ML20134A195
| ML20134A195 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 08/08/1985 |
| From: | NRC COMMISSION (OCM) |
| To: | |
| References | |
| REF-10CFR9.7 NUDOCS 8508150224 | |
| Download: ML20134A195 (112) | |
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Location:
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Date:
August 8, 1985
%P, h k 05080s PT9.7 PDR ANN RILEY & ASSOCIATES-
,i Court Reporters
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D 1 SC LA I M ER 2
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6 This is an unofficial transcript of.a meeting of the-7 United States Nuclear Regulatory Commission held on 8
, August 8, 1985 in the Commission's office at 1717 H Street, 9
N.W.,
Washington, D.C.
The meeting was open to public 10 attenhance and observation.
This transcript has not been 11 reviewed, corrected, or edited, and it may contain
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12 inaccuracles.
13 The transcript is intended solely for general 14 informational purposes.
As provided by 10 CFR 9.103, it is 15 not part of the formal or informal record of decision of the 16 matters discussed.
Expressions of cpinion in this transcript 17 do not necessarily reflect final determination or beliefs.
No 18 pleading or other paper may be filed with the Commission in 19 any proceeding as the result of or addressed to any statement 20 or argument contained herein, except as the Commission may 21 authoeire.
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UNITED STATES OF AMERICA 2
NUCLEAR REGULATORY COMMISSION 3
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Discussion /Possible Vote on Full 61 Power Operating License for 7
Limerick 8
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PUBLIC MEETING 10 11
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13 Room 1130 14 1717 H Street,.N.W.
15 Washington, D.C.
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Thursday, August 8,1985 18 The Commission. met in.public session at 10:35 a.m.,
19 pursuant to notice, Commissioner Thomas Roberts presiding.
20 NRC COMMISSIONERS PRESENT; 21 Thomas Roberts, Commissioner 22 James Asselstine, Commissioner 23 Frederick Bernthal, Commissioner
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24 Lando Zech, Commissioner 25
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1 STAFF AND PRESENTERS GEATED AT COMMISSION TABLE:
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Plaine, OGC 3
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Chilk, SECY
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Chri'stenbury g
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Martin 4
6 D.
Eisenhut s
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Murley 8
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Starostecki 9
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Ralph 4
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Boyer, PECo t, _/
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Everett, PECo 13 G.
Leitch, PECo s
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15-Al?DIENCE SPEAKERS:
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Russell 20 R.
Bernero 21 A.
Thadsni 22 R.
Wilkerson 1
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2 COMMISSIONER ROBERTS:
Good morning, ladies and
,3 gentlemen.
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Chairman Palladino is on travel overseas, and I will 5
act as Acting Chairman.
s.
6 The purpose of today's meeting is to discuss and 7
decide whether to authorize the Director of Nuclear Reactor a
8 Regulation to issue a full power license for the Limerick
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Nuclear Power Plant Unit 1 10 The merits review has been completed for the
-1 1 Licensinh Board's First Partial Initial Decision, and the
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12 Commission's order, CLI-85-13 of July 24th, 1985, allowed the 13 Licensing Board's Second and Third Partial Initial Decisions 14 to become effective.
15 Therefore, at this meeting we need only to determint 16 whether't'o allow the Licensing Board's Fourth Partial Initial 17 Decision to become effective.
18 The Fourth Partial Initial Decision addresses 19 hearing issues related to emergency planning for the State f
20 Correctional Institution at Graterford.
21 On October 16th, 1984 the NRC authorized a low power 22 lic*nse for the Limerick Power Plant, authorizing fuel load,
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23 pre-criticality testing and low power operation for power 24 levels up to 5 percent of full power.
a presentation, and I 25 The NRC Staff has prepared g
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1 understand that members of the NRC Staff, as well as
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2 representatives of the Philadelphia Electric Company, are 3
available to answer any questions we might have.
4 I also understand that Mrs. Phyllis Zitzer, 5
representing Limerick Ecology Action, LEA, has requested an 6
opportunity to speak at this meeting.
After the Staff 7
completes its presentation, the Commission will grant her five 8
minutes to make her comments.
After Mrs. Zitzer speaks, we 9
will allow the Applicant five minutes for any comment it 10 wishes to make.
11 At the conclusion of the meeting I intend to.ask for e
12 a vote on whether to issue an order authorizing the Licensing 13 Board's Fourth Pa'rtial Initial Decision to become effective, 14 thus authorizing the Staff to issue a full povrer license for 15 Limerick, Unit 1
-16 Would any of the other Commissioners like to offer 17 comments at this
,t i m e ?
18 COMMISSIONER ASSELSTINE:
No.
19
. COMMISSIONER BERNTHAL:
No.
20 COMMISSIONER ROBERTS:
I will now turn the meeting 21 over to Mr.
Ros.
22 MR. ROE:
I will ask Mr. Eisenhut to proceed with
.23 the Staff's briefing.
24 MR. EISENHUT:
Thank you.
i 25 As Commissioner Roberts said, the low power license
1 was issued in October 2
COMMISSIONER ROBERTS:
I am not going to do my 3
Alexander Haig act.
4 CLaughter.3 5
MR. EISENHUT:
I thought of that.
6
[ Laughter.3 7
The plant has completed its 5 percent power testing 8
phase.
This is one of the few plants that's listed as an 9
impacted plant in the Bevill schedule, it has bewen for 10 several months.
I believe they would have been able to 11 proceed.in something like March of this year, had there been
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12 no other constraints.
13 We are going to go through today a summary briefing, 14 trying to hit the highlights of the review that's been going 15 on now f o r. a number of years.
16 One item I will hi,ghlight is that yesterday we sent 17 down a memo pointing out an issue concerning a potential error 18 in a Chapter 15 analysis, more error in the sense of an input 19 omission.
We sent that.down to you yesterday.
We will~be
'20 discussing that briefly today.
That issue, however, is 21 resolved.
22 The people here with us today that will be going 23 through the brie'fing from the Region, of course Tom Murley, 24 the regional-admini *.ator and his division director, Rich 25 Starostecki are with us.
Tom Murley-will go through those
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portions relating to the completion of the 5 percent and 2
operations phase.
3 Tom Novak, on my left, the Assistant Director-for 4
Licensing, and with him is Bob Martin, who is the Project 5
Manager, they will be going through the principal part of the 6
briefing.
7-With that, Tom, why don't you proceed.
I B
MR.'NOVAK:
May I have the first slide.
9
[ Slide.]
5 10 Now may we move to the next one, please.
11
[ Slide.]
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12 Very briefly, I will c ov e r 's ome selected issues that i
13 occurred during the license process, and Dr. Murley will 14, discuss construction, his perspective on low power. operations, 15 and we will summarize with any comments regarding
-16 investigations and any outstanding 2206 petitions.
17 May I have the next slide, p144se.
18
[ Slide.]
19 As the Commission is aware, Philadelphia Electric 20 Company is the owner and operator of the Limerick Station.
21 They also operate the Peach Bottom Station, and have for over 22 10 years.
Peach Bottom 2 and 3 were licensed for operation in 1
23 1973 and 1974 respectively.
24 In many ways, Limerick resembles Peach Bottom.
It 25
'is a boiling water reactor.
There is a difference in the
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1 containment design, but more importantly, I think Philadelphia
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The architect-engineer both at 3
the Peach Bottom stations and at Limerick was-Bechtel.
So 4
they designed and constructed both stations.
5 As the Commission knows, the Limerick station is 6
located in what we consider to be an above-average site 7
population area.
8 May I have the next slide, please.
9
- Slide.]
10 With regard to the FSAR review, I would like to 11 touch on a few issues that the Commission has shown interest 12 in.
13 Initially'the fire prote'etion issue, I think here we 5
14 can say that the design and the implementation of the fire 15 protection at Limerick id very good.
The plan was approved 16 back in August of 1984.
There was an in-depth region 17 inspection at that time and there were no equipment violations i
18 identified.
I 19 As part of the review, there were seven deviations
~20 approved by the Staff to our review plan in Appendix R.
I 21 would consider this to be a low number, on the average.
So it 22 went pretty much along the guidelines we had been looking i
23 for.
It was implemented and there were no violations in terms 24 of equipment deficiencies.
25 With regard to environmental qualifications, again
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the Licensee was able to provide all equipment and 2
documentation necessary to meet our requirements prior to
'3 issuance of the OL license.
4 So as far as environmental qualification, he's there 5
and he continues to be there now.
6 We do plan to schedule an inspection.
The region 7
will talk about this briefly, but there were earlier 8
inspections as part of the licensing review, and we are 9
satisfied with the equipment that he has placed in the station 10 and its qualifications.
11 With regard to low level waste storage, the current r~
.j 12 storage capacity at Limerick is a two-month storage.
They do 13 have a contract with Barnwell, and I'm sure they will be 14 following this issue closely as it develops, 15 With regard to staffing, because of the Peach Bottom 16 experience they do come in with an experienced crew.
They 17 will be operating a six-shift rotation, and at the present 18 time they will only require what we refer to as one shift 19 adviser.
That person will be a Philadelphia Electric Company 20 employee.
He hos previous experience at Peach Bottom, and so 21 we are satisfied that they are coming in with an experienced 22 crew, and they do have a substantial numb"er of senior reactor i
23-operators as well as reactor operators.
-24 COMMISSIONER ASSELSTINE:
Tom, on low level waste 25 storage, do they have any plans for expansion at this time?
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1 MR. NOVAK:
I don't know specifically.
I do know 2
that they are looking at compaction and other things that they 3
can do on site.
4 COMMISSIONER ASSELSTINE:
Okay.
But you don't know 5
specifically about plans for expanding beyond two months' 6
onsite storage capacity?
7 MR. NOVAK:
That's right, I don't.
8 COMMISSIONER ROBERTS:
How does the two months 9
compare with other. plants?
10 MR. NOVAK:
We've seen them as low as one month, and 11 of course some of the more recent designs have five years.
i 12 COMMISSIONER ASSELSTINE:
A lot of plants seem to be 13 at least beginning to plant for extended storage onsite.
So 14 they've got the facility in place, yet they can plan for it.
15 MR. NOVAK:
With regard to technical specifications, 16 I think here is a place again where experience does pay off.
17 The Philadelphia Electric people did use experienced personnel 18 in the development of their tech specs, they relied on their 19 experience that they had with Peach Bottom.
20 Again, it is a standard design, so a lot of the 21 Staff's review could be put right back into the system.
The 22 tech specs that we reviewed on Susquehanna, for example, are 23 very similar to what was adopted for Limerick.
24 This plant has been in operation for eight or nine 1
25 months.
There has been no requirement to change any technical
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2 As in any case, there are some enhancements that 3
they do see, and we do' expect to approve them if the 4
Commission votes to authorize full power.
This is just a 5-fine-tuning that I would refer to it as.
6 With regard.to the issue that Darrell mentioned 7-earlier on a difference identified in the Chapter 15 analysis, 8
.I.would just like to sort of give you a little background on 9
this.
10 The region identified a difference between the 11 performance of the plant in the event of a loss of offsite power from a low power versus what was in the technical 12 13 specifications.
14 The Applicant'went back and confirmed in fact that 15 the Chapter 15 analysis did not specifically recognize some 16 design changes that were made to the plant back in 1973 and 17 1974.
I 18 We were concerned primarily with the fact that 19 whether under certification that the plant is designed in 20 conformation with the FSAR, with the technical 21 specifications.
We discussed this at length with the 22 Philadelphia Electric Company'1ast Friday.
They spent the 23 weekend with General Electric and Bechtel going over it.
24 More importantly, they took their own station 25
' operators and went through the analysis to ensure to
4 11 1
themselves that the actual plant, to their satisfaction, meets 2
the Chapter 15 analysis.
3 We are convinced that they did a good job.
We are 4
convinced that this was an isolated case, in reality not 5
changing the analysis.
So our conclusions regarding the 6
analysis to us say that the plant does meet the Commission's 7
regulations and that this change was actually missed several 8
years ago a..a was not picked up.
But on looking back, we are 9
satisfied that the plant and the analysis are consistent.
10 MR. EISENHUT:
Tom, just to make it clear.
It was a 11 question over what was in the FSAR, not in the tech specs.
It i
12 really didn't affect the tech specs per se.
The FSAR both had 13 it right in the description of where they described the 14 systems and how the plant functioned.
15-For example, this system as it was described I 16-believe in Chapter 7 of the FSAR was correct.
You really get l
17 to it by Chapter 15, which is the accident and transient 18 analyses.
They do a considerable amount of evaluation to 19 conclude that they have identified the bounding analyses.
20 They did define the bounding analyses.
That really didn't 21 change by this issue.
22 The issue was that the change of the system in m
23 Chapter 7 that occurred many years ago was not picked up and 24 factored in as an input to the analysis in Chapter 15 as one 25 of the calculations that you go through to verify.
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As Tom said, since this issue came up last week,
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utility, by Bechtel, by GE, and by the' Staff looking at it, 4
that we are confident that it was an isolated case that really 5
.didn't affect the issue that is in Chapter 15.
6-Chapter 15, which is the accident analysis, really 7
.doesn't describe all the inputs and bounding conditions, 8
anyway.
But we thought it w'a s a pretty serious matter to the 9
extent we asked them to go back and reverify to us that this 10 was an isolated case.
And that's basically where we came 11 down.
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So even in the fairly 13 short amount of time that you've had on this, you are 14 satisfied that they have gone back and looked enough at other 15 aspects of Chapter 7 as compared to Chapter 15 to assure that 16
'this is in fact an isolated instance, there aren't other 17 instances in which the FSAR is internally inconsistent?
18 MR. EISENHUT:
That's right.
But not limiting it to 19 Chapter 7,
because the issue really isn't just a Chapter 7 20 issue.
21 COMMISSIONER ASSELSTINZ:
Yes.
22 MR. EISENHUT:
It was -- generally the way the 23 vendor does accident analysis, he uses pretty much standard 24' assumptions.
They do it for a topical method to the extent 25
'they can, and they change the input parameters as they are
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unique to this facility.
2 The issue on the parameter that we are discussing 3
here happens to be unique to Limerick and one other plant that 4
is yet to be licensed.
So all of the other standard plants, 5
the calculation would have been right, all of the other BWRs, 6
it would have been right.
7 So we really asked the question a little broader 8
than Chapter 7.
How do you know, assuming that Chapters 1 9
through 14, let's say, are correct and the description is those have 10 right and we have no reas on to question that 11 bee'n verified in a number of cases -- how do you know that all
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12 of the Chapter 15 analyses had the right physical descriptions 13 of the systems as well as calculational inputs?
And the only 14 physical description problem we came up with was the one in 15 question.
16 There were other changes where they were unique, it 17 was verified to be correct in the analysis.
So we looked at a 18-little broader context than even Chapter 7.
19 COMMISSIONER ASSELSTINE:
Okay.
20 COMMISSIONER ZECH:
Could this specific issue apply 21 to other plants throughout the country?
22 MR. EISENHUT:
It is my understanding this specific 23 issue only applies to the Clinton facility.
Is that correct,
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24 Tom?
25 MR. NOVAK:
That's correct.
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MR. EISENHUT:
And yet to be licensed.
And, of 2
course, we will be looking at that one also.
3 COMMISSIONER ZECH:
All right.
4 COMMISSIONER ASSELSTINE:
As a general matter, how 5
do you go about assuring that the other chapters of the FSAR 6
match the plant?
