ML20137L352
| ML20137L352 | |
| Person / Time | |
|---|---|
| Site: | Fort Saint Vrain  |
| Issue date: | 11/19/1985 |
| From: | NRC COMMISSION (OCM) |
| To: | |
| References | |
| REF-10CFR9.7 NUDOCS 8512030423 | |
| Download: ML20137L352 (84) | |
Text
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M 3 wk i UNITED STATES OF AMERICA '
[_ NUCLEAR REGULATORY COMMISSION In the matter of.
COMMISSION MEETING ,
Discussion of Environmental -
Qualification Exemption Request - Fort St. Vrain E
- (Public Meeting) .;
Docket No.
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Location: Washington, D. C. 1 - 71 Date: Tuesday, November 19, 1985 Pages:
ANN'RILEY & ASSOCIATES Court Reporters i
- 1625 I St., N.W.
Suite 921 Washington, D.C. 20006 (202) 293-3950 0512030423 051119 PDR 10CFR .
PT9.7 PDR
. e' S
1 D I SC L4 I M EP 2
3 4
5 6 This is an unofficial transcript of a meeting of the 7 United States Nuclear Regulatory Commission held on a 11/19/85 . In the Commission's office at 1717 H Street, 9 N . tJ . , (Ja sh i ng t on , D.C. The meeting was open to public 10 attendance and observation. This transcript has not been 11 reviewed, corrected, or edited, and it may contain 12 inaccuracies.
13 The transcript is intended solely for general 14 Informational purposes. As provided by 10 CFR 9.103, it is 15 not part of the formal or informal record of decision of the 16 matters discussed. Expressions of 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 Cemmission may 21 .authorire.
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! 9 l 1 UNITED STATES OF AMERICA 2 NUCLEAR REGULATORY COMMISSION l
l 3 mmm l
4 DISCUSSION OF ENVIRONMENTAL QUALIFICATION
$ EXEMPTION REQUEST - FORT ST. VRAIN o mmm i 7 PUBLIC MEETING 8 mum
- 9. Nuclear Regulatory Commission 10 Room 1130 11 1717 H Street, Northwest l
12 Washington, D.C.
13 14 Tuesday, November 19, 1985 1
15 16 The Commission met in open session, pursuant to 17 notice, at 2:00 p.m., the Honorable NUNZIO J. PALLADINO, l 18 Chairman of the Commission, presiding.
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( 19 COMMISSIONERS PRESENT:
l 20 NUNZIO J. PALLADINO, Chairman of the Commission
- 21 THOMAS M. ROBERTS, Member of the Commission l
f 22 JAMES X. ASSELSTINE, Member of the Commission i
23 FREDERICK M. BERNTHAL, Member of the Commission 1
l 24 LANDO W. ZECH, JR., Member of the Commission l
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e 2
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1 STAFF AND FRESENTERS SEATED AT COMMISSION TABLE:
2 S. CHILK 3 H. FLAINE 4 K. HEITNER 5 E. BUTCHER e H. DENTON
? F. MIRAGLIA 8 E. 1 ER 9 O. LEE e
10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
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3 1 PROCE E D I N G S 2 CHA1MMAN PALLADINO: Good afternoon, ladies and 3 gentlemen. Today we meet with members of the NHC Stati to 4 discuss the environmental qualification of electrical equipment 5 at the Fort St. Vrain Nuclear Plant.
l 6 By generic letter in early August licensees were
! 7 advised of the Commission *s intention to grant exemptions only l
8 in rare circumstances, and that enforcement action will be 9 taken against licensees who continue to operate the plants 10 with unqualified equipment beyond November 30, 1985 without 11 approved evtensions. Justifications for continued operation 12 have to be provided to the Stati and extensions will have to 13 be approved by the Commission.
14 By letter dated September 24th, 1985 the Public 15 Service Company of Colorado requested an extension until March to 31st, 1985 -- in 1985, excuse me -- to complete environmental 17 qualification at Fort St. Vrain. The NFC Stati is presently 18 evaluating the licensee *s submittal 19 Due to the short period of time between now and i
20 November 30 deadline, the Statt has been asked to provide a l
l 21 status of their review. Therefore, the objective of today*s 22 meeting is to attord the Stati an opportunity to brief the 23 Commission on the preliminary evaluation of licensee s request, 24 and to advise the Commission of the Staff *s schedule for l 25 submitting the Statt*s recommendation.
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1 I understand that representatives of Public Service 2- Company are in the audience and available to answer any 3 questions wnich the Commission may have. I also understand 4 that Region -- representatives from Region IV are listening in 5 by telephone.
6 Do any of my tellow commissioners have any additional 7 opening remarks at this time?
8 COMMISSIONEN ZECH: No.
9 COMMISSIONER ASSELSTINE: Just one item.
10 CHAIRMAN PALLADINO: Sure.
11 COMMISSIONEM ASSELSTINE: Perhaps the Statt, 12 particularly given the information that we just received on 13 the status of JCO, perhaps the Stati could describe what 14 justifications for continued operation this plant has been 15 using for the past several years for equipment qualification, le and what we now understand about the adequacy of those JCOs.
17 CHAIRMAN PALLADINO: Okay, can you do that during 18 the presentation?
19 MR. DENTON: Yes 20 CHAIRMAN PALLADINO: Any other comments?
21 COMMISSIONER ZECH: No.
22 CHAIRMAN PALLADINO: All right, then let's turn the 23 meeting over to Harold Denton.
24 MR. DENTON: Thank you, Mr. Chairman. Today we have 25 here at the table Frank Miraglia on my right, Ed Butcher on my i 1
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1 left, who will be making the presentation. He will be assisted 2 by Ken Heitner, the project manager for this. plant. And we 3 have a number of other people that might assist us in the 4 discussions.
5 We're proposing today to summarize for you the 6 results of our review, which will be to deny in part and to
? grant in part the proposal. The licensee and our Statt have 8 worked on this issue, and I think it's fair to characterize 9 the licensee's position as one which he does not disagree with 10 the position.
11 As you know, this plant has some unusual and unique 12 characteristics. Has a very high heat capacity, very slow 13 thermal response to upsets. And it's because of this that 14 we've arrived at a solution for this issue that's somewhat 15 different than we have proposed for the light water plants.
16 Just to refresh your memory slightly, the heat 17 capacity of a light water plant is largely due to the water 18 that*s inside the reactor vessel, not the fuel. The heat 19 capacity in this plant is largely due to the fuel in the 20 graphite matrix, not the helium. So it's a very ditierent 21 situation in terms of the thermal response of the core. And 22 this core heats up very slowly.
23 With that introduction, let me have Ed go through 24 the tive slides or so that we have distributed and tell you 25 how we've come to the conclusion that we propose.
5 6
s 1 MR. BUTCHER: We'll start with the first slide.
2 [ Slide.]
3 MR. BUTCHER: This licensee in their September 24th, 4 1985 submittal addressed the two key areas which were 5 identitled in the guidance provided by the Commission. They 6 identified the exceptional circumstances that applied to their 7 case and they provided justification for interim operation are 8 based upon the unique characteristics of the plant, one ot 9 which Harold has just spoke to.
10 The Stati reviewed the information provided by the 11 licensee. However, we were unable to conclude and agree with 12 their finding that justification with the unqualified equipment 13 identified was -- had been satisfied. Our principal concern in 14 this area had to do with the operation of a new system which 15 they had proposed to design and install to isolate 16 automatically high energy line breaks, And also the operation 17 of filtration systems, which would control leaks following an 18 accident.
19 In the process of performing our evaluation of their 20 application we did, however, identity that there was a 21 threshold upon which you did not have to rely upon these 22 systems. And the Stati*s calculation was that it was roughly 23 somewhere in the neighborhood of 30 percent.
24 When it became clear that we were not going to be 1
25 able to agree with the licensee on 100 percent power, that we I I
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1 were not able to conclude that it was justified, the licensee 2 did some independent work of their own and was able to confirm 3 that, yes, the reactor could be operated safely .t 35 percent 4 power and came in and presented the results of that analysis 5 to the Statt We have reviewed what the licensee submitted,
! 6 and it is consistent with our own independent analysis.
7 On the basis of these discussions, the licensee has 8 determined that 11 they were allowed to operate at 35 percent 9 power there would be no health and safety concerns and that 10 they could complete all of the equipment qualification to l
11 completely quality all the equipment in the plant by May 31st, 12 1986.
l 13 CHAIRMAN PALLADINO: Would that mean another shutdown 14 in order to install the equipment?
