ML20132A424

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Transcript of 850918 Public Meeting in Washington,Dc Re Continuation of Briefing on Plant.Pp 1-80.Supporting Documentation Encl
ML20132A424
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Site: Davis Besse Cleveland Electric icon.png
Issue date: 09/18/1985
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NRC COMMISSION (OCM)
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REF-10CFR9.7 NUDOCS 8509250339
Download: ML20132A424 (115)


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UNITED STATES OF AMERICA 70

{ NUCLEAR REGULATORY COMMISSION .. _ . . -

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In the matter of: . ~ ' ' . : .,

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COMMISSION MEETING

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.j Continuation of Briefing . yg on Davis-Besse '!

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Docket No. h v-

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>L l Location: Washington, D. C.

Pages: 1 - 80 Date: Wednesday, September 18, 1985

-isNN RILEY & ASSOCIATES Court Reporters

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1625 I St., N.W.

8509250339 850918 Suite 921 PDR 10CFR Washington, D.C. 20006 PT9.7 PDR (202) 293-3950

1 D i SCLA I M ER 2

3 4

5

.6 This is an unofficial transcript of a meeting of the 7 United States Nuclear Regulatory Commission held on Wednesday, 8 Septatter 18,1985 n the Commission's office at 1717 H Street, 9 N . tJ . , 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 12 inaccuracles.

13 The transcript is intended solely for general 14 informational purposes. ,A s provided by 10 CFR 9.108, 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 enay be filed with the Commission in 19 any proceeding as the result of or addressed to any statement i

20 or argument contained herein, except as.the Commission may 21 authorire.

22 23 24 25

etts 1 o

1 UNITED STATES OF AMERICA 2 NUCLEAR REOULATORY COMMISSION

,m 3 - - -

l 4 CONTINUATION.OF BRIEFING ON DAVIS BESSE i i

5 6 PUBLIC MEETING 1 7 Room 1130 8

1717 H Street, N.W.

9 Washington, D.C.

10 Wednesday, 18 September, l

1985 I 11 12 --

The Commission met, pu,rsuant to notice,at 9:35 a.m.

13 COMMISSIONERS PRESENT:

14 NUNZIO PALLADINO, Chairman of the Commission 15 THOMAS ROBERTS, Commissioner 16 JAMES ASSELSTINE, Commissioner 4

. 17 FREDERICK BERNTHAL, Commissioner 1'

18 LANDO ZECH, Commissioner 19 STAFF AND PRESENTERS SEATED AT CCMMISSION TABLE:

20 S. CHILK r 21 H. DENTON l

22 F. MIRAOLIA i 23 J. TAYLOR 24 B. SHERON 25 M. BLUME

' 2 1 P ROCEED 1 NOS 2 CHAIRMAN PALLADINO: Good morning ladies and 3 gentlemen. Commissioner Bernthat will be joining us. He was 4 detained for a few minutes.

5 Yesterday the Commission heard from Toledo Edison 1

,6 regarding Davis Besse. Today the Staff will briefly address 7 their activities regarding actions necessary for the restart 8 of Davis Besse.

9 Subsequent to the event at Davis Besse the Staff was 10 requested to identify any other operating nuclear power plant 11 with specific features that needed to be modified or added.

~

12 where the required corrective action has been outstanding for 13 an extended period of time.

14 In response, Staff identified five facilities:

15 Browns Ferry, Ft. St. Vrain, Rancho Geco, San Onofre 1 and 16 Palisades.

17 1 understand the Staff will address the current 16 status of activities regarding these other five plants.

19 In addition the Staff will discuss two significant 20 generic issues; fire protection and containment purge and 21 vent 22 1 understand the Regional Administrator from Region 23  !!! is on the telephone available to discuss Davis Besse 24 concerns.

23 Do any of my follow Commissioners have any other

  • 3

( 1 opening remarks?

2 COMMISSIONER ASSELSTINE: No.

3 CCMMISSIONER BERNTHAL: No.

4 COMMISSIONER ZECH: No.

S CHAIRMAN PALLADINO: Let me go to Mr. Denton, 6 MR. DENTON: Thank you, Mr. Chairman. I would 7 propose to pick up on the slides we were going to use 8 yesterday, about how we were reviewing the new initiatives 9 being carried out at Davis Besse and talk about those first.

10 And t h e r, go to the five plants on the two generie issues 11 Then any other topics the Commission wishes.

12 So, I propose we start'with the slide called Other 13 Restart Considerations. I t. is about midway in the package, 14 because everything before that has been covered and described 15 in yesterday's briefing.

16 Slide 9.

17 (Slide) 18 I will just briefly mention that one of the things 19 we have done in NRR is assign more resources to the Davis 20 Besse project, and to all the B&W groups We now have two 21 project managers assigned to each project and traditional 22 technical strength in that area. And I think Jim has done 23 some of the same thing to monitor and inspect Davis Besse.

24 COMMISSIONER ASSELBTINE: 1s this just for Davis 25 Besse, Harold, or all B&W plants'

- 4 1 MR. DENTON: My actions woro for all B&U plants.

2 They all now have two project managers, and we have assigned 3 two section leaders to the branch and a deputy branch chief 4 So this is -- looking to the new organisation which will, in 5 effect, double the amount of project management attention that 6 B&W plants have been receiving. .

7 MR. MIRAGLIA: Not all the plants now have two. Our 8 intent is to get two. I believe there is one vacancy yet to 9 fill. Our intent is to have two per plant.

10 MR. DENTON: I would like to start first and maybe I

i 11 answer some of ths questions that were raised about feed and 12 bleed issues at Davis Besse, and what we have done in that 13 area.

14 Mr. Williams described the calculations he had done l

15 about the capability of the plant to be cooled i n the absence

]

16 o'f feedwater flow.

17 We have been doing similar calculations. I have I

18 requested that an ACES subcommittee meet with us on the 19 topic. The meeting has been held, and Brian Sheron will 20 summarise the presentation we gave to the ACRS on that topic.

i 21 Then after that I will have Frank Miraglia go 22 through and describe the other activities that are ongoing on 23 the Davis Besse restart.

24 MR. SHERON: Let me pass out, if I could, some 25 information on the feed and bleed capability at Davis Besse.

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, . 5 1 Basically what wo did is -- when wo lockod at tho 2 feed and bleed capability of Davis Besse, we looked at it from 3 two standpoints. One was actual analysis -- can you put in 4 enough water and remove enough water to maintain the core 5 covered condition and remove decay heat. The other was we 6 looked at the systems that would be required, and could they 7 he counted upon to operate in a feed and bleed mode, mainly 8 the environmental qualification and the like.

9 You heard some of that yesterday from the. Licensee.

10 They looked at the qualification of the Equipment, f 11 We basically agree with their assessment that there does i

J 12 appear to be a very high probabi'lity that feed and bleed J

13 would work at the plant.

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14 Certain equipment are not fully qualified in a 1

15 design base sense such that one could claim feed and bleed was 16 a design base type of condition. But we don't see anything I 17 that was outstanding or glaring that would say the equipment 18 would fail in the event it was used to feed and bleed.

19 COMMISSIONER ASSELSTINE: Is that the same kind of 20 analysis that was done prior to the June 9th event that led 21 you to the conclusion that the auxiliary feedwater system had 22 a high degree of reliability; that is, assumptions that the I

23 equipment would be properly maintained?

24 MR. SHERON: I don't think maintenance came into our i 25 assessment on that. It is really a matter of, if the PORV is t

. 6 1 collod on to oporato in tho ovont say of a safoty injoction  !

~^ 2 signal -- or for example, I know a lot of plants would isolate 3 instrument error -- is this PORV powered or actuated by 4

4 instrument error. And the answer is no, I believe it is the 5 electromechanical.

6 MR. DENTON: That's a very fundamental question that 7 you are asking.

8 One of the biggest efforts we are going to put into 9 this restart will be assuring the safety ' systems are tested in 4

10 the modes in which they are likely to be called upon, so that 4

11 we have the assurance that they really have been tested and 12 can perform in the manner in which they are expected to work.

13 Now, if the systems are not maintained in the way 14 they are described in the application, that is a problem at 15 any plant no matter how well designed.

16 I think we assume single failures, but we don't 4

17 assume massive 15 different failures of equipment. What Brian 18 is describing are some deterministic calculations that have 19 been done using the latest TRAC Code and these kinds of 20 things.

21 Assuming the equipment works, how does the thermal 22 hydraulics of the core respond?

23 . COMMISSIONER ASSELSTINE: Okay.

j 24 MR. DENTON: So Brian is really describing the mass 25 and energy calculations he has done, assuming makeup pumps are 1

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. 7 1 cotually warking.

2 COMMISSIONER ASSELSTINE: Yes. But it does seem to 3 me that once you do that then you have to go back and look at 4 the other part, which is, do we have sufficient confidence in 5 the way this equipment has been maintained in the past and is 6 likely to be maintain (& in the future to rest our judgment 7 that yes, we can count on the equipment working and not have 8 the kinds of massive failures that occurred.

9 MR. DENTON: I think two key areas that we will be 10 covering at Davis Basse specifically are: Has the maintenance 11 program really improved? Can we find that it has, and has the 12 equipment then been tested befor~e restart, and really 13 demonstrated to work the way it is supposed tot 14 COMMISSIONER ASSELSTINE: Right. Okay.

15 MR. DENTON: This will maybe take five 16 minutes, Brian, if you can summarise just what you did and the 17 findings you came to.

18 MR. SHERON: We did three types of calculations.

19 One was simplified mass and energy balances. These are hand 20 calculations using steam tables and hand calculators.

21 MR. DENTON: These were done more or less 22 immediately after the event and were reported to the ACRS I

23 about a month ago I guess.

24 MR. SHERON: Yes.

25 We also did analyses using research developed TRAC

' 8 1 PF-1 code at Los A1amso. And wo also used tho RELAP S codo 2 using the new plant analyser, using the in-house facilities.

3 So we had basically three sets of calculations.

4 Based on these calculations, our overall conclusion 5 that we drew was that the current Davis Besse configuration 6 can indeed go into a feed and bleed mode and successfully 7 genov e decay heat if the operator initiates it in a timely 8 manner. This is using two makeup pumps and the PORV to remove 9 decay heat.

10 COMMISSIONER ASSELSTINE: I take it none of those 11 three pieces of equipment are safety grade?

12 MR. SHERON: The makeup pumps, I believe, are 13 safety grade. And the FORV I don't think is fully safety 14 grade.

15 COMMISSIONER ASSELSTINE: Okay.

i 16 MR. SHERON: Our conclusion was by timely operator 17 actions if you initiate feed and bleed within 20 minutes 18 MR. DENTON: I don't want to overemphasise the 19 safety grade, because the two pumps that failed at Davis Besse 20 were safety grade. So, there are other indicators of 21 reliability other than that label that we stick on them, 22 COMMISSIONER ASSELSTINE: That's right.

23 MR. SHERON: Just to show you that we do have some 24 confidence on our analysis codes, we did do a one calculation 25 where we reproduced the Davis Besse event as it occurred, and i

. 9 1 wo got very good agrocmont botwoon tho ocmputor ecdo and tho l

l-I 2 event. So we do have confidence that the codes, what they are I

I 3 telling us, is correct.

I 4 MR. DENTON:  ! think this is an important finding

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i 5 because remember, the first few days we had said that you l 0 l 6 could not feed and bleed at Davis Besse. And that was based  :

1 7 on the considerations about the shuttle head of the pumps and i

4 the FORY retteving capability. l 9 We have not looked that close at the capahtlity of ,

i j 10 makeup pumps. Remember when you and I appeared in Congress !

11 said the calculations appear to indicate that, 1 12 COMMISSIONER ASSELSTINE: That's right.

i i 13 MR. DENTON: At that time we had the hand l 1

i

14 calculations and now we have the two more refined computer l

15 models which show the same thing; namely, the two makeup pumps

16 a'nd the FORV can keep the core sufficiently cool if they are i

I i

17 turned on early in the event.

j it Then we went further and said, what else could we do i

19 with the FORV to enhance its relieving capability? And Brian, 20 maybe you want to talk about that issue.

21 MR. SHERON: What we did is we understand on the i

i 22 Davis Besse plant there is a considerable length of piping

! 23 that exists from the top of the pressuriser before it goes i

24 into the FORV. And so we looked at what would happen if we 1

! 25 were to T off of that and add another PORV of about equal i

i  !

4 i

I 10 1 retteving capacity as tho eno that is otroody thoro, which is I

2 around 210,000 pounds mass per hour, r l

3 When we ran the analysis using the RELAP S code with 4

4 this additional PORV assumed to be on the plant, it did 1 S enhance the relieving capacity and the ability to depressurise 6 and go on to the high-pressure injection system pretty much.

7 There is a question about, you know, when the 4 ability to depressurise depends on when the operator actuates

9 it, the FORVs. But the overall conotusion is that if you did

! 10 put on a second PORV on the plant of equal relieving capacity, 11 you would substantially increase the feed and bleed capability 12 of the plant, and you would most"likely be able to feed and

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l 13 bleed, maybe without even having to rely on makeup pumps, but j i L

j 14 just on HP! plus the FORVs.

2 i 15 COMMISSIONER ASSELSTINE: Even given the existing i 14 HP1 pump as opposed to one that was with a larger pump 17 capacityt 18 MR. SHERON: Yes, with the current low head whtoh !

f 19 think is around 1836 psi to shut off head.

20 CHAIRMAN PALLADINO: You recommend that they put j 1

21 such additional PORV ont 22 MR. DENTON
We are looking at it in the long term 23 -- 1 don't reocamend it prior to restart, But what I have 24 asked the Division of System Integration to do is to take a l

25 retook at all plants in this area.

1

' 11 1 Ysu had askod yostorday about which planto had which 5 2 type of shutoff heads. Why don't we turn to that issue next 3 --

I 4 COMMISSIONER ZECH: Also, you ought to look at the I 5 potential disadvantage of additional PORV because I am --

I 6 that's an important factor to cover, I'm sure.

7 MR. DENTON: There is a wide spectrum of plants.

8 And if you could pass around, Brian, the information we put 9 together since your question yesterday, we will spend three 10 minutes talking about which plants have shutoff heads equal to j

l 11 the relieving capacity, and whtoh have lower.

f 12 But it is clear here that if they oculd add '

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i 13 additional PORV capacity -- and Mr. Williams said there were' j

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I i 14 some possibilities for that -- they could, in effect, look I

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! 15 like typtoal Westinghouse plant then with regard to HPCI PORV.

3 i

it If they have the We s t inghous e' type pump head  !

17 capacity, shutoff head type Westinghouse pump, but they 7 it didn't have the FORV relieving capacity in most Westinghouse J

l 19 plants.

20 So Brian, why don't you just spend a few moments and

21 give this broader look at all plants with regard to shutoff 4

22 head and FORV capsetties, 23 COMMISStONER ASSELGTINE: Harold, just before he i

24 does that, let me ask just one more question about the l

25 analysis that you have done for Davis Besse as it is now i.

l

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I

  • 12 l 1 configurod.