7 MR. EISENHUT:
Would -- maybe the region would like 8
to answer.
9 MR. MURLEY:
Aa a matter of fact, our inspectors 10 take the ?SAR and they start with that, and then the tech 11 specs and they walk down the plant.
And we concentrate on the f--s
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12 design chapters of the FSAR -- I guess it's 5,
6, 7,
8 and 9 13 and those chapters.
14 We in the region really don't get too much involved 15 in the Chapter 15 accident analyses because they deal with l
16 typically bounding cases, and that is what happened here.
17 Even though we found that there was a design difference, it i
18 didn't affect the bounding analysis.
i 19 So we tend not to focus too much on the Chapter 15.
20 But we do verify that the design aspects are accurate.
21 COMMISSIONER ASSELSTINE:
And since Chapter 7 is I
c 22 accurate, that's why the inspection program didn't pick this
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24 MR. MURLEY:
That's right.
I think I 25 MR. EISENHUT:
Oh, but the inspection
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1 should also give credit --
2 COMMISSIONER ROBERTS:
And it was found in the 3
region.
4 MR. EISENHUT:
It was found in the region by an 5
inspector verifying a comparison between the simulator and the 6
7 MR. MURLEY:
That's an interesting thing I think is 8
probably worth a second to' explain how.
They have a 9
plant-specific simulator at Limerick, and they were doing some 10 transi[nts, training their operators, and our inspector was 11 there watching them, and he found that the plant, tripped on a f
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12 particular transient, I guess in a couple seconds whereas the 13 FSAR said it was supposed to be almost a minute, roughly.
And 14 so he asked what's the reason for all this.
And that's how he 15 found it.
16 I'm proud of him for picking that up, and I think 1
17-this is an example where we can use the simulator and it's a 18 better representation of the transients than the bounding 19 calculations in Chapter 15 to look for these kinds of things.
20 So, Commissioner Zech, in answer to your generic 21 question, even though only Clinton may be only affected by 22 this particular change, there may be others, and I think we 23 can use the simulator comparison to..elp us look for these 24 kinds of things.
25 COMMISSIONER ZECH:
Well, it certainly does give you
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1 an excellent example of the value of the simulators.
2 MR. MURLEY:
Absolutely.
3 COMMISSIONER ZECH:
No question about it.
4 COMMIS570NER ASSELSTINE:
Apart from the forunate 5
instance in this case, where the inspector using the simulator 6
was able to find it, have you thought about, particularly NRR, 7
how you are going to go about making sure that this kind of 8
thing doesn't crop up in other cases in terms of the 9
relationship between the accident analysis and the balance of 10 the FSAR?
11 MR. NOVAK:
Well, let me speak to that.
We do, a;
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T 12 part of the review of the accident analysis, go back and 13 confirm that the selected setpoints for reactor trip and so 14+
forth as described in other portions of the plant are proper, 15 so there is that continuity.
16 This case is kind of unique in the fact that, one, 17 when you do simulator runs, you try to represent the plant as 18 you intend to operate it.
Now they were intending to try to 19 look at what is the response to the plant in the event of loss 20 of offsite power or loss of station auxiliaries from 25 21 percent power.
22 The reason they were looking at this, again to the 23 credit of the Licensee, a similar event had happened at the 24 Susquehanna station and, in fact, resulted in a short, brief 25
' station blackout.
And so they were concerned and wanted to
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i know how would their plant behave and how would they respond 2
and restore it.
3 So they worked at it in getting the system simulator 4
.to a point where they could then take these transients and go 5
back and look at them, 6
So you'll use the simulator as a learning tool and 7
try to understand it.
8 As far as the FSAR is concerned, we do look at the 9
bounding events.
Now you will never he able to get into the 10 lower layers of the more standard transients, because they are 11 what we would call more like best estimate.
The Chapter 15
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But I do think in terms of the specific parameters, 14 they are checked in terms of that.
15 COMMISSIONER ASSELSTINE:
Are you saying that absent 16 the kind of effort the Licensee put in, in terms of 17 programming and using their simulator, and absent the kind of 18 effort that our inspector put in in finding this, that we 19 wouldn't have found it under our normal review?
20 MR. EISENHUT:
I'm not sure we would.
I don't think 21 we look at that kind of detail on inputs as a general rule.
on the other hand, I think 22 That's not to say, though, that 23 we do need to go back and take a look to see if there is some 24 way we ought to be changing things.
25 We have been for a number of years highly
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1 compartmentalized in the way we do the review.
We do the 2
technical detailed review in one system, and another system, 3
when you get to the analysis people, they basically take the 4
assumptions and inputs as givens.
They don't go back and 5
correlate "are those the right inputs from the systems people 6
.who did the systems review," and the systems people who review 7
the thing don't necessarily go to the accident analysis.
8 So I think it is something that we want to look at 4
9 as how they marry together.
And I'm not sure, though, that we 10 are, as Tom said, going to get back to that kind of level and I'd like to see a plant-specific 11 depth.
But a check 12 simulator be used as a check to the system.
In this case it 13 weas fortunate, we do have a very good plant-specific 14 simulator.
We don't have that in most places around the 15 country.
16 COMMISSIONER ASSELSTINE:
I \\t h i n k it's worth looking 17 at, I think what the Staff did in this case is very good, and 18 what the Licensee did was very good.
But the fact is we don't 19 require simulators.
Some plants don't have them.
I mean it 20 does look like this was a fairly good effort on the part of 21 the licensee to use their simulator, and then a good effort by 22 a perceptive inspector to spot this kind of thing.
And I 23 think it's worth taking a look at, maybe giving us a paper on a
24 if you don't have that, then what are the implications for our 25 ability to spot these kinds of things; or conversely, is this
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1 a reason why maybe we ought to take the step that we haven't 2
taken so far and saying everybody has got to have a simulator, a
3 or with few exceptions.
Maybe some of the smaller, older 4
plants.
I think it's worth looking at.
5 COMMISSIONER BERNTHAL:
Yes, I have to say, we sit it's not quite year after year for 6
.here month after month 7
me yet, I guess, but at least for two years -- and everybody 8
says that we don't require having a simulator, but we all 9
agree and everything we say indicates that everyone should 10 have a simulator, and it kind of makes me wonder why we don't 11 bite the bullet and address that issue one of these days.
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12 COMMISSIONER ASSELSTINE:
Yes.
In fact, I agree 13 with you, Fred.
I'd sort of like to see a paper on - that A
14 particular issue.
Maybe we ought to do something about it.
15 MR. EISENHUT:
Well, you certainly have to look at o
16 it in the broadest context, because we do not do a 100 percent 17 review of FSAR detailed analyses by a figment of anyone's l
18 imagination.
And we never will.
We just do it as a 19 spot-check.
20-MR. RUSSELL; I might just point out to the 21 Commission as a part of the r,ulemaking --
22 COMMISSIONER ROBERTS; For the transcript.
We all m
I 23 know you.
24 MR. RUSSELL:
This is Bill Russell.
25 For the proposed rulemaking that's out now that's in
20 1
the comment period, we will be requiring the use of a t
2 simulator for examination of operators.
That package is going 3
through CRGR comment section this month, and we expect to have 4
a package down to the Commission shortly.
5 MR. EISENHUT:
Well, let's see, Bill, just to make 6
sure, that is not requiring a plant-specific detailed 7
MR. RUSSELL:
No, it requires a simulation facility, 8
but in fact all the facilities with the exception of about 9
eight are going to an ANSI 3.5 replica simulator within about
~
10 three years.
So it's a small number and it is generally the to' a simulation-11 smaller facilities that are going to go 12 facility where you'd use a walk-through plus a fundamental 13 simulator.
l
~
14 COMMISSIONER ROBERTS:
Let rae suggest, this is an 15 1.nteresting subject, but I think we're straying from the 16 subject in hand.
We've spent almost 30 minutes and we're on 17 page 4,
so let's try to proceed.
18 Claughter.]
i 19 COMMISSIONER ASSELSTINE:
I do think 20 COMMISSIONER ROBERTS:
I agree, but for another 21 time.
22 COMMISSIONER ASSELSTINE:
Let's see a paper as a e,
23 separate matter that addresses the question directly.
- l.-
24 COMMISSIONER ROBERTS:
Let's proceed with Limerick.
25 COMMISSIONER ZECH:
I think that Darrell's
i e
f I
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1 absolutely right, and I agree with Commissioner Asselstine's
.2 thought that we should learn from this lesson and perhaps your 3
procedure should be reviewed, and I think that's.what you're 4
telling us, and I agree with that.
5 MR. NOVAK:
The next topic was referred to as the 6
severe accident risk assessment.
That was the probabilistic 7
risk assessment that the Licensee did and that was his title 8
for the report.
It was a full scope PRA.
It looked at both 9
internal and external events.
I'd like to summarise just very briefl[some of the things that we see of benefit to this 10 11 work.
i
. m/
12 First of all, it really provided additional evidence 13 that thea design was sound.
It gave you that confidence.
14,
_Second, there was clearly a benefit to the utility.
15 It put him on a very steep learning curve about his plant.
He 16 was able then to better understand it and to do a number of 17 things about it.
As he went through this design and the PRA 18
~ work, he could see where changes could be made into the plant 19 design that would clearly improve the risk of operation:
20 things that are not very major, but you could go back in and 21 look at the ventilation system for a specific room and decide 22 that it would be better to provide additional ventilation to 23 that system, 24 You looked at valve performance and see where 25 changes in valve performance could improve the operation of
r--
1 j
s i
3 22 A) i that plant.
2 So we were very positive that this piece of work did 3
really check out the plant, put the Licensee on a very good 4
learning curve in understanding it, and reduced the risks of 5
operation.
6 This PRA is going to continue.
The Licensee is 7
committed to maintain it.
What he is doing now and will 8
continue to do for the rest of the year is to update it to 9
clearly reflect the latest cenfiguration of the plant.
10 He will then put it into his training program, he 11 will then put it into his maintenance program as appropriate.
i 12 So we are very positive on this effort, and I think it is to 13 his benefit.
14 With regard to emergency preparedness -- may I have 15 the next* slide, please.
16
[ Slide.]
17 I think I can sum up this slide in a few sentences.
18 FEMA has provided a finding that offsite emergency 19 planning and preparedness is adequate and can be implemented.
20 Based on this finding 'and on the Staff's previous assessment 21 of the adequacy of onsite planning and preparedness, the Staff 22 concludes that the overall state of emergency preparedness
.s 23 provides reasonable assurance that adequate protective 24 measures can and will be taken in the event of an emergency at 25 Limerick.
.t
?
I 23
,~\\
,' )
~s-1 In three ASLB Partial Initial Decisions, the Board 2
found in favor of the Applicant on all emergency planning 3
issues.
Two conditions concerning offsite traffic control and 4
unmet municipal staffing needs ws specified as requiring 5
resolution prior to operation abov 5 percent of rated power.
6 Based on the information provided by FEMA, the Staff 7
has concluded that the two Board conditions have been 8
satisfactorily resolved.
9 In the most recent Partial I n i t i'a l Decision, issued 10 on Jul 22 of this year, the Board found in favor of the
.11 7pplicant with regard to contentions related to the adequacy fs
- f i
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/
12 of the emergency plan for the State Correctional Institute at 13 Graterford.
14 In response to the Commission guidance related to 15 Garde vs. NRC decision concerning offsite medical facilities, 16 the Applicant has confirmed that the offsite emergency plans 17 contain a list of medical service facilities.
The existence 18 of such a list in the offsite plans has also been c on f i rrae d by 19 FEMA.
20 The Applicant has also committed to fully comply 21 with the Commission's response to the court decision.
22 Lastly, the Applicant has submitted a request for an 23 exemption from the regulatory requirement for the c o.n d u c t of a 24 full participation exercise within one year before licensing 25 of full power operating license.
One year ran out last G.m.,,,,,,,,,,.,
~
24 4
j t.
4 1
month.
This request, which has been filed with the 2
Commission, was referred to the Director of NRR by the 3
Commission, and the NRC Staff has found that the granting of 4
the requested exemption is appropriate.
5 I think that summarises for us the emergency 6
planning issues.
7 COMMISSIONER BERNTHAL:
As a matter of curiosity, 8
it's been some time -- I guess a year or so since I visited 9
that plant -- but I asem to recall there was a major freeway 10 about to go right in front of the plant site.
And I wondered 11 at the time whether that affects the entire emergency planning 12 picture in any way.
One would presume positively.
But it 13 wasn't finished at that time.
Does anybody know about that?
14 MR. MURLEY:
The freeway is finished, I can say 15
- that, 16
[ Laughter.)
17 1 don't know how it has affected the timing 18 analysis.
Perhaps someone from I&E -- I just don't know about 19 the analysis.
But it's bound to be better.
20 COMMISSIONER B E R!1 T H A L :
The analysis had to have 21 been finished before that road waa done, and you have now got 22 four lanes of super highway that weren't there before.
I'm 23 curious whether that makes a difference, 24 MR. MATTHEWS:
Just based on the available 25 information that one of the Staff members informed me of, that
3
]
25
(:
A 1
evacuation time estimate had been completed prior to the 2
completion of that freeway.
Therefore, you would only assume 3
that the availability of it would probably reduce those times.
4 However, the issue of traffic control is something 5
that was resolved with regard to plans for control of 6
personnel leaving the EPZ is something that was just recently
-7 completed.
So I would have expected those plans to have 8
incorporated the existence of that freeway.
9 This was Dave Matthews of the NRC Staff.
10 MR. NOVAK:
May I have the next slide, please.
11 CSlide.3 A
12 And turn it 90 degrees either way.
Thank you.
k,,)
13 COMMISSIONER ROBERTS:
Not either way.
14 CLau'ghter.1 15 MR. MURLEY:
Thank you.
16 Wo.would like to spend a minute talking about the 17 supplementary cooling water system.
Before I ask Bob Martin, 18 the project manager, to describe it, let me first say-that 19 none of this water is needed for any safety consideration at 20 the plant.
The plant does have a dedicated pond.
We refer to 21 it as the ultimate heat sink and it would provide necessary 22 cooling for a 30-day period following any design basis 23 accident.
24 The water we are going to talk a b o,u t now is strictly 25 for operation of the plant It's what you put through the
.i i
26 e
1 condenser, and I would like Bob just briefly to walk you 2
through the status of this design.
3 MR. ROBERT MARTIN:
As Mr. Novak just mentioned, the 4
supplementary cooling water system is a system for 5
transferring water from the Delaware River over a linear 6
distance of some 30 approximate miles to the Limerick plant 7
near Pottstown.
8 The system is comprised of basically the Point 9
Pleasant Pumping Station on the Delaware River with piping 10 going Op to Bradshaw Reservoir.
This portion of the system is 11 the portion which is the subject of the Neshaminy Water (3
4\\_
12 Resources Authority responsibility in Bucks County and the the status of construction is currently 13 system is currently 14 incomplete.
And the further schedule on it is pending the 15 progress of proceedings between these agencies and the 16 Philadelphia Electric Company.
17 Once a decision has been reached on completing the 18 construction, it's estimated it would take approximately nine 19 months to physically complete the construction on it.
20 COMMIS.SIONER ASSELSTINE:
Has construction started 21 on that portion?
22 MR ROBERT MARTIN:
Construction has been partially
)
23 completed on it, yes.
All of the work in the river has been 24 completed, and some of the foundation work on the pumping 25 station itself has been completed, and at that point it was
s s
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27 1
stopped some time ago.