15 MR. BUTCHER: There will be some required shutdowns 16 in the interim period in order to install some of the 17 additional equipment.
18 COMMISSIONER BERNTHAL: How many pieces altogether 19 are there? How much -- what are we talking about?
20 CCMMISSIONER ASSELSTINE: Items and components.
21 CHAIRMAN PALLADINO: What's that?
22 COMMISSIONER ASSELSTINE: How many items and 23 components?
24 MR. BUTCHER: The licensee identified in their 25 submittal that of 207 items of equipment on their qualification
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1 list, 156 of the items would have to be considered unqualified 2 in accordance with the most recent guidance and positions taken 3 by the Stati That would leave $1 items considered qualified.
4 CHAIRMAN PALLADINO: Are those items that are 5 installed now?
6 MM. BUTCHER: The 51 items are items that are 7 largely made up of equipment that is necessary for the new i 8 steam line rupture detection.and isolation.
9 CHAIRMAN PALLADINO: So it*s not installed now?
10 MR. BUTCHER: No.
11 COMMISSIONER ASSELSTINE: So the $1, I take it, have 12 been closed out?
13 MR. BUTCHER: The $1 we have not reviewed. The 14 licensee was taking the position that that equipment would be 15 qualified prior to November 30th, and it would be largely made 16 up of new equipment to be installed.
17 COMMISSIONER ASSELSTINE: So it*s 156 as of November 18 30th would still not be qualified?
19 MR. BUTCHER: That's correct.
20 COMMISSIONER ASSELSTINE: How many components would 21 that --
'- i 22 MR. BUTCHER: That constitutes, according to the 23 licensee's submittal, 1246 pieces of equipment 24 We're prepared to go on and discuss our basis --
25 CHAIRMAN PALLADINO; Now they think tney can do the
- 9 1 1243 picooe by March 31st?
2 COMMISSIONER ASSELSTINE: May.
3 CHAIRMAN PALLADINO: May 31st, '80?
4 MR. BUTCHER: The licensee has confirmed again this 5 morning that that's a date that they can meet. And it is a 6 date which the Statt has some confidence that can be achieved.
7 They have a lot of work to do in that interim time, but it 8 appears to be a realistic date at this point.
9 CHAIRMAN PALLADINO: So you think it is a realistic 10 date?
11 MR. BUTCHER: Yes, sir.
12 COMMISSIONER BERNTHAL: Is that partly because they 13 are having to meet generally less stringent requirements for a 14 lot of this equipment because of the nature of the tacility?
15 Or how do you define the parameters, temperature, pressure, le moisture, whatever? Let's see, I guess moisture is not a line 17 parameter here.
18 MR. MIRAGLIA: I think that that date is to come in 19 compliance with 50.49, which means you would apply the same
, 20 methodology that's been used to quality light water reactor 21 components. Certainly the pressure / temperature profiles for I
i 22 this particular plant are different That would be to comply I 23 with the requirements of 50.49, 24 COMMISSIONER BEHNTHAL: I understand that, but what 25 I'm saying is -- or wnat I'm asking is whether this plant
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1 gonorally, for tho equipmont you hevo, 11 I locked at tho 2 temperatures and maybe moisture or whatever, that that 3 equipment is required to meet, is this an easier, a less 4 stringent requirement because of the nature of the tacility or
$ not?
6 MR. MIRAGLIA: I think some of the temperature 7 profiles are higher, 8 MR. HEITNER: Yes. And you don *t have to quality 9 equipment also. But you don *t have to quality equipment for 10 radiation.
11 COMMISSIONER BERNTHAL: Radiation.
12 MR. HEITNER: And you don *t have to quality equipment 13 nominally for submersions.
14 CCMMISSIONER BERNTHAL: That"s the question, yes, 15 CHAIRMAN PALLADINO: For what?
10 MR. HEITNER: Submersions, flood.
17 COMMISSIONER BERNTHAL: Right.
18 MR. BUTCHER: For certain scenarios there are higher 19 temperatures and pressures that you see, but those are just i 20 for particular scenarios. With the new steam line detection 21 -- steam line rupture detection isolation system you*11 have 22 automatic isolation of all the breaks, which should ;
23 substantially reduce the environment, which will make the 24 qualification easier. And I'm presuming that that's the basis 25 upon wnich the qualification can be achieved in May.
11-1 [ Commissioner Bernthal left the room.]
2 CHAIRMAN PALLADINO: Their request had been for an :
3 extension to March 31st, 1986. Does this modify that request, 4 the last statement, licensee has committed ta complete all EQ 5 by May 31st, 1986?
6 MR. DENTON: I think the way we've approached this, 7 Mr. Chairman, is that at this lower level of operation they 8 don't really need to have the equipment qualified because of 9 the response characteristics of the core, and could run 10 perhaps indefinitely, like we've let other plants run with 11 JCOs.
12 But in the theory of having to bring this issue to a 13 close in the near future, we thought they should complete the 14 Job in roughly the same time trame as some of the other plants 15 that we've talked about. And they actually proposed the 16 date. They wanted more time than the March date that they had 17 originally proposed. But I didn't see that from a safety 18 standpoint, whether it was March, April, May or June was that 19 important, just provided we had a date certain.
20 So I understand that that's the date which they've 21 set, they feel comfortable they can come into full compliance 22 with.
, 23 : Commissioner Roberts lett the room.]
l 24 CHAIRMAN PALLADINO: So are you saying that you're 25 recommending an extension to May 31st, 19867 i
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13 1 MR. DENTON: Yoo. Uo roccamond that they bo 2 ptimitted to run at 35 percent power up until that time, and 3 then require they come into tull compliance.
4 MR. BUTCHER; It we can turn to the justification 5 for continued operation at 35 percent.
6 [ Commissioner Roberts returned.]
7 CHAIRMAN PALLADINO: I don *t want to get hung up on 8 a procedural matter, but nevertheless let me clear it up.
9 Would it take a request trem them for us to act, or --
10 MR. MIRAGLIA: They will have to modify the request.
11 CHAIRMAN PALLADINO: The request.
12 MR. MIRAGLIA: Yes. The information that Mr. Butcher 13 referred to was presented to us yesterday at a meeting and all 14 those analysis would have to be documented, docketed on the it record. And that would indicate a modification of request to 16 operate at 100 percent power, and the 31st of March date would 17 be reflected in that submittal 18 CHAIRMAN PALLADINO: 31st of May.
4 19 MR. MIRAOLIA: Yes, it would be changed to say 33 20 percent until the 31st at May.
21 CHAIRMAN PALLADINO: Okay.
22 MR. DENTON: I think it the Commission concurs with 23 the course of action we're on, we'll write up a paper and the 24 company would submit the necessary documentation between now 25 and November 30th, when we'd send this down.
13 1 MR. BUTCHER: It we can turn to tho justification ,
2 for continued operation,
! 3 [ Slide.] :
4 MR. BUTCHER: The first bullet there is very l 5 significant. At 35 percent power there is no electrical l
6 equipment required to be qualitted in order to safely shut the i
7 reactor down. At 35 percent there*s also adequate time l
available for manual action to initiate the one engineer B
9 safety teature system which would have to function. That's t
10 the liner cooling system.
I 11 CHAIRMAN PALLADINO: New ts that the one that the 12 requirement is tot 10 minutest You've got to be able to .
13 actuate in 10 minutes?
l l 14 MR. BUTCHER: No, sir, that system --
l 15 CHAIRMAN PALLADINO: Go ahead.
10 MR. BUTCHER: As I go on here -- the worst case core 17 temperature that would be achieved in the reactor it no action i
le were taken would be 2900 degrees Fahrenheit at 80 hours9.259259e-4 days <br />0.0222 hours <br />1.322751e-4 weeks <br />3.044e-5 months <br />.
19 CHAIRMAN PALLADINO: I see.
20 MR. BUTCHER: Now the liner cooling system has to be
( 21 initiated prior to the 80 hours9.259259e-4 days <br />0.0222 hours <br />1.322751e-4 weeks <br />3.044e-5 months <br />. It can't be initiated right 22 at 79 hours9.143519e-4 days <br />0.0219 hours <br />1.306217e-4 weeks <br />3.00595e-5 months <br />. It has to be initiated prior to the 80 hours9.259259e-4 days <br />0.0222 hours <br />1.322751e-4 weeks <br />3.044e-5 months <br />.
i 23 The calculations that we have done so far and that 24 were presented preliminarily yesterday indicate that it's on 25 the order of a couple of days as opposed to hours. The
. 14 1 lisonsoo is going to go back and rotino that calculaticn, and 2 we are also going to confirm the exact time that it muit be 3 initiated. But we are quite confident that it*s on the order 4 of days.
l 5 CHAIRMAN PALLADINO: But it is less than 80?
