ML20134D129
| ML20134D129 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point  |
| Issue date: | 01/06/1997 |
| From: | NRC |
| To: | |
| Shared Package | |
| ML20134C732 | List: |
| References | |
| EA-96-079, EA-96-79, NUDOCS 9702040329 | |
| Download: ML20134D129 (46) | |
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UNITED STATES OF AMERICA l NUCLEAR REGULATORY COMMISSION l
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PUBLIC MEETING 3N NIAGARA MOHAWK POWER CORPORATION, NINE MILE POINT UNIT 1
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MONDAY l
JANUARY 6, 1997
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ROCKVILLE, MARYLAND
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The meeting was held at the Nuclear Regulatory Commission, One White Flint North, Room 1-F7/9, 11555
- Rockville Pike, at 2:00 p.m. , Jim Lieberman, Director, Office of Enforcement, presiding.
- PRESENT:
JIM LIEBERMAN MARK SATORIUS JOHN A. ZWOLINSKI S. SINGH BAJWA DARL HOOD DANIEL J. HOLODY DENNIS ALLISON TIM MUtTIN 9702040329 970203 PDR ADOCK 05000220 NEAL R. GROSS O COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W.
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i
' 2 NIAGARA MOHAWK POWER CORPORATION:
RALPH SYLVIA
(
CARL TERRY MARTIN McCORMICK, JR.
DENISE WOLNIAK GARY WILSON MARK WETTERHAHN NICK REYNOLDS i
4 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W.
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1 PROCEEDINGS 1 I
2 2:04 p.m. I
\ i 3 MR. LIEBERMAN: Good afternoon. I'm Jim 1 l
4 Lieberman, the Director of NRC Office of Enforcement. This 5 meeting today is between the NRC and Niagara Mohawk. It's 6 being held at the request of Niagara Mohawk made by Nick 7 Reynolds, Niagara Mohawk's counsel to discuss enforcement 8 action EA'96-079, issued to Niagara Mohawk for violations 9 associated with Nine Mile Point.
10 This action was issued on December 3, 1996 and it 11 involved two violations subject to civil penalties and two 12 nonescalated violations not subject to civil penalties.
13 This meeting is being transcribed in accordance 14 with Agency policy since it involves an enforcement action 15 that has bean issued.
16 It is my understanding today that the meeting is 17 to discuss violation 2B which is now considered for escalated 18 enforcement action. This violation concerns reporting the 19 exceedence of the design basis of the pressure and relief 20 panels.
21 We have granted an extension of time until 22 January 24, 1997 for Niagara Mohawk's formal response to the 23 December escialated enforcement action so that this meeting 24 could be held.
25 Before beginning with the meeting, let's go NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W.
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1 around tho tablo and introduca ourzalvas for the record.
2 Mark?
k 4
3 MR. SATORIUS: Mark Satorius. I'm Deputy 4 Director of the Office of Enforcement.
3 5 MR. ZWOLINSKI: I'm John Zwolinski. I'm Deputy i 6 Director for the Division of Reactor Projects, Region 1 and 1
7 2.
i 8 MR. BAJWA: I'm Singh Bajwa. I'm the Acting l
- 9 Project Director for AD 1-1.
10 MR. HOOD: I'm Darl Hood. I'm the Project 11 Manager for Nine Mile Point.
12 MR. ALLISON: I'm Dennis Allison. I'm one of the 13 co-authors of the draft at Headquarters here.
14 MR. HOLODY: Dan Holody, Enforcement, Region 1.
15 MR. WILSON: I'm Gary Wilson, Attorney for 16 Niagara Mohawk.
17 MR. WETTERHAHN: Mark Wetterhahn, counsel to 18 Niagara Mohawk.
19 MS. WOLNIAK: Denise Wolniak, Niagara Mohawk.
20 MR. TERRY: I'm Carl, Niagara Mohawk, Vice 21 President, Nuclear Safety, Assessment Support.
22 MR. SYLVIA: I'm Ralph Sylvia, I'm the Chief 23 Nuclear Officer, Niagara Mohawk.
24 MR. McCORMICK: I'm Marty McCormick, I'm Vice 25 President of Engineering, Niagara Mohawk.
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5 1 MR. REYNOLDS: Nick Rsynolds, counsal of Niagara 2 Mohawk.
, t 3 MR. MARTIN: Tim Martin, I'm the Director of the I 4 Division of Reactor Corporate Management.
5 MR. SATORIUS: At this point, Ralph, you've asked l 6 for this meeting. Why don't you go ahead and give us your j 7 views on what you want to discuss.
j 8 MR. SYLVIA: Okay, first of all, I may thank you 9 for taking your time and bringing your folks to meet with us.
l
- 10 As you stated, we're not here to talk about the i
11 two violations associated with the civil penalty. You 12 proposed a civil penalty. We responded. You considered our 13 response and you told us that you still felt like we should 14 be fined $50,000 for failure to properly identify and take i
15 comprehensive appropriate action. We agree with that and we 16 will use those lessons learned to incorporate into our 17 programs and improve our performance in this regard.
18 Nor are we here to discuss one of the other Level 19 4 violations, one regarding corrective action report on human 20 performance.
21 We're really here to discuss the Level 4 22 violation on reporting, in the report. And the reason we 23 want to discuss this with you is because of the implications 24 that it has on our reporting for the future.
25 We think if we interpret what you're telling us NEAL R. GROSS COURT REPOHTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W.
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. 6 1 to rsport in tha futura, that you'll be floodsd with our
- 2 reports at the Red Alert reporting for one out wnuld become
- 3 routine rather than reporting significant issues that really 4 represent some degraded condition at the plant. We feel that
. 5 this would be a distraction in the control room. It would be 6 a burden on the shift supervisor running a plant and it would i
7 probably have overall negative impact on safety.
8 We don't feel this way because we don't like j
9 reporting. We tell our people if there's any question
.i 10 whatsoever, to send in a report and we can always reject it.
11 We think we're pretty conservative in our philosophy 4
12 regarding reporting. But the guidance we give our people for 4
13 implementing this philosophy is based on the regulatory 14 requirements and the guidance that you've issued regarding 15 those regulatory reporting requirements and this issue i
16 actually goes to what is the design basis. We think it's 80 17 pounds and you think it's 45. So we really have a z
18 misunderstanding about your position or we're a little j 19 confused actually. And what we'd like to do is to walk you 20 through our thought process why we think it's 45, how we 21 think that thought process relates to the example you're l ,
i 22 using in the NUREG 1022 and as we go through it, we'd like !
l 23 for you to give us your thinking, tell us what your thought .
I 24 process is for disagreeing with that and maybe we can reach I
25 an understanding about future reporting requirements before NEAL R. GROSS l COURT REPORTERS AND TRANSCRIBERS !