2 The portion from the Bradshaw Reservoir and the 3
transmission main is being constructed under the 4
responsibility of the Philadelphia Electric Company, and at 5
this time Philadelphia Electric is proceeding with getting the 6
needed permits and so forth from, for example, the Army Corps 7
of Engineers and other agencies as necessary to complete it.
8 COMMISSIONER ASSELSTINE:
Has construction on that 9
been started?
Or do they need the permits first?
10 MR. ROBERT MARTIN:
I believe portions of it have, 11 but it has not been completed yet.
T I
12 COMMISSIONER ASSELSTINE:
Okay.
And how long sill r
13 that take to complete?
14 MR. ROBERT MARTIN:
I believe it would be less time 15 than it would take to complete this.
16 Mr. Boyer?
17 MR. BOYER:
It would take about the same time or 18 possibly a little bit longer, and work has not been started.
19 We have done some preliminary blast survey work in preparation 20 for start-up, but we are waiting for the decision by the 21 Commonwealth Court on the appeal for the Print Pleasant 22 facility.
23 COMMISSIONER ASSELSTINE:
Okay.
Thank you.
24 MR. ROBERT MARTIN.
And then once the water 25 has flowed down the east branch of the Perkiomen Creek, it
{; i 5.
1 would arrive at the Perkiomen Pumping Station and be 2
transported through the pump line to the Limerick plant to go 3
into the basins of the cooling tower.
4
_This portion of the system has been completed and is 5
currently operational 6
COMMISSIONER ASSELSTINE:
Okay.
7 MR. NOVAX:
Thank you.
8 I would now like to turn the rest of the discussion 9
over to Dr. Murley.
10 COMMISSIONER ASSELSTINE:
Are you going to talk 11 about any water restrictions that apply at the present time to es
\\s,)
12 operation of the plant?
13 CCommissioner Bernthal left the conference room.3 14 MR. NOVAK:
We can, yes, sir.
15 COMMISSIONER ASSELSTINE:
That would be useful to 16 hear just briefly.
17 MR. ROBERT MARTIN:
The restrictions on withdrawal 18 of water from the Schuylkill River are restrictions imposed by 19 the Delaware River Basin Commission upon Philadelphia 20 Electric's withdrawal of water from the Schuylkill River.
21 They are principally active during the warm weather summer 22 months and conditions in the river are unsultable from an 23 environmental standpoint to permit withdrawal of the water.
24 When the plant arrives at that point, that's when 25 they would have a need for supplemental water from another
I 3
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source.
2 COMMISSIONER ASSELSTINE:
I was there, I guess, in 3
late spring and the restrictions, I think, were in effect at 4
the time.
They are still in effect, I take it, and will be 5
until this fall some time?
6-MR. ROBERT MARTIN:
That's correct.
The 7
restrictions this past spring were temperature limit, which 8
the Philadelphia Electric approached the Delaware River Basin 9
Commission on and got some relaxation in that they went to a 10 dissolved oxygen limit.
Temperature was intended to protect 11 the dissolved oxygen limit, basically.
That gave them a
\\/
12 little bit more flexibility.
13 There's also a flow r a't e limitation which, depending 14 upon how much water is in the watershed, is sometimes 15 exceeded.
16 COMMISSIONER ASSELSTINE:
Assuming the present 17 restrictions in force, how much operation and at what power 18 levels can the plant operate under, using the present water 19 restrictions as a limiting factor?
20 MR. ROBERT MARTIN:
Assuming the restrictions in 21 force today, they don't have very much flexibility.
- However, 22 Philadelphia Electric has applied to the Delaware River Basin 3
23 Commission for a swap of water currently allocated to two 24 other power plants on the river.
I understand that that 25 meeting of the DRBC is to take place possibly tomorrow, and we
o' i
30 s.
(
1 would learn the outcome of that.
2 That would provide, if the PECo application were 3
granted, a sufficient amount of water for them to get up to 4
approximately120 to 25 percent power level in,their start-up 5
test program.
6 COMMISSIONER ASSELSTINE:
For what period of time?
~
7 MR. ROBERT MARTINI That would give them B
approximately four weeks of start-up testing.
9 COMMISSIONER ASSELSTINE:
Okay.
And under the 10 present restrictions you say not very much, which is 11 MR. ROBERT MARTIN:
I would estimete substantially k#
12 less than that, yes, 13 MR. EISENHUT:
5 percent or less.
They did complete 14 the 5 percent testing program, but 15 COMMISSIONER ASSELSTINE:
So under present 16 restrictions, they couldn't do much more than what they've 17 already done?
18 MR. EISENHUT:
I would think that's correct.
And I 19 think two other comments.
As Bob said, this is during this 20 period of the year.
21 COMMISSIONER ASSELSTINE:
Right.
22 MR. EISENHUT:
Of course,'when you go into the fall
}
23 part of-the year',
the situation would be changing.as a 24 function of time.
25 COMMISSIONER ASSELSTINE:
Right.
L
1 e
1 I
{
31
.s 1
MR. EISENHUT:
Because of the -- one other issue I 2
ought to point out, and Ed Christenbury can correct me or help we used to regulate in fact temperature controls, 3
me 4
environmental limits, chlorides, different parameters in the 5
cooling supply.
Even though that's not directly a 6
safety-related system.
In fact, it's not a safety system at 7
all.
We used to do that.
'It evolved over time to the point 8
where today we are not putting those restrictions on.
We are 9
relying on other federal agencies which govern the 10 supplemental cooling modes.
11 Ed, would you want to make any comments on how that 12 works?
13 MR. CHRISTENBURY:
Well, I think in this case there 14 would -- I guess we had discussed among ourselves whether 15' there would be a need for any license condition that would 16 reflect the limitations placed on the Delaware River Basin 17 Commission.
I guess our thinking now is that probably that 18 would not be an approach we would recommend, nor did we 19 include'in the license.
The practice, as Darrell indicated, 1
20 that we currently follow is that where another federal agency 21 or entity has their own federal regulatory powers and i
22 enforcement powers, we rely on them to handle those papers, s
23 (Commissioner Bernthat reentered the conference 24 room.)
25 COMMISSIONER ASSELSTINE:
And you are satisfied they
3 '~
I
'f D 1
have sufficient authority to impose and enforce those 2
restrictions on their own initiative?
3 MR. CHRISTENBURY:
Yes, we are.
4 MR. EISENHUT:
Well, that's correct.
Either way, 5
there is no safety way.
If they don't take the water out.
6 they can't operate the plant.
If they do take the water out, 7
they operate the plant, but they're in violation of another 8
law, but that's not necessarily a safety issue.
9 COMMISSIONER ASSELSTINE:
Yes.
What is the status
'~
10 of the appeal on the Point Pleasant diversion?
Are they 11 awaiting an imminent decision, or is.it k,N
/
12 MR. CHRISTENBURY:
PECo could probably tell us.
As 13 you recall, the Court of Common Pleas ruled in favor of PECo 14 and that has been appealed.
There's an automatic stay of that 15 decision because it's a state entity, and I'm not certain 16 exactly where that stands.
17 COMMISSIONER ASSELSTINE:
Maybe I can cover that' 18 briefly.
Okay.
Thanks.
19 COMMISSIONER ZECH:
What you're saying, though, is 20 that even if full power is authorised, there are other 21 restrictions on the plant which could prevent them from going 22 to full power?
23 MR. EISENHUT:
That is correct.
As a matter of 24 fact, the best information we had was that there is a meeting 25 tomorrow of the DRBC.
That commission, as !-understand, had
A h
s 3
f)'
t
)
1 in fact delayed its decision on whether or not to grant this 2
interim relief to Philadelphia Electric who, as I understand 3
it, has. requested authority for the withdrawal of water to 4
-swap.from some of their own fossil plants to their nuclear 5
plant on the Schuylkill River, and it delayed that decision 6
until tomorrow.
That decision, if favorable, and if a full 7
power license would issue, would get them up to 20, 25 percent 9
power testing, covering about a month.
And then they'd have 9
to wait and see what would be the decisions at that time, 10 after that month, or where you'd stand from a weather 11 standpoint or a water supply standpoint before you'd really r~s 12 know precisely where they go after that.
13 COMMISSIONER ASSELSTINE:
Afe there other things 14 that the Basin Commisskon could do beyond that that would 15 permit power level, or is it basically 20, 25 percent until 16 the weather changes and the rains come?~
17 MR. EISENHUT:
I suppose they could do just about 18 anything they want to, but I'd certainly defer to Philadelphia 19 Electric.
20 COMMISSIONER ASSELSTINE:
- Okay, 21 MR. MURLEY:
Could we move to slide 10, please.
22 CS11de.3 23 I am going to start off with some general management 24 matters.
25 The bottom line is that'the regional staff believes
m
+
3 4
O 14 34 v
1 Philadelphia Electric Company is ready to operate Limerick 2
safely at full power.
Philadelphia Electric is a large, 3
well-staffed, experienced utility.
They have 20 some years of 4
nuclear experience, going back-to Peach Bottom 1,
which was an 5
HTOR licensed in 1967.
6 Peach Bottom 2 and 3,
which are boiling water 7
reactors, were licensed in 1974.
8 Some of their managers and operators in fact were 9
licensed on Unit 1 back in those days.
So they bring to it a 10 large staff.
11' A major strength, we find, is their large C
12 engineering and construction management staff.
Because of the 13 depth of talent in this area and their QA area, the 14 construction of Limerick went relatively smoothly.
And Rich 15 Starostocki is going to talk about that in a little more 16 detail.
17 Now the same organizational strength does not 18 necessarily carry over into plant operations, however.
There 19 have been some problems at Peach-Bottom and at Limerick during 20 the last year, and Rich is going to discuss those problems and 21 what we've done about them.
22 With regard to enforcement history, Philadelphia 23 Electric has had four civil penalties in the last three j
24 years.
This is s omev'h a t above the average in the region.
25 Most of these enforcement actions were taken for events at
=
s
.}
35 1
Peach Bottom, however.
2 There was one problem at Limertek that had to do 3
.with the contract security foroe, which I should talk about.
4 They contract out their guard force activities to Yoh 5
Securities.
We found that the root cahse of this problem was 6
inadequate control of their contractor force.
And we also 7
found a similar problem at Peach Bottom, where they had a 6
health physics contractor that was helping them in the pipe 9
replacement at Peach Bottom 2, and we found problems there, 10 and we think that there is a broader problem with the company 11 in controlling their contractors.
12 That was the basis for a civil penalty within the 13 last few months.
We have discussed this with the utility and 14 they agree that there's'a problem and they have taken some 15 actions.
16 With regard specifically to Limerick, the issue was 17 inadequate training of the guard force and programmatic 18 deficiencies in their security. program.
19 We've talked with then, we've had enforcement 20 conferences.
Philadelphia Electric has taken steps to 21 strengthen their onsite management of the contractor at 22 Limerick, and they're required Yoh Securities, the contractor, 23 to provide more corporation oversight.
/
24 So we went back in April to take a look at and 25 reinspect the security program.
We used a sampling technique
t s
i
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.s 36 i (.
l \\
l 1-to have selected members of the guard force retest it, and all 2
but one group tested acceptably.
That one group did have an l
3 unacceptable failure rate on the exam, so we made them be 4
retrained and requalified.
5 So our conclusion today i s that the security force 6
personnel are sufficiently knowledgeable to carry out their',
7 duties.
8 We also believe that_ the management improvements 9
that were taken by Philadelphia Electric should maintain this 10 oversi ht to prevent recur'rence of the problem.
11 COMMISSIONER ASSELSTINE:
Tom, let me ask you, my o
n
%/
12 recollection is this is not the only place where we've seen 13 some problems with this contractor.
Has the Staff thought 14 about, apart from what you've done in this particular case to l
15 satisfy yourselves of the afoquacy of this group here, taking i
16 sort of a step back and taking a broader look at this 17 particular contractor's performaner-in a number of areas, and 18 asking yourselves what does this mean about the performance of 19 that organisation at a number of sites?
20=
CCommissioner Roberts left the conference room.3 t
t 21 MR. MURLEY:
Yes.
I'd like to ask Tim Martin, my 4
22 regional director, to talk about that for a second.
1 23 COMMISSIONER ASSELSTINE:
Yes.
i i
24 MR. T!M MARTIN:
Yes. Tim Martin.
We took a look at l
l l
25 the Shoreham plant, at the security organisation there.
We i
I
(-
}
l)
'i J.
37
.3 l
.)
v.;J 7
1 also did the same thing at the Salem plant.
And in both cases 2
they had had problems, but they had turned their situations j
3 around.
4 COMMISSIONER BERNTHAL:
Who had turned the situation 5
around, the --
'6 MR. TIM MARTIN:
The Licensee.
'7
' COMMISSIONER BERNTHAL:
You know, I have to say that e
I guess ! don't know exactly what-freedom we have to 8
the 9
discuss the O! investi2ation in this matter, but it strikes me 10 that~th record of that particular contractor goes beyond the 11 point of sloppiness and oversight at this site, let alone what l' %
9 12 problems there may have been at other sites.
Am I wrong?
13 MR. TIM MARTIN:
You're not wrong, but I don't know 14 what freedom I have to discuss the 01 investigation, either.
15 COMMISSIONER BfRNTHAL:
Can anybody tell me what 16 freedom we.have to discuss the O! investigation?
17 MR. EISENHUT:
Well,'let's see, I talked to
~
18 discussed the matter with Ben, Hayes yesterday,'and I don't-19 think Ben is down this morning, but because of the present 20 status, we felt that at least preliminarily if we got into 21 this, we ought to have a closed session to discuss it.
I 22 COMMISSIONER BERNTHAL:
! see.
I i
23 COMMISSIONER ASSELSTINE:
Maybe what we ought to do l
24 is think about as a separate matter having a session to talk l
25 about this kind of a situation and the performance of the
1
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(
.)
't 4
38 X
1 contractor.
I would support something like that.
2 CCommissioner Roberts reentered the conference l
3 room.3 4
MR. TIM MARTIN:
Keep in mind, though, I think we l
5 have to maintain the pressure on the Licensee in the first 6
instance to make sure his contractors are doing the job, and 7
that's what we've done, in the case of Salem and Shoreham and l
8 Philadelphia Electric.
9 COMMISSIONER ASSELSTINE:
That's certainly true, but 10 at the same time when you see a contractor that operates at a 11 num'ber of sites and you see a pattern of activity that is of O
12 significant concern, then it seems to me that this sort of 13 case-by-case chasing around from site to site and 14 MR. EISENHUT:
Th,at is correct.
cleaning up the 15 COMMISSIONER ASSELSTINE:
l 16 problems may not be the whole answer.
i 17 MR. EISENHOT:
We have in fact also conducted a f'
16 survey where this guard force is, at what plants it is, and l
19 COMMISSIONER ASSELSTINE:
Well, that's the other l
l 20 thing, you're looking ahead.
21 COMMISSIONER BERNTHAL:
I want to emphasize that I I
I 22 don't doubt for a moment that PEco is doing everything they
)
23 can.
It's in their great interest, their great self-interest, l
24 to deal with the problem, and from my experience and 25 discussions with the management up there, they are a very
l 39 l[
and therefore, this is a 1
capable organization.
But l
2 second-order.NRC problem.
Our first-order dealings are with 3
the Licensees themselves.
