUARY 1985 C8ySTAL RIVER MARCH 1985 FORT CALHOUN APRIL 1985 RANCHO SECO MAY 1985 POINT BEACH 1/2 JULY 1985 BRUNSWICK 1/2 AUGUST 1985 NINE MILE POINT 1 AUGUST 1985 CALVERT CLIFFS 1/2 SEPTEMBER 1985 RESULTS FROM PILOT INSPECTIONS BEING EVALUATED O
INSPECTION TURNOVER TO REGIONAL OFFICES TARGETED 0
IE WILL CONTINUE TO PROVIDE TEAM MEMBERS AND CONSULTA IE WILL COORDINATE RESOLUTION OF SIGNIFICANT TECHNICA COMPLETION OF INSPECTIONS AT ALL OPERATING PLANTS TARG 0
END FY 87 I
e
,e SLIDE 7 1
JNSPECTION APPROACH REVIEW-0F LICENSEE PROGRAM FOR IMPLEMENTING 10 CF o
REQUIREMENTS REVIEW LICENSEE MAINTENANCE / SURVEILLANCE 0
QUALIFIED EQU.1PMENT REVIEW LICENSEE IMPLEMENTATION OF SAFETY o
CORRECTIVE ACTION COMMITMENTS REVIEW EQ DOCUMENT FILES (15-25% SAMPLE) o PERFORM PHYSICAL INSPECTION OF SELECTED EQUIPM O
9
SLIDE 8 INSPECTION RESULTS NO EQUIPMENT IDENTIFIED THAT WOULD BE EXPECTED TO O
MALFUNCTION IN ANTICIPATED ENVIRONMENT i
PROGRAM DEFICIENCIES IDENTIFIED AT MOST PLANTS 0
ORGANIZATION AND RETRIEVAL OF INFORMATION VITAL TO ESTABLISH QUALIFICATION EQUIPMENT MAINTENANCE / SURVEILLANCE PROCEDURES NOT DEVELOPED OR IMPLEMENTED DEFICIENCIES IDENTIFIED AT MOST PLANTS 0
IMPLEMENTATIlt INSTALLE9 CONFIGURATION DIFFERENT FROM QUALIFIED CONFIGURAYION
. SIMILARITY /\\ALYLIS NOT PERFORMED / INADEQUATE I
TEST ANOMALIE. NO" ADEQUATELY ADDRESSED i
AGING ANALYSIS 'NADEQUATE PERFORMANCE REQUI".EEENTS NOT DEFINED (INSTRUMENT I
ACCURACIES, OP. T1J4EL O
20-60% OF EQ DOCUMEN
.;.t'. REVIEWED DID NOT FULLY SUPPORT QUALIFICATION I
\\
L.
SLIDE 9
SUMMARY
/ CONCLUSIONS 89 0F 95 OPERATING PLANTS ARE CURRENTLY SCHEDULED TO HAVE o
COMPLETED OR TO COMPLETE QUALIFICATION BY NOVEMBER 30, 1985, OR PRIOR TO STARTUP AFTER THAT DATE i
SIX EXTENSION REQUESTS SUBMITTED, MORE EXPECTED SOME PLANTS SHUTDOWN /TO SHUTDOWN AND WILL NOT RESTART PRIOR TO COMPLETION NOT AWARE OF ANY PLANTS PROPOSING TO OPERATE WITHOUT APPROVED EXTENSION AND QUALIFICATION NOT COMPLETED 0
EQ INSPECTIONS TO CONTINUE.
TO DATE THEY HAVE IDENTIFIED DEFICIENCIES, AND WILL CONTINUE TO DO SO
~ T : " ~.'.1.:...