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. 7 1 wa loava. That's what we'd like to do.
2 MR. LIEBERMAN: I'm not sure if we're going to i
3 achieve a final NRC position, but we can certainly discuss 4 where we're coming from.
5 MR. SYLVIA: Okay. Carl Terry will make this 6 presentation on our thought process, but as we go through, we 7 want this to be a conversation type of thing, not us doing 8 all the talking, because we really need to understand the 9 issue.
10 MR. LIEBERMAN: Okay.
11 MR. TERRY: Before I get into the specifics on 12 the blowout panel, one of the thinge that we think is still 13 within -- and this all part of coming to an understanding of 14 what you're trying to tell us, but an important premise that 15 I'm going to have here and I want to get it up front is that i
16 the guidance in NUREG 1022 still is appropriate guidance to l
17 use in making determinations for reportability including the l l
18 design basis.
19 Is there fundamental message that you're trying 20 to send us as part of -- that's really kind of an opening 21 question al.d if there is something in there, then maybe we'll 22 want to talk about that a little bit.
23 MR. LIEBERMAN: Dennis, do you want to speak to 24 this.
25 MR. ALLISON: This is Dennis Allison. I don't NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W.
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l 8 1 sss any chenga of intsnt coming up in the final varaion of 2 NUREG 1022. It hasn't yet been reviewed by other offices k
3 like NRR and Enforcement. I've drafted this and I'm going to 4 redraft it again before they get a chance to comment on it, 5 but my intent is to embellish a little bit more and add more 6 examples.
7 I think the judgment, you'll still have to make.
8 There's like a single fire extinguisher or something. That's 9 one end of the spectrum. You can go up higher from there.
10 I think you'll still have to make that judgment 11 as to whether you consider it outside the design basis or 12 not. So that's where I see it headed.
13 MR. TERRY: Okay, good. Then really it was more 14 than fundamental than that as far as what's on the table ;
15 today you're really not kind of telling us NUREG 1022 is off I
16 the table, I guess is kind of where I'm coming from.
17 We read that in there. We're going to promise I
18 everything we say against the NUREG 1022 guidance, so I want I 19 to make sure that we've got the right benchmark for doing 20 this. I think that is and I just want to kind of confirm 21 that.
22 I understand it's still a revision, but it is the 23 latest information that's out.
24 MR. LIEBERMAN: We don't intend a new I 25 interpretation by this action. I think the issue really NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W.
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. 9 1 turno on what's tho dazign bacie and what dona ths FSAR cay 2 and we see it one way. I'm looking forward to hear what
(
3 you're going to say why we should be wrong.
4 MR. TERRY: Very good. That's what we thought, 5 but if that were the case we'd have to talk abut that first.
6 MR. LIEBERMAN: So I'll get into our kind of 7 rationale in just a minute, but and I really we expect that 8 most people here are generally familiar with the issues and 9 I'm not going to go back through that, but really just an 10 overview of the condition that existed back in 1993.
11 First off, before even getting into that just 12 talking about the blow panel panels themselves. They are 13 actually -- they actually perform two functions. One is to I
14 be part of the reactor building site, in other words, their 15 part and turbine building, the part of the enclosure for 16 that.
17 MR. SATORIUS: Keeps the rain and snow out.
18 MR. TERRY: Keeps the rain out. They're designed 19 not to blow out in a high wind and things of that nature and 20 those things are described in the FSAR.
21 Also, they're part of in the reactor case, the 22 reactor building, they are there to perform the secondary 23 containment function for reactor building exfiltration to 24 control --
have a control release in the event of an 25 accident.
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. 10 1 And that really is thnir dssign, ths dssign 2 function from a safety standpoint is in the case of a reactor
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3 building panels and in particular, from a design basis 4 standpoint.
5 They also -- and also described in the FSAR is a 6 function of pressure relief in the event of a line break or 7 some other event, but really presumed to be a line break 8 inside the turbine building or reactor building that 9 pressurized the buildings. And there the function is 10 described as providing a relief to the pressure in the ,
11 building such that we maintain the design capability of the 12 building ud avoid pressures in excess of 80 psf which is the 13 design basis for the citing itself and the overall 14 superstructure.
15 So that's where it is. Now the number that is in j 16 the FSAR also, for that particular function is approximately 17 45 psf. So to kind of lay that out, just to put together a 18 kind of short summary of what we, where we were back in 1993 19 and again, as I indicated at that time frame, we had 20 approximately 40 psf is the described value for what we call 21 blow out functions. They're also referred to as relief 22 panels. But that is described and that's what we would 23 ::onsider to be an operational nominal value as described, 24 again for that one function.
25 The building design capability, the way it's NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W.
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1 statGd in ths FSAR is actually that tha building citing ccn
$ 2 withstand an excess of 80 psf, but that's really the minimum
(
3 design capability as described in the --
4 MR. SATORIUS: And that 80 pounds is listed in 5 the design basis portion of the FSAR? Is that right?
6 MR. TERRY: It's under a section called " Design I 7 Basis", right.
8 MR. SATORIUS: What section is the 45 under?
l 9 MR. TERRY: They're both in a section that's
- 10 labeled design basis.
i 11 MR. SATORIUS: Okay.
i 12 MR. SYLVIA: It's referenced as a relief 13 function.
14 MR. TERRY: Under the same paragraph, the same i ,
15 two paragraphs, but they're under -- they're both under that l 16 section.
17 Also, we know that the building failure itself, 18 one of the things in discussing the response to the violation 19 as referred to as the point of failure in the building and i
20 the response. In fact, it's not the point of failure. the l d
21 building failure is a number greater than 80 psf.
22 Now subsequently, we've actually calculated that i 23 number because there were some operabilities questions that 24 came up later on because we, in fact, as I think we now have 25 a condition where it was even greater than 80, so we had to i
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. 12 i
) 1 do an cparability dstsrminntion and run coma calculations l 2 which ranged from 129 through -- ;
1k 3 MR. SYLVIA: That's when we reported it because i
2 4 we believed 80 was the basis and that's how the issue, how 5 you became aware of the issue, is what we reported, 80 was i
j 6 our interpretation.
7 MR. TERRY: So at any rate, this is a number 8 described in the FSAR and this is the structural design 9 =apability as described in the structure.
10 We had a condition in 1993 where we had in the 11 turbine building a number of 53 and in the reactor building 12 a number of 60 psf. That was calculated once we determined 13 : hat the installation was different than the construction 14 drawings. We ran a calculation and determined that, in fact, 15 i ts it turned out, and as you know that calculation happened 16 <
- o have been erroneous, but at the time the information 17 a lvailable for the evaluation of reportability and operability 18 of a melt had a number of 53 to 60 psf which was a calculated 19 blowout function. That's when they would blow out as far as 20 the pressure was concerned.