But we are getting a pattern here i
4 of a contractor that seems not to be performing up to maybe we should talk about that in closed 5
standards, and I 6
session a little bit, but it seems to me it bears some special 7
consideration by the Commission, 8
CCMMISSIONER ASSELSTINE:
I agree.
9 MR. TIM MARTIN:
Just some additional information.
4 10 Tim Martin again.
11 Because of PECo's involvement with Yoh, they did 6
12 require some changes in the corporate staff of Yoh, and those 13 not only addressed the Limerick site, but the other sites that 14 the Licensee or the contra'otor is responsible for.
15 They have also brought on a vice president of 16 nuclear operations which is a former NRC inspector out of 17 Region !!, and at least to our perspective at our three 18 plants, the contractor's performance under the oversight of 19 the Licensee has improved substantially.
l 20 MR. MURLEY:
Okay.
Moving on.
We have received, 21 just on Tuesday, a late allegation that was relayed to us 22 through a reporter, that some safeguards information on the
)
23 Limerick plant was not being properly protected.
We sent an 24 inspector -- a couple of inspectors out yesterday and looked l
25 into this, and we determined that the material provided by the
s-0
+
A
'n v
i reporter to us is not safeguards information.
l 2
But it does raise another question, and so we are 3
going to investigate further to assure ourselves that 4
Philadelphia Electric has adequate controls over safeguards l
5 information.
6 We believe this allegation does not meet the test of 7
safety significance that's in the Commission's policy S
statement on handling late allegations and, therefore, should 9
not hold up licensing action.
10 COMMISSIONER ASSELSTINE:
Do the questions tend to 11 center on the Licensee or its centractor or a mix of the two?
ksl 12 MR. MURLEY:
Well, the nature of the allegation is s
13 such that the alleger, who is to us at least still anonymous, he's 14 said that he has some material here that is safeguards j
15 an ex-security guard,.as a matter of fact, is our 16 understanding.
He has some material that are like plot plans 17 of the site and some drawings which we have determined are 18 fre'ely available in the FSAR or the Public Document Room, 19 otherwise.
20 COMMISSIONER ASSELSTINE:
Okay.
21 MR. MURLEY:
So we satisfied ourselves that he does j
i 22 not have safeguards information.
But it does raise the
')
23 broader question and we are going to satisfy ourselves that
_/
24 they have adequate controls generally.
i 25 COMMISSIONER ASSELST!NE:
Okay.
L
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k l
l l
41
'.v)
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l 1
MR. MURLEY:
There are no other outstanding I
2 allegations on Limerick, and I do understand that the 3
Commission has been informed by O! of the status of 4
investigations regarding_ Limerick.
5 I would like Rick Starostocki now to talk about the l'
6.
construction and the operation.
I 7
MR. STAROSTECKI:
I'd just like to very quickly go
{
l l
l 8
through an overview of the construction situation at Limerick, 9
and then address preoperational testing and start-up testing.
10
'The construction overview we conducted in October --
11 would you put up slide 89
'w 12 CSinde.3 13 In October, prior to issuance of the low power 14 license, we prepared a report that looked specifically at 15 construction and at QA and our recommendation to NRR.
And we 16 have had a number of reasons to sit back and say, okay, what 17 have we really seen from all the inspections we've done?
We 18 have put over 15,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> of inspection time at Limerick, 19 What we find is that through a variety of mechanisms and in particular we've seen it on our team inspections 20 21 where we've got a variety of disciplines going into the plant is that the organisation is pretty well controlled by f
22 l
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23 Philadelphia Electric Company, and that there is a very good l
24 integration of quality assurance and quality control into the 25 work activities on the construction site.
L
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v 42
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We have had a resident inspector assigned to the i:
2 Limerick site since 1979, so we have been able to verify 3
through the day-to-day activities that the QA/OC people are 4
doing the audits frequently,,
inere's a number of stop-work 5
orders'that we find have been used effectively by PECo and G
their contractors, especially when the activity levels were 7
high in the '82 '83 timeframe.
8 All these details we have put forth in the October 9
25 assessment, so I won't dwell too'much on those first two I
10 bullets.
11 It is of interest to note that in 1979-we did a SALP N
k 12 for construction and identified one Category 3 in the QA area, 13 and I think it is to FEco's credit that t' hey were able to turn 14 that around, and quality assurance has been a strength in the 15 construction SALPs since*then.
16 We have had no Category 3 areas at Limerick for the 17 SALPs in the four years that we have done them at Limerick, 18 other than the first one on quality assurance.
So we have'had 19 fairly consistent performance with very good management 20 oversight of the major contractor, which has been Bechtet, 21 This, in our judgment, has somewhat led to, ! think, 22 a favorable situation on allegations, We had about 28 23 allegations at Limerick over the period of construction, t
24
.Limertok has had no special allegation management system, but i
25 the pattern that we see at Limerick has been.the same pattern f
J
~
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s 43 t
1 we saw at Susquehanna and somewhat the same pattern we're 2
seeing at Hope Creek.
The major contractor on the site is t
3 Bechtet.
All three sites have very strong Licensee-management 4
involvement with the crafts and the laborers, and the 5
termination of large numbers of these workers has been done in f
6 a very organised and structured fashion, 7
The number, nature and analysis of the allegations 8
shows that there is no one area that predominates.
We have 9
had, for example, three allegations from the Bechtel engineers to in San Francisco that we followed up on that affected all 11 three of those plants that 1 just mentioned.
And we were able O
12 to, over the course of the year, with the help of both NRR and 13 1E, either resolve the issue or not substantiate the 14 allegation.
l 15 So the allegations are clearly indicating to us t
l 16 that, yes, when people have a concern, they get them elevated 17 to the right people within the organisation.
We have referred 14 several allegations to the Licensee for disposition, and based 19 on our follow-up of their handling of those-allegations, we 20 are satisited,that they do a good job on the technical end of 21 it.
t 22 With that, I would say from a construction overview 23 standpoint, I'd like to go to the next silde and address what 24 started happening after we left the construction area.
25 Preoperational testing really was our first look at L---
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44
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how does the utility organization pull together and prepare to 2
do all these tests, and it's our first real look at how the 3
operating staff, the licensed operators and the auxiliary 4
operators pull together with management in the preparation and 5
conduct of all these tests.
6 We've had no significant hardware problems 7
identified during any of the preoperational start-up test 9
programs.
I think just to elaborate a little bit, during the 9
preoperational and start-up tests, the regional inspectors 10 focused very much on the FSAR chapters that describe the 11 systems in preparing their inspection plans on what to be 12 observing.
And it's sort of a cascading type situation, as 13 you get through each of the chapters, you then start looking 14 more at the integrated response about this point in time with 15 the power escalation program.
16 The performance of the test review board was notable 17 strength.
We have had several meetings with the Licensee over to the preparations for these pre-op tests and the conduct of 19 them, because we've had some engineers espressing concern to 20 us over the long hours that people do work when these tests 21 are done, and a lot of things have been resolved over the last 22 year in terms of the adequacy of how the tests were done and 23 the manner in whtoh test exceptions were reviewed and allowed, 24 The test review board is ln fact a strength in that 25 that's where the ut'.11ty management gets involved with the m
2 m
il t
a 45 w-1 conduct of their program, to make sure it was done right, r
2 Things, I think, really were demonstrated quite 3
aptly with the turbine roll.
The preparations for the turbine 4
roll again are strength in that people were trained and l
\\
5 management was involved, the simulator was used, and the 6
turbine roll was,'I think, a unique, novel, first-of-a-kind I
a 7
activity that was performed without any really difficulty or o
problema arising.
9 During the later stages of the pre-op test, we 10 starte seeing indleators that we were not happy with.
In 11 parttoular, the resident inspectors would walk into the
~N 12 control room and find situations that they were not happy i
13 with.
In particular, they would find systema out of
}
14 commission or components out of commission that would force 15 the operators to take certain compensatory actions in 16 accordance with the tech speos.
And that was really the 17 genesis of our concern, that what we call personnel errors 18 we were seeing a lack of familiarity with the technical 19 speoffloations, t
20 In hindsight, that's to be understood, in that the l
21 technical specifications for Limerick are much different than 22 the ones for Peach Bottom.
And it took some time for.the 23 people to become more aware of the limitations imposed on 1 hem 24 by these newer toch spoos.
25 COMMf85!0NER ASSELSTINE:
! take it the concern was
r
("%
46 Q) i the conditions were such that they should recognise the 2
situation'they were in, and they weren't recognizing it?
3 MR. STAROSTECXI Exactly right And because the 4
resident would walk in there and say, "What about this?
5 Doesn't this tech spec control you in this regard, and 6
shouldn't you be doing something about i t?"
And the answer i s 7
yes.
8 And 1 make that point simply, that's really the 9
genesis of our concern about operator error.
That was further 10 confirmed when we started seeing technician errors with 11 surveillance tests and the way some other problems were
,L 12 handled.
13 Eventually it manifested itself through LERs, And 14 the point I'm just trying to make is there's a learning curve l
15 that the people at Limerick had to go through, and today we i
16 are more confident about the operators because the corrective 17 actions were taken.
You can walk into the control room today l
18 and you have a much greater degree of confidence when you talk 19 to those operators about, one, the tech specs they're familiar l
20 with, two, hardware changes have been made, so the 21 surveillances are being done better, i
22 But I want to put the issue in the proper context i n r
1 23 that we're not saying we're fully satistLed with everything 24 that's been done.
The LER analysis shows that there are fewer 25 LERs, but that's to be expected.
There have been. fewer 9
a
e i
1 47
/
L N
~1 challenges to the plant, since the activities have not been 2
that stressful.
3 Notwithstanding, we're still skeptical, and we're 4
going to keep an eye on this through the power ascension 5
phase.
But-by the same token, I think a lot of the learning 6
experiences early on have been well applied through both i
7 hardware changes and training and tech spec familiarity.
8 COMMISSIONER ASSELSTINE:
You know, the region had i
9 done a fairly extensive readiness review, the long document, 10 before th*y got their low power license, and this was an
- t experienced utility.
Were you surprised at the problems, the 12 numbers of these operator errors, the actuations of emergency t
13 safeguard features, the hardware problems that contributed to 14 a large number of 50.72 reports and LERs?
Is this atypical 15 from what you would expect for a new plant starting up, 16 particularly a new plant being started by an experienced 17 utility?
18 MR. STAROSTECK!:
My personal observ.ations were that 19 we were surprised when Susquehanna had similar problems when 20 they started up, so having survived Susquehanna and the kind 21 of problems they encountered, this was at first blush not all I
22 that different.
j s
i 23 What was different here 24 COMMISSIONER ASSELSTINE:
Difforent in terms of i
25 numbers, wasn't it?
I mean particularly for the first three i
f e-x 9
4 i
t 1
months of low power testing, I thought there were fairly 2
significant differences in.the numbers.
3 MR. STAROSTECKI-It may be in terms of numbers, but 4
then you start getting into the argument of what rule was l
5 applicable at the time.
What's more disturbing is the l
l 6'
commonality.of the technical specifications.
!I' 7
I quite frankly attributed an awful lot of the 8
problems early on to fairly late issuance of-the technical 9
specifications, they were i
10 When you license these operators 11 licensed about a year ago.
The plant was licensed in
's C,s/
12 October.
The technical specifications were not issued in 13 their final form until, you know, fairly close to the low l
they may l
14 power license.
So the operators aren't able 15 participate in the development of the tech specs, but they 16 don't get enough training in the technical specifications, 17 They get training in accidents, in abnormal events on the 18 simulator, but they don.'t really sit down'and look at the tech r
19 specs on the day-to-day level that one would expect.
20 The observations and comments from the examiners 21 that came back to me a year ago were related to that, and they 22 were commenting that a lot of these people referred to their 23 experiences at Peach Bottom, because that'is what they were 24 familiar with.
The procedures from Peach Bottom, the tech 25 specs 'from Peach Bottom.
And we' talked with Philadelphia
f w
1 i
49 1
Electric about that, and that improved with time.
2 So obviously I think the sequence of events causes 3
some of those errors up front.
4 COMMISSIONER'ASSELSTINE:
How about the pass-fail 5
rate for operators in the first two exams?
When I looked l
6 through your readiness review report, that didn't look f
7 terribly impressive, at least in terms of the first two 8
classes of operators.
I'd be interested in your comment,s on 9
that, again particularly for an experienced licensee that was to drawing from people with previous operating expertence.
11 MR. STAROSTECXI The first exam gave extremely high 1
12 failure rates to the point that I even had a meeting with the 13 operators who took that first exam, and I think the first exam l
14 reflected problems we had with some of our contractors, and i
i 15 they were the ones who had written the exam, and I think on 16 the part of Philadelphia Electric people who were expecting a 17 little different kind of exam.
l There is no one clear answer.
I will say, I think, 18 the familiarity 19 that some of the problems I just mentioned 20 and reliance on Peach Bottom procedures and Peach Bottom tech I
contributed to that.
But, by the same token, I think 21 specs l
\\
l our reliance on contract examiners to prepare the exam was l
23 also at fault.
24 Normally the experience we have for the first few 25 exams at one of these NTOLs is that we do experience a fairly
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50
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not as high as what we experienced at
-1 high failure rate 2
Limerick.
3 COMMISSIONER ASSELSTINE:
That certainly wasn't the 4
case for Fermi.
It's not your region, but that contrasted 5
rather sharply in my mind.
That's one of the things I was 6
thinking about, like the 95 percent pass rate.
7 MR. STAROSTECXI:
I'm comparing myself to 8
Susquehanna 1,
I am comparing to Millstone 3,
which we 9
currently have underway, Seabrook, which we have just done, 9
10 Nine Mile Point 2.
11 MR. MURLEY:
They've had high failure rates.
12 MR. STAROSTECK!:
Same kind of situation.
The first 13 exam generally gives you fairly high failure rates, but not as 14 high as what we had at Limerick.
I would say that the first 15 exam in my mind was an anomaly. and I would not say that is 16 characteristic of Limerick.
17 COMMISSIONER ASSELSTINE:
How about the second one?
18 That was a little better, but not much.
19 MR. STAROSTECXI:
Could I have supplementary slide 20 16, please.
21 IS11de.3 22 COMMISSIONER ASSELSTINE:
It was better, yes, but it 23 was still 18 candidates for SRO, and 12 out of the 18 passed, 24 and 11 RO candidates, and six out of the 11 passed.
It's 25 still pretty high.
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y 51 Oc N.
1 MR. STAROSTECKI:
In February 1984, we gave the u
2 initial exam for reactor operators, and you see a slide up 3
there which shows 50 percent pass rate for the repotor erators.
4 operators, and 58 percent for the senior reactor 4
5 Subsequent, in May
'84, we still had, I th 6
unacceptable pass rates for reactor operators, but reactor 7
operators are coming up.
And the third and fourth tests !
8 think are a little more typical.
9 when you look at the numbers of people taking them, I'm obhiously gratified by 15 of 22 SRos having passed.
10 11 COMMISSIONER ASSELSTINE:
What happened between one CL 12 and two, classes one and two and classes three and four, do 13 you think, to account for the dramatic improvement?
14 MR. STAROSTECK!:
Again, one, we've had more of an 15 emphasis after the first exam on using region-based examiners 16 to do the testing, first of all 17 When you look at the failure rates for"the first 18 test, you find an awful lot of failure rates occurring because 19 of the written exam.
And that's why I say I dismiss the first 20 one as an anomaly.