6 MR. BUTCHER: Yes, sir.
? MR. DENTON: Well, I think this is a key point and 8 goes back to the comment I made at the beginning. 11 th y 9 have no electrical equipment working for whatever reason, this to core heats up very, very slowly. It's not a matter of minutes 11 and hours as you have in a light water plant. It's a matter 12 ci hours and days before it heats up to a temperature of 13 concern.
l l 14 So there's much more opportunity for operators to
! 15 take action to either restore the circulators or restore liner 16 cooling In fact, I understand the fire prevention system can 17 be used with the liner cooling and so forth. So they have a 18 lot of options in that several day period to get some sort of 19 cooling provided to bring the temperatures back down.
20 And therefore, I think overall EQ is just not that l
J1 big an issue in this plant at these lower powers.
22 COMMIS810NEM ASSELSTINE: Now when did the Statt 21 receive the analysis supporting this JCO? ,
I 24 MM. BUTCHEN: For 35 percent power?
25 COMMISSIONER ASSELSTINE: Yes, i
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1 MM. BUTCHER: Wo woro informod vorbc11y of it evor 2 the weekend, but it was confirmatory in nature. The Statt had 3 done its own calculations and had concluded that likely a case 4 could be made here. Over the weekend the licensee elected to 5 drop from the 100 percent and to make a case at 35 percent, 6 because we didn't think a case could be made at 100 percent.
i 7 COMMISSIONEN ASSELSTINE: Okay.
8 MR. BUTCHER: So the Statt has known about this l 9 option for perhaps 30 days or longer, a little bit longer.
10 But just yesterday received the licensee's calculations.
11 MR. DENTON: Well, I think the applicant, however, 12 provided a different case. He's been -- he provided a 13 different case the first time the Commission issued its rule 14 and we've been arguing over whether his case was the correct 15 one or not. Because, I guest all along he*s thought he could 16 initiate liner cooling much laster, and circulate action much 17 taster. So over the several years he's had a different bases
! 18 for the plant than we've come around to.
19 COMMISSIONEW ASSELSTINE: Okay, so going back to the 20 time when the rule was issued and whenever we went through all i
J1 those iterations of JCOs all the way along, I take it, the 22 Ilconsee's position has been that they could operate the plant 23 at 100 percent.
24 MR. MlHAOLIA: And they believe to be in compliance.
JS MR. DENTON: Yes, and that they thought they had
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- 1 onough timo ovon at 100 porcont to tako whatover oporator 2 actions were necessary to keep core temperatures down.
3 COMMISSIONER ASSELSTINE: And I take it, we've never 4 really agreed with that position all the way along?
5 MR. DENTON: Well, we didn't give this plant the e same attention that we did others because of its unique 7 characteristics. You know, it has such a slow thermal response 8 it just didn*t get looked at that hard because we knew it 9 wasn*t as crucial as for light water plants.
10 COMMISSIONE4 ASSELSTINE: Did the plant operate at 11 100 percent power at any time atter the rule was adopted.
12 MR. MIRAGLIA: I don *t believe that to be the case.
I 13 I'm not sure.
14 COMMISSIONER ASSELSTINE: Did it operate above 3$
15 percent?
16 MR. MIRAGLIA: I don't think it's been to 100 17 percent power at all.
18 MR. DENTON: I don't k r. ow for sure, Commissioner.
19 I'd have to ask the company.
20 COMMISSIONER ASSELSTINE: Okay.
{
21 MR. MIRAGLIA: I think the highest power level it
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22 got to was on the order at 80 percent, I believe.
23 COMMISSIONER ASSELSTINE: Okay.
1 24 MR. MIRAGLIA: The utility is here and could --
25 COMMISSIONER ASSELSTINE: I can ask them when they l
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. l 1 make thoir prosentation.
2 MR. MIRAGLIA: -- confirm it.
3 CHAIRMAN PALLADINO: Are they going to make a 4 presentation?
5 MR. DENTON: They're prepared to.
6 MR. MIRAGLIA: They're available for any questions 7 the Commission might have.
8 MR. DENTON: I think we just have a couple more 9 slides to show the basis for the proposal we have here and 10 then --
11 CHAIRMAN PALLADINO: I remember reading about the 80 12 hours at least somewhere. There was also another question 13 about 10 minutes. Could you clear up --
14 MR. HEITNER: Okay, that's the question of -- in the 15 initial design of the plant, breaks in certain steam lines, lo the hot and cold reheat lines are operated -- are isolated 17 manually by the operators taking the actions manually. Now 18 the original design basis to the plant as it was licensed in 19 '73 and reconfirmed in let's say, '70, '77 was that the 20 operators could detect the break from the instrumentation and 21 take the necessary actions in the control room within four I i
I 22 minutes, j l
23 And of course, the Stafi's human factors criteria 24 now are much more severe and they would require a much more 25 conservative assumption about the operators taking their first l
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.' 18 1 action in 10 minutos, and completing the nocessary actions 2 tour minutes later. So you're talking about an operator time 3 of more like 14 minutes.
4 So that*s been an issue also in trying to arrive at 5 the basis for determining what is the environment to which the 6 equipment has to be qualified. Because if you allow the 7 breaks to go for long periods of time, the temperatures that 8 you do get, the harsh environment that you do get has a much 9 higher temperature profile. And that's why, in the long run, 10 the licensee has proposed an automatic isolation system.
11 CHAIRMAN PALLADINO: I see, that*s the way they*re 12 solving it.
13 MR. MIRAGLIA: It moots the question of whether it*s 14 tour or --
15 MR. BUTCHER: And that question is only relevant for 16 100 percent operation.
17 CHAIRMAN PALLADINO: Yes, I appreciate that. All 18 right.
19 MR. BUTCHER: Another significant factor and a 20 justification for continued operation at 3$ percent power is 21 the small doses that you receive from this event. And the 22 scenario we postulate are that the doses that you could expect 23 in the worst case situation would be on the order of a few rem 24 and no mere than that.
25 (Commissioner Bernthat returned.]
19 1 MR. BUTCHER: In a moro likoly sconario it*s on tho 2 order of millirem. It*s very ditticult to calculate it*s so 3 low.
4 All of the work that the licensee has presented has 5 been, to some extent, verified by our consultants at Oak Ridge 6 by independent calculations. In fact, as I indicated, we were 7 aware of this situation earlier, about a month ago.
8 We have some remaining actions which have to be done 9 in order for the Staff to draw a bottom line on this.
10 [ Slide.]
11 MR. BUTCHER: We just received the licensee *s 12 calculations yesterday. And the licensee has some follow up
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13 actions and we have some follow up actions, 14 COMMISSIONER BERNTHAL: What is that, about 100 15 megawatts then, megawatts electric.
16 MR. MIRAGLIA: That*s about right.
17 CHAIRMAN PALLADINO: You mean at 35 percent?
18 COMMISSIONER BERNTHAL: Yes, 19 MR. BUTCHER: The licensee needs to complete these 20 calculations which were presented to us in preliminary firm to 21 confirm that, in fact, the analysis is correct. There are 22 approximately 12 different areas that they have to look into.
23 These calculations are all confirmatory in nature, and they 24 have to docket the material in order for us to consider it 25 CHAIRMAN PALLADINO: Now is that a time consuming
. 20 1 problem?
2 MR. BUTCHER: We don't estimate that it will take a 3 great deal of time. Our current estimates are something like 4 10 days. We will have performed our independent confirmation 5 by that time also.
6 CHAIRMAN PALLADINO: Now these are items that have 7 to be done before you allow them to continue at 35 percent?
8 MR. BUTCHER: Yes, sir.
9 MR. HEITNER: Well, right now they have no 10 authorization to operate.
11 CHAIRMAN PALLADINO: Yes. But --
12 MR. BUTCHER: The plant is shut down now and it has 13 no authorization. It's under confirmatory action letter right 14 now.
15 CHAIRMAN PALLADINO: So these calculations would 16 have to be submitted and approved by the Stati prior to 17 authorizing them to go to 35 percent?
18 MR. BUTCHER: Yes, sir.
I 19 MR. MIRAGLIA: They would term tho basis of the !