21 Now at that time we did an operability 22 t ietermination and also assess reportability. And what we
- 23 had, what we looked at, was whether or not the function of 24 the panels would work, the function being to protect the 25 ouperstructure of the building and that is described in the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHOOE ISLAND AVENUE, N W.
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13 1 FSAR that you want to maintain tha turbine of the 2 superstructure.
I l 3 So we ran an calculated analysis. In fact, in !
l 4 that operability we see the curve would show you that we 5 expect the pressure to rise somewhat about these numbers in )
6 the original assumption. When you have it, you kind of have 7 a spike and that it comes down as relief panels go. So it's 8 not instantaneous. It stops off at 45 and goes down.
9 The key thing really is that it is still low 10 enough to assure that the pressure would remain below 80 psf 11 and the function would be maintained.
12 Now what we did when we looked at that is we did 13 focus on whether or not that design function was maintained.
14 Re think that's consistent with the guidance applied in NUREG 15 1020 and in fact, that's applied in the definition of a 16 design basis in 50.2 that talks there about the fact that you 17 may have specific values that are stated, but what you really 18 need to look at are what are the specific values to insure 19 the functional capability.
20 In this case, the functional capability must be 21 such that it stays below the design allowable for the 22 building which is a minimum capability, not a failure point 23 as was indicated.
24 Now we think that this is exactly analogous to a 25 :ondition where you're looking at say a piping system. This NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W.
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- 14 1 is a chort ekstch, and I'll kind of take you through that, )
2 how we are looking at this. !
This really gets down to the
?
! 3 heart of what we based our operability, excuse me, 4
reportability evaluation at that time and it is the way we 5 would do it today, so that's why it's very important to get 6 a clear understanding of what it is that you may be trying to l
, 7 tell us.
} 8 When we look at the blowout panel number where we i i
9 and a situation where it was at 45 psf, which is analogous to 10 something that might be described on a piping system, let's l 11 .
say . We have piping system stresses within the piping system 12 with all hangers intact. Now what we found is that there was 13 a deficiency on the blowout panel against its construction-14 < 1rawings. It was not installed as it was supposed to be.
15 So we went ahead and did a calculation to 16 <
letermine what does that mean in terms of the capability of 17 that component to perform its function, its function being to 18 perfect the building. We calculated it at 53 and 60 psf and 19 ve also did determine whether that would be sufficient to 20 ntate the number in terms of the pressure inside the 21 building.
22 We think that's analogous to a condition where 23 rou go out in the field and you find a pipe support that 24 night be missing or broken. You would look at that pipe
( 25 i,upport, obviously, here as well as here. You write a NEAL R. GROSS COURT REPORTERS AND TRANSCRl8ERS 1323 RHODE ISLAND AVENUE, N.W.
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' 15 1 dsficiency report, eithsr an opsrability dstsrmination, but 2 in terms of reporting, you would take a look at well, what
(
3 are the consequences of that pipe support being missing on
- 4. the stresses in the pipe or on other supports?
5 And our guidance is and we think this is 6 consistent with 1022 would be if you look at the stress 7 remains below your code allowables, that it would not be 8 reportable. On the other hand, if you had a condition that 9 would allow the building to go in excess of 80' psf, or a 10 condition where the piping system exceeded its code 11 allowable, it would then be clear to us that it's reportable.
12 So that's why we say once we got above this point s
13 as Ralph indicated earlier, we found a mistake in that 14 calculation back in 1995. Determined that, in fact, the 15 pressure, blowout pressure would be greater than 90 or 80, 16 eventually around 90 psf, in addition to fixing the panels 17 immediately, we happened to have been shut down. We didn't 18 do a shut down because of that. We happened to be down, but 19 We did fix it before.
20 We also determined that there was a issue about .
21 that, and we do agree today there's no question that 22 condition is reportable. It's just like here.
23 What we're struggling with and kind of what's 24 fone is done on the violation itself. We've been through 25 that. We've modified it and we've taken the bolts out.
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' 16 1 W3'ra in a differsnt cituation today than wa wars in '93 2 anyway. It comes in a manner as kind of historical, but 3 we're still doing it this way. If we found that we had 4 sufficient margir. below the design capability for the 5 allowable, we would say it does not affect the functiot - '
6 the component and consequently it would not be reportable and 7 that's really where our struggle is because we think --if we 8 take another interpretation what we wind up with is any time 9 you have a number that is let's say less consrivative than a 10 number in your FSAR or even a description in your FSAR, it 11 doesn't just stop at numbers. There's something described in 12 there that's different and somehow a little less 13 conservative, that would automatically be reportable. That's 14 Where Ralph is coming from in terms of we think that would be 15 an excessive number of reports. It would be a burden on us, 16 a burden on you and it would dilute, we think, the intent 17 behind 50.72, .73 and everything else.
18 That's why we're here and that's what we need to
.17 understand.
20 MR. SYLVIA: We believe the industry is reporting 21 this way too, just conversations with them and talking with 22 folks.
23 We believe this is consistent.
24 MR. LIEBERMAN: What does 10.22 actually say?
25 It says a single pipe support missing, all the pipe support NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 F4HODE ISLAND AVENUE, N W.
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17 1 miccing?
2 MR. TERRY: It uses an example of a missing pipe 1
3 support as I recall. Its' an example. It doesn't just say 4 it can only be one. But it says you've got a pipe support 5 that's missing or broken and do the analysis. This is the 6 important determination.
7 Now what happens to the piping system as a result 8 of that, again, similar to this. In this case, the panel 9 performs a function. And it's the component, just like the 10 pipe support that keeps the piping in place, the panel keeps 11 the building from becoming overpressurized.
12 MR. SATORIUS: The only difference being that the 13 panel has a quantitative number associated with it. In this 14 case, it's 45 pounds. Typically, pipe support is listed, 15 every pipe support is listed on the FSAR --
1 16 MR. TERRY: You should read the FSAR, the insert. I l
17 MR. SATORIUS: This is -- ,
l 18 MR. TERRY: Okay, but there are other numbers in 19 there, so again my concern is how to give guidance to people I
20 on how to do an evaluation. I'm not here to debate per se 21 whether this is right or wrong. It's more important to me to 22 figure out what is the right guidance and right now, we do 23 evaluation, we do find conditions where you could have a pipe 24 support that's a little off in terms of its placement. We 25 analyze it. We make this determination and that is thee way NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W.
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. 18 1 wa do it. Eithsr ona just happsns to hava less datnil, but i
l-I ;
2 it's really -- again, it's the principle of how to apply it. ,
i l 3 It kind of doesn't matter whether it happens to be described l
1 4 10 times or one time or whatever. We just think we're 5 applying the direction, the guidance correctly and that's
- 6 where we're struggling. '
7 We think we're doing it right.
l 8 MR. MARTIN: Carl, let me ask you a question. I l
9 assume that your numbers that you're reporting up there are 10 static pressure numbers, not dynamic pressure numbers?
l 11 MR. TERRY: Correct.