21 The others, as ! recall, were more of a balance,. in 22 not so much reliance on the written exam, but general
)
23 familiarity with the plant and the practical exam with the 24 simulator and the oral walk-throughs.
And I don't think the 25 industry is really used to us giving simulator exams.
They've
. -. ~.
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52 i
1 been used to the practical exam with the walk-through and the
.2 written, and we're starting to see more simulator exam.
3
. failures coming through now, and.it's more spread out.
L 4
. COMMISSIONER ASSELSTINE:
Does NRR have any comments 5
on the operator licensing?
6 MR. EISENMUT:
On this particular plant?
7 MR. RUSSELL:
Well, let me give you some feel for 8
what has happened nationwide.
The average is about 81 percent 9
pass rate on written exams for Ros, SROs, in that range.
Limer1[k was substantially below 'that on the written exams for 10 i
l'1 both Ros and SROs.
I i (~s.
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12 There is an anomaly, however, in the simulator 13 exams.
They were below average for the senior operators, that 14 is directing activities on the simulator, but substantially 15 above average for the reactor operators,.the individuals that j
16 actually manipulate the controls.
They're about comparable 17 for-retake exams.
I 18 I think Rich was right, the thing that should be 19 pointed out is that.they have put.a far larger number of 20 candidates up, in the fact that they have 51 licensed i
l 21 operators.
22 Recall at Diablo Canyon, you had 72 for two units.
23 That's about 36 per unit And they have 51, and.they made a i
l 24 substantial effort to get additional people qualified, and !
25
-think they are to be commended for that.
'l
iI i.
53 1
COMMISSIONER ASSELSTINE:
I'm going to ask you to 2
comment on one other thing, Rich's point about the other 3
plants in Region I having a bad history on the first take.
In 4
that typical across the country?
My impression was that l
5 wasn't the case.
6 MR. RUSSELL:
It's not uncommon.
There is somewhat t
l 7
of a learning curve on the first examination.
9 MR. EISENHUT:
I would suggest we could certainly
! think I agree with you, Commissioner 9
put together
~
10 Asse1stine, it varies all over the map.
I remember one plant
^
11 that had 100 percent success rate in the first three years of
(, )
12 NTOL.
I know another one with a 95 percent rate.
So I think 13 it varies considerably.
14 And I think we do have, Bill, compilations of 15 statistics.
16 MR. RUSSELL:
We have the statistics by region, by 17 plants, and it is in the report we sent to you.
18 COMMISSIONER ASSELSTINE:
Let mi ask one other 19 question on the operating experience during the low power 1
20 testing program.
Denny Crutchfield's memo makes the point of l
21
-- well, if you look at the trend, things are getting 22 dramatically better, and he broke it down into three-month 23 periods.
First three months, quite bad; second three months,
)
24 much.better; and the third three months, dramatically better, l
25 and in fact, well below the average for low power testing for
a f
f 54
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other plants.
2 How much weight should we put on that trend, given j
.3 the amount of work that's been done since March?
The. OPE memo 4
that we got said basically not much had been done since March, 5
and that is that third period.
Should we still temper that 6
with caution in terms of how much weight we put on that 7
MR EISENHUT:
That would be a good i
dramatic improvement 6
COMMISSIONER ASSELSTINE:
9 the last three months.
to MR. EISENHUT:
I think that would be a good way to t
.11 look at it.
You have to temper that, and any time you look at I
12 these statistics in fact, I think the last plant I was s.
13 pointing out, when you look at these, you have-to really look 14 at the frameworks they're taken under, 15 COMMISSIONER ASSELSTINE:
Okay.
16 MR. EISENHUT:
I think there is a general trend of t
~
17 improvement.
I don't think 1t's as dramatic as these memos l
18 show.
19 COMMISSIONER ASSELSTINE:
- Okay, So the sense, !
, 20 take it, from the Staff is that the kinds of efforts that have 21 been made since that first three-month period really are 22 working; that you are seeing an improvement in operator
.~
j 23 errors, improvement in these kinds of actuations of emergency a
24*
safeguard features and these other problems that you were i
25 seeing early on?
r
~
i 55 1
MR. STAROSTECKI.
If you look at LERs and recognize 2
that they really are geared to activities at the plant, you 3
have to go back to the January-February timeframe-and say yes, 4
based on limited data back'then, it looks like it's improving, 5
but I think I see an awful lot of improvements when we walk 6
into the control room and you talk to the operators, they are 7
more knowledgeable.
When you talk to the resident inspector, 8
they are a little bit more upbeat.
But I still think it is 9
healthy to have some skepticism ence they start doing more 10 activities, to see how it all comes out 11 COMMISSIONER ASSELSTINE:
What kind of activities s
_/
12 are you planning to follow, the full power testing program, 13 higher power levels, to ensure that in fact those early 14 problems-have been corrected and you are seeing good 15 performance?
Have you got anything special in mind?
16 MR. STAROSTECK!
We are going to be assigning a 17 second resident inspector to Limerick here in the short term.
18 We have dedicated start-up test engineer from the region is 19 going to be at the site, and we're most probably going to have 20 two' start-up test engineers from the region available to the 21 site.
So in essence we'll have four people almost daily 22 following the start-up and power ascension program, which is 23 pretty'auch what we did during the preoperational test
./
24 program.
We had people onsite when the activity was 25-happening, irrespective of the day and night, and I think that a -
t
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?
56 k
1 is a little bit unusual.
2 Again, it's an advantage when the plant is 30 3
minutes away from the regional office.
4 CLaughter.3 5
COMMISSIONER ROBERTS:
I guess that depends upon 6
one's point.
7 CLaughter.3 8
MR. MURLEY:
That pretty much concludes our 9
discussion on the operation experience.
10 MR. EISENHUT:
I guess that pretty well concludes 11 the items we were going to present today.
12 We concluded the plant does satisfy our 13 requirements.
The plant is physically ready, operationally 14 ready to receive a full ~ power license.
15 It was my understanding, based on discussions with 16 the utility this morning, that the plant is heating up, they 17 do plan or they're hoping to go back to criticality about noon 18 today, or early afternoon.
They are awaiting the license to 19 proceed past the 5 percent point as soon as they get to that 20 point.
21 That concludes our briefing at this time.
22 COMMISSIONER ROBERTS:
Any other questions?
23 COMMISSIONER ASSELSTINE:
I have a few more, but 24 maybe somebody else wants to ask some first, since I have been 25 asking a few.
f
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/
i y
i COMMISSIONER ROBERTS:
Go ahead.
2 COMMISSIONER ASSELSTINE:
Okay.
A couple on the 1
3 license.
4 Page 5 of the draft license.
I noticed item 9, i
5 turbine system maintenance program.
I was just curious what s
6 led to that requirement.
j 4
7 MR. ROBERT MARTIN:
This was an issue that came up 8
in our SER review quite some time ago.
At that time we were 9'
looking at protection against the possibility of turbine 10 oversp ed events, and we reviewed the history of the issue at 11 the time, and identified a program that specified the Staff's e
12 criteria, what we were looking for in this area.
And 13 generally speaking, I understand that the utility, in 14 conjunction with General Electrio, is working on a program, a 15 more formal program, to be submitted perhaps as a topical 16 report, and we plan to come in some time in the future with 17 it.
18 In the meantime, we specified certain things that 19 must be done periodically to inspect the turbines to protect 20 against the possibility of turbine overspeed and destructive 21 event.
22 COMMISSIONER ASSELSTINE:
Is that a unique problem 23 for this plant?
24 MR. EISENHUT:
No, it's generic.
It's not really 25 aimed so much at eliminating the overspeed as much as given an
e f
I f:
.(
1 overspeed, you want to make sure that the turbine rotor is in 2
good enough condition that you don't have a turbine missile 3
problem.
4 MR. ROBERT MARTIN:
That's correct.
5 COMMISSIONER ASSELSTINE:
Okay.
The second question 6
I had was on page 6 of the draft license, item No.
12, the 7
remote shutdown system.
I was interested in understanding a 8
little more about what the problem there was with the remote 9
shutdown system.
10 MR. ROBERT MARTIN:
The Staff requirements, in 11 response to GDC 19, are that the remote shutdown system shall t
12 have two independent. trains of equipment, separate and 13 redundant trains of equipment of safety grade equipment to 14 bring the plant down in the event the. operators have to 15 evacuate the control room for some reason.
16 One train already existed prior to this issue.
We 17 were reviewing the capability of the other train and I
18 identified a list of things at the time we issued the low f
19 power license that needed to be done.
Since then some of L
20 those things have been satisfied, and what we were left with 21 at this time was the-requirement to put transfer switches to 22 handle the transfer of control of three specific pumps, o
}
23 transfer the control from the control room to the remote 24
' shutdown panel.
'And i n' that' interim period, until those 25 transfer switches are put in, the Licensee has presented a
2 59
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+
i description of how jumpers, in accordance with procedures, 2
would be used to effect this control.
l 3
And so that is what that condition is about.
4 COMMISSIONER ASSELSTINE:
Okay.
And when are they 5
going to have that fixed so they don't have to lift leads and 6
rely on jumpers?
7 MR. ROBERT MARTIN:
It would be prior to start-up, 8
following the first refueling outage.
9 COMMISSIONER ASSELSTINE:
Okay.
And also I was 10 interested in the next item, too, what the issue was with the 11 operation of the partial feedwater heating.
~
12 MR. ROBERT MARTIN:
That's simply that the analysis 13 is not encompassing enough to cover that mode of operation, so 14 we precluded it as a possibility.
15 COMMISSIONER ASSELSTINE:
Okay.
I also had a couple 16 of questions on the exempticas under item D on page 7.
I take 17 it the GDC 19 exemption is for the standby shutdown?
18 MR. ROBERT MARTIN:
That Ls correct.
19 COMMISSIONER ASSELSTINE:
Or remote shutdown panel.
20 Okay.
21 How about the first one and the second one?
A, 4
l 22 which is exemption from GDC 61, operation of that portion of
^
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23 the standby gas treatment system; and the second one, j
j 24 exemption from GDC 56 for containment isolation valves, l
25 hydrogen recombiners.
l
'i, 60 (M
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MR. ROBERT MARTIN:
The standby gas treatment 2
system, one, is basically the ductwork that would connect the 3
ductwork and other equipment that would be used to connect the 4
refueling floor area into the STGS, has not been completed.
5 Since there will be no spent fuel and thus no radioactivity in 6
that area until the first fuel is removed from the reactor 7
core, there would be no radioactivity hazard.
8 COMMISSIONER ASSELSTINE:
Okay.
And the second one, 9
Automatic --
10 MR. ROBERT MARTIN:
This is one of the additional 11 isclation valve on the hydrogen recombiner lines.
There is
)
12 already one isolation valve in each of these lines.
Our 13 requirements, pursuant to GDC 56, is that there shall be a 14 redundant one for each line coming into and going out of 15 containment.
And that condition is directed at requiring the 16 installation of the second one prior to start-up, following 17 the first refueling outage.
18 COMMISSIONER ASSELSTINE:
And also I had a question 19 about H on page 8,
which has to do with inerting.
I guess I 20 was wondering why they won't be inerting, and is the six 21 months specific in terms of when they will be inerted?
22 MR. ROBERT MARTIN:
That one was required based on 23 the' stretch-out of the start-up testing program.
Had the 24 testing program, for instance, proceeded without delay, it is 25 quite possible they would have completed their start-up test
. - ~
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1 61
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1 program and gotten to a point to where they could inert within 2
the six-month time period called out in 10 CFR Part 50.44.
3 However, since the plant has been shut down since 4
April and they have not completed their testing, they needed 5
the exemption from the regulation to permit them to continue 6
the start-up test program, without having to inert the 7
containment, which would otherwise present them with 8
difficulties as far as getting people into and out of the 9
containment to observe status of equipment and so forth as 10 they were starting up.
11 COMMISSIONER ASSELSTINE:
Okay.
But that will in z
12 fact be done within six months, so at that point they will be 1
13 inerted from then on?
14 MR. ROBERT MARTIN:
That's --
15 MR. NOVAK:
Well, what they had done 16 MR. ROBERT MARTIN:
The limitation would be they 17 shall inert by the time they reach either 120 effective full 4
18 power days of core burnup, or by the time they reach the 100 19 percent thermal power trip test, which generally marks the end t
20 of the start-up test program.
21 COMMISSIONER ASSELSTINE:
Okay.
You mentioned EQ 22 earlier, that the plant was basically in good shape on
.m 23 environmental qualification.
I know from one of the OPE memos
)
24 they have given us on one of the Board decisions, that there 25 was a question at least at one point in time about' the t
s
.5 1
6.
(<
1 Limerick pressure temperature profile.
and it seemed to me that that 2
Has that now been 3
was characterizing the environment for which the equipment 4
would have to be qualified.
If they had had a lower base than 5
other plants did.
Has that issue now been settled so that 6
MR. ROBERT MARTIN:
That was an open SER review 7
issue at the time, and it has subsequently been closed out.
8 COMMISSIONER ASSELSTINE:
Okay.
And I take the 9
Staff is satisfied with that lower profile?
~
10 MR. ROBERT MARTIN:
We are.
11 COMMISSIONER ASSELSTINE:
Okay.
s/
12 MR. ROBERT MARTIN:
What we did, we -- there was a 13 lower profile in the Licensee's documentation, and what we did 14 was verify that all the equipment would satisfy the higher 2
15 profile in a Staff document, NUREG 0588, directed at the 16 environmental qualification.
17 COMMISSIONER ASSELSTINE:
And the last other 18 question I had, other than a couple of emergency planning, had again I think it was in 19 to do with the PRA, and I noticed that there were a number 20 an OPE memo that they had given us 21 of changes that had been made to deal with the ATWS question, l
22 and that in fact those changes had reaulted in reducing the
.s f) 23 frequency of ATWS sequence by a factor of 10.
And I guess it 24 was more curiosity on why, to what extent we considered those i
25 kinds of' changes when we considered -- when the Staff
L
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1 considered the ATWS rule, and why those weren't included in 2
the ATWS rule.
3 It's basically, I think, what, improvements in the 4
automatic depressurisation system, and improving the 5
reliability of RHR.
6 MR. BERNERO:
This is Bob Bernero of the Division of 7
Systems Integration and the NRR Staff.
8 Those things, I don't recall them being specifically 9
considered in a generic way during the ATWS rulemaking.
We 10 considered automation of the standby liquid control system, 11 which is one feature that Limerick has, but not those things
\\,/
12 as such in the ATWS rulemaking.
13 COMMISSIONER ASSELSTINE:
In view of the fairly 14 dramatic improvements they had, maybe we ought to take a look 15 at some of those.
16 MR. THADANI:
Ashok Thadani, Division of Safety 17 Technology.
18 During the early discussion of A'TWS proposed rule, 19 there were.a number of alternatives considered.
In fact, one 20 alternative was very close to what Limerick has implemented, 21 what we call 86 gallons per minute capability for automatic 22 actuation, in terms of poison.
23 We had an option which also considered much greater j
24 capacity, which could have taken care of additional failures 25 as well.
Various options -- we did a bunch of cost-benefit
I ss 1
studies as well, 2
COMMISSIONER ASSELSTINE:
I remember those.
3 MR. THADANI-There were a lot of arguments, I think 4
you might recall, in terms of what is the reliability of the 5
protection system.
Considerable uncertainty was involved.
6 Even today people think that a number of Staff assessments 7
were overly conservative.