2 If you lost one or both of the makeup pumps, then 3 what would that do to your analysis?  ;

l 4 MR. SHERON: The plant right now we don't believe

$ would be able to suooessfully feed and bleed with only one 6 makeup pump in the current PORV. single FORV. And obviously 7 -- let me qualify that, If the operators had one makeup pump 4 and also started, properly started the current -- I'm sorry 1

?

9 the startup feedwater pump that they have, the combination of 4

1 10 the one makeup plus the startup feed pump would be able to h

! 11 remove all the decay energy and there would be high -- !

i 12 guess a fairly high probability"that it would be successful.

I I 13 COMMISSIONER ASSELSTINE: But absent feedwater, get i 14 total loss of feedwater, you had lost one of the makeup pumps l 15 --

16 MR. SHERON: We don't believe one makeup pump would i

17 do it.

18 COMMISSIONER ASSELSTINE: Okay.

19 CHAIRMAN PALLADINO: What can you do with the

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20 high-pressure injection system?

21 MR. DENTON: You could raise the shutoff head. You l

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22 could put in a pump with a high shutoff --

23 CHAIRMAN PALLADINO: The extsting one, could they do l

! 24 anything in terms of feed and bleed by piggybacking, I 2S depressurising?

13 1 MR. DENTON: Tho problem is the roliof espacity of

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2 the PORV is not sufficient to blow the system down to even the 3 cutoff head of the piggyback system, so they are limited at 4 the moment by that PORV relieving capacity. It is relatively

$ small compared to the relieving capacity in many plants.

6 CHAIRMAN PALLADINO:  ! thought they were able to do 7 some injection by piggybacking. l s MR, SHERON: The piggybacking is when they run the 9 HP1 pump suction from the low-pressure injection pumps. That has the effect of raising the pressure of the system. B u t, it 10 11 only raises it to about 1836 psi, I believe, shutoff head for 12 maybe a pressure of around 1700.

13 So, it still doesn't raise it to the point where it 14 can pump and raise the FORV valve.

l 15 MR. DENTON: 1 think there was some water going in i 16 the vessel during the event because of that, but that is 17 because they did have the makeup pumps on, both of them, and it they were beginning to get water into the steam generator 19 also.

20 to that combination of those things were lowering 21 the pressure sufflotently, so that piggybacking did become 22 effective.

23 COMMISSIONER ASSELSTINE: Have any of these PORVs 24 failed closed as opposed to failing opent Any history of 25 PORVs failing closed?

14 1 MR. DENTON: We didn't bring down at this point our 2 PORV experts.

3 COMMISSIONER ASSELSTINE: Maybe you will just let 4 me know later.

5 CHAIRMAN PALLADINO: I think it would be of interest 6 to all of us.

7 MR. DENTON: I think a key consideration in talking 8 about this area is from early days on the primary mode of i

9 removing decay heat was through the steam generator. And the 10 early plants were all designed to remove heat through the 11 steam generator.

12 You recall some of the early plants did not have i.

.; 13 emergency cooling system. So there you had to rely on the

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l ( '- 14 steam generator. And everyone felt that the combination of 15 main feed and some auxiliary feed was an adequate way to 16 remove heat. And it is usually a very reliable way.

i 17 Emergency core cooling systems were designed to cope i

18 with pipe breaks, and they came in a variety of configurations 19 and pressures and so forth.

20 It wasn't until after TM1 that we started looking at 21 -- let's assume then that you lost feedwater, can this system i

22 designed for emergency core cooling systems do feed and bleed?

23 And that is where there was a variety of plant f 24 designs and that is why 1 wanted Brian then to deserthe and 5

i 25 respond to your question yesterday, Mr. Chairman, We can telt j

1 I

19 1 you the groups of plants, and some plants do have higher 2 shutoff heads than other groups, just because of the way they 3 follow the ECCS criteria.

4 (Commissioner Bernthal arrived) 5 CHAIRMAN PALLADINO: Is the feed and bleed situation 6 at Davis Besse similar to all the other B&W plants?

7 COMMISSIONER ASSELSTINE: It looks like there is a 8 big range.

9 MR. DENTON: Why don't we start and give you five 10 minutes to cover that topio, Brian.

11 COMMISSIONER ASSELSTINE: In fact, it looks like 12 most of the B&W plants are in the better category.

13 MR. SHERON: That's correct 14 All the B&W plants with the exception of Davis 15 Desse have HPI pumps which have shutoff heads that are above 16 the safety valve set pointt I think some plants go up to 17 about 2700 pounds, and another group can pump up to around 18 2900 pounds.

19 CHAIRMAN PALLADINO: And where did Davis Besse 20 happen to be the exception?

21 MR. DENTON: Well, in none of these plants did we 22 have at the time a requirement to design for feed and 23 bleed. So they all did their own balancing in how to meet the 24 ECCS requirements And so they ended up then with this mixed 25 ability of the feed and bleed.

16 1 CHAIRMAN PALLADINO: Now which cro tho @&W?

2 COMMISSIONER ASSELSTINE: Arkansas, Rancho Seco, 3 Crystal River, TMI-1, Oconee Plant 2 and 3.

4 MR. DENTON: Why don't you start with the first 5 group Brian, describe what they are.

6 MR. SHERON: Okay.

7 Well the first group are plants that have an HPI 8 shutoff head that is either equal --.approximately equal to 9 the safety valve relief pressure, or actually greater than it.

10 The B&W plants are the ones that have the shutoff 11 pressure that is much higher than a safety valve set point.

12 The Westinghouse plants, most of them have shutoff 13 heads that are around the s a f e't y valve set point which is 14 around 2500 pounds pressure.

15 MR. DENTON: Now in terms of feed and bleed 16 capability, I would rate these the highest. Here you don't l

17 need to rely on the PORV. You don't need the PORVs, you can 18 pump water right through against safety valves and have 19 sufficient relieving capacity to keep the core cooled under 20 all conditions just by the amount of water you are pumping 21 through the core.

22 So I guess if you were looking at feed and bleed 23 capability this would be the top group, because very little 24 else has to function.

25 CHAIRMAN PALLADINO: When you open those valves and

17 1 reduce. the pressure, can you crocto bubblos in tho prossuro 2 vessel or elsewhere in the system?

3 MR. SHERON: Yes. Eventually -- it depends on when 4 you are depressurizing from what condition. But once you 5 depressurize to the point ahere the hottest fluid in the 6 system reaches the saturation temperature -- or the pressure, 7 I'm sorry, drops down such that it is at the saturation 8 temperature, then the hottest water in the system will begin i

9 to flash.

10 Typically, that would be in the upper head or right 11 above the core in that region, and you would start to void 12 probably in the upper head of t h'e vessel. ,

13 MR. DENTON: So I have covered the. first group here, 14 the ones that are say in the best position.

i j 15 CHAIRMAN PALLADINO: Feed and bleed is to try to I

i 16 cool the reactor. Would we get into any trouble if we have 17 too much depressurisation capacity?

l 18 MR. SHERON: Actually, the concern was raised that 19 if you remained at high pressure in a feed and bleed mode,

! 20 namely, just at 2500 pounds, and you continued to put cold l 21 water into the primary system and relieve it through the FORV, 22 what you are doing is you are cooling down the primary system 23 at high pressure and you run a thermal shock type of 24 concern. So it is actually desirable, if you are going to feed 25 and bleed, to try and get the pressure down when you are doing

18 1 it. So even though these plants have the capability to food 2 and bleed at high pressure, it would be desirable for them to 3 open the PORVs if they have them and try to get the pressure 4 .down anyway because getting the pressure down, besides 5 reducing the pressure, also allows the pumps to put more water 6 in at the lower pressure.

7 MR. DENTON: It certainly isn't the preferred way to 8 cool. The steam generator should be used if at all available, 9 but if for some reason you had neither main nor auxiliary 10 feed, then you would go to this. So this group is clearly in 11 the best position for feeding and bleeding if it is called 12 for.

13 [ Commissioner Bernthal rejoined the meeting.)

14 The next page shows the different categories, then, 15 for pumps with the HPI shutoff head below the safety relief 16 tr a l v e pressure.

17 Brian, why don't you describe those.

18 MR. SHERON: These plants, with the exception of 19 Davis-Besse, which you know has the shut-off head around 1834 20 pounds, I think, in the piggyback mode -- these are 21 Westinghouse plants -- I'm sorry. Except there is, I believe 22 -- there is a CE plant in here. You_will note there is a bunch 23 of two-loop plants in here, Point Beach, Prairie Island and-24 Ginna -- I'm sorry -- and Kewaunee. These plants would have 25 to open the PORVs and depressurize the primary system to below

i 19 l

1 approximately 1600 pounds before the HPI pumps could inject.

2 CHAIRMAN PALLADINO: All of them have to go to 1600, 3 or don't I read the heading right? It says plants with HPI 4 shut-off head approximately 1600.

5 MR. SHERON: Yes. They would have to pressurize to 6 below 1600 before these pumps could inject. -

7 CHAIRMAN PALLADINO: All of these plants?

8 MR. SHERON: Yes.

9' COMMISSIONER ASSELSTINE: Lift point for all of the 10 code safeties is about the same, what, 20 --

11 MR. SHERON: 2500.

12 COMMISSIONER ASSELSTINE: 2500?

13 MR. SHERON: Yes.

(

14 MR. DENTON: The point I was trying to make 15 yesterday and didn't do so clearly is most of these other 16 plants, with the exception of Davis-Besse, have rather large 17 PORV reliev'ing capacity and can, in fact, blow the system down 18 rather promptly to 1600. Is that a good characterization?

19 MR. SHERON: Yes. Most Westinghouse plants have 20 either two and some plants have three PORVs.

21 MR. DENTON: In those type p l a n.t s , you can get down 22 to 1600 very last. Then you can demonstrate that you can feed 23 and bleed with the HPCI Davis-Besse only has that one FORV, 24 and a relatively.small one, at that. So that is why we have 25 kind of focused in seeing if we can increase the l

i l

6 20 1 PORV-relieving capacity of Davis-Besse to make it look similar 2 to that other group of plants.

3 COMMISSIONER ASSELSTINE: Is Davis-Besse the only 4 one in that group that has that combination of the load head 5 capacity on the pumps and the limited relieving capacity?

6 MR. SHERON: Yes, that's correct.

7 MR. DENTON: There are some further plants with even 8 lower shut-off heads, so in terms of where Davis-Besse is, 9 they are not the lowest shut-off head. Why don't you drop 10 down to Group 2?

11 MR. SHERON: Okay. This group of plants are the 12 Combustion Engineering plants, and these plants have a 13 shut-off head of approximately 1300 pounds. These plants take

(

14 a lot longer to depressurize down to the safety injection 15 actuation setpoint -- I'm sorry. The shut-off head of the 16 pump, 1300 pounds. -

17 While these plants can feed and bleed, they require 18 a lot more prompt operator action to initiate it because it 19 takes so much longer to depressurize the system. In other 20 words, instead of having to go to 1600 pounds, you have to go s

21 to 1300 pounds.

22 One of the considerations is that when you 23 depressurize these plants, usually the hottest fluid in the 24 system will start to flash at around 1600 pounds. That has 25 the tendency to hold the pressure up once it starts flashing,

. 21 1 so you rocch 1600 pounds and you go on'a moro -- a slow 2 depressurization until you hit 1300 pounds.

3 So it takes longer and therefore the operators would 4 have to initiate feed and bleed rather-promptly.

5 CHAIRMAN PALLADINO: Do they have more relieving 6 capacity than, say, Davis-Besse? How do they relate to the 7 other plants except Davis-Besse in Group 1 so far as relieving 8 capability is concerned?

j 9 MR. SHERON: With the exception Palo Verde, San 10 Onofre and Waterford, all of which, as you know, don't have 11 any PORVs and therefore don't have a feed and bleed 12 capability, these plants all, I'believe, have relieving 13 capacity that would be greater than Davis-Besse.

14 COMMISSIONER ASSELSTINE: And those three Combustion 15 plants rely on the core spray?

16 MR. SHERON: No , core spray can only be 17 pressurized --

18 COMMISSIONER ASSELSTINE: Pressuriser spray.

19 MR. SHERON: Pressuriser spray can only be 20 pressurised, but it doesn't allow you to put water into the 21 system, so there is no relieving.

22 MR. DENTON: We put a great deal of faith in that 23 so-called auxiliary pressuriser spray, and incidentally, it 24 was tested at Palo Verde within the last week at 55 percent 25 power. It's a safety grade system. It's designed for single f

22 1 failures. It didn't work. So we are looking into tho generic 2 implications, 3 CHAIRMAN PALLADINO: In what way didn't it work? It 4 didn't depressurize or something didn't function?

5 MR. DENTON: Its electrically-powered pump.

6 It was one of the required tests. As they go up in power, they 7 tripped from 55 percent power, and the test was supposed to demonstrate that this sort of equipment operated. Apparently, 8

9 power never got to the pumps. The pump that powers --

10 MR. MIRAGLIA: The valves.

11 MR. DENTON: The event just happened. It's not fully 12 understood but it is an indicatihn that the system we are 13 relying on, CE plants, needs to be looked at very 14 carefully. That is a safety grade system and that didn't work 15 properly.

16 COMMISSIONER ASSELSTINE: Maybe they will revisit 17 that issue.

18 CHAIRMAN PALLADINO: I don't know whether it is 19 something fundamental, and maybe you don't, to the design or 20 whether we are just not hooked up right. Or the valves --

21 MR. DENTON: We don't know either. I understand 22 they repeated the test shortly thereafter and everything did l

l 23 work, but we are looking into what happened, and it may be the .

24 way they arranged the turbine trip. They have to simulate 25 loss of off-site power and that sort of thing.

23 1

In none of theso plants, is this the main way of 2 cooling. If you really wanted to design a plant to do feed 3 and bleed, you would put in high pressure pumps with a high 4 shut-off head. You would put in some control valves in order 5 to control the blowdown so it wouldn't be PORV either open or 6 shut.

7 We have struggled with this issue, and normally from 8 -a cost-benefit standpoint we cannot find the basis for 9 requiring either PORVs at the CE plants, because it's unlikely 10 that you lose feedwater and auxiliary feedwater to begin 11 with. It's not a dominant contributor to risk, generally.

12 COMMISSIONER ASSELSTINE: Evidently it gets back to 13 that assumption --

14 MR. DENTON: Feed and bleed is a last ditch stand to 15 protect the core if you have lost all means of removing heat 16 through the steam generator.

17 CHAIRMAN PALLADINO: You said feedwater reliability 18 is high? I don't have that feeling.

19 MR. DENTON: After TMI, we adopted this criteria to 20 try to get feedwater reliability up to 10 to the minus 4, 10 21 to the minus 5, the idea being that it is very expensive to 22 change the PORV HPI system because it is designed for one 23 purpose and you want to make it do another purpose. There is 24 a lot of effort required to do that. Let's instead work on 1

l 25 the reliability of feedwater.

l l

24 1

That is when the Staff adopted in the Standard 2 Review Plan this 10 to the minus 4, 10 to the minus 5 goal for 3 auxiliary feedwater reliability. Of course, that assumed that 4 the systems were well maintained and were tested properly and 5 would operate reliably. There is a mixture of those systems, 6 and I put on the next page the types of auxiliary fesdwater 7 systems that are out there.