12 MR. MARTIN: For instance, even though the 13 blowout panel was designed to relieve the 45 pound static, 14 even that would not prevent the actual peak pressure from 15 being higher than 45 in a steam blowout. Did you take that 16 into account in determining that the 80 was -- I mean, I i 17 don't know where the 45 came from. If the 45 came from an 18 analysis that says I've got to have it starting to open this 19 point to make sure that it doesn't exceed 80 in reality.
20 MR. TERRY: Where I think the 45 actually came i
21 from and this is looking at some other words in the FSAR is l
( 22 actually where that comes from is you need at least that much l 23 strength to keep it from blowing on into burden of 125 mile
! 24 an hour wind. So again, you have to remember this panel has 2 i l 25 two functions, so it isn't the best thing in the world for it a
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19 1 to fall cut end in fcct, on cny dasign b: sic of that you want 2 it to stay in there.
~
t i
3 This event happens to be, for Unit 1, happens to 4 be outside of our design basis. This is a nonevent as far as 5 the design basis, but nevertheless, it is a design --
6 MR. MARTIN: Let me take my argument a step 7 further. I mean if you're asking a shift supervisor to know i
8 What is the point between 45 and 80 where the design basis of 9 the building is not met, how in the hell is he going to do 10 that?
11 MR. TERRY: He doesn't do that. He comes to 12 engineering and what we do -- that's what I said -- we deal 13 with operability, which is something we're obligated to do 14 cight at that time, right at that time and we looked at it.
15 In fact, if you were to read our operability -- I don't have 16 it with me, but it in fact showed that they would expect the 17 pressure to go above 60. It doesn't -- it starts to relieve 18 st 60. It goes up to some number and then comes back down.
19 30 that's FS-wide, so what you have to look at is whether --
20 if that peak pressure were to exceed this number, then yes, 21 then clearly you wouldn't be performing the protection 22 . function of the panel.
23 Again, that's the key word, I think, starting 24 Tight with 50.2. When you look at the design basis, I think l 25 you have to look at the function that it's starting to form, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W.
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- 20 1 not just -- and if you look at numbers, you look at th:m in 2 the sense of what are they doing from an overall design. In
(
3 this case, what's important is keep it below 80. Keep it 4 below 80 because that's the minimum. That's not the failure 5 number. That's your design value. So it's analogous to 6 keeping the piping pressures below a point where you've 7 exceeded a co-allowable or perhaps in the case of lead piping 8 the pressure design of the piping.
9 MR. MARTIN: Doesn't the FSAR say that 10 vulnerability of structure failure would occur at a general 11 pressure in excess of 80?
12 MR. TERRY: In excess of 80.
13 MR. MARTIN: So at 81, you expect --
14 MR. TERRY: No, no, no, no. That's not when we 15 would expect it -- that would be done in a calculation. ;
I 16 MR. MARTIN: It sayc "would occur at".
17 MR. TERRY: In excess of 80. 80 is the design.
18 80 is the design number, the minimum design capability of the 19 -- like I said, in fact, we didn't run this analysis until 20 later. I'll grant that. But 'oack when we looked at that 21 about six months ago, the fact is that number was at least 22 129, 129 in the turbine building.
23 MR. LIEBERMAN: But the reviewer is reviewing 24 this FSAR. We're basically saying there's really no margin 1
f 25 at 80.
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21 1 MR. TERRY: I wouldn't agree with that. Tha
! 2 people reviewing -- knew that was an engineering number, that
! (
l 3 that was a minimum capability number, not a failure number.
4 No sir. That's a design value, not a failure -- it would be 5 just like reading a piping table and seeing la pressure.
6 MR. LIEBERMAN: You're well above the design rate 7 due to required design?
8 MR. TERRY: I'm sure of it.
9 MR. LIEBERMAN: Or any design --
10 MR. TERRY: It really is the only way you can 11 read that.
12 MR. HOOD: Did you have any other failure at that l
13 time other than 80?
14 MR. TERRY: That's what I said -- you're right, 15 i
all we know is the excess. That's why we're not talking i 16 about --
l 17 MR. SYLVIA: So we have to worry about si.aying 18 below 80. Once we went above 80 we had to calculate that.
19 MR. TERRY: And once we went above 80 we reported 20 Lt. We have conditions where we exceed allowable, let's say 21 ve exceed let's say a pressure capability. I think then you l 22 pet into yes, it's reportable, but then for operability.
23 MR. SYLVIA: Then you need to calculate that j 24 '
umber.
I 25 MR. ALLISON: I'd like to follow up on that first 1 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS
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. 22 1 for just a little bit.
2 One is that the draft of NUREG 1022 you have, we
(
3 didn't make a big deal out of the 1390 definition. The NUREG 4 1390 it says that the design basis, describing the difference 5 between the engineering, the design and there are various 6 bases that are related to design inspections, calls the 7 design basis the thing that the reviewer relied upon.
8 Now that's a little vague, but if you look at 9 this page of the FSAR, it's hard to see what else the 10 reviewer relied upon under the simple statement of a minimum 11 design capability of 80 and less than 40.
12 MR. TERRY: Well, I think first of all it's 13 impossible not to report it. If they were relying upon it, 14 E would have expected that they would have insisted upon that 15 3eing a lot more defined than just approximately 45 psf.
16 That's my opinion. I mean it's difficult. I mean was it 30 17 years ago when this plant went through the design? But I 18 quess I'm familiar with numbers that you rely upon and you i
19 <lon't just state them as approximate numbers. You really I 20 clon ' t .
21 It's hard to speculate what people think about it l
1 22 and I understand your logic.
23 MR. HOOD: Let's say you're looking at some f acet 24 of the model that we use, some particular parameter and you e
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23 1 as a rGviewIr crs trying to judg3 whsthsr or not that
. 2 particular variation is significant. You see yourself with i (
a 3 a design that's going to relieve at 45. It's in the design 4 basis for that. I mean you know the building is good for at 5 least 80. So you're judging the significance of the j 6 variation around tnat parameter for that model based on that j 7 margin.
1 1 8 MR. TERRY: I guess first off, I think it would i
! 9 be a fundamental mistake to say that well, okay, if it's in 10 the design basis then the number is holier than other l 11 numbers. That I think is wrong. I think there are numbers
{ 12 that aren't explicitly stated as design basis numbers that i
j 13 are far more important than this.
- 14 Second, in this case, you're not even dealing 15 with a design basis accident. This is beyond the design 16 basis event and a feature, it's really a feature that it's 17
- lescribing.