Judgment was arrived at as a result 8
of a number of discussions that for plants which were 9
operating, the improvements in the reactor protection system.
10 as well as improved capability for injecting poison, 86 11 g a l'1 o n s per minute, was adequate.
2 12 But in terms of Limerick, the -initial design had 13 already incorporated the automatic actuation capability, plus 14 they have a three-train system, which in my judgment, and'I 15 think the judgment of most of the Staff members, is that 16 improved safety significantly.
17 COMMISSIONER ASSELSTINE:
And yet they still went 18 beyond those and did these other things as well, 19 MR. THADANI; They went well beyond the ATWS rule, 20 and they went well beyond the next level of protection that we 21 considered 22 COMMISSIONER ASSELSTINE:
That's right.
and they're pretty close to the
)
23 MR. THADANI:
24 best system that we have analysed.
25 COMMISSIONER ASSELSTINE:
I find it very
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interesting, what they've done, and commendable.
2 MR. THADANI:
I think so.
And in fact, that is just 3
one example.
Tom Novak mentioned to you earlier that there 4
were a number of other areas where they have moved forward and 5
done a number of things.
Very positive, I think.
6 COMMISSIONER ASSELSTINE:
Okay.
I had a couple of 7
quick questions on emergency planning that basically were 8
concerns that had been highlighted in I guess it was the 9
Second Partial Initial Decision by the Board, and I was just 10 wondering what follow-up had been done on those items.
11 The first one had to do with meeting the requirement
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12 in NUREG 0654, planning standard J-5, that the Licensee has to 13 be able to account for all individuals on site within a 14 30-minute time period, including construction workers at Unit 15-2.
16 Can you tell me what, if anything, has been done to or did the exercise show that they can in fact do that?
17 18 CCommissioner Bernthal left the conference room.3 19 MR. COLLINS:
There was an inspection report that 20 was'put out August 2nd which documented the results of the 21 remedial exercise, where the Licensee went through the various 22 stages of declaration of an emergency, and demonstrated the
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23 capability of evacuation and accountability of personnel.
'.J 24 I think for Unit 1 that was within 23 minutes.
I'm 25 quoting off the top of my head.
And they also demonstrated
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the evacuation of Unit 2.
And the inspection report shows 2
that that area was adequate.
3 COMMISSIONER ASSELSTINE:
How about the emergency 4
hospital care, too, at Pottstown Memorial Medical Center?
Did 5
the personnel get the training they need in handling 6
contaminated individuals?
And did the exercise confirm that 7
as well?
8 MR. MATTHEWS:
It is my understanding that the 9
Applicant will be able to directly respond to that, but it is 10 my understanding that all the training that they committed to 11 with regard to Pottstown Memorial has been completed.
12 Does the Applicant have any information?
13 MR. BOYER:
That is correct.
14 COMMISSIONER ASSELSTINE:
Okay.
And how about the 15 conflicting responsibilities question for the Goodwill 16 Ambulance Unit?
Did the exercise show that in fact they would 17 be able to carry out both their onsite and offsite 18 responsibilities?
19 MR. MATTHEWS:
FEMA has reviewed that, and they have 20 concluded favorably with regard to the fact that there is no 21 conflicting problem existing.
there 22 COMMISSIONER ASSELSTINE:
Good.
How about (m) 23 were a couple a l's o from the Third Partial Initial, Decision.
24 One of those was this one-lift evacuation issue where you have 25 to get all the school children out in one wave.
Did the
1 o
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i exercise show that that. requirement of Pennsylvania law would 2
be satisfied?
3 MR. MATTHEWS:
It is my understanding that the plans 4
commit to that, and FEMA has reviewed it in the form of their 5
plan review and their observation of those portions that were 6
exercised, that that is a feasible plan for implementation.
7 COMMISSIONER ASSELSTINE:
Okay.
And have all of the 8
letters of agreement with bus drivers, schools, health care 9
facilities, reception centers, have those been completed?
10 MR. MATTHEWS:
I will have to defer on that one to 11 our representative from FEMA, who is with us today, Robert 12 Wilkerson.
13 COMMISSIONER ASSELSTINE:
I gathered at the time 14, that the Third Partial Initial Decision in the record was 15 closed, most of them had, but'not all of them had.
16 MR. MATTHEWS:
I 'could say in summary that the Staff 17 was aware of all those outstanding issues that OPE had 18 identified with regard to their review of the initia1 19 decisions, insofar as they related to emergency preparedness.
20 and the Staff, FEMA, and Region I have gone over those in 21 detail and confirmed to their satisfaction that all of the 22 issues raised by OPE in that memo have been satisfactorily
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23 addressed.
24 COMMISSIONER ASSELSTINE:
Oxay.
25 MR. MATTHEWS:
Would you like.to hear from FEMA on
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that issue?
2 COMMISSIONER ASSELSTINE:
Yes, on that one.
3
[ Commissioner Bernthal reentered the conference 4
room.]
5 MR, WILKERSON:
My name is Bob Wilkerson.
I am with 6
FEMA.
7 With direct response to your question, Commissioner, 8
all those agreements have not gone through the legal 9
formalities of completion.
Our regional staff has assured a.
10
,through review and phone contact with all the parties involved 11 that there is a meeting of the minds, and it is simply the
/
12 matter of the signatures, and that the training has taken 13 place, has been provided, that there is adequate assurance 14 that were the need there, that the drivers would respond, 15 there is adequate resources, and there would be no problem.
16 COMMISSIONER ASSELSTINE:
Good.
So the school staff 17 and bus drivers basically, the training has been done?
18 MR. WILKERSON; The training.has' been provided and 19 it will be provided on a repetitive basis to provide refresher 20 training.
21 COMMISSIONER ASSELSTINE:
Okay.
Thank you That 22 covers the questions I had.
-~
23 COMMISSIONER ROBERTS:
Any other questions?
We are 24 already over time.
Can we proceed?
25 COMMISSIONER BERNTHAL:
The only comment I would
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69 A*;
1 make is that I would hope that we would have some time to hear 2
from Ben about this problem that I raised earlier with the 3
security force people, and I would like to hear what the 4
Licensee has to say about the steps that they have taken.
5 COMMISSIONER ROBERTS:
Well, we are going to hear 6
frca the Licensee.
7 COMMISSIONER BERNTHAL:
Are we planning to do that 8
today, or when are we going to address that issue?
I thought 9
that we were going to 10 COMMISSIONER ROBERTS:
It was my i n t e n t i o n..-- not 11 today.
12 MR. EISENHUT:
I think, if I am not mistaken, the 13 activity of OI is complete.
14 COMMISSIONER ROBERTS:
Yes.
15 MR. EISENHUT:
With respect to Limerick.
16 COMMISSIONER BERNTHAL:
Oh, yes, I understand that.
what 17 COMMISSIONER ROBERTS:
Well, let's not 18 you're interested in is not germane to what we are about 19 today.
20 COMMISSIONER BERNTHAL:
Well, let's hear what the 21 Licensee has to say before we decide whether it's germane, 22 because they're one of the licensees that has had a problem s
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23 there.
24 COMMISSIONER ASSELSTINE:
It may be separable, 25 though.
I think it's separable.
>l 1
70 1
COMMISSIONER BERNTHAL:
It's separable, I agree.
2 The question is, should we let that slide for another month.
3 But let's go ahead.
I'm finished with this.
4 COMMISSIONER ROBERTS:
Any other questions?
S COMMISSIONER ZECH:
No, I don't have any other 6
questions.
7 COMMISSIONER ROBERTS:
All right.
We thank the 8
Staff and ask them to stand by.
9 The Commission has had a request from Phyllis 10 Zitser, president of Limerick Ecology Action, to speak.
We 11 are going to ask her to speak, but please limit her remarks to o
12 five minutes.
%s 13 MS. ZITZER:
I want to thank you for this 14 opportunity to address the Commissioners'today.
15 My name is Phyllis Zitzer.
I am the president of 16 Limerick Ecology Action, which has participated in this 17 operating license proceeding as the lead intervenor.
18 We do not believe that the NRC should grant an 19 operating license for the Limerick Nuclear Power Plant.
We
~
20 also believe that it would be irresponsible for you to 21 consider issuing a license for this facility today.
22 It has been recently disclosed that the FSAR for i
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23 Limerick does not contain a site-specific analysis of how
,/
24 Limerick would respond if there was a loss of offsite power 25 during an accident at Limerick.
F i
t i
1 There was some information in our newspaper 2
yesterday.
I hope that you have been informed of this.
I 3
would assume you have been.
4 However, the quote that was in our paper yesterday l
5 from Mr. Kelly, the NRC senior resident inspector at Limerick 6
indicated that it was his belief that before the NRC would 7
vote, that the FSAR would be reviewed and rereviewed for, any 8
other errors, and that as of yesterday, according to him, this 9
matter still was up in the air.
10 We strongly object to the consideration of licensing 11 this facility until and unless the FSAR has been properly
. /
12 reviewed and revised to include the required analysis which we 13 believe must be provided to the parties in this proceeding.
14 Also, as stated by this gentleman, this omission 15 raises serious concerns about the adequacy of the FSAR as 16 well, and any other possible omissiens.
17 Ever since the 1979 coremelt accident at the Three l
18 Mile Island facility, which forced the NRC to abandon its l
19 naive faith that no serious nuclear accident could ever occur 20 at a licensed facility, the Commission has reexamined the 21 wisdom of siting large nuclear power plants in major 22 metropolitan population centers.
I I
..g 23 The hi'ndsight of wisdom, however, could not be 24 applied to the Limerick facility under construction prior to i
25 1974 and sited a more 25 miles from one of the largest
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72 the 1
metropolitan population centers in the United States 2
city of Philadelphia.
3 Preliminary probabilistic risk assessment analyses 4
perform *,4 by the NRC following the destruction of the agency's 5
confidence in its own certitude of nuclear reactor safety, 6
identified three reactors in the United States as posing a 7
risk substantially above average:
Indian Point, Zion and 8
Limertok.
9 Limerick was identified as being one of the most 10 hasardous reactors in the country.
The Director of Nuclear 11 Reactor Regulation, Harold Denton, testified in an Oversight 12 hearing before the Subcommittee on Energy and the Environment 13 of the Committee on Interior and Insular Affairs of the House 14.
of Representatives at a special hearing on nuclear siting and 15 licensing on May 27th, 1980 in Bucks County, Pennsylvania.
16 At that time Mr. Denton said that given the siting 17 standards now, that with a local population density greater 18 than 500 people per square mile, the NRC would conduct a very 19 expensive search for alternative sites, 20 The population density at Limertok was twice that in 21 1940.
Obviously it is far too late to search for alternative 22 sites in this situation.
The only possible means to reduce
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23 the risk at Limertok was to examine design changes.
24 Mr, Denton also said that if the risk at Limerick 25 were found in fact to be greater than the average reactor,
O,
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73 1
that the NRC would consider design changes.
2 Since that time the risk at Limerick has not been 3
shown to be less than the average site, but in fact 4
substantially greater.
5 The statistics that were presented before the House 6
Interior Subcommittee on Oversight concerning reactor accident 7
consequences had shown that Limerick is among the worst in the 8
country.
The worst accident scenarios for every nuclear power 9
plant in the country were presented before the committee, 10 With r spect to early fatalities, Limerick was the third worst it in the country, with an estimated worst case scenario of
/
12 74,000 people dead.
13 It is interesting to note that with respect to early 14 fatalities, it is plain that the State of Pennsylvania is the 15 worst state in the country for nuclear reactor risks to its 16 citisens.
The top 10 reactors with the risk for early 17 fatalities include Limerick, Peach Bottom, Three Mile Island 18 and Susquehanna.
19 In the entire country, four out of the top 10 20 highest nuclear risk reactors are located within Pennsylvania.
21 With respect to early injuries, Limerick 1 is the i
1 22 worst in the country, with 610,000 projected early injuries in
)
23 a worst case scenario.
24 The next closest reactor to that had 340,000 early 25 injuries.
k A
74
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1 With respect to cancer deaths, Limerick is projected 2
to be the fifth highest in the country.
3 With respect to economic damages, Limerick was 4
projected to be the third worst in the country.
5 The recent site-specific risk assessment done by the 6
NRC for the Final Environmental Statement shows the risk of a t
7 core accident at Limerick to be one in 1000 per reactor year.
8 Over a 40 year projected operating life, the chances are about 9
ene in 25.
If two reactors are completed and operated at 10 Limerick, we have about a one chance in 12 that there will be 11 a core damage accident at the Limerick site.
The chances that C#
12 1000 people would die of latent cancer caused by an accident 13 at Limerick was estimated to be a little less than 1 in 25 14 over the projected 40-year life.
15 If two reactors are operated, there is about a one 16 chance in 12.
17 Limerick Ecology Action has attempted since the 18 beginning of this proceeding,.which did begin in 1981, to 19 force the NRC to seriously consider design changes to the 20 plant.
21 COMMISSIONER ROBERTS:
Pardon me.
You have exceeded 22 your five minutes.
Could you quickly finish.
23 MS. ZITZER:
Certainly.
24 Despite analysis done by the Commission's own 25 contractor showing that the cost effective risk reduction
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f 75 O4 1
measures could be made, including some potential design 2
changes which would eliminate almost 95 percent of Limerick's 3
severe accident latent cancer risk, the Ccamission has 4
consistently refused to consider those design changes in this 5
licensing proceeding.
6 We have appealed these matte'rs as well as the Third 7
Partial Initial Decision to the Appeal Board, which has 8
refused to make a decision on our appeals.
9 At this time we are left with no choice but to 10 prepar to pursue these appeals before'the judicial courts and 11 are prepared to file an appeal immediately once you act, if C*i
~
that judicial review is obtained so 12 you do so today, to ensure 13 that these issues can be reviewed by the Third Circuit Court 14 of Appeals.
15 We respectfully request that any order authorising 16 full power operations for Limerick therefore be made effective 17 no sooner than 14 days after your decision, for the purposes 18 of judicial review by the Third Circuit Court of Appeals.
19 We do not believe that the court would respond 20 favorably to your failure to allow a reasonable period of time 21 for judicial review.
22 I want to thank you again for the opportunity to s%' )
23 speak.
24 COMMISSIONER ROBERTS:
Thank you.
And I would ask 25 does anyone have a question of Ms. Zitzer?
T 4I 1
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^
76 1'~
1 COMMISSIONER BERNTHAL; I guess I don't have any for the record, 2
particular question.
I would like to 3
though, I think the Staff should respond to some of the PRA 4
numbers that we've had thrown at us here.
5 COMMISSIONER ROBERTS:
All right, why don't we 6
COMMISSIONER BERNTHAL:
It's useful, I think, to 7
place that in perspective for the public.
8 CCMMISSICNER ROBERTS:
All right, why don't we hear 9
from the Licensee, and then we'll hear from the Staff, and let 10 Staff comment both on the matter you speak of and whatever the 11 Licensee may have to say.
/
12 COMMISSIONER ASSELSTINE:
Right before you do that, 13 Tom, I don't have any questions, but just a couple of comments 14 on the loss of offsite p'ower analysis.
In essence what I hear 15 our Staff telling us is that the Licensee has now done its 16 review to show that they're within the bounds of the original 17 accident analysis, and they've made sure that this is an s
18 isolated p r o b'l e m, that this wasn't something broader; and that 19 the Staff has looked at it enough to 54tisfy themselves that 20 in fact the Licensee !s right.