I 20 Stati's recommendation to the Commission saying, we authorize 21 operation at 35 percent past -- through --
22 CHAIRMAN PALLADINC: Does this have to be done 23 before November 30th, I guess is what I -- l 24 MR. DENTON: We'd like to get it done before the 25 30th, yes.
.' 21 1 CHAIRMAN PALLADINO: And we hevo to act on it botoro
_ 2 the 30th?
3 MR. DENTON- I think, yes, ideally.
4 CHAIRMAN PALLADINO: The last time the Commission is 5 together is the 20th, 11 1 --
6 MR. MIRAGLIA: It would appear to me that the 7 utility is down now. It would be -- 11 we can get it before 8 the 30th of November that would be fine. It it*s --
9 MR. BUTCHER: The schedule --
10 MR. MIRAGLIA: He requires an authorization by the 11 Staff to start up. The Statt wouldn*t be able to authorize 12 that without also the grant of the extension past the 30th.
13 COMMISSIONER BERNTHAL: Is there going to be a SECY 14 paper, I presume?
15 COMMISSIONER ASSELSTINE: Yes, Harold said he was 16 going to give us a paper.
17 MR. DENTON: Yes.
18 COMMISSIONER BERNTHAL: Is there any reason why we 19 can't do it by then?
20 CHAIRMAN PALLADINO: Well, only because these things 21 have to be done. We could do our part.
22 MR. DENTON: We see these as confirmatory, and 11 23 you agreed with the approach we would proceed this way, 24 CHAIRMAN PALLADINO: All right, we could make that a 25 condition.
. 22 1 MR. BUTCHER: And actually that's ono approach. Tho 2 Commission's approval could be conditional upon the Stati 3 completing its evaluation, and then we could act on our own at 4 that point.
5 CHAIRMAN PALLADINO: Yes.
6 MR. BUTCHER: They are truly confirmatory. We have
? done some calculations already.
8 COMMISSIONER ASSELSTINE: Is the system dried out 9 now, or do they have a dry-out period they have to do through?
10 MR. EUTCHER: There will be a dry-out period -- an 11 additional dry-out period that they have to go through to 12 return to even 35 percent power. They have been in the last 13 46 days under a restriction of operation at 8 percent in order 14 to dry out. And I believe the licensee has stated that 15 they've gotten as much moisture out as they can get out at 16 that power level, and that it will require higher power leve ;
17 to get additional moisture out, ,
18 The Statt follow up actions, of course, are to 19 review confirmatory calculations that the licensee provides, 20 and to do some independent work of our own.
21 The schedule right now is dictated by the licensee.
22 I estimated here two to three weeks, depending on when the 23 licensee could provide their additional informatton back to 24 us, their confirmatory analysis. We're prepared to move on it 25 as soon as we receive it.
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- 23 1 CHAIRMAN PALLADINO: But you wouldn't nocosecrily 2 have to have it to give a SECY paper to the Commission for 3 action.
4 MR. DENTON: That's right. We could give you the 5 paper saying how we were going to proceed.
6 CHAIRMAN PALLADINO: All right.
7 MR. BUTCHER: That concludes our prepared remarks 8 with the exception oi, 11 the Commission wishes some additional 9 details on the operation of the plant and its layout, we're 10 prepared to do it.
11 MR. DENTON: Maybe it will be worthwnile 11 the 12 project manager spent Just a moment or two on the last two 13 slides to show you why this presents quite a different question 14 than in the normal light water plant that*s inside 15 containment. Maybe you should just cover the last two to show 16 the areas and assumptions we've been working on.
17 MR. HEITNER: Could we have the next slide, D-19 18 tSlide.3 19 COMMISSIONER ASSELSTINE: Turn it sideways, please.
20 CHAIRMAN PALLADINO: Other way.
21 COMMISSIONER ASSELSTINE: Other way.
22 MR. HEITNER: Thank you. Th< harsh environment can 23 be created at Fort St. Vrain in two areas. In the annular 24 region in the reactor and --
25 CHAIRMAN PALLADINO: Excuse me, can people hear in !
l i
. 24 1 the back?
2 MR. MIRAGLIA: Move the microphone over.
3 COMMISSIONER ASSELSTINE: Use that mike there.
4 MR. HEITNER: The harsh environment for Fort 5 St. Vrain is created in two areas. In the reactor building, o in the annular outside the reactor vessel, and in the turbine 7 building, depending upon where the steam line break that's the 8 limiting accident takes place.
9 In order to either check on the operation of certain 10 equipment that would be required to restore the liner cooling 11 system, which is the basic system that we*re depending on for 12 this limited period of time, or to restore the circulators to 13 operations, the operators have to be able to get access to 14 these two areas.
15 And what the licensee has done is developed curves 16 which -- and through the process of developing these curves it 17 indicates that that access will be available to the operators 18 in the order of a day's time. That*s assuming that the 19 equipment that would be normally running has tailed and 20 some restorative manual actions on the part of the operators 21 is necessary.
22 May I have the next slide, D-2?
23 [ Slide.3 24 MR. DENTON: There are just two things you need to 25 cool this core, two options. One is, you can cool it with a
. 25 1 linor cooling system, which aro tho coils around tho outsido 2 of the vessel.
3 CHAIRMAN PALLADINO: Outside of the concrete vessel?
4 MR. HEITNER: Go back to D-1, please.
5 [ Slide.]
6 CHAIRMAN PALLADINO: Where are these?
? MR. HEITNER: The liner cooling system is a series 8 of cooling pipes through which water passes that entirely 9 surrounds the reactor vessel.
10 CHAIRMAN PALLADINO: The steel liner?
11 MR. H'EITNER: And the steel liner, and keeps that 12 cool.
13 CHAIRMAN PALLADINO: So it's inside --
14 MR. DENTON: Yes.
15 CHAIRMAN PALLADINO: It*s inside the concrete?
16 MR. DENTON: So that's one way to get heat out and 17 keep the core down. And the other is to keep the circulators 18 running.
19 MR. HEITNER: The second way is to supply pressurized 20 water to pelham wheels that drive the helium circulators.
21 These tour devices here (indicating) that circulate the helium 22 through the core and remove heat through the. steam generator 23 tubes, much like you do in a normal pressurised water reactor.
24 CHAIRMAN PALLADINO: How does environment get over 25 to this turbine generator? Or did I misunderstand *
. 26 1 MR. HEITNER: Woll, tho stoem linos run from tho 2 bottom of the steam generators up and over to the turbine 3 hall. And so, depending upon where the break takes place, the 4 harsh environment can be created in either building, and the
$ equipment that the operators need to manipulate for shutdown 6 is in these two areas. And those are the areas that they have a
7 to have access to in order to manually --
8 CHAIRMAN PALLADINO: You're saying it it breaks 9 inside the pressure vessel then --
10 MR. HEITNER: That*s an entirely separate situation.
11 But it's not going to create a harsh environment out here where 12 the other equipment is.
13 CHAIRMAN PALLADINO: Where does it have to break for 14 it to get the harsh environment over there?
15 MR. HEITNER: Outside in the reactor building here 16 (indicating.) That*s what we're considering.
17 MR. DENTON: In the steam line passing through that 18 area.
19 MR. HEITNER: Right, in the steam line passing 20 through those areas.
21 CHAIRMAN PALLADINO: Okay, any place in that i
22 building. -
i l
23 MR. DENTON: Yes. Then let's go to the next slide.
24 MR, HEITNER: D-2, please.
25 [ Slide.]
i
, 27 1 MR. DENTON: Tho data wa'ro shewing horo is what's 2 attributable -- or rather than my explain it, why don *t you 3 explain this one.
4 MR. HEITNER: What we*ve done is we've calculated 5 the peak temperature in the core of the reactor based on the 6 liner coolin2 system which is the most basic, simple system 7 that can be used to cool the roactor and remove decay heat 8 operating.
9 There are two options involved and that has to do 10 with whether the reactor is allowed to remain pressurized, or 11 whether the helium from the reactor is released separately and 12 the reactor is bled dow'n ettectively to atmospheric pressure.
13 CHAIRMAN PALLADINO: Are the circulators running?
14 MR. HEITNER: No, the circulators are not running.
15 Only the liner cooling system is running.
16 Now we've calculated here is a percent, as a 17 percentage of the tull power at which the reactor is operating 18 what the peak temperature is as the core heats up, because the 19 core heats up to some peak temperature and then cools down 20 again. And what the calculations show is that the 35 percent 21 power level, that you're not going to get to the 2900 de2rees 22 Fahrenheit -- that's the magic number for the fuel to actually I 23 tail.