18 MR. HOOD: We're looking at the FSAR in the 19 section that's talking about the structure and it's talking 20 about --
21 MR. TERRY: Right.
22 MR. HOOD: And we're looking at the design basis 23 section and you see there under pressure relief, you see a 24 '
iescription that says it's relieved at 45 so you don't go 25 over 80.
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24 1 MR. TERRY: Right, and go I guass ons of the 2 things we would need to know, Darl, is okay, if this came out
(
3 at 46, would that be reportable using this guidance?
4 MR. SYLVIA: The way I would look at it and 5 trying to answer the question you're raising is I would look ,
6 at the relief aspect of the design basis as a functional 7 requirement to protect that design that I want a review on, 8 rather than 45 pounds being the assigned value.
9 I think you've got to look at what the words say 10 in the FSAR. Even though it is on the design basis section, 11 it's describing a relief function for protecting the design 12 basis which is --
13 MR. LIEBERMAN: So what you're basically saying 14 approximately weight 5 pounds was chosen for controlling the 15 parameters as a reference bounds for design, that the 45 16 controls the 8.
17 MR. TERRY: No.
18 MR. LIEBERMAN: Gives you protection that you )
19 Won't see --
20 MR. TERRY: No. We're saying --
21 MR. SYLVIA: It's a description. It is a 22 description and actually we . ave a reason to believe that 23 that's what the -- if the 3/16th inch bolts were in there 24 asing the calculation methodology, you do get a number pretty 1
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, 25
- 1 the way tha pnnnis that ware in thsro waro designnd. I don't l 2 think -- I really think that that's how the number got there
{
3 is the panels themselves, when they did a calculation would 4 blow out at approximately 45.
4 5 MR. LIEBERMAN: What was the purpose of the 6 blowout function of the panel?
i j 7 MR. TERRY: To protect the superstructure.
8 MR. SYLVIA: And it says that in the design 9 basis.
't 10 MR. LIEBERMAN: And we would argue that you have
, 11 a specific value for controlling that parameter, the 80, in 4
12 your design.
13 MR. TERRY: Okay, then what we will need to i
, 14 understand -- I think we understand what you're trying to 15 tell us, so how is that then -- we also had situations where 16 there are numbers here as well.
4 17 MR. SATORIUS: In the design bases section of the 18 FSAR.
4 19 MR. TERRY: The whole thing is design basis from 20 everything I know.
4 21 You don't write them in that same format today.
22 MR. SATORIUS: We have what we have.
23 MR. TERRY: I understand, but are you saying --
24 I guess first off, find what you're trying to tell us is that I 25 t; hat is in the design basis section, gives it more NEAL R. GROSS COURT REPORTERS AND TRAt: SCRIBERS 1323 RHODE ISLAND AVENUE, N.W.
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, 26 1 cignificancs then othOr numbers in othar eactions of tho 2 FSAR? Is that part of what you're trying to tell us?
(
3 That's my question. Because we're trying to 4 figure out how to give people guidance. Is that what we 5 should tell people is this is okay except if you're in an 6 explicit section that says design basis and the number is the 7 number and you all have to stick with it. Is that what 8 you're trying to tell us? That's what I'm trying to 9 understand.
10 MR. SATORIUS: I guess my own view would be if 11 your design basis section of the FSAR and let's look at your 12 example, it said that for this specific high energy line, 17 13 pipe restraints or pipe supports are required and you go out 14 in the field and you find less than 17, I guess my position 15 is that you've discovered a condition that is outside of the 16 design basis. It will be reportable.
17 MR. SYLVIA: Simply because it's written in the 18 format --
19 MR. SATORIUS: Because you have a quantitative 20 number associated with how many is acceptable and you find 21 less than the quantitative number that lists what is 22 acceptable .
23 MR. TERRY: I don't see that as consistent with 24 1022. If that's the case, I agree that's what you did here, I
25 my opinion, you said it's one less or it's different, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W.
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, 27 1 th3rafora it's reportable, whsrste I think 1022 eays if it's 2 different, if you go out there and you're missing a support 1 l
3 --
4 MR. SYLVIA: What value would that have to have 5 safe operation plant using this interpretation if it's in the 6 design basis, it's more sacred. But we could do that.
7 *R.
. TERRY: That's a way of doing it, but it 8 doesn't seem logical.
9 MR. HOOD: Are in the operations space or are we 10 in the reportability space?
11 MR. SYLVIA: We don't want to circumvent the 12 rules. We want to interpret it in a way that's meaningful 13 and with the overall safe operation in mind.
14 MR. TERRY: Excess reporting, we think is an 15 important issue. You really shouldn't be doing -- we've got 16 no problem with having some conservatism in our reporting and 17 averreporting versus underreporting. That's --
we're 18 ertainly not here today -- it's really this guidance and how 19 bo apply it. We just see these things as lining up.
20 MR. ALLISON: I've got a number of other 21 questions. I'm thinking about what the final version should 22 say.
23 The first one -- well, I'm not going to get into 24 that. What would you think about guidance that has several 25 :cickouts, that says it's reportable. You're trying to make NEAL R. GROSS COURT REPORTERS AND TRANSCHIBERS 1323 RHODE ISLANO AVENUE, N W.
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28 1 ths inportanco judgmsnt right hsra, tho onn that I mtntiontd 2 earlier. What would you think if there were several things?
t 3 If it's a violation of one of the NRC's principal rules,'like 4 GDCs or the fire protection rule or the ATWS rule, that would 5 be reported?
6 MR. TERRY: Regulations, I think, are pretty 7 straightforward for us. We don't have --
8 MR. ALLISON: And you follow Rule 1390 if the 9 reviewer had to rely upon or that gets into guess work.
10 MR. TERRY: A little bit of gray there, yeah.
11 MR. ALLISON: That's their standard you apply 12 with the idea that if you make that conclusion it's 13 reportable under this criteria and similar to this, a litany 14 of things which includes this kind of logic. And -- but you 15 know this particular event, in that thing that I envisioned 16 would probably kick out as what the reviewer relied on at 17 least in view of the staff and it would probably kick out in 18 two or three different ways.
19 MR. TERRY: I don't know. I guess to me what the 20 reviewer relied upon is awfully, awfully gray.
21 If you have like an SER or something where they 22 got into the description, I think that might be something 23 :nore -- but the fact that there was a number that was in 24 there, I'm really struggling with because I've got to tell 25 (ou this section might seem like it's a standout and fold or NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHOOE ISLAND AVENUE, N W.
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. 29 1 somsthing lika that, but tha fact that it asyn dasign basis, 2 I don't think should make it carry any extra weight than --
(
- 3 no less, no more. You've got to read it for what it is.
I j 4 I think in terms of the guidance, what I like
] 5 about the 1022 guidance, the way I see it, is I think it's ;
i 6 consistent with the 50.2 definition which talks about the 7 functional capability and the numbers are really ranges and j 8 parameters for control over the function. I think that's i
9 what design basis is all about.