Granted, the detailed written 21 explanation of their review.hasn't been done, but it did seem 22 to me that from what the Staff was saying, they're satisfied 23 that the analysis now has been done and corrected.to deal with 24 that problem.
25 And I guess I'm wondering whether you still had your
4
~1 3
1 77
(
1 concerns about that item.
I recognize the quotes that our 2
resident inspector had said, but it does seem now that more 3
has been within the past few days beyond what he reflected in 4
the statements that were in the newspaper.
5 MS. ZITZER:
My belief is that it is such a 6
significant issue that we would want additional assurances, 7
and we would hope that the NRC would want those same written 8
assurances before it took any action that would result in the 9
authorization of full power operation.
10 COMMISSIONER ASSELSTINE:
My second one is more 11 comment with regard to your concerns about siting large i>
12 nuclear plants in high population density areas.
I'd have to 13 say I agree with that concern.
My own view is that you're 14.
right, that the potential consequences are substantially 15 higher.
I don't know whether your numbers are the right ones 16 or not, but -- and I personally would favor taking a look over 17 the long term for additional measures that could be taken to 18 reduce that.
19 I would also have to say, though, that it does 20 appear that some of the things that the Licensee has done at 21 least move in that direction.
They have in some areas gone i
22 beyond what other plants have dene, and I think in partial
)
23 recognition of the fact that they are in a high population i
24 density area, and the potential consequences of a severe 1
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25 accident are worse there than at other sites.
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1 But I would agree with you, that more should be done 2
for the high population density sites over the long term, and 3
second, that we ought to insist upon a very high level of 4
operational competence and demonstrated performance from the 5
plants in the high population density areas.
Because I would 6
agree with you, they are different.
7 COMMISSIONER BERNTHAL:
I would just comment, if I 8
may, that beyond agreeing that we ought to take a look at 9
these plants, we are in the process, this Commission has 10 promulg'ated a severe accident policy statement, and one key 11 element of that statement and the action that will come out of
.)
12 it will be to do the kind of evaluations that need to be done, 13 and frankly this Licensee has begun to do already for this 14 plant.
There will be further work along those lines 15 associated with the source term, latest source term data and 16 research work as it fits in with severe accident policy 17 statements.
18 So one of the Commission's objec'tives, and the thing 19 we are about-to begin, is an evaluation of particular plant
'20 designs and further confirmation, one hopes, of the safety 21 margins that we believe to exist in those plants.
22 So.I want to compliment you on a cogent statement, 23 but I also want to reassure you that some of the concerns that y
/
you have are being addressed, as Jim has suggested,- by this 24 25 Licensee and, I would also suggest, by actions that.the
79 1-Commission has decided to take in the wake of its severe 2
accident policy considerations.
3 COMMISSIONER ASSELSTINE:
My colleague knows that we 4
have got some differences on whether we have gone far enough 5
on the severe accident policy statement or not, but I hope 6
he's ri ght,- that the detailed plant reviews such as the 7
efforts that have been undertaken so far by this Licensee I hope he's right, that 8
and hopefully that will continue 9
they will continue to search for ways to improve the level of 10 r.afety and reduce the risk of severe accidents and the kinds 11 of consequences that you describe.
x_-
12 MS. IITZER:
If I just might comment briefly.
Our 13 major concern stems from the fact that almost-a year ago we 14 appealed the Second Partial Initial Decision, and in that 15 appeal have documented the design modifications we believe are 16 cost effective for Limerick and we believe the evidence shows 17 are cost effective.
18 We already believe that low power operation has made 19 it much more difficult to even consider those, and certainly 20 full power operation will make it more difficult, if not 21 entirely moot the whole discussion.
22 That is the reason we are moving inmediately into j
23 the Third Circuit' Court of Appeals, frankly to get some kind
,s 24 of a decision one way or another on the issues we have raised 25 in our appeal of the Second Partial Initiation Decision.
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And again, I would like to emphasize, we would 2
appreciate your consideration of any order authorizing full 3
power operation not being made immediately effective for a 4
reasonable period of time, so that the court could consider 5
those appeals.
6 And I thank you again.
7 COMMISSIONER ROBERTS:
Thank you very much.
Thank 8
you.
9 Now we will hear from the Licensee.
It is my 10 understanding we have Mr. Everett and Mr. Boyer.
Would you 11 gentlemen please join us.
And I would ask you also to limit i
12 your remarks to five minutes.
Of course you will be 13 questioned by us.
14 MR. BOYER:
Yes.
Thank you.
My name is Vincent 15 Boyer.
I am Senior Vice President for Nuclear Power for 16 Philadelphia Electric.
17 From the earliest part of the design stages of 18 Limerick, we recognized the limitations of the site and our 19 plant design has incorporated features which reduce the 20 potential hazards to the public.
21 The management of Philadelphia Electric Company is 22 committed to safe operation.
We have been leaders in the 23 development of quality assurance programs.
We have been
,j 24 leaders in the development of and the implementation at 25 Limerick of all the Appendix R fire protection programs-and n
81 1
the equipment qualification programs.
We have not had any 4
2 quality problems at Limerick due to the extensive quality 3
assurance and quality control programs which we have 4
initiated, both in our construction and i n our operational
+
5
- areas.
6 With regard to the Chapter 15 error, I will note 7
that it was an isolated case.
We have spent extensive e
investigation in a multi-pronged effort to confirm that.
The 4
9 analysis which was in the FSAR referred to a design which was 10 change in 1974 to effect an improvement in the plant 11 performance, so that the analysis was a bounding one and was ij 12 conservative, so that it was en t'a safe side in the FSAR, i
13 though it did not truly represent the-actual design that 14 presently exists.
This*is being corrected by a change in the 15 FSAR.
16 The simulator was programmed correctly, and the 17 training which has been conducted has been based on the true i
18 plant design.
19
-In the area of low level waste, we have been 20 finalizing the preparation for shipment of low level waste 21 with Region I.
We have installed a facility at Peach Bottom t
22 for five years storage of low level waste.
This facility 23 could be used, 1f-necessary, at Limerick, and we have plans,
+
24 potential plans in the future, if necessary, to construct a 25
'similar facility at Limerick.
So we do have plans,
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contingency plans.for low level waste.
N 2
. With regard to the water situation, the matter 3
relating to Point Pleasant was argued on June 6 on an 4
expedited basis before the Commonwealth Court of 5
We are presently awaiting that decision.
6 In the meantime, we have obtained a docket change 7
from the Delaware River Basin Commission so that we can 9
withdraw water from the Schuylkill River when the flow is 9
adequate and the oxygen levels are adequate, and we are 10 monito ing the oxygen levels at six points in-the river, six 11 times a day.
0 4
12 Tomorrow we will review -- the Delaware River Basin 13 Commission will review and hopefully approve the reallocation 14 of water from two existing plants for use at Limerick.
They 15 considered this a week or two ago, and decided that they did 16 not want to prejudice the decision on the part of the Nuclear 17 Regulatory Commission, so they deferred action until.after the 18 NRC had acted.
4 19
[ Laughter.]
20 They agreed, however, to hold a hearing the next 21 day, which they are doing.
22 We have also submitted a request for the discharge 23 of water from an unused strip mine near Pottsville, 24 Pennsylvania, which contains 2 billion gallons of water of 25 reasonable quality.
We have submitted our applications to the i
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1 il 83
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1 DRBC and to the state for the discharge of this water which 2
would satisfy our needs for ver a five-month period.
3 Thus, I think that we will not suffer any extensive 4
limitations in our plant operation due to limited water.
- But, 5
of course, we will in the meantime pray for rain.
6
[ Laughter.3 7
With regard to 8
COMMISSIONER ROBERTS:
Mr.
- Boyer, I'm sorry, could e
9 you summarize quickly.
10 MR. BOYER:
Right.
We have definitely gotten the 11 attention of our security contractor.
We have made extensive t
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12 changes, both in the way that we monitor his operations and
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13 the way he conducts his operations, and I can assure you that 14 we have effected improvements, and I think that this will be 15 seen as you conduct a review, as the Staff conducts a review 16 in its total operation in all projects.
17 with that I will pass to Mr. Everett.
18 MR. EVERETT: ' Gentlemen, I appreciate the 19 opportunity to be here also.
This is not my first time in 20 these halls.
It goes back to 1954 and '55 with Fermi 1,
and 21 again with Peach Bottom 1 in the late
'50s, early '60s, and 22' then with Peach Bottom 2 and 3,
and now with Limerick.
I am
)
23 quite_used to being here, as a matter of fact I don't come 24 as often as I used to, because others know more about these 25 plants than I do now.
In fact, I think I predate most of you
I 1
84 W'h
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1 in my activities in the nuclear industry.
2 It has been my responsibility to see that the 3
nuclear interests and nuclear functions of my company, 4
Philadelphia Electric, we're properly developed.
With the 5
completion of Limerick 1 and hopefully Limerick 2,
60 percent 6
of our electricity will come from nuclear power plants.
7 It has organized.or reorganized our entire company B
around the nuclear funotaons.
We are completely a different 9
company today because of our nuclear involvement than we were 10 before we got into the nuclear generation business.
11 We are highly competent, we've developed a good team
,m N_/
12 of people, they're dedicated, they work together as a team, 13 and they work openly with this Commission and its Staff.
Most 14 often we report errors or violations voluntarily before they 15 are detected obviously by the inspectors, and that's the way 16 we'd'like to be.
We not only want to operate this plant 17 safely and competently, but we want it to be viewed by this 18 Commission, its Staff, and therefore the public in that vein.
19 With respect to contractor personnel, I think every 20 generation of engineering managers has to learn that a 21 contractor is only as good as you make him be.
And we found 22 that out in the case of Yoh.
I can assure we do have his
-s 23 attention, and he will'be a good contractor, because he won't 24 do business unless he is.
And therefore we have learned that 25 again painfully in this particular case, and I suppose we will
4 -
d!
il 85 it--
1 keep on learning it, but that is the nature of the contracting 2
business.
3 I have Graham Leitch here, the station 4
superintendent, to my left.
He has trained a very competent 5
staff.
No one is perfect.
I wish we could tell you we have 6
reached that degree of human perfection that would make us 7
different than anybody else, but obviously we can't.
We are S
going to continue to strive for it, and we are going to strive 9
to be the best in the-business.
10 Gentlemen, I think we are ready for license.
11 COMMISSIONER ROBERTS:
Thank you, sir.
n
- j 12 Are there questions?
13 COMMISSIONER ASSELSTINE:
Just one brief one, and 14 that would be, I'd be interested in your perceptions of both 15 your operating licensing program and your early experience 16 with that, and also the experience with the low power testing 17 program, and both the way you perceive that program and where 18 you think you are now, and what you have done to get 19 yourselves to that point, and all summarized in one minute.
20 MR. BOYER:
It was an excellent program, and we did 21 not have any difficulties of any consequence arise as a result 22 of that.
New I would ask Graham to. speak to the operator
-m
'\\
23 examination and make any other comments he'd like to make.
24 MR. LEITCH:
Just another comment on the low power 25 testing program, if I might.
We feel that we very
,i 4
i.
86 7
1 successfully" completed both the open vessel phase and the
's -
2 heat-up phase of-the testing program.
We were particularly 3
gratified by our ability working with the NRC to develop l.
l~
4 procedures _which allowed us to roll the turbine and indeed i
1 5
synchronizefthe turbine and run'the turbine for a 24-hour O
(
6 period'at 'very low loads.
1 7
HSo we feel that'by so doing,'we have expanded the s
8 envelope.of knowledge of the plant, perhaps greater than it 9
would normally be the case under a 5 percent license.
We feel 10 very confident with the results of the low power testing 11 program,.
We have recently conducted what we call our plateau 12 13 review where we summarise and review the results of all those 14 tests.
That plateau review has been conducted and approved b y' 15 the plant operations review committee, and we feel that we are 16 ready to move ahead.
17 With regard to the operator licensing area, we were, 18 as you, somewhat=didappointed with the results particularly of
^
19 the first examination.
We had some people in that exam who 20 were senior licensed operators'at Peach Bottom that were s
21 candidates for senior license at Limerick.
We would have 22 expected those people to;have no difficulty whatsoever.
We c,
23 w e r e - s u r p'r i s e d,
s 24 I think the exam was somewhat challenging.
It was a 25 very difficult exam, and I'think perhaps not directed so much
...)..
y t
87
/ -
V 1
to the kind of knowledge that one might expect an operator to 2
have.
3
,Nevertheless, those people went through the second 4
exam and indeed did an outstanding job.
I'm recalling scores 5
now in the cases of some of the failures on the first exam, 6
scores of in the high 90s.
Just an outstanding job on the i
4 7
second exam.
8 So we would agree that there was a certain amount of 9
anomaly in tht first exam.
We are continuing to prepare 10 people for senior licensing exams, and we plan to put up 11 another class of about 16 candidates for senior Itcense, both 12 operator types and engineer types, in a November examination, 13 and we are very hopeful of a high rate of success on that 14 exam.
15 MR. EVERETT With respect to the general 16 observations over a long, long period of time, as far as 17 licensing, training, et cetera, we have seen a tremendous 18 evolution, obviously.
The Peach Bottom 1 construction permit i
19 hearing took one day.
The construction permit hearings for 20 Peach Bottom 2 and 3 took two days The construction permit 21 hearings for Limerick took four years, approximately.
I don't 22 know what the next one will take, but I won't be around to m j 23 pursue it.
J 24 We have seen that same evolution in the requirements 25 for operator training and operator testing.
As more and more
Y l
j
)
88 1
emphasis is placed on personnel, obviously more and more is 2
required of those people, and more is required to be 3
demonstrated of their competence.
And unless there is an 4
understanding in the Licensee's own shop of what those new 5
requirements are going to be, we simply are going to always be 6
running to catch up with the increasing difficulty of the 7
nature of the requirements.
8 We have seen the same thing in the plant design.
9 Peach Bottom 2 and 3 cost $375 per kilowatt, finished.
~
10 Limerick will cost over $3700 a kilowatt.
They were designed 11 by the same people, built by the same people, bought from the v./
12 same equipment manufacturer, and supervised by the same 13 utility.
And the difference, you well know, was caused by 14 inflation and additional requirements.
15 How far that is' going to go, nobody knows.
But 16 that's where we are today.
17 COMMISSIONER ROBERTS:
Thank you.
18 COMMISSIONER ZECH:
Let me just make one quick 19 comment, if I may.
I think you are to be commended for the 20 many initiatives you have taken t h. *. certainly have the 21 potential for increasing the safety of operations for your 22 plant.
23 You are an experienced utility, and in my view you 24 should be well above average in all respects, but frankly 1 25 was disappointed when I heard about the personnel errors, as
i i
t i
89 1
Mr. Boyer knows, you had initially.
And I recognize that 2
moving from Peach Bottom to Limerick is a different plant and 3
so forth, but it seems to me that no matter what, the message 4
should be that continual vigilance and supervision is 5
necessary.
And I think that even though you are experienced,
-6 it seems to me that if I were you, I would be very watchful 7
and very mindful of the way things went, and I think certainly 8
there should'be no complacency set in.
9 I think you should have an attitude of doing it 10 right and working hard at it, rather than accepting of the 11 personnel errors for some other 12 MR. BOYER:
We have not accepted them.
as things that just happen.
13 COMMISSIONER ZECH:
14 Because they don't happen.
And my view is that management 15 should be involved in analysing those errors and benefiting 16 from them, and lessons should be learned and so forth.