8 You recall we have done several PRA studies of every 9 plant's auxiliary feedwater systam.

10 [ Slide.)

11 And we have required a number of plants to add

~

12 additional pumps in their auxiliary feedwater system to bring 13 them up.

14 CHAIRMAN PALLADINO: Let me asA a question and maybe 15 make an observation independent from exactly what we are 16 t 'a l k i n g about here. The Staff is learning a lot of things by 17 all this review, and I was wondering, had you ever thought of 18 sitting down and saying if we were designing a plant to 19 optimize its safety and without getting too complicated, what 20 would you do? I think that would be a useful exercise. But 21 that is an aside.

22 MR. DENTON: A lot of this thinking is going into l 23 that new EPRI design, which is trying to design up a safer, 24 more reliable plant of the future. These kinds of 25 considerations are the starting point there.

25 1 COMMISSIONER BERNTHAL: I think it is worth noting j i

1 2 that that is the very issue that the Advanced Reactor Policy 3 Statement intended to address. Whatever else might be said 4 about current generation plants, that the objective of this 5 agency as the guardian, if you will, of public health and 6 safety should be that the next generation have imprevements, 7 and that is the main thrust of that policy statement.

8 I had to get in my editorial here.

9 CHAIRMAN PALLADINO: I was just trying to take 10 advantage of the current Staff thinking to get it set down.

11 MR. DENTON: The point, I think, from our point of 12 view is even one pump is sufficient if it works. You know, we 13 have always required single failure, so we require two pumps.

(

14 Three pumps give you more redundancy, and we would like to go 15 for diversity, but if'a plant is really being operated poorly 16 and not maintained well, then all these concepts of redundancy 17 in operation would be kind of ineffective.

18 Let me go to the auxiliary feedwater systems because 19 that is really what we have been relying on rather than feed 20 and bleed. We always realized feed and bleed is a backup to 21 auxiliary feedwater reliability.

22 COMMISSIONER ASSELSTINE: Before we do that, I think 23 the point, Joe, you were raising and Fred was raising is one 24 that is worth capturing just for the moment. That is, if 25 there really is a consensus on the part of the Commissioners, i

. 26 1 what we want'the Staff to do with any futuro plants is to mako 2 sure as a broad matter there is a higher margin of safety in 3 those plants. I think that is a point that is well worth 4 noting because I think that concept has somehow alluded us in 5 various policy statements that the Commission has dealt with.

6. I think that is a good point worth noting.

7 MR. DENTON: It is a lot easier to deal.with in a 8 new design than, say, the diversity of all designs, and that 9 is why we have been struggling with some of the USIs for old 10 designs, because they are so varied.

11 MR. MIRAGLIA: I think, Commissioner Asselstine, the 12 very point in TMI in looking at aux feed reliability has led 13 to those kinds of changes to seek those improvements to the 14 extent possible with the designs that we had out there, 15 looking at~the stage of design that we are in.

16 COMMISSIONER BERNTHAL: I think in part what the 17 Chairman, I assume, is talking about here in my judgment was a 18 very important part of another policy statement, one which we 19 have approved, in fact, now, and that is the severe accident 20 policy statement.

21 If I understand what you are saying,. Joe, I gather 22 it is that now is the time to sit down and for the plants we 23 have already got, this diversity of plant, is sit down and do 24 what we have talked about doing and do what is in that 25 policy statement, and you guys with all the expertise you

- ~ . - - - . . . - , - ,-v..

27 1 have, put your compasses on those plants that in your judgment 2 need some special attention and need some PRA work done, s 3 perhaps, or whatever it takes.

4 If you will indulge me for a second, I am curious to 5 know about the Combustion plants, particularly.

6 Surely there has been something close to a 7 full-blown PRA now done on those plants in connection with

! 8 their seeking final design approval, I guess, or something 9 closely akin to that?

10 There has not been a PRA done on it?

11 MR..MIRAGLIA: No, sir. It is one of the things they 12 would have to commit ~ to in order to get --

13 COMMISSIONER BERNTHAL: I see. So that has not yet

(,

14 been done.

t 15 MR. MIRAOLIA: For the Combustion Engineering l

i 16 system 80 plant, that's correct, sir.

17 COMMISSIONER BERNTHAL: I was curious as to whether j 18 it picked up these -- obviously it didn't pick up that the i 19 pump failed, but if that is a single item event, it sounds 20 like there is a vulnerability there.

21 MR. DENTON
Not in a sour grapes vein, but I 22 proposed to the Commission when we reviewed Palo Verde that we 23 have them study a design for PORV, but I was not able to l

l 24 substantiate that it would really be that valuable an l 25 addition, all. things considered, because it did have a l

28 1 negative side. It also put in a valve which could stick open 2 and actually cause the reaction we were trying to prevent t

3 So a lot of study went into that, and finally the 4 Staff concluded that, on balance, considering all the 5 advantages and disadvantages of PORVs, we could not justify 6 requiring.a PORV on CE plants. But there was credit given in 7 those considerations to this auxiliary feedwater system, and I 8 think it is important to find out why it failed at Palo Verde 9 so that we can make sure that it doesn't fail again if called 10 upon in real life.

11 This time we detected it during a plant test, which 12 was what the test was intended for.

13 COMMISSIONER ZECH: I think it is very important.

14 I hope you follow it through and let us know .about that 15 particular situation at Palo Verde. I would be most 16 interested to find out how that turns out.

17 MR. DENTON: This slide, then -- I just want to 18 spend a moment, since feed and bleed is not a solution to core 19 cooling --

20 COMMISSIONER ASSELSTINE: Not the preferred one.

21 MR. DENTON: Not the preferred one. Just look at 22 the diversity of auxiliary feedwater systems which have been 23 designed.

24 Brian, why don't you give just a brief rundown on 25 these categories, and I will remind the Commission we did a l

29 1 PRA study of every plant's auxiliary foodwater system in the 2 years following TMI, and that led to improvements in many of 3 these plants.

4 MR. SHERON: The Vu-graph that you see there, I 5 think is kind of self-explanatory on summarizing the auxiliary 6 feedwater systems in the operating plants today. -

7 As. Harold said, we did an evaluation of the 8 reliability of these systems following TMI, and from this 9 list, we have identified seven plants which we are currently 10 proposing to go to CRGR and require that these plants improve 11 the reliability of their auxiliary feedwater systems. These

-. I 12 are Prairie Island-1 and 2, Arkansas Unit 1, Arkansas Unit 2, 13 Fort Calhoun, Crystal River-3, and Rancho Seco.

14 We are not proposing at this' time that any definite 15 hardware be added to these plants. We are not trying to 16 backfit new pumps or anything of the like. What we are trying 17 to backfit is the reliability criteria. We are saying that 18 these plants should meet the reliability criteria set forth in the Standard Review Plan, Chapter 10, which is a 10 to the -4, i 19 i 20 10 to the -5 reliability.

21 COMMISSIONER ASSELSTINE: Which category do those 22 plants fall in, the ones that you just mentioned, in this 23 list?

24 MR. MIRAGLIA: I think it's both,. Commissioner 25 Asselstine. What it shows is for 50 plants, that's the kind 1

_ _ - - ._ _ , _ . - . . . __ ---_..._r.- - . . . - _ . -

l

  • 30 i 1 of configurations you see, and what you soo aro the oxcoptions 2 to that general configuration of two motor, one steam, or one 3 each.

4 COMMISSIONER ASSELSTINE: Some of these that you 5 mentioned might well have two motor-driven pumps and a 6 steam-driven pump, but you're not satisfied with the 7 reliability of the system.

8 MR. SHERON: That's correct.

9 MR. MIRAGLIA: That's correct.

10 COMMISSIONER ASSELSTINE: Ginna looks terrific, four 11 motor-driven pumps and a steam. Are those all full

~

12 capacities?

13 MR. SHERON: I don't know.

,' '(

14 MR. DENTON: From a designer standpoint ideally, as i

15 we have talked about before, you would want diversity, you 16 would want both. Electric. pumps are more reliable for 17 steam-driven pumps, but for station blackouts you'd want 18 steam-driven.

19 Jim, you might want to mention your look at the 20 Turkey Point steam side recently as another example where you 21 think a plant has highly reliable systems. Then when you look 22 into some details, you begin to wonder about its maintenance.

23 I know this isn't the planned Davis-Besse 24 presentation, but I though I would use it to answer the broad 25 question of feedwater, feed and bleed, auxiliary, because it's

' 31 1 biggor than a Davis-Bosso issuo.

2 COMMISSIONER ASSELSTINE: That Turkey Point 3 configuration is a strange bird.

4 CLaughter.]

5 MR. TAYLOR: We just exited at Turkey Point last 6 Friday. I went down last Thursday. We had a group of people 7 in there. What I did is, I combined people really learning 8 from Davis-Besse. I was concerned that some of the messages 9 out of Davis-Besse went beyond what we frequently call pure 10 maintenance to engineering and test and system actions. So I 11 put together a group.

12 The team leader is h e r'e , Mr. Joe Callan.

13 And what I did is, I took two systems engineer

(

\

14 consultants, electrical and mechanical, that I had confidence 4

15 in, put several PAT people with them and several Regional 16 people from Region II, and we spent essentially the better 17 part of two weeks at Turkey Point reviewing the auxiliary 18 feedwater system.

19 The inspection report is not finished yet, but we 20 have a number of issues of unrecognized casualty conditions 21 that the team was able to develop, and where both the training i

a 22 and procedures were not in place for various casualties 4

23 affecting the auxiliary feedwater system that could occur, and 24 we did find a situation that is a system that has many 25 air-operated valves in it, using -- and I think even ACRS has

32 1 been into that -- using instrumont or sorvico typo cir, which 2 they back up with a safety grade nitrogen -- pressurised 3 nitrogen system.

4 One of the teams -- the team looked at that nitrogen 5 system in detail, and the design people did a quick 6 calculation on the capacity of that system and the ability to 7 operate in automatic when you lost the air system. And our 8 design people said, " Gee, the numbers that the operators have j 9 are off by a factor of two'or four from the way that system 10 would really behave."

11 1 The system had never been tested, completely 12 tested. They ran statse tests on it. At our request, Florida l

j 13 Power & Light did a test, and the calculated predictions by

.e k our design engineers were that the system would sustain --

14 15 that is, the nitrogen system would sustain the auxiliary 16 feedwater system for roughly about five minutes, and the 17 company was using numbers between ten and twenty minutes. In 18 reality, it became about six minutes.

19 For other unanalysed conditions in that system, at 20 my request, the company did two things over the weekend. They 21 put in effect certain procedures to both recognise the 22 casualties that could occur -- that's a shared system for 23 Units 3 and 4 -- and they also conducted training over the 24 weekend. That led me to believe, at least, their immediate 25 remedial actions were sufficient, that we should not take

33 1 sterner action at that timo.

2 But the maintenance. situation in the air system was 3 not good. The steam system, the steam supply to the auxiliary 4 feedwater system leaks by all the valves, such that.they have 5 had to sustain drains open constantly to drain the condensate 6 of the auxiliary feedwater system.

7 One of the reasons we are worried about that is, if 8 you get slugs of water -- it takes quite a bit; Davis-Besse 9 did -- you can trip the turbines on the aux feed system. With 10 the drain conditions, they had tested and the pumps did 11 respond, but it is of concern that they have got so many-12 maintenance difficulties.

13 I have the team leader. I didn't intend to get into.

(

~ 14 all of the details of that inspection, because we have not 15 finished even the report yet. But I think we have an 16 inspection process that will help us.

17 And by the way, we went to Turkey Point at the 16 request and suggestion of the Regional Administrator down 19 there, because there has been a' continuing issue about 20 maintenance and system type problems.

21 COMMISSIONER ASSELSTINE: Wasn't there a loss of 22 that system a couple of years ago, I think due to valve 23 configuration?

24 MR. TAYLOR: Does anybody here know? I don't know.

25 Joe? This is Mr. Joe Callan. Joe, would you like

34 1 to come up and answer that question?

l 2 CHAIRMAN PALLADINO: I wonder if we should get'more 3 deeply into that. I think we will be diverted.

4 MR. TAYLOR: I don't mean to divert.

5 Joe, can you answer the question.

6 MR. CALLAN: Recently in July, the end of Guly, they 7 had overspeed problems on the auxiliary feedwater pumps. They 8 also had failures of their flow control valves, those 9 air-operated valves. A number of years ago -- the exact .

10 number escapes me -- they had valve lineup problems, .that with 11 manual valves shut, that disabled the entire _ system of both 12 units.

13 CHAIRMAN PALLADINO: That's the one I was thinking 14 about.

15 MR. CALLAN: About three years ago.

16 COMMISSIONER ASSELSTINE: It's such a Rube Goldberg 17 type of system.

18 MR. CALLAN: It's a very strange system.

19 MR. DENTON: I think I achieved my purpose in 20 raising the whole issue of auxiliary feedwater systems and 21 feed and bleed. We've had a great deal of activity in this 22 area for years, trying to raise everyone up to the right 23 level And I will just observe that we would probably be more 24- effective if we didn't put any more effort into the 25 Davis-Besse review and we went out and reviewed some other

35 1 plant, because we have now gotten Davis-Besse's attention to 2 the need for a reliable auxiliary feedwater system. But there 3 are a lot of other plants out there that we have never looked 4 at that hard.

5 CHAIRMAN PALLADINO: They sort of get added to that 6 list of five for different reasons.

7 COMMISSIONER ASSELSTINE: I would just add, Joe -- I 8 don't want to belabor the point -- on Turkey Point, I think 9 the Staff is to be commended on doing the type of special 10 inspection that they did. I think both Nelson and Jim, you 11 put that kind of effort on it, and I think that's really 12 good.

13 And I think Harold's right. The key is to begin to 14 look for some others where you have these kinds of 15 vulnerabilities that somehow have escaped the system in the 16 past and where operating experience is telling us that the 17 reliability 's i not what it has to be for those systems.

18 MR. DENTON: These systems are not called upon to 19 operate very often, and they are not the normal, 20 well-maintained system as a system that's continually 21 operating.

22 COMMISSIONER ASSELSTINE: As you say, that's the 23 system you are really relying upon in this kind of situation, 4

24 and the backups aren't nearly so good.

25 MR. DENTON: I think originally in the designer's

36 1 mind you rely on main foodwater. Very rarely would you have 2 to go to auxiliary feedwater.

3 Let's come back to the planned briefing. Frank, why 4 don't you pick it up at the second bullet.

5 MR. MIRAGLIA: Slide 9.

6 CHAIRMAN PALLADINO: We're back on --

7 MR. MIRAGLIA: On the Davis-Besse handout from 8 yesterday, Mr. Chairman, starting with the slide that reads, 9 "Other NRC Restart Considerations."