24 In other words, the calculations show that the tuel 25 is going to remain at or below the fuel tailure limits, so no l l
. 28
- 1 radioactivo motorial will actually be rolossed from the 2 individual fuel pellets, and therefore, no radioactivity can 3 be released to the outside of the reactor. Now those are our i I
4 calculations, and the licensee is doing it' own confirmatory 5 calculations to bear those, our calculations out.
6 MR. DENTON: And this is the temperature at the 80 7 hours that we're talking about, So a lot of time has passed 8 from the original break. And that*s what leads us to think 9 there*s plenty of time for restorative actions to be taken by 10 the operator to get the circulators running, or to get the 11 liner running and so forth.
12 CHAIRMAN PALLADINO: Or to get what?
'O 13 MR. DENTON: To get the liner system running it it
- j. 14 wasn*t running at the beginning.
IS CHAIRMAN PALLADINO: Those are the two actions that t
16 --
17 MR. DENTON: They are the two key ones to take, yes, 18 sir.
19 MR. BUTCHER: These. data on this graph here are very 20 conservative. They are based upon the conservative assumptions 21 as the licensing basis for the plant. There have actually been 22 a number of experiments done which show that there*s probably l
23 several hundred degrees of conservatism in these data, and that !
I 24 information was presented by the licensee also.
25 CCMMISSIONER BERNTHAL: Is this core or vessel l
i
- l
, 29 j 1 Jackot coolant normally running, or is that an omorgonoy --
2 MR. HEITNER: Yes.
3 COMMISSIONER BERNTHAL: Is that normally in 4 operation?
5 MR. HEITNER: The liner coolant system is running 6 normally.
7 CHAIRMAN PALLADINO: Is what?
8 MR. HEITNER: Is normally running.
9 MR. DENTCN: But 11 it got knocked out, we thought 10 it could be restored within a day by actions that didn*t 11 require superhuman procedures and staffing and so forth, and 12 that*s what these calculations are based on.
13 COMMISSIONER BERNTHAL: That's the protection of the 14 concrete that surrounds the vessel essentially? Is that the 15 reason for that jacket around the vessel?
16 MR. MIRAGLIA: Protects the concrete vessel as well 17 as the fuel temperature.
le MR. DENTON: As it removes heat.
19 MR. BUTCHER: It can be used to remove decay heat 20 but it was not put in.the plant for that purpose. It's 21 primarily to control the temperatures of the concrete.
22 COMMISSIONER BERNTHAL: So what the. British.do in 23 the AGE with insulation you do with an active water cooling 24 system?
25 MR. BUTCHER: There*s actually several layers of
- 30
~
1 insulation also.
2 MR. HEITNER: There's insulation also between the 3 liner -- the cooling of the liner and the inside of the i
4 reactor. In other words, as you go in from the liner you then 5 hit layers of insulation, and then you go into the core of 6 the reactor.
7 MR. DENTON: So I see what we're proposing then as i
8 an extension. We're granting an extension to this utility for l.
9 some period of time to come into full compliance at tull e
10 power, but I don't see that this equipment is needed for the i
11 low power operation because of its different design features.
12 CHAIRMAN PALLADINO: This liner system has pumps in 13 it?
! 14 MR. HEITNER: Yes. The normal pumps are exposed to 15 the harsh -- potentially exposed to the harsh environment and 16 currently not qualified. So what the operators would have to 17 do, if the normal pumps fall, is line up the system with a 16 source of cooling water from pumps that are outside the harsh 19 environment which can be expected to continue to operate. And 20 that would be done basically by manipulating -- manually 21 manipulating valves.
22 CHAIRMAN PALLADINO: Are there oit-site -- are there-23 pumps outside that are connected to this system'r 24 MR. HEITNER: Yes.
05 CHAIRMAN PALLADINO: That don't face the harsh !
- 31 -
1 environmont?
2 MR. HEITNER: Right, there are other pumps.
3 CHAIRMAN PALLADINO; They're all set up and all you 4 have to do is start them and line them up --
5 MR. HEITNER: Yes, they*re fire water pumps, right.
6 CHAIRMAN PALLADINO: Line up the valves?
? MR. HEITNER: Hight.
8 MR. DENTON: But they're not -- I wouldn*t say 9 they're all set up. But they could be set up in a day, we 10 think.
11 CHAIRMAN PALLADINO: I see. Tnat's wnat you're 12 looking for a couple of days.
13 MR. DENTCN: Yes.
14 CHAIRMAN PALLADINO: They aren't installed pumps.
15 MR HEITNER: No, they are insta.11ed fire water 16 pumps.
17 CHAIRMAN PALLADINO: They are installed?
18 MR. HEITNER: Right. Part of the normal --
19 MR. DENTON: But they're not routed this way. But 20 we don't think it's necessary because you have plenty of time 21 to take, sort of a jury-rigged approach 11 you have to in a 22 matter of days.
23 CHAIRMAN PALLADINO: But they aren't piped to )
l 24 service this liner? f l
25 MR. HEITNER: They would require, I believe, some l
J 1
. 32 1 spool piocos and somo menuel valvo oporations. And that 2 equipment is available and in place right at the site where it 3 is necessary to be used.
4 CHAIRMAN PALLADINO: But you'd have to connect 5 piping?
6 MR. HEITNER: I believe you would have to install 7 some spool pieces. The local NRC resident inspector has 8 walked through the process with the licensee on this to 9 confirm, and we have confidence, exactly what to do.
10 CHAIRMAN PALLADINO: And they would have the people 1
11 to do it, properly trained?
12 MR. HEITNER: And there's procedures established at 13 this point already to do it.
14 CHAIRMAN PALLADINO: Well, would they have available 15 people to do it?
16 MR. DENTON: Well, that's why we think the 24-hour 17 time --
18 CHAIRMAN PALLADINO: 11 you want to double it.
19 MR. DENTON: -- you*d make sure that they do have 20 it. If they had to do this in a few hours we might not be so 21 receptive to the approach. But the fact that it takes 80 32 hours3.703704e-4 days <br />0.00889 hours <br />5.291005e-5 weeks <br />1.2176e-5 months <br /> to get these temperatures indicates to us there's plenty 23 of time and stati to do it.
24 MR. HEITNER: The necessity to do it, of course, 25 would be dictated by the fact that the pumps tailed inside,
__ .-. ~_
, 33 I and that thoro was no way to maintain circulation. And thoro l
1 2 is a fairly high level of confidence that you will maintain j I
3 circulation, because the issues that are in question on the i 4 qualification of this equipment are fairly exotic issues, 5 In other words, there is some confidence now -- and 6 a high level of confidence that the equipment that*s there 7 would, in fact, still remain operational 8 COMMISSIONER BERNTHAL: Consicering the fact that we 9 are talking about four to eight hours in the station blackout 10 rule, 80 hours9.259259e-4 days <br />0.0222 hours <br />1.322751e-4 weeks <br />3.044e-5 months <br /> seems fairly conservative here.
11 CHAIRMAN PALLADINO: But they do have -- that*s why 12 I was trying to understand what it is you have to do. I was 13 trying to understand how difficult it is to do what you're 14 requiring them to do in a couple days.
15 MR. DENTON: That would be one approach is to keep 15 the liner working. The other would be to get the circulators 17 back running. And if you could get tne circulators running, 18 that*s another way to get heat out. So either path would 19 provide a great deal of heat removal 20 COMMISSIONER BERNTHAL; But the 80 hours9.259259e-4 days <br />0.0222 hours <br />1.322751e-4 weeks <br />3.044e-5 months <br /> is the 21 worst case scenario, the sort of nothing works?
22 MR. HEITNER: That*s the one that we have calculated, 23 the worst case just standing there and looking at it.
24 COMMISSIONER BERNTHAL: Right.
2$ CHAIRMAN PALLADINO: Do you have more to present us?
e 34 1 MR. DENTON: No, this concludos our prosentation.
2 We would -- 11 you concur with this course of action -- write 3 up the paper the way we have the other papers and send it 4 down, and work with the licensee on confirming that the 5 calculations are really correct as he*s presented them.
6 CHAIRMAN PALLADINO: But before we open for 7 questions, let me make sure I understand what your thinking is 8 now. That you say you would deny in part and you would 9 approve in part The denial would be that you wouldn*t allow 10 them to operate above 35 percent until they have made the 11 modifications and got the equipment qualified.