17 So even though you are experienced, I think you 18 should recognise that perhaps you can do an even better job 19 than you're doing.
20 MR. EVERETT:
Our motto is going to be we'll never 21 rest until we're the best.
22 COMMISSIONER ZECH:
Good motto.
But you have got to
)
23 follow through on it.
24 MR. EVERETT:
Absolutely.
And we intend to.
25 COMMISSIONER ZECH:
Good.
'h O
1 COMMISSIONER ASSELSTINE:
I would agree very much 2
with the comments that Commissioner Zech just made.
I think 3
he's right on the mark.
I think all of us, quite frankly, 4
were a little surprised at some of the problems that occurred.
5 MR. BOYER:
I think it's partly due to the fact that 6
the operators hadn't been working with the tech specs for a 7
long period of time, and suddenly this whole bible of 8
documents and requirements is thrust on them.
And it takes a 9
while to work into them and become familiar with them.
10 MR. EVERETT:
Well, we won't make excuses.
We'll 11 just make up for the failures of the past by the success of i
\\~/
12 the future.
13 COMMISSIONER ASSELSTINE:
Good.
14 COMMISSIONER ROBERTS:
Any further questions?
15 COMMISSIONER ASSELSTINE:
No.
16 COMMISSIONER ZECH:
No.
17 COMMISSIONER ROBERTS:
Thank you, gentlemen.
18 MR. BOYER:
I would like to thank the NRC Staff 19 Region, Washington and Bethesda, for their cooperation through 20 the whole entire construction and preoperational program.
We 21 have worked well together.
They've worked hard and our 22 engineers of Philadelphia Electric and operators of g
f
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23 Philadelphia Electric have worked extremely diligently and 24 hard, too.
1 25 COMMISSIONER ROBERTS:
Thank you.
Thank you, i
i l
.i
.)
I 1
Now why don't we have the Staff rejoin us.
i
[
2 Based upon what we have heard, do any of my brothers 3
have any questions of the Stafff 4
MR. EISENHUT:
I would like to try to clarify the, 5
question that was referred to us just a second ago, if I f
6 could, just very briefly.
And that is the question of the i
I l
7 Staff did require a PRA on this plant and an examination of 8
what additional features should be in the plant.
We went 9
through that process over the last four or five years.
i 1
10 We concluded that the probability of coremelt in 11 this plant was orders of magnitude less than was referred to O
12 earlier.
The number'of something like 1 in 30,000 sticks in 13 my mind.
But it's that order of magnitude for the probability 14 of coremelt.
l 15 The probability of early fatalities, of course, is 16 even less.
And those numbers were done without consideration 17 of any of the source term considerations.
18 Some of the numbers referred to were, I believe, 19 referred back to the numbers of the worst case estimates that t
20 were in our Final Environmental Statement.
These issues have L
21 been debated quite a bit.
I r.
fact, they were the subject or 22 some of them were the subject of the Second Partial Initial l
~
l 23 Decision, and although the Commission completed its 24 Immediately Effectiveness Review, that issue still is pending 25 before the Appeal Board.
1 COMMISSIONER ASSELSTINE:
That's right.
2 MR. EISENHUT:
And because of that and the 3
complexity of the numbers, the Staff would prefer to respond l
4 in writing'to the Commission if you'd want to go into the i
I 5
detailed numbers that wert gone by here real quickly.
6 One other thing, so we didn't leave the Commission l
7 with the wrong impression 8
COMMISSIONER BERNTHAL:
Darrell, I think, though, to 9
make clear what you're saying here, I gather from the number 10 you quoted, that the judgment of the Staff at this point is 11 that those numbers of 1 in 12 or 1 in 25, whatever they were, O
./
12 coremelt probability for the life of the plant, are somewhere 13 between 10 and 100 times too high.
Is that a fair statement?
14,
MR. E!SENHUT:
I think that's correct.
I think the i
15 number that sticks in my mind, as I said, is something like 1 16 in 30,000, the chance of a corement per year.
17 COMMISSIONER BERNTHAL:
Right.
18 MR. EISENHUT:
As our best estimate.
And, of 19 course, the early fatality number would be less than that, i.
20 COMMISSIONER BERNTHAL:
Certainly.
I 21 COMMISSIONER ASSELSTINE:
All this is still a matter 22 that's s
I 23 MR. EISENHUT:
It's a matter that is in adjudication
'..d l
(
24 before the Appeal Board,-and we would prefer to go back, since and address them in writing.
25 all the numbers were
y m
t i
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)
i P
93 x
1 COMMISSIONER BERNTHAL:
But there is no changing the 2
fact that it is in a higher population density area, and one 3
has to simply flatly recognize that.
But the question is
'4 whether the plant is adequately safe, and I take it it is your 5
judgment that the plant is adequately safe, given the 6
population density of that area.
7 MR. EISENHUT:
That is correct.
In fact, that is 8
why we went to the extra level of requiring a full PRA 9
evaluation, looking at additional design features that might 10 be in the plant, and there are additional features in the 11 plant to actommodate the situation.
'\\
i 12 COMMISSIONER ROBERTS:
Go ahead.
13 MR. EISENHUT:
The other issue I wanted to clarify 14 to make sure we didn't leave you with the wrong impression 15 related to the Yoh Securtty guards.
The 01 investigation on 16 Limerick has been completed.
It was summarized in the status 17 memorandum to the Commissioners, dated August the 2nd.
The 18 investigation did not disclose evidence that any of the 19 Philadelphia Electric personnel were involved.
20 The Yoh Security situation, with respect to the Yoh 21 Company, we felt was resolved on Limerick in that the 22 situation had been corrected.
The overall situation,
'3 therefore, on Limerick we feel satisfies our requirements.
l 24 We are continuing the evaluation of the Yoh matter, 25 as discussed in Ben's August 2nd memorandum.
4.
.g 3
94
- ,q
')
1 COMMISSIONER ROBERTS:
Further questions?
2 COMMISSIONER ASSELSTINE:
No.
3 COMMISSIONER BERNTHAL:
No.
4
. COMMISSIONER ROBERTS:
All right You have heard 5
the Staff's presentation, the Licensee and Intervenor.
7 i
'6 All in favor of allowing the Licensing Board's 7
Fourth Partial Initial Decision to become effective, thus e
authorizing the issuance of a full power license for Limerick, 9
Unit 1,
indicate by saying eye.
10 Aye.
11 COMMISSIONER ASSELSTINE-Aye.
lf
..,e 10 COMMISSIONER BERNTHAL:
Aye.
13 COMMISSIONER ZECH:
Aye.
I 14 COMMISSIONER ROBERTS:
All opposed?
15 CNo response.)
16 COMMISSIONER ROBERTS:
All in favor of issuing the 17 order which you have all seen proposed tur the Office of 18 General Counsel, indicate by saying aye.
19 Aye.
20 COMMISSIONER ZECH:
Aye.
21 COMMISSIONER BERNTHAL:
- Aye, 22 COMMISSIONER ROBERTS:
Opposed?
23 COMMISSIONER ASSELSTINE:
No.
While I agree with 24 the conclusion of the order, I have some problems with the 25 substance of the order, and I will have just a couple of 4
?!
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}1 Y
95
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1
' sentences to stick'in the order that just lays out the areas 2
where I have a fow p r o b l e m s'.
3 CODO4ISSIONER. ROBERTS:
. Adjourned.
4 CWhereupon, at 12:35 p.m.,
the meeting was 5-adjournedc3 4-7 8
9 10 11 m.'
12 13 14 15 16 17 18 19 20 21
-22
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'23 s
24 25
i
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7 9
1 CERTIFICATE OF OFFICIAL REPORTER 0
+
3 4
5 This is to certify that the attached proceedings 6
before the United States Nuclear Regulatory Commission in the 7
matter of:
9 Name of proceeding:
Discussion /Possible Vote on Full Power Operating License 1
to for Limerick
.i 11 Cocket No.*
A
- s. ;
12 piace:
Washington, D.C.
13 Date:
August 8, 1985 14 15 were held as herein appears and that this is the original 16 transcript thereof for the file of the United States Nuclear 17 Regulatory Commission.
13^
(Signature)
, p, (Typed Name of Reporter)
And Riley-20 21 22
]
23 Ann RiIey & A s s'o c i a t e s, Ltd.
.s 24 25 m
e m
m.
y 8/8/85 SCHEDULING NOTES TITLE:
DISCUSSION /POSSIBLE VOTE ON FULL POWER OPERATING LICENSE FOR LIMERICK SCHEDULED:
10:30 A.M., THURSDAY, AUGUST 8, 1985 (OPEN)
DURATION:
1-1/2 HRS SPEAKERS:
- NRC STAFF
. PHYLLIS ZITZER, PRESIDENT (5 MIN)
LIMERICK ECOLOGY ACTION 4
i eJ. L. EVERETT, CHAIRMAN OF THE BOARD AND CHIEF EXECUTIVE OFFICER T
I VINCENT BOYER, SENIOR VICE PRESIDENT FOR NUCLEAR POWER (PHILADELPHIA i
ELECTRIC COMPANY) f 4
h e
-4 r,
I f
COMMISSION BRIEFING LBfERICK UNIT 1
~
Pull POWER flCENSE AUGUST 1985 CONTACT:
R. E. )LEdIN X24937 SLIDE f
e
. -.' I.....*.......
}
BRIEF:NG OUT:1TE l
l LICENSEE / PLANT BACKGROUND SELECTED ISSUES CONSTRUCTION OVERVIEW LOW POWER LICENSE OVERVIEW l
I MANAGEMENT PERSPECTIVE l
l l
INVESTIGATIONS l
2.206 PETITIONS CONCLUSION SUDE 2
l
- ZC3XS33/ZE" 3ACIG30'JJ LICENSEE - PHILADELPHIA ELECTRIC COMPANY SOLE OWNER AND OPERATOR OF UMERICK GENERATING STATION OPERATOR OF PEACH BOTTOM VNITS 2,3 FOR OVER 10 YEARS PLGT GE, BWR/.4, MARK II, 3293 MWT,1092 MWE (CEOSS)
SIMILAR TO SUSOVEHANNA UNITS 1 AND 2 A/E AND CONSTRUCTOR - BECHTEL SITE AB0VE AVERAGE SITE POPULATION FACTOR LOCATED ON SCHUYLKILL RIVER IN MONTGOMERY AND CHESTER COUNTIES, PENHSYLVAtllA NEAREST TOWN - POTTSTOWN (/.7 #/lES, F0FulE/0N 23,000) 21 MILES tl0RTHWEST OF PHILADELPHIA SLIDE 3
I SEsC"sD ISST3S 1
FSA3 K3 vin FIRE PROTECTION ENVIRONMENTAL QUAllFICATION t
LOW-LEVEL WASTE STORAGE STAFFING
'.EC:EK: CAL S:?EC3::CA"::0NS SEVER:S ACCIDE:ST RISK ASSESSMEr l
EME3G:INCY.:?REPAREDEISS d
t S~:?:?:23k3M.A3Y C00::FG WA"33 SLIDE 4
-- f
6
- l 3h3RG3NCY ?E?A33DNESS
~
ON-SITE EP REVIEW COMPLETED FULL PARTICIPATION EXERCISE JULY 25,1984 SUFFLEMENTAL AND REMEDIAL EXERCISES -
NOVEMBER 20,1984, MARCH 7, APRIL 10 AND 22,1985 FEMA REPORTS OF ADEQUATE PLANNING AND PREPAREDNESS ISSUED MAY 21 AND 30,1985 STAFF SER ON OFFSITE ISSUES - JULY 1985 ASLB PARTIAL INITIAL DECISIONS - MAY 2, AND JULY 22,1985.
STAFF SER ON EXEMPTION FOR' FULL PARTICIPATION EMERGENCY EXERCISE - AUGUST 1985 SLIDE 5
SUPPLEMENTARY COOLING WATER SYSTEM (POINT PLEASANT DIVERSION PROJECT)
'A"ESENOi$
NEW JERSEY AND PERK 10MEFJ PUMP STATION TRANSMISSION MAlfJ A
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- 00 0aaoa 9
e?cp u
POINT PLEASANT 1
O$NTA gje*N.
PUMP STATIOrd
- (
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F WATER TREATMENT PLAf Ooylestown O
PECO TRANSMISSIOf1 LINE O*
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TRANSMISSION MAlfJ g,
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CONSTRJC" ION OV33Visu LOW P0Y33 :ZCENS3 OVE3 VIEW 4
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1
>l CONS:liCION OVERV]W CONSTRUCTION - READINESS ASSESSMENT REPQRT (10-25-84)
QA - SpECIAL ASSESSMENT OF THE QUALITY OF CONSTRUCTION (10-25-84)
ALLEGATIONS
-NUMBER, NATURE, AND ANALYSIS SALP RESULTS - FOUR REPORTS ON CONSTRUCTION ACTIVITIES SUDE 8
]
7 LOW POW 33 IZC3XS3 OVIRVOat PREOPERATIONAL AND STARTUP TEST PROGRAM PERFORMANCE OF TEST REYlEW BOARD TURBINE ROLL CONDUCTED SATISFACTORlLY NO SIGNIFICANT HARDWARE PROBLEMS IDENTIFIED DUR TEST PROGRAMS ASSESSAENT OF OPERATIONS OPERATING STAFF INITIAL CONCERNS REGARDING PERSONNEL ERRORS 1
SLIDE 9
e MANAG3MEr :?33S?ECC:YE 3FF3C"VB3SS 0:? kIVAGE13NT A"3N" ION AXJ 3V0Zh3M? "0 WAD XUC:AR SAZ3"Y
)
LICENSEE STRENGTHS INCLUDE:
LIMERICK SITE STAFF ENGINEERING STAFF OVERSIGHT OF CONSTRUCTION CONTRACTORS I
LICENSEE WEAKNESSES INCLUDE:
OVERSIGHT OF SERVICE CONTRACTORS SLIDE 10
-. 2 l
1 --.: -.... - --...... - -.... -...
i i
SALP SUhfhfARY 12/1/82 To 12/1/83 To FUNCTIONAL AREA 11/30/83 11/30/84 TREND
- 1. CONSTRUCTION 1*
1 CONSISTENT ACTMIlES
- 2. PREOPERAil0NAL AND 2
2 IWFROVING STARTUP TESTING
- 3. OPERAi10HAL 2
2 IMPROVING READINESS AND PLANT OPERATIONS
- 4. PJ410LCGCAL NOT ASSESSED 2
IMPROYlHG CONTR01.S
- 5. RRE PROTECTION /
NOT ASSESSED 1
IMPROVING HOUSEKEEPING
- 6. EMERGENCY NOT ASSESSED 2
IMPROVING FREPAREDHESS
- 7. SECURITY AND NOT ASSESSED 3
IWPROVING SAFEGUARDS
- 8. UCENSING 1
1 CONSISTENT
- EXCEPT 2 IN INSTRUMENTATION AND CONTROL AND IN &YGINEERING/C[5/GN CONTROL SUDE 11
r-
-f
. _............ ~...,......... _ _, _.,,,,,
=
i 6
1r C0XCLUSION STAFF CONCLUDES THE LICENSEE MEETS ALL THE REQUIREMENTS FOR ISSUANCE OF A FULL POWER LICENSE a e 9
SUDE 12
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TRANSMITIAL 'IO:
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documents wherever known.
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