10 [ Slide.]

i 1

11 The initial part of the briefing essentially 12 parallels the information you heard yesterday. The utility

]

13 was sent the 50.54(f) letter and was told to deal with the k' equipment. issues identified as a result of t! e event and the 14 15 other programmatic issues stemming from the analysis of the r

16 event, and that response was received on the 12th of September 17 and is undergoing Staff review.

18 This chart here is to indicate some of the other 19 activities that the Staff has underway with respect to the 20 Davis-Besse restart.

21 Mr. Denton has already discussed the first bullet.

22 There is a briefing of the ACRS in October, the subcommittee.

f 23 They have tentatively scheduled a meeting at the site or the 1

4 24 site vicinity for early October, I believe the 4th of October..

In addition, the Staff is looking at the utility's 25

,_ _ . _ _ _ . . _ - y _ . . . , , _ _ , - . _ _ _. , ,,-__my ... - - - -

37 l

1 response to determine and fully agree with and assess the 2 actions that need to be completed prior to startup and what we 3 might want to see subsequent to startup.

4 A number of special investigations and inspections 5 have been underway, conducted out of Region III, Mr. Keppler's 6 office, following the troubleshooting and corrective action 7 programs that the utility has in effect to assure that they 8 were done according to the protocols that were agreed upon 9 when the special investigation team was sent to Davis-Besse.

10 In addition, the NRR and the Region are conducting a 11 special maintenance assessment at the facility. There is a I 12 team at the site this week. This is a pilot program that we 13 had started to go out, and based upon Regional input, look at

( 14 plants that we thought had relatively good maintenance 15 programs, get some assessment as to what the performance l

J 16 indicators were, to get a feel for that.

17 We have done one or two of those, and we thought it 18 would be useful, based on those kinds of things, to go in and 19 look at Davis-Besse, since we talked about maintenance being a 20 problem, do an assessment there, get a report from the team as 21 to what they see the issues with respect to the maintenance 22 program being, and that team is there next week.

23 A training accreditation site review is scheduled

24 for next week at Davis-Besse. This is the normal type of 25 review, which was scheduled even prior to the event. It is

38 1 not a special activity. It was occurring before the evont, 2 and we also expect to look at the results of that review and 3 consider that.

4 CHAIRMAN PALLADINO: Is that the INFO accreditation 5 training?

6 MR. MIRAGLIA: I think this is our assessment of 7 where they are with INPO, what have they provided INPO, and 8 its our look.at that kind of accreditation.

9 CHAIRMAN PALLADINO: It is related to INPOS 10 MR. MIRAGLIA: Yes.

11 COMMISSIONER ASSELSTINE: I gathat the Staff had 12 picked a few plants to go out and look at.

13 MR. MIRAGLIA: This one was already scheduled. The 14 Licensee also, as they indicated yesterday, had agreed to a 15 performance improvement program in concert with Region III 16 last year, and has relooked and reexamined that. And we are 17 also going to evaluate his response to implementing those 18 concerns. As he indicated yesterday, he is aggressively 19 trying to close out many of those issues.

20 In addition, we are going to evaluate the changes to 21 the operating procedures that have been made. A new 22 philosophy was outlined to you yesterday by the utility. I 23 think there is some evidence that that philosophy is being put 24 into place, and we're going to continue to watch and see that 25 progress.

_ . -- ... - . . .. . -~ . _ . - ~ - - . - . _- ._- - _ . _ . . . - _ . . _ _

39 l

)

I 1 CHAIRMAN PALLADINO: What was the philosophy?  !

2 MR. MIRAGLIA: As the utility indicated to you ,

h 3 yesterday, i t i s, " Safety First, and Enhance Performance," and 4 I think that is going to result in lots of changes in >

i 5 operating procedures, some of which may not be related to this 6 event at all. But I think we're going to be interested in

  • I 7 seeing how that program gets implemented and follow through on

) 8 it. r i

9 COMMISSIONER ASSELSTINE: Frank, in terms of the j

i  !

1 j

10 improvement program, this improvement program was started, ! 3 f 11 guess over a year before or about a year before the June 9th i -

j 12 event and had been underway for some time. I gather from what

! 13 the company had said yesterday, that they are-still pretty i(~

14 satisfied that that improvement program addresses the right I

i 15 things and represents the right way to go, with some ,

i e

? 16 modifications, and there have been a lot of interim measures.

! 17 It sounds like mostly reorganizing people, bringing in some 18 new people, and beefing up their efforts in some areas, 19 How is the Staff going to go about satisfying i 20 itself, and what are you going to be able to tell us to l i

t i 21 satisfy us about the overall adequacy of the improvement 22 program?

23 Again, as we go back to these improvement programs, I 24 they all look good on paper, they all sound pretty good, but {

I l

25 how are we going to have confidence that, yes, in fact, that l

i

. - - ,ww mmne-,,- e - - , ., - - - - - ,--m --r .,-- - - , - - - -m - - 7

40 1 program really needs --

2 MR. DENTON: I think Jim Keppler is listening in, 3 and since he started the improvement program, maybe he would i

4 like to respond to that first. ,

5 Jim, are you with us?

6 MR. KEPPLER: Can you hear me? Yes. -

7 COMMISSIONER ASSELSTINE: Barely. It could be a t

8 little louder.

9 MR. KEPPLER: Can you hear me now?

10 COMMISSIONER ASSELSTINE: Yes.

11 CHAIRMAN PALLADINO: Yes.

4 12 MR. KEPPLER: The commont I would make on that is 1

1 c

< 13 that the program was always viewed as being pretty good on i

k i 14 paper, but in terms of implementing the program, it fell f

i 15 short. We conducted a review with the consultant on the 16 program, and he does consider the program to be basically i 17 sound, but he'had felt that they need to prioritise certain 18 things, so that the accomplishments can be recognized. And I 19 think that's what we're going to have to do, to follow it 20 through to see that the program is actually being implemented, 21 and that's where we're going to put our efforts.

22 COMMISSIONER ZECH: That was my itapr e s s i on when i 23 visited out there not to long ago, too, that the program was a 24 fine plan, and there was a lot of emphasis on the planning, 25 but there wasn't as much emphasis on execution. And so 1

. 41 1 think that's oxactly what is hopponing now. And as I 2 understand it, that's what Joe Williams and the new management 3 team is intending to focus on, is execution as well as the 4 planning, and I'think that's the right approach.

5 CHAIRMAN PALLADINO: Jim, I think we heard you. We 6 just didn't acknowledge that we had heard you.

7 MR. DENTON: We are somewhat behind schedule in this 8 briefing. The next point, though, is one that deserves a r

9 little bit of mention. This is the testing of systems and 10 equipment and the need to review the startup test program, and 11 this is something that I&E and the Region and NRR are all 12 working closely together on.  !'think this one area is going 13 to take a lot of our attention, to be sure that all of the

( 14 equipment which either failed or was modified has been 15 properly restored to service and that they have done the right 16 tests, so that when the p l an t restarts, we can be sure that 17 all of the safety systems will perform in all the modes in 18 which they might be called upon, 19 I think testing is the key area. The company has 20 not fully developed the type of test that is going to be 21 done. We have not reviewed it. But I think there is 22 agreement between the company and us as to the objective, and 23 that is.to make sure that all safety systems will perform 24 under all conditions under which they might be called upon.

25 Implementing that and carrying out those reviews and

42 1 inspections is going to be a big effort for the Staff.

2 MR. TAYLOR: Some of the testing will probably have 3 to be done after they return to some power level, too. I 4 wouldn't be surprised.

5 COMMISSIONER ASSELSTINE: Would that mean actually 6 doing tests for every configuration of the plant for which the 7 safety analyses have depended?

8 MR. MIRAGLIA: With respect to that issue, 9 Mr. Asselstine, when Mr. Denton and Mr. Keppler and I were at 10 the site last week, we said that that should be the operating 11 philosophy or the objective of such a test program. We 12 recognise that whether we can get them all may not be 13 possible, but to the extent that they can be done, and if they i

14 can't be done, what can we do to get some confidence, because 15 some tests you just may not want to put the challenges within 16 the system. But as an overall objective, that should be the 17 goal of such a test program, and they have indicated that that 18 was their intent. That's why they're doing these systems 19 reviews, to try to pick out those things and what additional i

20 tests are really needed to identify those.

i

! 21 MR. DENTON: They have submitted quite a bit of

! 22 information on testing, but the actual tests to be performed, 23 1 don't think will be developed by the company until the end 24 of this month. So about that time, then, we can start looking 25 in detail at what are they actually going to be able to do.

l l

l

43 1 COMMISSIONER ASSELSTINE: Do you hevo a fool for how 2 many tests you are talking about, how many different system 3 configurations?

4 MR. MIRAOLIA: No, we don't. We got the briefing 5 yesterday about the five groupings, the groupings of systems 6 that they are looking at, and those systems reviews are 7 underway, 'and they are scheduled to be completed towards the 8 end of this month.

9 We hope to start interacting with the utility as 10 they feel th'ey are complete enough on the first system, so we 11 can get an idea of, how are they going about that, what is the 12 scope of the testing for these systems, and interact as early 13 as possible with them.

(' 14 COMMISSIONER ASSELSTINE: They can start with the.

l 15 primary system?

1 16 MR. MIRAGLIA: I'm not sure which system is first.

17. MR. DENTON: The last item on this slide was 18 enforcement considerations. We didn't really want to talk 19 about that today. We'll just flag it.

20 CHAIRMAN PALLADINO: Have we identified the 21 violations?

22 MR. TAYLOR: Our headquarters staff is working with 23 the Region, and we're laboring --

24 CHAIRMAN PALLADINO: With the what?

25 MR. TAYLOR: With the Region, with Region III

44 1 We're working on it.

2 MR. DENTON: In view of the time, Mr. Chairman, we 3 could go on in more detail, but I tried to give the impression 4 we're following'up on these items, or we could go to the five 5 plants. It's your choice as to how we spend the remaining 6 time this morning.

7 CHAIRMAN PALLADINO: I think it might be valuable to 8 go to the five plants unless there are specific points of ,

9 interest.

4 10 COMMISSIONER ASSELSTINE: It might be good to go 11 ahead.

12 COMMISSIONER ZECH: That would be good, o

13 CHAIRMAN PALLADINO: All right. You might dwell for

! 14 a moment on the significance of the five plants compared to 15 statements I remember reading in some of the documentation, 16 that while these plants are plants that have a lot of things 17 that need attention, they are not necessarily the plants that 18 have the most significant safety issues, or words to that 19 effect, let me say, most significant problems, i.

20 MR. DENTON: That's true,

(

i 21 CHAIRMAN PALLADINO: So putting that in context 22 would be helpful to me because, you know, you form an i 23 impression "There are five plants, well, we will fix them i

) 24 up." But really, we have some other plants we ought to be l 25 giving attention to as well.

r l

I 45 1 MR. DENTON: I think our intont in idontifying thoso l

~2 five has not been fully understood the way we intended it. A 3 few days after Davis Besse we asked ourselves, "Well, what are ]

4 the long-lingering issues that are frustrating the project 5 managers?" We didn't ask them which were the five most safe 6 or the five least safe plants, but I was trying to identify 7 long-lingering frustrating issues.

8 We sent out a questionnaire to all the NRR project 9 managers and got back their responses. And if you look at the 10 five, you will find there are really two classes of these 11 plants. Browns Ferry, Fort St. Vrain, and Rancho Seco are 12 management-related issues. They are the kind of issues you 13 have been hearing from the regional administrator about, and

( "

14 us, where the management is not giving adequate attention or 15 resources, in our view. -

16 That's quite different from the Davis Besse 17 third-pump issue, which was a lot of back-and-forth on the PRA-18 studies. If you look at the Palisades issue, that's an issue 19 where the company had committed to put a valve in and then had 20 analyses where they felt justified taking it out. So that's 21 more of an NRR sort of design issue.

22 Likewise, San Onofre is not presenting us any 23 problems from a management standpoint. We're.quite satisfied 24 with the way San Onofre 1 is being managed and operated.

25 But there are a lot of items that had been deferred

46 1 at that plant. The fact when they shut down, they woro not 2 clearly going tc resume operation. They have now committed to 3 put most of those in during this outage, and that should make 4 that one go away.

5 So these are not at all what I felt the five least 6 safe plants or the plants we expect problems with in the.

7 future, but they were the ones which for some reason or other 8 there was a long issue of frustrating the PM.

9  !.have the PMs down here today, and I would propose 10 to walk through each plant very briefly, and if you have some 11 questions about some aspect, then we can have someone clarify.

~

12 Browns Ferry, I think we've said enough about the 13 last couple of days, and I wouldn't do any more. We did send

' - 14 out the letter to Chairman Dean this week from Bill Dircks 15 that gave to him our view of the SALP performance. And I 16 think we discussed that with the Commission just a day or two 17 ago.

18 MR. MIRAGLIA: You might point out, Harold, these 19 plants were identified in response to the Chairman's request

> 20 back in August, and we have provided a monthly update and sent 21 it down to the Commission, dated yesterday.

22 MR. DENTON: Fort St. Vrain is the plant where I 23 sent them a letter over a year ago that identified essentially 24 the same list of s issues. And they have been -- at that time, 25 the main issue that led to the shutdown was the failure in the

.s

  • ' 'y a

\.

47

. l 1 control rod drive system, which was the final straw for tho l 2 staff.

3 (Slide.)

4 Many of these issues have still not gotten resolved 5 and were identified by the PM because they had been 6 outstanding and lingering for a long time, and management 7 seems to have difficulty putting these issues to bed.

8 CHAIRMAN PALLADINO: You call that the management 9 problem plant?

10 MR. DENTON: Yes.

11 COMMISSIONER ASSELSTINE: It has been for years, 12 really.

4 13 MR. DENTON: It's a small plant, a small company 14 that operates it. We've had several meetings in Bethesda with 15 the management, who is committed, they say, to bringing it up 16 to modern-day reactor standards. But when it was built, they

17 didn't really see it as having necessarily to meet the kinds 18 of requirements that we expect today.

19 COMMISSIONER ASSELSTINE: How old about? Was it a 20 year and a half or two years ago? Authority for Fort 21 St. Vrain was transferred to Region IV, and the idea was that 22 we would have a small group of people there that could really 23 give this plant attention. They could concentrate their 24 efforts on it. It would be a lot closer. It could be more

?S responsive to the utility but at the same time could be more l

48 i

i .

i aggressive from our standpoint in making sure that kind of 2 changes that'needed to be made there would get done.

3 Has that process not worked very well?

4 MR. DENTON: We've decided, I think, the regional 5 administrator and I, to return the project management to l

6 headquarters for a variety of reasons. The regional i  !

7 administrator has his hands full with other types of' plants,

8 as it turns out, with the Waterfords and Wolf Creeks and j 9 Comanche Peaks, and has not been able to give it undivided 9

l 10 attention. Plus, these kinds of issues require a large i 11 technical staff and unique skills to deal with it.

12 So.a lot of progress was made in getting cmendments 13 issued at one time, but i t just seems that these issues are 14 still lingering. But we do have a commitment from the upper 15 management of Fort St. Vrain to not let them linger, not 16 much longer. So we have schedules, and they have a 17 performance enhancement program such as Davis Besse had, with 18 operating tech specs. And they've requested our approval now f 19 for low-power operation in order to dry out the core again.