12 But you would allow them to operate at up to 35 13 percent during that time. And you would approve an extension 14 for ecmplete equipment qualification until May 31st, 1986.
15 MR. DENTON: Yes.
16 CHAIRMAN PALLADINO: All right.
17 COMMISSIONER ASSELSTINE: Although technically I 18 gather from what you said earlier, the licensee will withdraw 19 a pending request and substitute a request that conforms to 20 wnat you're prepared to accept, which you would then propose 21 tc accept.
22 MM. DENTON: Yes, that*s -- you might want to -
23 confirm it with him, but that*s my understanding.
24 I think part of what led to this was his view that 1
l 25 he really didn*t need 100 percent autnorization during this
. 35 -
1 poriod for other reasons. And while there are some osotorie 2 issues to debate at full power, this would suit his operational 3 needs and provide time to work out exactly what qualifications 4 may be appropriate for full power.
5 CHAIRMAN PALLADINO: But I gather they would withdraw 6 their current request and submit the new request for May 31st.
7 MR. DENTON: Yes.
8 COMMISSIONER BERNTHAL: Remind me again of how we 9 got here in this particular case. It's a unique facility, but 10 the EQ rule says things about beyond the licensee's control.
11 And this case -- was it the fact that you and the licensee --
12 our Staff and the licensee had not come to closure on exactly 13 what needed to be done? Or what's the stcry?
14 MR. MIRAGLIA: I think that's a contributing factor, 15 Commissioner Bernthal. The utility has maintained, up until I 16 believe June of this year -- certainly March of this year in 17 response to the generic letter we sent out, said, do you 18 comply and do you need an extension -- it*s always been the 19 utility's view that they did comply with the EQ rule. ,
1 20 There were, during the Staff reviews, some questions 21 concerning-the tour-minute rule. Did they adequately consider 22 the question of aging. There were some questions _in the 23 Sta11's mind regarding operability of -- you know, have you 24 adequately demonstrated that the equipment can operate for 25 that period of time required. ;
I
- 36 1 And thoso quostions went to the utility, I guoss it 2 was early part ci this year. And subsequent to the March time 3 period the St2it has been working very, very closely with the 4 utility in raising these kinds of concerns and issues. And 5 it*s in the examination of these issues that the utility has 6 seen that it*s going to be ditticult to show in all cases that 7 -- they"ve started an aging program. They*ve started an 8 operability program. With respect to the four-minute criteria, 9 it was going to be ditticult to perhaps conclusively 10 demonstrate for every piece of equipment required that they 11 met the four minutes.
12 And they looked into this steam rupture isolation 13 and detection system, which is a relatively new advent, which 14 came in the September or August submittal to us. And so 15 that*s kind of the evolution.
16 CHAIRMAN PALLADINO: So we're not relying entirely 17 on the fact that these matters were beyond the control of the 18 licensee?
19 MR. DENTON: Well, I think it*s analogous to what 20 we've done in the other in that we're not permitting him to 21 operate where he needs to show qualification beyond November 22 30th is one-way to look at it. __
23 CHAIRMAN PALLADINO: Okay.
24 MR. DENTON: And when he goes beyond where he needs 25 it, then he"s got to be qualified. It just so happens he
37 .
. I doesn't -- whoroas light water plants nood it et protty Icw 2 levels -- he doesn't need until he gets up a ways, is the way 3- I view it.
4 CHAIRMAN PALLADINO: Well, we are sort of departing 5 from our criterion. But -- tnat's it we go along with your 6 proposal, we're accepting that their combination of uniqueness, 7 the tact they didn't have an owner's group to work with, the 8 tact that they didn't get the Statt attention as promptly as 9 the others did, and that there are complications that are 10 associated with cooling modes that we haven't explored.
11 MM. DENTCN: And that EQ is not as big an issue for 12 this type of plant as it is for a light water plant where 13 you*ve got instrumentation inside the containment. You've got 14 to worry about getting the cooling, the medium back in there 15 all the time. This is just a simpler core design to remove 16 heat from.
17 CHAIRMAN PALLADINO: Yes, but that wouldn't justify 18 the extension. That would say, ah-ha, should have done it 19 sooner.
20 COMMISSIONER ASSELSTINE: Yes. I have much the same 21 question and concern. And I just, quite trankly, after having 22 heard your description of how this has evolved, I'm not sure I 23 see a real big ditterence between this case and Brunswick.
24 I mean, it sounds like this licensee took the 25 position up until well into this year that all the equipment
~ - -
[ 38
- 1 was qualified and they didn't havo to do anything to quality ,
i 2 the equipment. When the Statt finally looked at that question, 3 and the basis for it, the Staff had a lot of problems with 4 that. Went back to them and said, wait a minute, we think t 5 you're wrong on several of these instances. And when the 6 company looked at it, they said, well, you're right, we're 7 wrong on these things.
8 That sounds to me like a licensee that didn't make a f 9 good faith effort starting when this rule was adopted to 10 understand what the rule required; to do an analysis of its i
11 plant to determine what had to be done to quality the 12 equipment; and to vigorously pursue qualification of the 13 equipment. I mean, it sounds much like the Brunswick.
14 It sounds a lot more like Brunswick than some ci the 15 other :ases where we've granted exemptions where a licensee 16 had a good program, they worked at it, and because of problems 17 with equipment suppliers, or problems with particular outages 18 they weren't able to get all the equipment installed by the 19 deadline.
20 Am I wrong on that? I mean, what's -- it sounds to 21 me like this is a case where the licensee has not made a 22 good faith effort.
23 MR. DENTON: I think that's why we're down here is 24 to interpret how you read -- is there anything beyond --
25 COMMISSIONER ASSE!,STINE: Tell me your opinion. Is 4
. 39
- 1 it moro liko Brunswick? Or is it moro liko Point Bosch, or 2 Nine Mile Point where they had a good program, where they 3 worked right along, where they kept the Stati informed of what 4 was going on every step of the way, and where because of 5 supply problems they weren't able to get the equipment and get 1
6 it installed?
? Or was it more like Brunswick where they just didn't 8 have an effective program, and now they've got lots of 9 equipment that hasn't been qualified?
10 CHAIRMAN PALLADINO: I'd like to hear that. But I 11 should make the comment, the solution is between the two. It 12 says, approve in part, deny in part. So even 11 it's more 13 like one or the other, our solution is in between.
14 COMMISSIONER ASSELSTINE: We11, it*s sti11 giving 15 them a fairly lengthy extension. The limitation is on our --
16 CHAIRMAN PALLADINO: No, no.
17 COMMISSIONER ASSELSTINE: The limitation is driven 18 by the fact that the Staff can't at this date come up with an 19 adequate justification for c o n t i ntr e d operation at 100 percent.
23 CHAIRMAN PALLADINO: Well, but that's why you*re 21 denying it 22 MR. DENTON: I think this case has more merit tnan 23 the Brunswick case did.
24 CHAIRMAN PALLADINO: What's that?
l 25 MR. DENTON: I think this has more merit than the i l
1
s 40 4
1 Brunswick caso did. It*s truo wo didn*t givo this plant a lot 2 of attention. We've always given it very low levels of 3 attention reflecting to some extent its design 4 characteristics. And we're trying now to bring it up, treat 5 it like light water plants and wherever they're comparable.
6 COMMISSIONER ASSELSTINE: But how about on the
? licensee's standpoint. What leads you to believe t'h a t this 8 licensee made more of good faith ettort to ptt e in place a good 9 program and to get its equipment qualified than CP&L did in 10 Brunswick? What's the ditterence?
11 MR. DENTON: I think the ditterence -- I don't 12 remember Brunswick that well since we've gone through 19 of 13 them. But this one, I think the licensee originally thought 14 he had to do very little qualification. And we had a --
15 MR. BUTCHER: That's correct. I don't want to be in 16 the position of defending what the licensee did, but I would 17 have to concede that the licensee did, in tact, inform us very 18 early in the process that he telt that aging was not 19 applicable to an HTGR because ut the fact that they could 20 regain access to the area and repair any equipment that would 21 sutter aging problems, or sutter tailures that resulted from 22 aging. And he informed us of that, and we did not immediately 23 reject that. We waited until tairly recently before we 24 challenged him on that issue.
45 And the same is true of operability times. He said
41 4
- 1 it was not so significant how long it would oporato in tho
., 2 environment, because even it it -- I did do a test and I ran 3 my test for several hours, and then the Commission passed its 4 EQ rule and asked me to look at it beyond that period of 5 time. But since I have two days or a day or whatever to get 6 in there, I can postulate that even it it does tail after the 7 tour hours, I'd still have 20 hours2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br /> or 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> to repair it.