10 MR. HOOD: It was not design basis in my view, it l
) 11 doesn't belong in that section. I think otherwise, you i j
12 mislead the reviewer and what guidance you give to the k 13 reviewer, if you can't go to the FSAR in that section and t
l 14 pull out your design basis or you have to go to that i
j 15 particular section and make judgments as to whether or not l
! 16 the values are in there are design basis or not. I can tell
- 17 you that. That's not what is done today. If it's there, 18 its' taken as a design basis.
19 MR. SYLVIA: It has to describe a function to 1
1
] 20 attribute it to the design basis.
! 21 It's describing a function, that is protecting i 22 the design of --
l 23 MR. TERRY: I think --
24 MR. SYLVIA: It says "approximately".
i l 25 MR. SATORIUS: It says to prevent the failure of
)
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. 30 1 th2 euperstructura.
2 MR. TERRY: And we agree with that.
t 3 MR. LIEBERMAN: It's protecting the design.
4 Right, it's for controlling -- I read it as you -- the way l 5 it's worded here is that number which is used to control the 6 design, to protect the design.
7 MR. SYLVIA: It's the approximate --
8 MR. TERRY: No, it isn't the control number.
9 See, that's the key --
10 MR. HOLODY: Is protecting the agent --
11 MR. TERRY: The control number is sufficiently i 12 for over 80. Really, that's what you have to control. This 13 isn't an appr;ximate number.
14 MR. HOOD: Are you talking abo"'. the design of 15 the superstructure? When you look at just the subtitle of 16 this section it says " pressure relief design." When I look 17 at that, what's pressure relief? Pressure relief are these 18 bolts which you're going to share or fail some way to relieve 19 pressure. What's that designed at? According to what you've 20 stated here, that's designed for 45, so your pressure relief i
21 system I read the design of that to be 45.
l 22 MR. TERRY: First off, we agreed that that was 23 the way it was supposed to have been designed. That's not a 24 debate. We're not here to debate that that's not a design 25 number. It is a design number. It's like lots of design NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISt.AND AVENUE, N W.
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31 1 numbers though and that's what you'va got to cppraciato in wa 2 then determine that, in fact, that wasn't installed the way
(
3 it was, supposed to have been installed. So now we've got a 4 new number. And that goes down to reportability and 5 reportability is not a matter of taking a number and just 6 saying well the number is different and it's less 7 ::onservative, therefore it's reportable. Otherwise you 8 wouldn't need NUREG 1022 or any of this stuff.
9 MR. LIEBERMAN: The design which is described in 10 the design basis is such --
11 MR. TERRY: It was too, the feature was met. The 12 design feature and the function of the feature was met.
13 MR. SYLVIA: Relative to your point --
14 MR. HOOD: 'Ihn ytic stion is, is that reportable? l 15 And the rules say yes.
16 MR. SYLVIA: Let's go back to what we are 17 :oncerned about and why we are here. We're here to give --
18 so that we can give guidance to our people on the report. We 19 .1 sed NUREG 1022, okay. Now, would it make sense and are you 20 belling us or are you suggesting, I guess at this point in 21 bine that we use 1022 unless something in written somewhere 22 in this outline of an old FSAR that says if it's in a design 23 base you don't use that any more. It becomes a sacred 24 aumber. Is that what we should tell our people for the I 25 guidance so that we don't have this concern with NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W.
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- 32 1 reportability being datrim:ntol? Is that whzt wa want to do?
2 MR. LIEBERMAN: The specifics of an FSAR governs
(
3 over the generality of a NUREG guide.
4 MR. TERRY: The specific design -- see, the thing 5 is --
6 MR. SYLVIA: It's interpretation of the FSAR.
7 MR. TERRY: There's all kinds of specific things.
8 MR. LIEBERMAN: In that section which is --
9 MR. SYLVIA: If it's going to be called design 10 bases, every number in there is a design number, even if it's 11 approximate.
12 MR. ALLISON: I don't think we're trying to make 13 conclusions here. If I read 50.2, every number that's in 14 here of any significance is a design basis number and I don't 15 think we want to say th:r every number that's written 16 everywhere.
17 MR. SYLVIA: I agree with you, but in order to 18 get to where we -- what we're concerned about, I wanted to 19 raise this issue to see if it made sense, to take that 20 approach.
21 I don't think it does. But we need to know what 22 to do. We've got inconsistencies and confusion between what 23 you're telling us about this thing and 1023 and the guidance 24 that we currently use. But that's the whole reason for 25 asking for the meeting.
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! . . 33 1 MR. TERRY: If that's the distinction youra 4
2 trying to make, there really isn't a response, but we can --
l( '
3 MR. ALLISON: There is a rule that says it's the i
4 FSAR update rule or statement of considerations for it, that f
. 5 says the design basis is contained in the FSAR. And I don't i
3 6 think it necessarily says the converse that everything in the i
7 FSAR is the design basis. I don't remember the words i
l 8 exactly, but would that be better guidance if the final 9 version said that?
1 10 MR. TERRY: I don't know. I think we're trying I
11 to figure out what was the right thing to do in the current 4
12 version and then maybe look at the final version.
13 What we're really trying to figure out is the 14 right thing to telling people tomorrow and that's really what i
j 15 we're trying to figure out and --
1 16 MR. SYLVIA: I think that may help in terms of 4
i i 17 future clarification. I don't know, but that's really where 18 we're struggling. We read it and I still don't see where we 19 went astray from a logic standpoint, but 1022 doesn't say if
- 20 it's in the design basis section then you can't mess with it
! 21 at all. There's nothing in 1022 about that.
22 MR. MARTIN: Carl, remember 1022 is not the 23 regulation. The regulation talks about --
24 MR. TERRY: It does --
25 MR. MARTIN: The regulation also defines design i
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1 bnoic rcgardloca of what 1022 asys. 1022 fixss an exemple to 2 use, something that is usually not articulated in sufficient
(
3 detail until you get the design basis is usually in the 4 piping system code. This is a case where for whatever reason 5 there's a great deal more specificity and if you read the i 6 second part of the definition design basis, one that is 7 joined by the word A-N-D and A-N-D doesn't mean the second 8 part is any less important than the first and the second part i
9 talks about controlling parameters used for reference
. 10 purposes to assure the design is met.
11 MR. TERRY: Right.
12 MR. MARTIN: That's right, but when you evaluate 13 that, it all centers on because the opening thing on 50.2 is
)
14 the design bases means that information identifies a specific i 15 functions to be performed by a structured system of a --
16 MR. TERRY: And --
17 MR. MARTIN: And a specific value or ranges of f
18 values chosen for the controlling parameters as reference 19 bounds for design.