1 l

20 It is a unique plant -- it's not a light-water plant l

i 21 -- i n that it has different safety features, very slow to 4 22 respond to system upsets, and doesn't heat up very fast, So 4

j 23 we tried to take all this into account. But nonetheless, I

' 24 think they operated for a long thinking there were just a lot ,

l 25 of requirements that they just didn't have to meet. And we f I

s

,w -,.y g-, ,, -.

--., - _ - ,,, ,y .,-e ,-. <-. - . - , , , , , , - . --g- --..w.- e,, - - - , , , . . . , . . . _ . . - . - .

49 1 felt different.

2 COMMISSIONER BERNTHAL; Is it really certain 1n your 3 mind that there is a reasonable position being taken by us as 4 an agency, by you as the technical people that have to 5 evaluate their problems out there? I have to confess that I 6 have been to Fort St. Vrain twice, once out of curiosity when 7 I worked in another place and was a supporter, and still am, 8 of that concept; a second time as a regulator. And neither 9 time have I been particularly impressed by the management.

10 But aside from that, it is a very forgiving plant 11 design, and one wonders whether that buys you quite a bit or a 12 little bit or -- I grant you that we all have our justified 13 prejudices on how a plant ought to look and how the management

~'

14 ought to be responding. But it's somewhat more important when 15 you are driving a Ferrari than when you are driving a golf 16 cart, I guess.

17 (Laughter.)

18 COMMISSIONER ASSELSTINE: You don't want the wheels I

19 to fall off.

20 (Laughter.)

21 MR. DENTON: We have wrestled with that. We have 22 retained Los Alamos as our technical consultant, who knows 23 quite a bit about that. )

24 Let me ask Ed Butcher, who I think is our branch 25 chief for this group. We did that apecial inspection about a

l 50 1 year ago and found a lot of things that woro botherscm3 to us, I

2 and that did lead to a plant shutdown.

3 COMMISSIONER ASSELSTINE: I think Victor had gone 4 out there just before that, hadn't he, and found just a lot of 5 things that were troublesome?

6 MR. DENTON: What this illustrates, I think, if you 7 get into a plant that is management-related, we don't have a 8 lot of criteria as we do for hardware in our rules and GDCs, 9 and it's very hard. The regulatory tools that we have for i

10 a plant where we think that management attention isn't being 11 given are pretty bleak. It's either: suspend the authority 12 to operate, or not. We're not u'r g i n g the company to give it

.- 13 more management attention to fix these problems, but we can't a

^

14 point to a detailed Part 20 and say, "Do this thing and 15 everything will be all right."

16 COMMISSIONER BERNTHAL: I guess I am really asking 17 how good is your baseline here? We are used to operating 18 wtihin a certain framework, I think, of a broad understanding 19 of what PRA and your vast engineering experience and the years 20 since Three Mile Island have taught you in terms of technical 21 requirements and acceptability of the. light-water systems.

22 But this is a very different plant, very different 23 design, and I guess I would appreciate knowing whether you 24 think you have that kind of baseline understanding and 25 confidence and knowledge based, in part, perhaps on a PRA.

51 1 I cort of doubt that you havo that so that you 2 really know what the appropriate stance of the regulator is in 3 the case of an HTGR, given the forgiving nature of the 4 design. Or are we applying to that plant standards that are 5 more approrpiately applied to the LWR?

6 MR. DENTON: Our staff have asked that kind of 7 question. Let me ask Ed, since he's responsible for Fort 8 St. Vrain and deals with it day-to-day, to answer that.

9 MR. BUTCHER: I think Commissioner Bernthal is going 10 right to the heart of the problem for regulating a plant like 11 Fort St. Vrain. We struggle with that issue every day, There 12 are some unique design characteristics of the plant which tend 13 to temper our application of the regulations, and sometimes

(,

14 it's very difficult to make an interpret.ition of the 15 regulations which fit the unique characteristics of Fort I

16 St. Vrain. -

17 But if I might use your Ferrari-and-golf-cart 18 analogy -- and I believe it was Commissioner Asselstine that i 19 said, "The wheels must stay on both, regardless," and there 20 are certain fundamental requirements -- and equipment 21 qualification is a good example -- which received very little 22 attention at Fort St. Vrain untti very recently.

23 Regardless of how much time you have to deal with 24 the accident, there is certain equipment which must survive j ,

25 the initial severe environment. And to that extent, the l

l

  • 52 1 oquipmont qualification rogulations aro just as applicablo to 4

2 Fort St. Vrain as they are to any other reactor.

3 COMMISSIONER BERNTHAL: Providing that the 4 probability of having those severe conditions is in the same 5 ballpark as the probability of having similar severe 6 conditions in LWRs.

7 MR. BUTCHER: To some extent, the probability of 8 certain pipe breaks is higher at Fort St. Vrain than it is at l 9 other plants because of higher operating temperatures and 10 pressures.

11 There are characteristics of the plant which make 12 it safer; there are characterist~ics of the plant which make it 13 necessary for you to direct additional attention to it

(,

14 There are assumptions about operator action which 15 are very important at Fort St. Vrain. You can make ,

16 assumptions that nothing happens for, say, 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> in the 17 case of loss of forced circulation. However, in the case of a 18 break in one of the main steam lines, operator action is 19 necessary within four minutes to make that a tolerable 20 situation, given certain assumptions about failures of 21 equipment when there is doubt about its qualification.

22 So you can see that things happen awful fast in an 23 HOTR, and they happen awful slow. So it's the unique 24 characteristics of the plant, in fact, that the regulations 25 were not written to accommodate those characteristics which

  • 53 1 mako it difficult for both tho staff and the licensoo to deal 2 with it.

3 However, I must say at this point my own experience 4 indicates that the licensee has not regarded this plant as a 5 power reactor in the sense that the reactor regulations 6 apply to a power reactor.

7 There has been a certain tendency on the part of 8 both the licensee and the staff to regard it as a 9 developmental research type of facility and attempt to 10 regulate it in that manner. It seems to me that for the 11 future we have to regard this plant as a power reactor, giving 12 special considerations to its unique design characteristics, 13 and regulate it in that manner.

J' 14 COMMISSIONER ASSELSTINE: In fact, I thought the 15 effort over the past couple of years to grant some license 16 amendments was to give them some leeway in those areas where 17 they could demonstrate the characteristics of the plant were 18 different from the light-water reactors that had led to our 19 basis for regulations.

20 I guess my concern goes more to just the broader l

21 question of the quality of operation and the quality of 22 management attention, quality of day-to-day operations at the

, \

23 plant. I am not sure that, at least when you get to that 1 4

24 point, that you can grant major exceptions and say we're 25 prepared to accept a much lower level of performance across I

l

54 1 the board simply becauno this is an HTOR as opposod to a 2 light-water reactor.

3 CHAIRMAN PALLADINO: Do we see any progress in terms 4 of management attention, the progress that gives you a greater 5 degree of confidence in the resolution of some of these 6 problems?

7 MR. DENTON: The last time I met with them, we did 8 get this assurance they were going to commit the resources and 9 management attention to it. It is a small plant, so it 10 doesn't earn a lot of money. In fact, it probably loses 11 money.

12 But let me ask Ed if hie sees -- what sort of 13 progress he is seeing, since it is his group that identified t'

14 it.

15 MR. BUTCHER: I would have-to say, particularly in 16 the last six months, that I have seen wha *. I would consider- an 17 improvement in the management situation, management's 18 recognition of the importance of treating this reactor like a 19 power reactor. They made commitments to substantially 20 increase their staff. I don't remember the exact numbers, but 21 in the order of 60 to 70 additional personnel which they are 22 bringing on to the plant.

23 I have made tours through the plant, and I have seen ,

24 a marked improvement in housekeepign and what appears to be an 25 improvement in maintenance. It is a very nice-looking plant

' 55 1 now in that regard, and it has boon cleanod up.

2 The staff, the morale of the staff is good at the 3 site now, and there seems to be a genuine recogition of the 4 fact that there needs to be greater attention laid to 5 regulatory compliance and t' h e kinds of things we do for power 6 reactors in general.

7 MR. TAYLOR: I would echo that, I think, for the 8 Region, speaking for Bob Martin, who is gone. I was at the 9 last SALP out there. Very definitely, I would echo that.

10 COMMISSIONER BERNTHAL: I am pleased to hear that 11 because I think it's important that that plant be a bit of a 12 showcase, if possible. I don't'like to have to rely on the 13 feeling like I had somewhat in the past that it must be safe.

14 I won't say any more than that.

15 CHAIRMAN PALLADINO: I grant you the plant is small 16 and they're probably not earning any money for the company.

17 They do have people assigned to them. There is plant i,

18 management, and the plant management ought to shape up or ship 19 out. I know that sometimes it's a question of resources, and 20 that's where the upper management perhaps fits more into this 21 situation. But I am glad _to hear that you are seeing some 22 progress.

23 MR. DENTON: The next plant, I think, is on the list 24 mainly for management-related issues. Also, you know, Jack

'5 Martin has had many, many meetings with the Rancho Seco l

- 56 1 utility and tho board of directors, and thoro has boon a lot 2 of studies.

3 (Slide.)

4 We just had, I guess, a SALP meeting with the 5 licensee, and Jack told me yesterday that he is now of the 6 view that when these latest commitments are met, he is willing 7 to let the plant resume.

8 We don't have an order shutting the plant down. I 9 understand the plant would be expected 'o t resume operation 10 early in October, and in Jack's view, that is fine. So it's a 11 management issue. It has gotten a lot of attention by Jack.

12 CHAIRMAN PALLADINO: What are the things that are 13 going to be done before they start up, or the significant 14 ones?

15 MR. DENTON: These are ones that exist in the Region 16 V confirmation. Let me ask Sid Minor who was out there 17 recently, maybe to hit the highlights of a few of the major 18 items.

19 MR. MINOR: There were a number of mechanical 20 problems that they had found because of lack of supports and 21 then went on an extensive support program. That has all been 22 fixed.

23 CHAIRMAN PALLADINO: What was it?

24 MR. MINOR: They had an unisolable leak in the high 25 point vents. They discovered it was due to a lack of supports

57 1 in tho system.

2 They extended that to look at a little over 2000 3 additional items in other systems. And that has all been 4 finished.

5 The main thing right now that they have to complete 6 is something that is a result of an INPO inspection that had 7 to do with some training, some additional training of their ,

8 nonlicensed operators; some procedural stuff to get their i

9 supervisory people more in the plant to astuae that they a .r e 10 making sure that the people sie adhering to. procedures.

11 And the third thing that came up was, some 12 maintenance activities were going on without notifying the 13 control room. The control room didn't know it was going on.

(_ 14 they are correcting that item.

15 When these things get implemented and the licensee ,

16 has assured himself that they are adequately implemented --

17 and I think they are going to do one more thing. They are 18 going to get INPO back to reevaluate these things to make 19 sure that INPO is satisfied with them, then they will start 20 up. And that is expected to be early October.

21 MR. TAYLOR: I might add that INPO I believe has P

22 been in the plant this week, and I think part of last week.

23 INPO has been out there following up on some of their issues, 24 and they may even conclude the end of this week.

! 25 The company has committed to the Regional i

l

'

  • 58.

1 Administrator to moot with him and go over the things that 2 they have taken care 'o f as further assurance that there aren't i

3 any lingering things before they start up. Startup could come in the latter part of this month as against in October. But 4

5 INPO is currently there.

l

6 So, Sid, 1 don't know whether you knew that.

l 7 COMMISSIONER ASSELSTINE: Have we seen the July 8 INFO report?

9 MR. DENTON: I suspect the region has --

10 MR. TAYLOR: 1 don't know whether the report has 1

11 caught up with everything else. Region was briefed by the l '

1

[ 12 company on all the issues that were significant. So the ties 13 have been made.

14 The company, of course, has the interface with 15 INPO. But the company came and laid out to Martin and 16 Falkenberg -- really Martin was on leave -- the issues that 17 they had agreed with INPO that they would get fixed. Probably 1

18 some of the things that Sid has mentioned.

19 COMMISSIONER ASSELSTINE: The word we had heard on 20 the INPO appraisal was that the concerns were so serious that 21 INPO said the plant should not operate. .

22 Is that accurate? Have we found out if that in fact 23 was an accurate assessment?

24 And if that is the case, I'm not aware of any other

{

25 instance in which INPO has said their concerns are so serious i

. _ _ _ _ _ _ _ _ _ _ _ _ . . _ _ , _ _ _ _ _ . _ , _ = _ __ _ . _ .

59 1 that the plant shouldn't sporato until their concerns aro 2 fixed.

3 MR. TAYLOR: INFO said that they wanted to come back l 1

4 before they ran it, and that is what they are doing.

5 1 don't know the record on that. That's the one 1

6 that I know about.

t 7 MR. DENTON: I think many of the issues have been

6 recognised; poor performance, poor QA, poor engineering, these

! 9 are ones that Jack has been working to improve for some time, i t 0

10 And this plant shut down for refueling early this year, and I i

11 know that Jack has had endless meetings on these points.

i 12 Whether INFO recognised the same points or some ,

I-J

. 13 additional ones I'm not certain, but in talking to Jack he

(' 14 thinks now that the plant is in much better shape than it was j 15 when he began his concerns.

) I l 16 COMMISSIONER ASSELSTINE: On the high point vent a

17 question, are there programmatic aspects of that?

l i .

f I 18 Why did that happen? Do we know why it happened?  ;

i 1

l

! 19 Were they not managing their design process, did 4 l

i l

I 20 their modifications work? Were they just relying on f

! 21 contractors that were operating without adequate supervision I  !

f 22 and direction?

1 t

23 What were the sort of root causes of that problem?

il 1

24 MR. DENTON: I'll just mention, you realise it is I

i 25 another small utility, public utility that has probably had i

I i

i

. __ .-. _ _ _ _ _ = -

' 60 s

1 troublo gotting a largo capablo ongincoring staff and kooping 2 them. I understand they paid rather low salaries out there 3 for a long time. And those sort of problems may be the I

4 fundamental root cause for many of these issues.

i 5 MR. TAYLOR; As I understand that event which 6 precipitated this rather extensive inspection of supports, the 7 high point vent was added as a post-TMI fix and they used 8 architect engineering support. And there were several 9 supports -- this thing actually failed of fatigue, which is i

j 10 kind of unusual 11 The support -- there was an error in the drawing 12 from the original design drawing to the field drawing. But 13 then there was a QC failure because QC did not pick up one or 14 two of the supports that were remaining, because if they just 1

) 15 had even the rudiments of support they wouldn't have had a 1

16 fatigue factor.

17 So they really ended up with a length of line that i e 18 was essentially unsupported on one side due to a combination 19 of those two, which is what precipitated the crawl back to the 20 original design drawings, back to the working drawings and the 21 QC followup on all the support areas and the changes that they 22 have made fur, I guess, the last four or five years.