8 So he maintained his original position and informed 9 us of it. We didn't challenge it until Just recently.
10 COMMISSIONER ROBERTS: Let me ask a question. In 11 their original submittal they enclosed a long chronology of i
I 12 their interpretation of the events. Not line by line, or word 13 by word, but do you have any disagreement with what*s in that 14 attachment?
13 MR. BUTCHER: I would agree with his chronology. I 16 would like to say something in defense of the Statt though.
17 The licensee could have, it he were inclined to maintain a 18 closer awareness of what was going on in the light water 19 reactor industry, instead at just assuming that the large part l
20 of that was not applicable to his plant.
21 But I can understand his point of view when he's got 22 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> to deal with an accident and somebody else has a 23 half-hour to deal with it, to draw the conclusions he did.
24 But I would have to agree with his chronology, and we don *t i
25 take exception to that.
. 42
. 1 COMMISSIONER ROBERTS: Okay. Coll, I moan, wo all 2 get overtaken by events. But they cite a meeting in 1980, NRC 3 Staff stated that they were not exactly sure how to handle 4 Fort St. Vrain other than the EQ schedule must be maintained.
5 I wouldn't call that particularly enlightened guidance.
6 I would also point out in a meeting of 1980 --
7 again, I ask you if you had any problems with the accuracy of 8 this document and you tell me no -- reiterate that the NHC 9 Staff was complete publication of the safety evaluation report 10 by February 1, 1981 It was issued in July of 1985. At a 11 meeting in 1981, it was stated by the Statt that Fort St Vrain 12 should receive their SER sometime in August of '81. I repeat, 13 it was received, as I understand it, July of '85, 14 Here's a. meeting in 1984, stated that.the SEM on 15 Fort St. Vrain should be issued by September or October of 16 1984. It's my understanding it was received July '85. S a' 17 this is not --
I'm.noI" coming down unduly or being t'a r r i b l y -
'18 critical of Statt I'm just saying, this is a complicated
. 19 circumstance.
/
~
20 s MR. DENTON: _We didn't give this planU a lot of 2 ', attonthon, as much attention as we gave other plants. And x - <-
22 neither dad this plant, operate as much as other plants. You 23 know, it's been down a lot. And when y'ou alloo (e resources 24 and you look and see a plant's down, they never'*get above --
l 25 COMMISSIONEH ROBERTS: Don't be d e t' e n s t v e .
A
- 9 'O' 4
. 43
+ 1 MR. DENTON: But, just that*s o part of tho basis.
2 So I think the difference between Brunswick and here, I don *t 3 think Brunswick ever intended to meet the Commission *s EQ 4 deadline. I think that they had planned -- the tront ottice 5 plan was not to meet it, and they thought they could get by 6 with not meeting it.
7 I think this appiicant had a ditiering view of what 8 was required to meet it, and we didn*t really focus on it 9 until late in the review and came with some different 10 positions. Eut it*s clear that he*s got quite a capability to L
11 cope with a lot of --
12 COMMISSIONER ROBERTS: No question.
13 HR. DENTON: -- transients, even witT unqualified 14 equipment.
15 COMMISSIONER ASSELSTINE: Well, it strikes me that 16 -- granted, I*11 give Commissioner Roberts his due on this --
17 that the Statt*s responsiveness may well have been a
- le contributing tactor in all of this. But it also strikes me 19 that to a large extent it comes down to the reasonableness c1 20 the judgment that was made by the licensee when it took the 21 position that, hey, we don *t have to do anything to quality 22 this equipment.
23 There are other licensees out there for LWWs who 24 have taken the position that their equipment is qualified. 11
'J 5 we go out atter the November deadline and innd that there is
. 44
. 1 oquipmont that wasn't qualitiod and that cloarly they should 2 have known needed to be qualified, and we find that their 3 judgments underlying their decision not to qualify -- that 4 nothing further needed to be done to quality the equipment are 5 Just without basis, we're going to do something about it.
O And it strikes me that in this case, part of the
? question of whether they made a gcod faith effort is the 8 reasonableness of those judgments. And I guess I'd be 9 interested in your views on whether you think those were 10 reasonable judgments for the licensee to make. Or whether 11 they really were unsubstantiated. ,
l l
12 MR. DENTON: You may disagree, Commissioner, with 13 me, but my view was that we treated this plant somewhat like a 14 research reactor for much of its life.
15 COMMISSIONER ASSELSTINE: No, I won't disagree with 16 that. Whether we should have or not is a different question.
17 MR. DENTON: Right. And they weren*t -- and so 18 their views of issues like this were not unreasonable ones to 19 hold. And I think we have become tougher in looking at this 20 plant over the past few years than we were during its early 21 life.
22 COMMISRIONER ASSELSTINE: Okay.
23 MR. DENTON: And I think -- so, to some extent, 1 24 think they're still catching up with our intent to force them 25 to have operational controls, management systems, procedures,
- 45
. I as all other plants do, bocauno I think they ccmo up in a 2 different era and were somewhat between a power reactor and a 3 research reactor sort of approach to life.
4 COMMISSIONER ASSELSTINE: Given that context then, 5 the sort of research reactor mentality that applied, would you 6 say that those judgments were reasonable at the time the EQ 7 rule was adopted, and up through a period, say earlier this 8 year where we changed to more of a power reactor operating way 9 of thinking?
10 MR. DENTON: I think it's reasonable. I don *t think 11 the Statt looked that hard. And no one was questioning their 12 judgment that much a few years ago. It was just not thought 13 to be a real problem.
'14 MR. MIRAGLIA: Clearly, they made their judgments in 15 submittals --
i 16 COMMISSIONER ASSELSTINE: We knew about it, we just 17 accepted it.
18 MR. MIRAGLIA: -- and dkdn't give positive or 19 negative feedback.
20 COMMISSIONER ASSELSTINE: If you were to apply the 21 power reactor level of performance that we're now trying to 22 apply, would you say those judgments are reasonable? If you l
23 say basically these people ought to be treated like a power l 24 reactor, they ought to maintain the same level of performance 25 that we would expect of others.
. 40
, 1 MR. DENTON: VJo l 1 , I think it would roasonablo to 2 expect that now because we*ve had several sessions with the 3 company management about how things should go. I don *t think 4 in the future we won *t be tending to look back and saying, 5 you*re excused because of this. I think it*s much clearer now 6 between ourselves and the company what is required.
7 But at the time, I think their arguments were 8 certainly reasonable. And it we were to have a hearing on the o
9 topic, you know, they may prevail on whether their views on it i .
10 all being qualified anyway is correct or not. We can*t reach 11 the same conclusion today that they*re reached about some of 12 this equipment.
13 COMMISSIONER ASSELSTINE: Now so I take it tor this 14 plant there really never was a JCO then for this plant, up 15 until now, because the position they maintained was, the 16 equipment was properly qualified.
17 MR. MIRAGLIA: That's correct.
18 COMMISSIONER ASSELSTINE: Okay. j 19 CHAIRMAN PALLADINO: Did we determine what power 20 level they operated at --
l 21 Md. MIRAGLIA: It was sometning asked --
22 COMMISSIONER ASSELSTINE: We're going to hear from 23 the company.
24 MR. MIRAGLIA: The numbers that stick out in my mind 25 is that the average capacity factor for this facility over its I
I
- 47
. 1 oporating lito cinco liconcing is loss than 30 poroont, J 2 MR. HEITNER: Less than 20 percent.
3 MR. MIRAGLIA: About 20 percent.
4 CHAIRMAN PALLADINO: But there were times when they 5 went --
6 MR. MIRAGLIA: As high as 80, but I don't know for 7 how long.
, 8 MR. DENTON: Very briet times.
9 CHAIRMAN PALLADINO: 80 percent
- 10 MR. MIRAGLIA: I'm not sure of the duration of 11 periods of time.
12 CHAIRMAN PALLADINO: It was 80 percent?
13 MR. MIRAGLIA: At 80 percent, a
14 MR. DENTON: It seems to me that they scramed quite 15 otten, and whenever they scram they got water in the system.
16 Then in order to dry it out they have to have an extended 17 outage at low power, and they went through that --
18 MR. MIRAGLIA: The reactor was shut down --
19 MR. DENTON: Otten.
l 1
20 Mh. MIRAGLIA: -- in June or July of *94, wnen it 21 experienced some control rod tailures. And it was just 20 started up at the low power operation at July of this year. .