J'
,,~
~
o STAFF'S REVIEW EFFORTS WILL FOCUS ON:
DISPOSITION OF EXTENSION REQUESTS TO BEYOND NOVEMBER 30, 1985 SPECIAL CIRCUMSTANCES, E.G., FORT ST. VRAIN AND TVA PLANTS EVALUATION OF HADDAM NECK SYSTEMS ANALYSIS TO LIMIT SCOPE OF EQ EQUIPMENT G
0
'e BRUNSWICK 2 BACKUP SLIDE 1 EXTENSION REQUEST TO MARCH 30, 1986 FOR 53 ITEMS (MORE THAN 179 COMPONENTS)
EVALUATION CONSIDERATIONS LICENSEE'S ARGUMENTS IN FAVOR OF EXTENSION O
PLANT IS SAFE (JC0s) o REFUELING OUTAGE SCHEDULED FOR MARCH 30, 1986 o
SHUTDOWN NOVEMBER 30, 1985 RESULTS IN LOSS OF 120 DAYS OF FUEL o
UNIQUE PLANT DESIGN RESULTS IN MORE EQUIPMENT REQUIRING QUALIFICATION AND HARSHER ENVIRONMENT o
REPLACEMENT OF RIP SYSTEM (LARGE NO OF COMPONENTS) o MINIMUM TIME FOR COMPLIANCE - FIRST REFUELING OUTAGE WAS
~
APRIL, 1982 o
SUBSTANTIAL RESOURCE ALLOCATION FOR OTHER WORK o
COMPENSATORY ACTIONS IN EFFECT (E.G., ENHANCED DRYWELL LEAK DETECTION CRITERIA) o BRUNSWICK 1 UNDERGOING EXTENSIVE OUTAGE - 9 MONTHS LONG; I
WORK INCLUDES EQ; SCHEDULED TO RETURN TO SERVICE DECEMBER o
UTILITY ARGUES WORKER EXPOSURE AND OVERALL EFFICIENCY OF
(
WORK WOULD BENEFIT FROM ALLOWING TIME TO EVALUATE AND APPLY UNIT 1 LESSONS TO UNIT 2 (1700 MAN-REM EXPOSURE PROJECTED FOR UNIT 1 OUTAGE EXTENSIVE ALARA REVIEW EXPECTED TO RESULT IN 100-MAN-REM SAVINGS ON UNIT 2) o CP&L SYSTEM RELIABILITY (MULTIPLE UNITS SHUTDOWN) o DILIGENT EQ EFFORTS o
UTILITY ARGUES CIVIL PENALTY APPROACH NOT VIABLE o
IE EQ INSPECTION RESULTS FAVORABLE o
"LIVING SCHEDULE" LICENSE AMENDMENT REQUEST (WORK DURING REFUELING OUTAGES)
ARGUMENTS AGAINST EXTENSION o
EQ ISSUE HAS BEEN IN EXISTANCE FOR A LONG TIME o
NUMBER OF COMPONENTS YET TO BE FULLY QUALIFIED IS RELATIVELY LARGE o'
COMMISSION'S DESIRE TO MAINTAIN NOVEMBER 30, 1985 DEADLINE (GENERIC LETTER 85-15) o EQ EFFORTS SLOW STARTING THROUGH EARLY '80s
BACKUP SLIDE 2 TVA PLANTS o
A TEAM CONSISTING 0F TVA AND WESTEC PERSONNEL REVIEWED TVA QU LIFICATION DOCUMENTATION FOR BROWNS FERRY, SEQUOYAH AND WATTS BAR, AND OTHER ASPECTS OF TVA'S EQ PROGRAM o
THE TEAM IDENTIFIED MANY DEFICIENCIES IN THE INDIVIDUAL EQ PACKAGES IT REVIEWED AND IN TVA'S EQ PROGRAM IN GENERAL 0F 33 EQ PACKAGES REVIEWED (18 FOR BROWNS FERRY, 11 FOR-SEQUOYAH AND FOUR FOR WATTS BAR), THE TEAM CONCLUDED ONLY THREE DOCUMENTED QUALIFICAT-ION
~