(

23 COMMISSIONER ASSELSTINE: So in essence they are 1

1 24 going back a period of time --

f 25 MR. TAYLOR: Again. That's what has been taking 1

61 i sovoral months as thay followod up becauso of this brockdown.

2 COMMISSIONER ASSELSTINE: Do you have a good sense 3 for what they found in that review?

4 MR. TAYLOR: Yes. I think they found one other 5 instance where there were some strap supports for two solenoid 6 operated. valves which were the only cases in which they found 7 where loadings could come that would exceed design. But it 8 wasn't the same kind of thing where this thing was working in 9 fatigue.

10 . In all other cases, although they saw some 11 aberrations as you always do when you crawl supports, you 12 know, something not exactly in Tine, everything was well 13 within design which was the typical kind of pattern in the

(

\

14 support areas.

15 MR. DENTON: I think we may be stealing their thunder 16 for when Region V and Region IV come back.

17 Palisades, I think we have already briefed you about 18 --

19 CHAIRMAN PALLADINO: Can I ask one question on 20 Rancho Deco?

j 21 Do you foresee a near term startup date?

I

22 MR. DENTON
Yes, f

l 23 CHAIRMAN PALLADINO: like what?

24 MR. DENTON: I will refer to Jim.

25 MR. TAYLOR: As I said, INPO is wrapping up as I 1

I

l l . 62 t

i undor, stand at the ond of tho wook. Tho company is obligod to 2 gather with the region which, if the company indeed has 3 corrected the conditions, some of which got down to the 4 unlicensed watch people, then I presume the company would want 5 to come in and talk to the region in the next week.

i 6 CHAIRMAN PALLADINO: And will the region have ~ a i

7 basia, or will you have a basis for authorizing or agreeing to i

8 restart?

9 MR. TAYLOR: Right. We have a confirmatory action 10 letter which requires the company -- and they, of course, have 11 agreed -- to come in and brief' the region on all corrections, 12 and we will, of course, have our inspectors making sure -- and

13 you know that they will be aware of all the issues.

'( '

14 That is where it is. There is no real formal hold 15 other than the confirmatory action letters, which Martin has 16 put cut.

17 MR. DENTON: Basically on Palisades, during the SEP 18 program they committed to'fix the problem in the main steam 19 line in 1982. And in 1983 they proposed to defer it until a 20 PRA could be done.

21 This one is not a management sort of issue, it is a 22 design detail. They came in, they added a third auxiliary 23 feedwater pump and they went to new procedures and so forth, 24 and are trying to convince us that their commitment no longer 25 needs to be met.

i

- 63 1 I havo told tho Staff I want a decision oither up or 2 down on that by the end of the year, and we will meet that.

3 CHAIRMAN PALLADINO: Up or down on which?

4 MR. DENTON: That we will either require them to fix 5 it as they originally committed, or we will agree it doesn't 6 need to be fixed. But it is one of these issues that my 7 survey was intended to flush out, where it has been a long, 8 lingering issue back and forth.

9 After we originally had a commitment to get it 10 fixed, they keep bringing forth arguments. And we want to be

11 always open to new information, and so we keep postponing our 12 decision saying, yes, we will wait until you do that.

13 The next two issues were generic issues.

(%

~

14 Containment purge and vent.

15 (Slide) 16 This goes back to an abnormal occurrence in 1978, I 17 believe, where we found problems in containment purge valves

! 18 being able to close under design basis accident conditions, f

19 We started a program to be sure that everyone would maintain 20 containment integrity. We are down to just a handful of 21 plants left.

22 Let me ask the project manager, who has a duty 23 following this action, to summarize briefly for you the table.

24 CHAIRMAN PALLADINO: These are. big valves?

l 25 MR. DENTON: Yes. )

l

  • 64 1 CHAIRMAN PALLADINO: 60 inchos?

2 )UL . DENTON: I think we have worked through the big 3 valves and have now satisfied ourselves -- I knsw item 1, for 4 example, which is the Dresden 2, 3, Quad Cities valves are 18 5 inches.

6 CHAIRMAN PALLADINO: Where are you looking at item 7 1?

8 MR. DENTON: Containment purge and vent.

9 CHAIRMAN PALLADINO: Is that something we have got?

10 MR. DENTON: It is at the back of the individual 11 plants.

12 Ed. do you want to jus't summarise what is on that 13 table, or where we stand?

14 MR. REEVES: This table indicates the last elements 15 of this longstanding issue that started in November of 1978.

16 The Staff has essentially got all of this complete. There is 17 only one valve, one Licensee with a valve that has not been 18 proven to -- reviewed by the Licensee and analyzed by our 19 staff, but still has questions. And that is the Quad Cities 20 and Dresden plants.

21 I understand as of yesterday they have done a 22 . reanalysis on our last questions back to them and with our 23 added conservatisms they are indicating to us that these 24 18-inch valves will stand a LOCA consideration, and we feel 25 that by December we will be able to write off on that issue.

' 65 1 CHAIRMAN PALLADINO: Aro thoso volvos --

2 MR. REEVES: Those were the large valves, sir. When 3 we started off, some of them were as large as 66 inches in 4 diameter down to someplace in the BWRs in the small 2-inch 5 valves.

6 CHAIRMAN PALLADINO: How much? -

7 MR. REEVES: 2 inches. And that is the next 8 question which came up in the --

9 CHAIRMAN PALLADINO: Let me ask you though, aren't 10 those valves normally closed?

I

11 MR. REEVES
All these BWRs, they are closed except 12 during inerting and de-inerting.~ And the Staff concern is a

13 when the reactor coolant system temperature is above 200 k" 14 degrees, whether the plant is operating in power or not. The 15 source term is the same, and if you had the LOCA at pressure 15 and temperature above 200 degrees with these valves open, the 17 same amount of the source term reactivity would exit 18 containment fairly rapidly.

19 So there is a much bigger concern with the 3-inch 20 valves -- 2-inch valves.

21 And the second part of this --

22 CHAIRMAN PALLADINO: I was getting to why are they 23 open?

24 MR, DENTON: What we found back in 1978 was, 1 25 guess, many of these purge valves were open in order to keep

' 66 1

1 tho tocporaturo dcwn or koop down radiation lovels in the L

2 containment if they could exhaust the containment and still 3 meet Appendix ! levels.

t 4 And then the issue became I think originally, over i 5 some of the linkages between the motor and the valve. It 6 might not have been designed to close --

7 CHAIRMAN PALLADINO: See, I was'getting more 8 fundamental. You know containment to me, I picture it as i

9 containment. And when you have got a big valve that is open,

) 10 1 don't feel like you have got a containment.

11 MR. DENTON: Well that is item 3. There are still a 12 number of Licensees --

13 MR. REEVES: Mr. Chairman, all of those large valves i

I 14 are shut and are maintained shut. Originally when this came 15 up they were not. Plant probably had a 40-inch valve fully 16 open all the time. Rancho *Seco had the 66 open all the time, i

17 All those are shut now. That's not the problem any more.

18 CHAIRMAN PALLADINO: Thank you for at least giving 19 me that one.

20 Now get me on to where you want me to go..

21 MR. REEVES: The second point was the automatto --

22 CHAIRMAN PALLADINO; What sort of Innes are we i 23 talking about now?

24 MR. REEVES: We are talking about the 2-inch or so 4

l 25 valve on the MARK ! BWRs that did not have a radiation signal l

i i

  • 67 1 olocuro. Had all tho other roquirod closuros, but did not 2 have a radiation signal closure, which after TMI the Staff put 3 a position out that said 2.E.42 position 7, they would close 4 on all valves that ventilated, would close on high radiation 5 signal as an additional diversity.

I 6 All of them in the operating plants do that now 7 except for a few of them and these are the ones that are 8 listed here that appeal this decision. We have gone back and 9 forth for several years.

10 The Staff is prepared now, after doing the last 11 analysis of radiological consequences, by the end of October 12 we will give an evaluation on (Mat issue of whether those very i 13 small valves have to have the same diversity on radiation I 14- signal that all the larger valves have.

15 MR. DENTON: The utt11 ties have been trying to

] 16 demonstrate that they will still meet Part 100 with these l 17 valves open.

18 MR. REEVES: That's correct. And the BWR owners 19 group has an analysis in here that shows that is the case.

20 MR. DENTON: So this falls in the category, not a 21 management issue, but one of these long back and forth low 22 priority sort of issues, but an important issue.

23 If it were a higher priority we would have solved it 7

24 a long time ago. But it is one where a small subset in this 25 group has continued to debate it, s

  • 68 i

1 CHAIRMAN PALLADINO: Is this only a prob 1cm in BWRs?

2 MR. DENTON: Yes. I think it is only BWRs, and only 3 some of the BWRs.

4 MR. REEVES: Only the older ones. Most of them 5 committed, sir, except the ones that are listed here. They 6 appealed.

7 The final item was time constraints on how long you 8 can purge and vent these containments. All the Licensees have 9 committed to vent and purge operations for safety-related 10 reasons only,

!! They have technical specifications which in some

'. 2 cases are still being processed *on a plant specific basis 13 and we assume -- we are scheduling all these to be complete

( But the ramifications are so different with so many 14 FY'86.

15 different plants of different designs, that the technical 16 specifications have to be worked on a plant unique basis and 17 are being done so.

18 CHAIRMAN PALLADINO: Are you saying this is not a 19 serious problem at the present time? That it is one under 20 control, but it is' serious?

21 MR. DENTON: It was certainly serious when we 22 started in 1978. We have made great strides, but --

23 CHAIRMAN PALLADINO: I came in with the premise it 24 was serious, then you talked me out of it.

25 MR. DENTON: We have got it down to just a handful

69 1 cf incuos and I think Ed would liko to got back to othor 2 activities and wrap this issue up. And it just shows how some 3 of the things we started down the road to do, by the time you o

4 do them all at these diverse plants, it takes a long time.

5 So it is serious enough it deserves our attention.

6 I've asked for a monthly report on all these issues to put 1

7 them behind us so we can clear the deck, so to speak, and work 8 on more recent problems than some of these older ones.

9 CHAIRMAN PALLADINO: But how did it get to be listed 10 as one of your two generio items of significance'

11 MR. DENTON
A number of project managers identified 12 that as a frustrating and long ringering issue that they have 13 not been able to close on.

[ 14 CHAIRMAN PALLADINO: I see.

15 MR. REEVES: The length of time required for 1

16 documentation is a many-faceted issue of compliance with the I 't 17 containment, with our requirements that we have issued in 1

18 1978. And then TM! came along and quite a long review for 19 each plant. Each one unique.

20 COMMISSIONER ASSELSTINE: What is the backfitting 21 rule going to do to your efforts to try and bring about an 22 early resolution of these items?

23 Are you now going to have to go back and redo an 24 analysis, do a new analysis, go back to CROR because these 25 affect more than one plant?

i 70 1

y 1 MR. MIRAGLIA: I think this was approvod as a 2 multi-plant issue prior to CROR. and is going to get closure.

3 It is a multi-plant action that we are seeking closure on.

4 MR. DENTON: We would not propose to run this one i

5 back through, It is one the system had approved and is nearly 9

j 6 completely implemented. j 7 COMMISSIONER ASSELSTINE: Okay.

6 MR. DENTON: But that issue is beginning to surface -

9 in other areas already, J

10 MR. REEVEG: It is essentially closed on this issue ,

11 except for the technical specifications. One-valve write off I 12 MR. DENTON: The last ' plant was San Onofre 1 and

. 13 somehow we didn't get the slide into the handout I

14 I r.ade the point San Onofre 1 is not a management i 15 issue. We are very satisfied with the way that plant has been 16 running since it started, t i

17 (Silde) l

! 18 But there were some long-term seismic upgradings, j 19 fire protection, EO, auxiliary feedwater issue, TDI issue, i

4 20 control room issue, and a number of others. And those things, I 21 the great bulk of them, are due to be implemented during this l 22 forthcoming outage.

I 21 And so it was itsted by the PM as having a lot of i

1

, 24 things. But in my view they were -- it is not a management 25 issue because these were deferred back when there was

' 71 1 unsortainty about whother the plant would over bo allewod to 2 return to operation or not.

3 Once that decision was made they have aggressively 4 moved, and I don't think you will see this plant on the list S the next time around if we do this kind of survey again.

6 MR. MIRAGLIA: They had a large number of issues and 7 they are a facility that has availed itself of the integrated 8 scheduling. And we have agreed on a scope of work to the 9 plant in this outage which is a substantive part.

I 10 We have resolved many of the issues that are on the 11 list and the commitments are at the next refueling outage,

12 have the decks cleared.

i 13 MR. DENTON: I guess the last Generic issue we

(,

14 mentioned in our memo to you is fire protection, which was due 15 to be discussed in a separate forum.

16 COMMISSIONER ASSELSTINE: Before you leave San 17 Onofre, in terms of the long-term seismic upgrade program, j

18 which approach are they taking?

19 Or is it clear yet which approach they are taking?

20 More modifications to the plant or an attempt to I 21 justify the adequacy of the existing plant through analysis?

22 MR, MIRAOLIA: I think it is a mixture of both. The 23 project manager, Dick Dudley is here, and perhaps he could add 24 to it 25 We have been interacting with them as part of the

i 72 1 integrated systematic evaluation program, agreeing on the 2 criteria of what they are going to look at, the criteria that 3 is going to apply and the kinds of judgments they are going to 4 reach.

5 So I think in some areas you will see upgrades. I 6 think in other areas they will be justifying the design as is 7 is sufficient.

8 Dick, would you want to add anything to that?

9 MR. DUDLEY: I guess they were originally designed' 10 to .5g. They're operating to .67. It will be a hardware 11 fix, a lot more bracing and more reinforcement of the 12 components.

13 The staff is doing what we can in many cases to come t ( .

14 up with different acceptance criteria and perhaps in the 15 seismic analysis and perhaps remove a conservatism or two that 16 may not be necessary. But they will be' upgrading to .67g 17 design.

1 18 COMMISSIONER ASSELSTINE: Will that work, or at 19 least will there be an agreement by the end of this next 20 refueling outage on what has to be donet 21 MR. DUDLEY: They will be completed by the end --

22 COMMISSIONER ASSELSTINE: The work will be done as 23 well?

24 MR. DUDLEY: Yes. The analysis is ongoing. The 25 staff review is ongoing. The commitment is there to be fixed

73 1 beforo they start on the 11/30/85 refueling outage.

2 COMMISSIONER ASSELSTINE: Okay. Thanks 3 MR. DENTON: So I think the plants which deserve our A

4 attention are the Browns Ferry-type units, which are getting 5 considerable attention from all quarters. The Palisades-type 6 issues.are important, but they are not of large safety 7 significance. The survey was intended to find those things so 8 we could deal with them, not let them lie and linger.