20 MR. TERRY: Right.
4 21 MR. MARTIN: Now for whatever reason you chose 45 f 22 approximately as a reference design for the blowout feature 23 --
24 MR. TERRY: Well, again, Tim, that's where we're i 25 struggling. You say that, but again it's like every other NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W.
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35 1 number in a cids. Evsry othsr number was chorsn and ths
- 2 original intent was that that's the way the plant would be 3 built. The stresses would be at that level. Every number in j 4 there is that way. It wasn't just pulled out of the air. It 5 was put in there based upon an analysis, but it also 6 describes what it's going to do and that's why I think --
7 MR. MARTIN: Usually there's a different part of i
8 the FSAR that describes the general operation of the system 9 and how it works. Here, you're under a section which is 10 specifically titled " relief function," and specifically calls 11 out this is a design number.
12 MR. TERRY: Again, I think we can certainly ;
. l 13 consider that, that helps in terms of limiting it, although I i
14 I still would have to tell you I don't see those values as 1
j 15 having any greater or less significance without further s 16 evaluation of any other number in the FSAR.
l MR. MARTIN: Niagara Mohawk can come back in and 17 18 say hey, we want to change our design to make the relief i
l 19 feature at 65, you've probably got a good argument for us 20 because the feature, the building capacity or its ability to 21 stay together is probably still maintained. It might be very 22 easy for the staff to grant and amendment to change that 23 design value, but it doesn't mean, it looks to me like that 24 you guys have to specify what the design is here.
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.. - 36 1 said th n too bectuco if wm hnva to coma in with a licsnsa 2 amendment, we couldn't do it on a 50.59 process and any J
3 response here for the 50.59 process was appropriate, but we 4 didn't do it in a timely manner. So there's inconsistency l 5 between what you're saying now, I think --
6 MR. MARTIN: I don't know how you can change 45 7 to 65 with just a 50.59 process, I personally don't.
i 8 MR. SYLVIA: That's not your position that you 9 might personally want, but --
I don't know. That's 10 inconsistent with what you're saying but I think it's very 11 closely related. Those two things are very closely related 12 and we both agree with that. The reportability goes with the 13 ability to use 50.59, I think.
14 MR. TERRY: Not 1 for 1.
15 MR. SYLVIA: No, not 1 for 1, but it's very 16 difficult to interpret the reportability of the requirement 17 based on the 45 and then allow 50.59 process to work. I think 18 it's okay.
19 MR. MARTIN: Then the question becomes did you 20 reduce margin and if you reduce margin, you're outside of 21 50.59 space.
22 MR. SYLVIA: We had this discussion at the 23 enforcement conference. We're back to that. If you get in 24 -- if you require or stick with the 50.59 thing which I think 25 is proper, but you're stuck with the reporting thing which is NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W.
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l ,
"
- 37 1 totally confusing.
2 I think -- we talked about it back then as these
(
3 two issues being pretty broad issues and I think they are.
4 I think if you didn't allow us to move up from 45 to 53 and 5 went over to the 50.59 process and that compounds this thing 6 that we're concerned about as far as reportability, I think 1
l l 7 that's a tremendous change to industry. I think we'd all be 8 impacted. I think we should go with the reporting and 9 licensing amendment. I don't know what would happen. But 10 we've got to work the issue.
11 MR. LIEBERMAN: Another issue is what is the 12 system that is the design basis for?
13 MR. SYLVIA: The system is ability.
14 MR. LIEBERMAN: Or is the system the pressure 15 relief system?
16 MR. SYLVIA: The system is ability.
17 MR. TERRY: Clearly, this is the design basis of 18 it --
l 19 MR. SYLVIA: This is like a relief found on a '
20 piece of pipe. I think that's a pretty clear analogy. You 1
21 wouldn't look at the relief valve -- I I
22 MR. TERRY: You're really getting into a !
23 subcomponent in the relief panel as a design basis, moving as 24 a design basis. i i l 25 MR. BAJWA: Excuse me, do you have any procedure, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N W.
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.. . 38 i 1 any procosa that would rsquiro any action to b3 teksn by ,
i 2 operators or any other person when the pressure goes above j i 3 45?
4 MR. TERRY: This -- if this happens, there's no 5 operator action. You don't have time. This is like an 6 explosion.
7 MR. BAJWA: Is this a design basis accident?
8 MR. TERRY: Again, it's not a design basis 9 accident, but that would be the assumption if we had a -- the 10 only way to get there is to have guillotine line break or i
11 something analogous to that of a main stean line, say, a 12 turbine broken. It occurs instantaneous. l 13 MR. BAJWA: So you have nothing --
14 MR. TERRY: There's no operator actions. Shut 15 off -- I mean steam shutoff happens, but that takes seconds.
16 MR. SYLVIA: These are not related.
17 MR. ALLISON: If you look at the piping system, 18 aren't the safety factors considerably higher for relief l 19 valves using say about 10 percent of the design, but analyzes 20 specifically like a CPA -- ;
1 21 MR. SYLVIA: Between failure and allowable?
22 MR. ALLISON: Right, the failure is --
23 MR. TERRY: I would agree, if you had a relief .
24 valve you would actually set it -- right, you'd set it at t
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i j 1 10 ptrcant above ths dzsign valua, I think is more -- ,
i i
2 & ALLISON: So that's where you set the relief l
[
3 valve, but the breaking value in the pipe is factor 53 or i
- 4 something like that.
i 5 MR. SYLVIA: Way above the safety --
4 6 MR. ALLISON: More than a factor of 2 that we've f 7 got here.
l 8 MR. TERRY: Right, that's true. Again, we're j 9 just trying to understand the logic path and that's just --
l 10 earlier, we felt that drawing up the piping analogy out of
]
j 11 hand -- that's kind of where we're coming from. We agree 12 it's not piping although it is pressure retaining or 13 preserving the integrity kind of a thing.
- 14 MR. SYLVIA: The logic is it moves you closer to 15 the design.
j 16 MR. ALLISON: Yeah. ,
1 j 17 MR. TERRY: This isn't to figure out what to do i
! 18 on the blowout panel really. It really isn't. It's where 19 are we going astray in terms of defining the NUREG 1022.
20 MR. ZWOLINSKI: There is some degree of apples l
j 21 and oranges. Blowout panel is fundamentally tied to one l
- 22 system and the building, whereas your hangers when you fail i
i 23 one of many hangers, your challenge to that piping system is 24 far less than the challenge over with the blowout panel.
3 k
! 25 MR. SYLVIA: That's a detailed design, but from i NEAL R. GROSS I COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W.
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.. . 40
{
1 a logic point of vicw, I don't think it ankss cny differenca 2 whether it's one panel or 10.
f-3 MR. TERRY: Right.