DEFICIENCIES IDENTIFIED INCLUDED SIMILARITY NOT ESTAB-LISHED, AGING EVALUATION NOT PERFORMED OR INADEQUATE, QUALIFIED LIFE NOT ESTABLISHED, TEST DURATION NOT ADEQUATE, SPRAY QUALIFICATION NOT ESTABLISHED, MAINTENANCE / SURVEILLANCE REGUIREMENTS NOT ADEQUATE, INTERFACES NOT ADDRESSED, AND TEST ANOMALIES NOT RESOLVED PROGRAM / GENERIC DEFICIENCIES IDENTIFIED INCLUDED INADEQUACIES IN LIST OF EQUIPMENT REQUIREi TO BE QUALIFIEID, APPROVED PROCEDURES D0 l3T REFLECT PROJECT ACTIVITIES, INADEQUATE PROCEDURE FOR -REPARATION OF QUALIFICATION MAINTENANCE DATA, INCORREC1 OPERATING TIMES, AND CABLE TRACEABILITY PROBLEMS
~
7 BACKUP SLIDE 3 2
o PLANTS WITH EVALUATION COMPLETED EXCEPT FOR PRESSURE / TEMPERATURE PROFILE:
DRESDEN 2 DRESDEN 3 MILLSTONE 1 QUAD CITIES 1 QUAD CITIES 2 YANKEE R0WE o
PU,NTS STILL UNDER REVIEW:
BIG ROCK POINT FORT ST, VRAIN HADDAM NECK SEQUOYAH I SEQUOYAH 2 c
a 4
BACKUP SLIDE 4 PLANTS WITHOUT EXTENSIONS BEYOND MARCH 31, 1985 ARKANSAS 1 ARKANSAS-2 BRUNSWICK 1 BROWNS FERRY I BROWNS FERRY 2 CATAWBA 1 CRYSTAL RIVER 3 DAVIS-BESSE 1
^
DRESDEN 2 DUANE ARNOLD FARLEY 2 FITZPATRICK FORT ST. VRAIN GINNA f(hA EE LACROSSE LIMERICK 1 MAINE YANKEE MCGUIRE I MCGUIRE 2 MILLSTONE 2 OCONEE 1 OCONEE 2 OCONEE 3 PRAIRIE ISLAND 1 QUAD CITIES 2 i
RANCHO SEC0 ROBINSON SALEM 1 SALEM 2 l
SAN ONOFRE 2 SAN ON0FRE 3 ST, LUCIE 1 i
ST, LUCIE 2 SUMMER 1 SURRY 2 TURKEY POINT 3 TURKEY POINT 4 YANKEE R0WE ZION 1
^
l BACKUP SLIDE 5 PLANTS WITH EXTENSIONS FOR SELECTED EQUIPMENT GRANTED FOR FERIOUS UF 10 NOVEMBER 50, 1985 BEAVER VALLEY I NORTH ANNA 1 BIG ROCK POINT NORTH ANNA 2 BROWNS FERRY 3 0YSTER CREEK BRUNSWICK 2 PALISADES CALLAWAY I PEACH BOTTOM 2 CALVERT CLIFFS 1 PEACH BOTTOM 3 CALVERT CLIFFS 2 PILGRIM COOK 1 POINT BEACH 1 COOK 2 POINT BEACH 2 COOPER PRAIRIE ISLAND 2 DRESDEN 3 QUAD CITIES 1 FARLEY 1 SAN ON0FRE 1 FORT CALHOUN SEQUOYAH 1 GRAND GULF 1 SEQUOYAH 2 HADDAM NECK SURRY 1 HATCH 1 SUSOUEHANNA 1 HATCH 2 SUSQUEHANNA 2 INDIAN POINT 3 THREE MILE ISLAND 1 LASALLE 1 TROJAN LASALLE 2 VERMONT YANKEE MILLSTONE 1 WNP-2 MONTICELLO ZION 2 NINE MILE POINT 1 l
t
~..
^^
s
'a BACKUP SLIDE 6 o
NEW OPERATING LICENSES ISSUED WITH A NOVEMBER 30, 1985 COMPLETION DEADLINE:
BYRON 1 FERMI 2 PALO VERDE 1 RIVER BEND 1 SHOREHAM WATERFORD 3 WOLF CREEK o
NEW OPERATING LICENSES ISSUED WITH QUALIFICATION COMPLETED:
DIABLO CANYON 1 DIABLO CANYON 2 l
9
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h ) &f p( h t
9/35
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