9 COMMISSIONER BERNTHAL: Harold, as a matter of 10 curiosity, is this list of plants and of issues something 11 which we should take or I should take as representing the kind 12 of action plan, for wa'nt of a better word, that I had presumed 13 should follow in the wake of the severe-accident policy 7,

{

14 statement, or are you envisioning a much broader, more 15 detailed kind of effort? And if so, how soon will we be able 16 to see your action plan reflecting the policy and set forth in 17 the severe-accident policy --

18 MR. DENTON: It's definitely the latter. The latter 19 view is the correct view. I will have to get back to you on 20 what our schedule is. It involves IDCOR interaction. As I I 21 recall, we're waiting for Research to complete some i

22 plant-specific reviews which were scheduled. I think taey 23 have fix or six plants, and we're going to use that result to 24 apply against all of the existing plants. So I think that's 25 off a few months before we would even begin to see the results

74 1 of that.

2 If I were looking in the interim for plants that we 3 can focus on, I would look to the SALP reviews, the ones which 4 have 3s in maintenance operations.

5 COMMISSIONER EERNTHAL: Okay.

6 CHAIRMAN PALLADINO: Okay. Any other questions or 7 ' comments?

8 COMMISSIONER ASSELSTINE: Just one last question on 9 that last point. For a plant that has a 3 in maintenance, 10 particularly for those who have had 3s in maintenance for more 11 than one SALP period, why shouldn't we just assume that the 12 reliability of the system is questionable, much more 13 questionable than for a plant where we assume the equipment is i

14 being maintained properly, and put a high-priority attention 15 on digging back into those systems to decide if something more 16 needs to be done?

17 MR. DENTON: Jim and I have talked about that, "What 18 is a SALP? If you get a SALP 3 in maintenance, what does it 19 mean, and how can we couple, say, NRR's knowledge of the 20 design with the Region's knowledge of the -- what area of 21 maintenance is going down?"

22 We need to come up with something that would 23 integrate those problems. We don't have it yet.

24 MR. TAYLOR: I would agree with that. Clearly, it's l

25 a flag, and you have to get into what are the symptoms?

l

75 1 You've got to do a little bit of anclysis. But that's tho 2 intention of what we're doing. Sometimes, you know, it can be 3 a close call, and it's on specific issues and not a broader 4 issue.

5 So your question is right, and I think we are trying 6 to see That's at least what SALP was always -- it was 7 s u p p o r..e d to be a flag to them.

8 COMMISSIONER ASSELSTINE: That's right.

9 MR. TAYLOR: It's supposed to tell them, "Fix it."

10 MR. DENTON: I have gotten concerned, like Jim, I am 11 sure, if you see a rocurring SALP 3 and you ask them, what 12 are we accomplishing? We're only verifying that it really is 13 'a 3. If we had inspections and we find out, "Well, last time 14 we were right. It really was a 3," that doesn't mean that 15 it's necessarily that it has been fixed. We may have 16 inspected it more; we may have more knowledge about it. But 17 what we really want is a change in the plant.

18 Just inspecting more doesn't necessarily -- it often 19 does. Many utilities don't like SALP 3s, and they respond 20 vigorously to get out of that category. But then we have some 21 examples where utilities appear stuck in the Category'3.

22 COMMISSIONER ASSELSTINE: It does seem to me that 23 maybe if not the most important, certainly one important 24 lesson from Davis Besse is that when you see that kind of a i

i 25 breakdown in maintenance, it certainly has the potential to 1

- 76 1 load to widospread equipmont failuros that wo havo proviously 2 assumed just wouldn't happen.

3 MR. DENTON: I think this whole area of maintenance 4 is worthy of more attention. NUMARC, INPO has talked about 5 it, we've talked about it But certainly, the key, the key to 6 the plants running safely for 40 years after we've gone 7 through all this design review, testing, and peer review of 8 the original concept is to maintain the plant in the 9 configuration that it was intended to be, 10 COMMISSIONER ASSELSTINE: What is the status'of the 11 maintenance program plan, the discussions with NUMARC? I 12 guess we said we would be willin'g to let them take a shot at 13 presenting something,'but I am beginning to get increasingly 14 concerned that this is a sufficiently serious problem that we 15 just can't wait forever, we've got to get something done.

16 MR. STELLO: Let me first-say that we're not 17 waiting. What Jim has talked about in Turkey Point is what we 18 are getting underway. Where we have a concern in a plant, 19 we're not waiting for anything. .I think in terms of looking 20 at how well the industry is responding too, that is something 21 that we stil1~are reflecting on. They have recently agreed on 22 the kinds of performance indicators that they as an industry 23 ought to be interested in, and are now, I believe.

24 In the last. week or they two have sent out letters 25 to all the utilities to require -- this is INPO -- the

77 1 utilities to gather that kind of data so that they will be 2 able to look at the kind of trip points that indicate the 3 kinds of problems they are having.

4 And all I can say is we are watching, we are 5 encouraged. We wil be meeting with them again to look at the 6 progress they have made. I think it's scheduled for next 7 month.

8 Our mode at the moment is to watch and see how well 9 'the industry is reacting to it. But I think we basically have 10 concluded that we're not going to sit back and not take any 11 action on a plant when we believe there's a problem. We're 12 doing the kinds of things that Jim has just described that 13 we've done. We're getting more and more into it.

14 COMMISSIONER ASSELSTINE: Joe, I would suggest -- I 15 don't know when our next meeting with the NUMARC people is --

\

16 but that we communciate to them that maintenance is one of the 17 issues that we would like to discuss.

18 And, Harold, I would like to, I think, take a fresh 19 look at the maintenance program plan that you had discussed at 20 the ACRS some months ago in preparation for that.

21 CHAIRMAN PALLADINO: Why don't we ask SECY to make 22 sure that that gets out as the next item?

23 I wonder if I might return briefly to Davis Besse.

24 It seems to me there is a l' o t of activity still to be 25 completed before restart. There seemed to be a sense of

-2: .+

. 78 --

1 optimism for early November yesterday, but I want to make suro 2 that when the plant is restarted, that the staff is satisfied 3 that all of the appropriate things have been completed.

4- One issue that I have been asked absut I was asked 5 yesterday in a press statement, "Well, does the Commission get And I said, "Well, we 6 involved in a decision to restart?"

7 will be in close -- the' staff will maintain close consultation 8 with the Commission."

9 But the Commission has not decided whether or not 10 it's going to interject itself into this decision. And I 11 think this is something we ought to. clear up in the reasonably

~

12 close future, and I don't know whether we should seek a staff 13 paper on the extent to which the Commission should'get into it 14 or the Commissioners want to express their own individual 15 feelings.

16 But I think we ought to have SECY polled in a 17 notation sort of a vote on how the Commissioners feel on this 18 question.

19 COMMISSIONER ASSELSTINE: I certainly agree with 20 that, Joe. As you know, several weeks ago I tried to provide 21 a catalyst for getting positions on that very issue as well as 22 some others. I think we ought to come to a resolution on it 23 as soon as possible.

l 24 I read the staff's responses to my memo as basically 25 saying that they thought that there should at least be l

l l

. 79 1 thorough Commission briofing before any decision is modo for 2 restart.

3 CHAIRMAN PALLADINO: Yes.

4 Well,'could I ask each Commissioner to send SECY a 5 note, if possible by the end of this month, expressing your 6 opinions or seeking any information to help you make a 7 decision?

8 COMMISSIONER ZECH: Sure.

9 COMMISSIONER ROBERTS: Yes.

10 COMMISSIONER ASSELSTINE: Fine.

11 CHAIRMAN PALLADINO: Anything more that should come 12 before us?

13 COMMISSIONER ZECH: I would just like to say I think 14 this briefing has been very helpful and very well done by the 15 staff.

16 Also, I would like to thank -- I believe they are 17 handling these issues in a very responsible manner. I think I 18 understand exactly what you are telling us about the issues 19 you presented to us and why they're frustrating issues, some 20 of them, as well as the Davis Besse issue itself and others 21 and your reference to the maintenance problems and other 22 hardware problems.

l l

23 But I think it was very well done, and again I think 24 from my view, you are handling it in a very responsible 25 manner.

  • 80 1 CHAIRMAN PALLADINO: Thank you very much, i

~

2 gentlemen. I think Commissioner Zech spoke for all of us when s.

3 he complimented you on your work.

4 4 Okay, we wi11 stand adjourned..

5 (Whereupon, at 11:20 a.m., the Commission meeting 6 was adjourned.) -

7 8

. 9

. 10 4

k1 12 i 13 14 15 16 4

17 ,

18 19 20 21 22 23 24-25 I

h t

A s 1 CERTIFICATE OF OFFICIAL REPORTER 2

to 4

5 This is to certify that the attached proceedings 6 before the United Statos Nuclear Regulatory Commisslon in the 7 matter of . COMMISSION MEETING e

9 Name of proceeding: Continuation of Briefing on Davis-Besse (Public Meeting) -

10 -

11 Docket No.

12 place: Washington, D. C.

13 Date: Wednesday, September 18, 1985 14 ,

15 were held as herein appears and that this is the original 16 transcript thereof for the file of the United Statos Nuclear 17 Regulatory Commission.

13

] '/

(Signature)

.t , , , g, /('[. (j' "

(Typed Name of Reporter) Mimie Melf.zer 20 21 22 I 23 Ann Riley & Associates, Ltd.

I l

l 24 25

l COMMISSION BRIEFING

September 17,1985 1

l Followup Actions Resulting From The Davis-Besse June 9, ~1985 Event I

^ ' ^ ' ~ '

~ ~~

e AGENDA I. Plant-Specific Actions ll. Generic Actions 1

l i

i i !

a 1

PLANT STATUS e Facility in Cold Shutdown e Troubleshooting and Corrective Action in Progress

  • System Modifications in Progress, including installation of Diverse Drive AFW Pump i

e Licensee Forecasts Ready to Restart Early

! in November l

i

Contact:

D. Eisenhut, NRR '

l l

4 l

l 1

NRC RESTART REVIEW MILESTONES e Findings and Conclusions of incident investigation Team (NUREG-1154) Issued in July 1985 e Staff Action Items Established by EDO on August 5,1985 1

l

  • 50.54(F) Request issued to Toledo. Edison on August 14,1985

!

  • Licensee Met with Staff on September 4,1985 e Staff Reviewing Licensee's Root Cause and Corrective

! Action Reports

!

  • Licensee's Response to 50.54(F) Letter Received
September 12,1985 l

Contact:

D. Eisenhut, NRR -

i i

RESTART EVALUATION ITEMS f

a Derived from Staff Concerns in 50.54(F) Letter

  1. Completion of Event Investigation

- Completion of the investidation of Equipment Malfunctions and Operator Errors

- Determination of Root Causes of the Malfunctions and Errors and implications to the Restart of' the Plant

- Corrective Actions Needed to Nssure the Reliability

{ of Systems Which Mitigate Loss of Feedwater Events l

Contact:

D. Eisenhut, NRR

, RESTART EVALUATION ITEMS

! (CONTINUED) e Concerns Directly Related to June 9,1985 Event Evaluate Licensee's Response to Concerns identified i

in NUREG-1154: .

(1) Adequacy of Loss of Feedwater Analysis

(2) Adequacy of Design / Operation of SFRCS
(3) Physical Security and Administrative Features (4) Role of STA -

! (5) Reliability of AFW Containment ~lsolation Valves and Other Safety-Related Valves (6) Adequacy of ENS Reporting '

(7) Reliability of AFW System, Pumps, and Need ,

for Diverse Pump

Contact:

D. Eisenhut, NRR 4

\

RESTART EVALUATION ITEMS (CONTINUED)

(8) Reliability of PORV (9) . Adequacy of Control. Room Instrumentation and Controls (10) Inability to Place Startup FW Pump in Service from Control Room -

(11) Resolution of Other Equipment Deficiencies (12) Adequacy of Procedures for " Drastic" Action i (13) Adequacy of Safety System Testing

Contact:

D. Eisenhut, NRR

RESTART EVALUATION ITEMS (CONTINUED) e Evaluate Licensee's Response to Additional NRC Concerns

- Adequacy of Procedures, Equipment and Training for Restoring Equipment for LOF Mitigation

- Adequacy of Programs to Resolve Likelihood of inadvertent Isolation of AFW~to Both Steam Generators

- Installation of Diverse Drive AFW Pump

- Other ESF Systems Adequacy in Light of Single Failure Vulnerabilities identified in SFRCS and AFW Systems contact:

D. Eisenhut, NRR

RESTART EVALUATION ITEMS (CONTINUED)

  • Evaluate Licensee's Response to Management and Programmatic Concerns

- Adequacy of Management Practices

- Adequacy of Maintenance Program improvements

- Adequacy of the implementation of the Performance Enhancement Program ,

- Adequacy of the Resources Committed to the Davis-Besse Facility for the investigation of the Event, Resolution of Findings and Conclusions, and Longer Term Actions e May Be Additional Restart issues as a Results of Continuing Staff Review

Contact:

D. Eisenhut, NRR

OTHER NRC RESTART CONSIDERATIONS e Organizational

- Regional lil Section Created to Monitor Davis-Besse

- NRR Enhanced B&W Projects Group; E.G., Extra Project Managers

  • ACRS Briefing in October on Da'vis-Besse Restart e Determine Actions to be Completed Prior to and Subsequent to Facility Restart .

l e Conduct Special Inspections of Licensee's Corrective Action Programs; inspections to Monitor and Evaluate Troubleshooting e NRR-Region Maintenance Assessment - Prior to Restart

  • NRR-Region Training Accreditation Site Review - Prior to j Restart l

l l

Contact:

{ D. Eisenhut, NRR

OTHER NRC RESTART '

CONSIDERATIONS (CONTINUED)

  • Evaluate Licensee Programs Being implemented to Address NRC Concerns Relating to Regulatory Performance e Evaluate Changes to Operating Procedures and Philosophy e inspect Special Confirmatory Testing of Systems and Equipment involved in June 9,1985 Event e Conduct Augmented Inspections During Startup and Operation e Enforcement Action Consideration

Contact:

D. Eisenhut, NRR

- - - - - - _ - - --- -- --- --- - w- - - - - -

NRC GENERIC TECHNICAL ACTIONS e immediate Generic Issues - None e Short Term Generic issues

- Potential Inability to Remove Decay Heat i Because of Questionable. Reliability of AFWS

- Adequacy of Emergency Procedures, Operator Training and Available Plant Monitoring Systems i for Determining Need to initiate Feed and Bleed Cooling

- Physical Security System Constraints which could

- Deny Timely Access to Vital Equipment i

- Prioritization of Short Term Issues is Nearly

Complete i

Contact:

l D. Eisenhut, NRR l

[

i

NRC GENERIC TECHNICAL ACTIONS (CONTINUED) e Potential Long Term Generic issues: '

(1) Availability and Role of STA (2) Actions to improve Reliability of PORV, and Need for Failure Mitigation (3) Adequacy of Requirements for SPDS Availability (4) Need for Plant-Specific Simulator (5) Adequacy of Safety System Testing (6) Re-Evaluate NUREG-0737 Item II.E.1.1 (AFW System Reliability)

Contact:

D. Eisenhut, NRR i

--- -- . . _ _ - a_._,i . _ _ _ ,

~

NRC GENERIC TECHNICAL ACTIONS (CONTINUED)

(7) Adequacy of Maintenance Requirements (8) Adequacy of Single-Failure Aspects of Steam Line/ Feed Line Break Mitigation Systems (9) Effects of Loss of Feedwater On OTSG (10) Thermal-Hydraulic Aspects of Loss of Feedwater Event on Reactor Vessel (11) Re-Examine PRA-Based Estimates of Core Damage Resulting from Loss of Feedwater Other Additional Issues, as iden'tified

Contact:

D. Eisenhut, NRR

NRC GENERIC TECHNICAL ACTIONS (CONTINUED) e Information Notices - Bulletins ISSUE ACTION Generic Applicability of Bulletin Drafted and Distributed ,

Fai'ure of Safety-Related for Comment. Plan to Meet with Valves CRGR in Early October Guidance on Notification Prepare Information Notices by '

! of Most Severe Plant October 15 on " Emergency ,

Condition Notifications" and " Timely l

Declaration of an Emergency Class and implementation of an '

Emergency Plan" i

Contact:

J. Taylor, IE

NRC GENERIC TECHNICAL ACTIONS (CONTINUED)

ISSUE ACTION Generic Aspects of Auxiliary Following Confirmation of Failure Feedwater Turbine Reliability Cause at Davis-Besse, issue Information Notice or. Bulletin on Generic Problems Po'ssible Actions are with Respect to Startup and Post Modifications Testing.