4 MR. SYLVIA: That's a feature of design which 4
5 makes the system different, but the blowout feature could 6 have had 10 panels instead of one and from a logic point of 7 view and how to apply 10.22 I believe we would think about it 8 the same way. Now if there's something wrong with that, 9 there's something unique about this design we're discussing 10 now that makes it -- put it in a bucket all to itself, with 11 no logic to it and you tell us that. If we keep on like 12 we're doing --f 13 MR. SATORIUS: I'd like to explore just one more 14 thing. One of your arguments and certainly I hear what 15 you're saying is that this is going to reduce some of the 16 distractions of the control board. If I were a shift 17 supervisor, and I was confronted with a very crisp, clear 18 number that I know as 45, for example, and all of a sudden 19 engineering calls me up and says I've got the blowout panels 20 and we're going to go 53 and I check the FSAR real quick and 21 I see a crisp number there and I have a crisp number from 22 Wayne's department, I'd say there's a lot less stress there.
23 It's very clear what I need to do. I don't need to wring my ,
i 24 bands or gnash my teeth and say is this enough or is this not 25 enough? It's very easy. l NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS I 1323 RHODE ISLAND AVENUE, N W.
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- 41 1 MR. SYLVIA: Hsving besn a senior rcsctor 2 operator, what does this 45 panel thing do?
f 3 MR. SATORIUS: It's a relief function. It's in 4 the design basis.
5 I'm not sure I agree with that argument.
6 MR. SYLVIA: I think, I don't know, this --
7 because it's in the design section shouldn't, I don't think 8 should dictate how we'll apply 1022 for this situation.
9 MR. HOOD: Any reason why?
10 MR. SYLVIA: Why we did it at 69? I don't have 11 any idea.
12 MR. TERRY: We really don't know why.
13 MR. SYLVIA: If we wrote it today and used the 14 format of today --
15 MR. LIEBERMAN: I think so far has been very 16 belpful to describe the issue clearly and I think we clearly 17 appreciate the issue you've raised and where you're coming 18 from. Do you have anything more that you wanted to say?
19 MR. SYLVIA: I agree with you. I think we have 20 a clear understanding of each other now.
21 MR. LIEBERMAN: We brought people here from the 22 various offices and we'll take back this information. Since 23 we've had a public meeting here, we'll provide you with a 24 response. At this moment being a Level 4 violation, the 25 violation essentially stands. What we will -- we will review NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W.
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, , . 42 1 thite trenncript end spank to tha various psople within staff 2 and provide you a response for the record as to whether we i
3 are still of the same view or we have a different view and 4 withdraw the violation and we need to work closely with AEOD 5 to make sure if we need to give better guidance out, we'll 6 give better guidance out.
l 7 MR. SYLVIA: Okay, very good. I agree with the 8 assessment of where we are.
9 What I'm hoping for is you decide that you 10 shouldn't retract the violation. Some reasoning that makes i i
11 this unique relative to how to interpret the data that is out 12 there for reporting so that we can give guidance to our )
13 people. j 14 MR. LIEBERMAN: I think that the issue is what 15 guidance should you be giving your people. I think that's 16 fair.
17 MR. MARTIN: Yes.
18 MR. TERRY: Jim, just one other thing for 19 :onsideration. I think we had a pre-discussion on this. The 20 ather part of this issue to consider when we look at design 21 oasis, we're looking at it in the context of design basis of 22 the plant, so it's not a component level that we think you're 23 ceally required to look at, but really in terms of functional 24 :apability and what design basis of the plant overall, so if I 25 fou also consider that as part of your deliberation.
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- 43 1 MR. WETTERHAHNs Jia, ons thing while wa're still i 2 on the record, as I understand it we will then respond to the
(
, 3 Level 3 violation by January 24.
I 4 MR. LIEBERMAN: We're really not weighing, we're j
5 not seeking any more response to the Level 4. The only issue
]
6 is the -- whether you're going to pay the penalty, ask for a j 7 hearing on the escalated portion.
8
) MR. SYLVIA: So back for what Mark is saying, you J
9 would give us some feedback and then we would P.now how to J
- 10 respond from this meeting to Level 4. Is that right.
! 11 MR. LIEBERMAN: No, we're not asking you to i
1
]
12 provide any further response on a Level 4. Am I right on i 1 a 13 that? We have to -- is the corrective action still open? l l
l 14 MR. TERRY: We disagree with the violation, I
15 that's where we are.
j 16 MR. LIEBERMAN: So you need to know if there's 17 any corrective action?
18 MR. TERRY: No , because we didn't think we did 19 anything wrong.
1
{ 20 MR. LIEBERMAN: We will provide you a response
- 21 and so that you don't have to respond to the Level 4 until 22 you have our response. l
}
i 23 MR. SYLVIA: Thank you And thank you very much.
l 24 MR. REYNOLDS: We wouldn't object to receiving 25 something from the company to further elucidate this.
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- 44 1 MR. LIEBERMAN No , if you want to provid2 2 additional information, I think this is very clear.
(
3 MR. ZWOLINSKI: The utility may want to take the 4 transcript and enhance it or make their argument sligh t ly i 5 different or whatever.
6 MR. LIEBERMAN: The transcript is what the 7 transcript is.
8 MR. SYLVIA: As you desire. If you're going to 9 do that, let us know so that with the timing we have an idea 10 of how we should be working.
11 -
MR. HOLODY: There's a response due on the 24th 12 to the remainder of the package.
13 MR. WETTERHAHN: Yeah.
14 MR. HOLODY: I don't think there's a question of 15 a response of the remainder violations by January 24th.
i 16 MR. WETTERHAHN: Is your expectation that there 17 will be some reference to this in that response to the 18 report?
19 MR. LIEBERMAN: I don't see a need to do that by 20 this meeting we'll get you a response in due course. It
, 21 probably won't be before January 24th.
22 MR. SYLVIA: I think the main thing is we need a E
23 little feedback before we respond to No. 4.
24 MR. LIEBERMAN: Okhy, with that, I guess the 25 meeting is closed.
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, .. e o f) 45 il 1 (Whereupon, at 3:10 p.m., the meeting was '
2 concluded.)
{
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16 17 18 19 20 21 22 l
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! CERTIFICATE This is to certify that the attached proceedings before the United Stacas Nuclear Regulatory Commission in the matter of:
Name of Proceeding: PUBLIC MEETING ON NIAGRA MOHAWK POWER CORPORATION, NINE MILE POINT UNIT 1 Docket Number: N/A Place of Proceeding: ROCKVILLE, MD were held as herein appears, and that this is the original transcript thereof for the file of the United States Nuclear Regulatory Commission taken by me and, thereafter reduced to typewriting by me or under the direction of the court reporting company, and that the transcript is a true and accurate record of the foregoing proceedings.
h? W -
(AEFTREVLINS' official Reporter !
Neal R. Gross and Co., Inc.
(