Action Planned by October 25 Generic Aspects of Equipment Following Confirmation of Failure Malfunctions from Table 5.1 Cause at Davis-Besse, issue of NUREG-1154 Information Notice or Bulletin on Challenges to Safety Systems.

Contact:

J. Taylor, IE l _______ _ _______ _ _ _ _ -_ _ _ _ _ _ _ _ _ _ - __ _

.i NRC GENERIC TECHNICAL ACTIONS (CONTINUED)

!

  • Generic Long-Term Studies -

I .

i - Assess Safety-Related Motor Operated Valve Failures and Failure Modes Affecting Valve Performance Under Design Basis Conditions .

~

- Conduct Study of Steam-Turbine Driven Pump Performance to Determine Root Cause(s) of Overspeed Trips l

i

Contact:

T. Ippolito, AEOD i

4 I

- - - - - ^ - - -- . - - - ._._ _ __ - - - -

,s  ; e q,, ' -

N , , , .

SAN ONOFRE UNIT 1 .

CURRENT PLANT STATUS:

93% POWER; NEXT SCHEDULED REFUEL!teG OUTAGE 11/30/85.

SUpmARY OF ITEMS:

1. Lo#6-TERM SEISMIr UPGPADE - ANALYSIS AND map 9tfAPE IfetEMEtrTATICII 2.- FIRE PPOTECTION - DESIGN AND IttSTALLATIM of A M31 tait 9 5AFE SHUTDOWN SYSTEM AND eTHEP APPEtt!X F pc8IFICAT100ts
3. EoVIPMENT QUALIFIC/TICW - OLELIFICATIcel CR REPLACEMENT OF ALL

- REMAINING MON-QUALIFIED EQUIP 9ENT

4. . INSTALLATION OF A THIRD AUXILIARY FEEEteATER PWMP
5. UPGRADE AUXILIARY FEEDWATEP To THIFD (SAFETY-6MAM ).TRAlp
6. TDI-DIESEL GENFPATOPS - STAFF REVIEW OF ACTIONS REQUIRED TO .,

ENSURE LONG TEPW OPERABILITY

7. CowTRa. Rcca HABITArILITY - FURTHER DeCEPENTATICP GF A01ALYSES T.0 MTERMIPE IF REfum CastTatt #ff*' ENE SYSTEM Is answa
8. SUPPLE 8ENT 1 TO 0737; DCRDR, SPDS, PEG. GUIDE 1.97 CURRENT RES0luTION ITEMS 1 TO P.E COMPLETED PRIOR TO RESTART FPOP 11/30/85 0UTAGE ,

ITEM 5 - TO BE COMPLETED DURIleG BEXT REF ELIBE CarYAGE ITER 6 - STAFF SER PRIOR TO RESTART FacM ll/'NVW5 cerTAsE ITEM 7 - LICEPSEE SUBMITTAL BY SEPTEMBER 30, 1985;' STAFF REVIEW t BY 12/1/85 -

1 ITEM 8 - DCRDR PROGRAM PLAN DUE 12/16/85 ,

REG. GUIDE 1.97 SUBMITTAL DUE 12/16/85 SPDS SUBMITTAL DUE 1/9/87

i .

BROWNS FERRY UNITS 1, 2 AND-3 PLANT STATUS j UNIT 1 SHUT DOWN 03/19/85 DUE TO FAILURE OF SEVERAL CONTAINMENT i ISOLATION VALVES TO PASS LOCAL LEAK RATE TEST.

UNIT 2 SHUT DOWN 09/15/84 FOR REFUELING.

UNIT 3 SHUT DOWN 03/09/85 DUE TO REACTOR VESSEL WATER LEVEL

INSTRUMENTATION DISCREPANCIES.

4 - s - __ -~

TVA PROJECTED RESTART DATES:

UNIT 1 - LATE 1986 4

UNIT 2 - FIRST QUARTER 1986 UNIT 3 ~ SPRING 1987 .

~

SUMMARY

OF ITEMS HPCI RELIABILITY QUESTION ,,

TVA TASK FORCE EVALUATED PROBLEMS CONTRACTED GE TO EVALUATE FIRE PROTECTION -

SUBMITTING REVISED DESIGN - JANUARY 1986 REQUESTED SCHEDULAR EXEMPTIONS DELAYED IMPLEMENTATION OF MODIFICATIONS 1

l

BROWNS FERRY (CONT.)

NRC-REQUIRED MODIFICATIONS DELAYED IMPLEMENTATION OF SOME MODIFICATIONS INEFFECTIVE MANAGEMENT POOR OPERATING PERFORMANCE ABOVE AVERAGE NUMBER OF VIOLATIONS ABOVE AVERAGE NUMBER OF ABNORMAL OCCURRENCES AND EVENTS CURRENT RESOLUTION HPCI MODIFICATIONS TO SYSTEM NRC REVIEW INDICATES RESOL'UTION BEING ACHIEVED f

FIRE PROTECTION

~

NRC/ CONTRACTOR REVIEW 0F REVISED' DESIGN COMPENSATORY MEASURES BEING REQUIRED INTEGRATED SCHEDULED FOR NRC REQUIRED MODIFICATIONS REVISED SCHEDULE TO BE DISCUSSED 10/02/85 NRC EVALUATION '

INP0 ASSISTANCE INCREASED NRC ATTENTION ON TV4 PLANNING AND SCHEDULING PROBLEMS T

BROWNS FERRY (CONT.)

NRC EXECUTIVE TEAM ESTABLISHED TO PROVIDE OVERVIEW _ 04/12/85 SECY 85-231 ISSUED 06/28/85 DESCRIBING NRC LONG-TERM PLAN OF ACTION TVA'S PLAN OF ACTION PRESENTED TO NRC 09/06/85 COMMISSION BRIEFING 09/12/85 i

SPECIAL EDO SALP ISSUED 09/17/85 50.54(F) LETTER ISSUED 09/17/85 INCREASED NRC INSPECTIONS CLOSER NRC ATTENTION TO CORPORATE AND PLANT PERFORMANCE OPERATIONAL READINESS REVIEW PRIOR TO RESTART 0F ANY UNIT,

~

O

FORT ST, VRAIN NUCLEAR GENERATING STATION CURRENT PLANT STATUS

- PLANT SHUT DOWN

SUMMARY

OF ITEMS

- EMERGENCY DIESEL GENERATORS - FIRE PROTECTION (APPENDIX R)

- FIREWATER SYSTEM (SAFEGUARDS - ISI/IST PROTECTION) _.

- STATION BATTERIES - PCRV INTEGRITY (TENDONS AND LINER) ,

- CONTROL ROD DRIVE MECHANISMS - OVERALL PLANT TECH, SPEC, UPGRADE

~

- CONTROL R0D POSITION - LIQUID EFFLUENT RELEASES INSTRUMENTATION

- HELIUM CIRCULATORS - EQUIPMENT GUALIFICATION

- MANAGEMENT CONTROL - MOISTURE' INGRESS

FORT ST, VRAIN (CONT.)

- BUILDING 10 CONSTRUCTION -

CRACKED FUEL BLOCKS

- CHLORIDES IN REACTOR ONGOING STAFF AND LICENSEE ACTIONS A DETAILED TECHNICAL REVIEW BY THE STAFF 0F EACH OF THE OPEN ISSUES IS ONGOING WITH SCHEDULES ESTABLISHED LICENSEE HAS INITIATED A PERFORMANCE ENHANCEMENT PROGRAM PLANT TECHNICAL SPECIFICATIONS ARE BEING UPGRADED TO STS FORMAT .

LICENSEE HAS REQUESTED NRC APPROVAL OF LIMITED LOW

, POWER OPER'ATION TO CONTINUE REACTOR " DRY OUT" O

O

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RANCHO SECO NUCLEAR GENERATING STATION CURRENT STATUS SHUT DOWN FOR REFUELING OUTAGE MARCH 1985 LICENSEE PROJECTED RESTART: EARLY OCTOBER

SUMMARY

OF ITEMS NON'-ISOLABLE HIGH POINT VENT LEAK INPO APPRAISAL I

INDEPENDENT CONSULTANT ORGANIZATIONAL REVIEW e

HISTORY OF POOR PERFORMANCE QA/QC, ENGINEERING CONSTRUCTION,

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RADIOLOGICAL CONTROLS

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CURRENT RESOLUTION PRIOR TO STARTUP (REGION V CONFIRMATION ACTION LETTERS)

O REPAIR HIGH POINT VENT PIPING AND SUPPORTS 0 COMPLETE SAFETY SYSTEM SUPPORT WALKDOWN

RANCHO SECO (CONT.)

~0 EVALUATION OF OTHER SYSTEMS l.E. CABLE TRAY SUPPORTS 0 INP0 APPRAISAL SUPERVISORY INVOLVEMENT IN ADHERENCE TO PROCEDURES CONTROL OF MAINTENANCE ACTIVITIES' WATCH STANDING PRACTICES OF NON-LICENSED OPERATORS O MANAGEMENT REORGANIZATION O SALP MEETING WITH LICENSEE

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LONGER-TERM ITEMS 0 TRAIN'ING QA/QC PERSONNEL O NEW ENGINEERING PROCEDURES 0 TRAININ$ OF CRAFT PERSONNEL O PURCHASE SIMULATOR 0 IMPLEMENT ROOT CAUSE PROGRAM O IMPLEMENTATION OF' CONSULTANT RECOMMENDATIONS

PALISADES PLANT PLANT STATUS 90% POWER; NEXT SCHEDULED REFUELING OUTAGE 11/30/85 ITEM t

MAIN STEAM LINE BREAK WITH SINGLE FAILURE OF MAIN STEAM ISOLATION VALVE, CURRENT i

IDENTIFIED IN SEP IN 1982 1

LICENSEE INITIALLY COMMITTED TO FIX 4

IN AUGUST83, LICENSEE REQUESTED DEFERRAL UNTIL PRA COULD

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BE DONE MAY '85 SUBMITTAL OF PRA CONCLUDES FIX NOT NECESSARY 4

STAFF IS REVIEWING-TARGET DECISION DATE 12/85 a

JUSTIFICATION FOR OPERATING UNTIL REVIEW COMPLETE 1

PALISADES (CONT.)-

HIGHLY UNLIKELY EVENT LIMITED TO SMALL FRACTION OF STEAM LINE ADDED THIRD AUXILIARY FEEDWATER PUMP (2 MOTOR DRIVEN-ONE STEAM TURBINE-DRIVEN) REDUCING LIKELIHOOD OF DRYOUT PROCEDURES UPGRADED TO USE CONDENSATE PUMPS'AND SYSTEM'

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AS BACK-UP TO AFW ADDED WIDE RANGE STEAM GENERATOR LEVEL INSTRUMENT NEW AUXILIARY FEEDWATER LINES AND SPARGER FAVORABLE INSERVICE INSPECTION RESULTS OF STEAM LINES 1979 AND 1983 e

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CONTAINMENT PURGE AND VENT

1. ISSUE: . CONTAINMENT PURGE VALVE OPERABILITY FOLLOWING DESIGN BASIS LOCA SOURCE OF GENERIC REQUIREMENT: GENERIC LETTER DATED NOVEMBER 29, 1978.

AFFECTED PLANTS: DRESDEN 2, 3 AND QUAD CITIES 1, 2 STATUS LICENSEE INFO DUE 10/85. STAFF RESOLUTION 12/85.

2. ISSUE: AUTOMATIC ISOLATION OF PURGE VALVES IN SMALL LINES BY HIGH RADIATION SIGNAL SOURCE OF GENERIC REQUIREMENT: NUREG-0737,ITEMII.Ek.2(7) ^

AFFECTED PLANTS HATCH 1, 2, PILGRIM 1, PEACH BOTTOM 2, 3

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STATUS THE BWR OWNERS GROUP APPEALED SIGNALS FOR SMALL LINES (ar2 INCH). STAFF EVALUATION SCHEDULED FOR 10/31/85.

3. ISSUE: TIME CONSTRAINTS ON CONTAINMENT VENTING / PURGING OPERATIONS SOURCE OF GENERIC REQUIREMENT: GENERIC LETTER DATED NOVEMBER 29, 1978~.

T-CONTAINMENT PURGE AND VENT (CONT,)

AFFECTED PLANTS: SEE STATUS DISCUSSION STATUS ALL LICENSEES HAVE COMMITTED TO VENT / PURGE FOR SAFETY-RELATED REASONS. ' TECHNICAL SPECIFICATIONS BEING PROCESSED ON A PLANT-SPECIFIC BASIS.

SCHEDULE COMPLETIONS FY 86, 9

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FEED AND BLEED CAPABILITY AT DAVIS BESSE STAFF

SUMMARY

-STAFF PERFORMED A NUMBER OF INDEPENDENT CALCULATIONS OF FEED-AND-BLEED CAPABILITY OF DAVIS-BESSE

- - SIMPLIFIED MASS AND ENERGY BALANCE ANALYSES ,

- ANALYSES USING TRAC-PF1 CODE AT LANL

. - IN-HOUSE ANALYSES USING RELAP5 AND NUCLEAR PLANT ANALYZER OVERALL CONCLUSIONS:

- BASED ON AB0VE ANALYSES, STAFF AGREES THAT CURRENT DAVIS-BESSE CONFIGURATION (1 PORV + 2 MU-PUMPS) IS CAPABLE OF SUCCESSFUL FEED AND BLEED IF INITIATED WITHIN 20 MINUTES.

- STAFF ANALYSES INDICATE THE ADDITION OF A SECOND PORV 0F CAPACITY EQUAL TO THE EXISTING PORV ENHANCES FEED AND BLEED CAPABILITY (TIME AVAILABLE FOR OPERATOR ACTION IS GREATLY EXTENDED, RELIANCE ON MU PUMPS GREATLY DECREASED OR PERHAPS ELIMINATED),

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