1 23 So it's been shut down for --
24 COMMISSIONER BERNTHAL: Why did they scram so often) 25 MR. MIRAGLIA: It has to do with the -- I guess, the
. 48 1 moisturo ingrossos is ono of tho big prob 1 cms.
2 COMMISSIONER BERNTHAL: They scramed because of the 3 moisture ingress.
4 MR. DENTON: Well, I don *t --
$ MR. HEITNER; That*s one of the --
6 COMMISSIONER BERNTHAL: Which was exacerbated then
? by the scram.
8 MR. MIRAGLIA: Yes, It's a vicious --
9 MR. DENTON: It gets back to one of their design 10 concepts. A little ott the topic, but they have steam driven 11 circulators. And apparently the seals between the circulators 12 and the core were prone to leakage under certain conditions, 13 and that wasn't foreseen.
14 COMMISSIONER BERNTHAL: Fundamentally, it's not 13 clear to me that the EQ rule notwithstanding, that other than 16 to prove or attempt to prove that the Commission is tough, 11 17 the plant running at 3$ percent simply needn*t meet the EQ 18 rule, I think you'd have a pretty hard time arguing the 19 Commission isn't required in any circumstance to provide them 20 a license to run at that power level 21 COMMISSIONER ASSELSTINE: I disagree with that 22 because, keep in mind, every one of these plants that has 23 requested an exemption had an adequate JCO.
24 COMMISSIONER BERNTHAL; No, no. But not -- under 25 different circumstances. I think Harold's point is that none
- 49
. 1 of tho PWHs, and I guess BWRo, can run at a low powor lovol 2 where the hazards are comparable to this plant at 33 percent.
3 Isn*t that -- is that an accurate' statement?
4 In other words, it one of these had come in and 5 said, all right, we aren't going to -- well, take Brunswick.
6 If they*d come in and say, we aren't going to meet your EQ
? deadline but we're going to run a.t a power level that -- where 8 the EQ becomes essentially inapplicable, what would that power 9 level have had to have been? Very low, to say the least.
10 Much lower than this.
11 COMMISSIONER ASSELSTINE; But at the same time, in 12 terms of sate *y. what's the ditterence between that and 13 saying, we can run at 100 percent power, and we still provide 14 a safe plant because we've got an alternate means. We have a 15 Justification for continued operation that assures that we can
, 16 operate the plant safely at 100 percent power, which is 17 precisely what Brunswick argued, and which the Statt agreed le with.
19 COMMISSIONER BERNTHAL: Well, I guess the difference 20 is --
21 COMMISSIONER ASSELSTINE: What the Commission said 22 is, we*ve got a rule -- -
23 COMMISSIONER ROBERTS: I happen to agree with that 24 also.
l 1
25 COMMISSIONER ASSELSTINE: Well, to give Tom his due, me
- $0 1 that's oxactly right 2 COMMISSIONER BERNTHAL: The difference is --
3 COMMISSIONER ASSELSTINE: Tom said, it's only a 4 safety issue and that's all we care about.
5 COMMISSIONER BERNTHAL: The ditterence is that in 6 one case there is a -- if there is a tailure of a system that 7 they say will work, that justifies operation, then they're in 8 the soup. In this case, they're operating below the threshold 9 where systems are required, I guess, assuming you don't have a 10 747 plowing into the plant or something. That's the 11 difference.
I 12 MR. DENTON:' We can explain our logic, and I think 13 we're learning how to interpret your guidance on this one.
14 And this is the last one.
15 CHAIRMAN PALLADINO: In case you're trying to 16 interpret guidance, I'm not sure that I would not entertain 17 your proposal. Well, to make it more positive, given what I 18 know now, I would entertain a proposal such as you're 19 discussing with us today.
20 Maybe when you come with more detail I might have 21 more questions. But I wouldn't say that the guidance is 22 necessarily all negative. I don't know how others would feel 23 COMMISSIONER BERNTHAL: Well, I'm -- as I say, I'm 24 not convinced that -- let me state it the other way. I think 25 we'd be hard-pressed to dispute the course of action that the
. 51 1 Stati is proposing horo, and I suggost wo como in with 2 something that approximates that. For the reasons that we've 3 gone through.
4 -
Now there may be differences in philosophy here, but 5 I don't think it's been shown that -- the argument that this 6 is a different circumstance doesn*t hold water.
? CHAIRMAN PALLADINO: I would say that in your 8 submittals you should address this question of the interaction 9 of Stati and licensee, insofar as it applies to the fact that 10 the licensee didn't control all the circumstances.
11 COMMISSIONER ASSELSTINE: I had one other question 12 for the Statt on the previous Stati reviews. I understand 13 that in this case -- or at least the sense I had was that in 14 this case, up until early this year Stati did not really do 15 much of a review of the argument that the licensee made all ;
16 the way along, that for their plant they didn't need to do 17 anything, or essentially anything more to quality the 18 equipment; is that right, for this one?
19 MR. BUTCHER: That's correct. I believe at was 20 probably July before we seriously challenged their position on 21 the qualification of the equipment.
1 22 COMMISSIONER ASSELSTINE: Okay. How does that l 23 compare with instances in which LWRs have asserted that 24 equipment does not have to be qualified? That equipment -- or 25 that equipment is already adequately qualified for the plant
$2
, 1 --
in torms of emount of roviGw, 10v01 01 roview, quality of 2 review that has been done of those assertions up until now?
3 MR. BUTCHER: I would have to say that we put a lot 4 more ettort on the light water reactors and the feedback came 5 much earlier.
O COMMISSIONER ASSELSTINE: Okay. Is that also true 7 of the JCOs that you*d received from the LWRs in previous 8 instances going back over time?
9 MR. MIRAGLIA: Yes, I think 11 you go back in EQ l
10 time when the deadlines were much earlier, the Statt did some 11 preliminary evaluations and requested JCOs for everything that 12 we said wasn*t qualified.
13 COMMISSIONER ASSELSTINE: That*s right.
14 MR. MIRAGLIA: And so we've been in the JCO review 15 process with LWRs very, very early in the game. l 16 COMMISSIONER ASSELSTINE: So this one just tell 17 through the cracks?
18 MR. MIRAGLIA: And atter we had, you know, the l
19 Franklin TERs and we reiterated that several times.
20 MR. DENTON: I wouldn't say it tell through the l
21 cracks, but we gave it lower priority in that we are an audit l 22 organisation. And we push our ettort toward Indian Point, ,
1 23 Zion. And I don't think we should, you know, push back and 24 say, I wish I had put the ettort that I did in *83 and *84 on J5 this plant versus Indian Point, because I think Indian Point
- 53
. 1 roprosonts tho moro subatontial quostion.
2 So I think we tried to allocate from a safety 3 standpoint. It we'd had another gas cooled plan, coming by 4 for an OL review this might have turned out differently 5 because then it would have gotten caught up in modern, sort 4
6 of, level reviews. And it was only the Commission's deadline ,
7 that kind of pushed us to be sure we got every plant covered 8 by November 30th.
9 COMMISSIONER ASSELSTINE; Did Franklin ever look at 10 this plant?
11 MR. MIRAdLIA: No, sir.
12 MR. DENTON: In tact, this is one we had regionalized 13 for awhile.
14 COMMISSIONER ASSELSTINE: Okay. So this was --
! 15 that's true, this all occurred when it was shifted out to the 16 region.
17 MR. MIRAGLIA: But the review -- the EQ review would 18 have been done --
19 COMMISSIONER ASSELSTINE: Still would have been done 20 at NER.
21 MR. MIRAGLIA; Right, yes.
22 CHAIRMAN PALLADINO: Other questions of the Stailb 23 COMMISSIONER ZECH: I just have a comment. It seems a
24 to me that this is a very special case, and you've, of course, 25 emphasised that.
- $4
, 1 Cut also wo*ro planning tho EQ provisienc to thio 2 plant. And it seems like we're, you know, doing it, applying 3 it, or trying to apply it in a very similar manner that we've 4 applied at all the other plants. And I think it is in.po r t a n t 5 to recognize there are great differences in this plant But 6 also, I think the circumstances, the exceptional circumstances i 7 that we*ve applied, and the provision that we've looked at for 8 other plants is important here.
9 And it strikes me as, although exceptional 10 circumstances can be interpreted different ways, you could in 11 a sense put this whole plant in a category of a special 12 circumstance. And I seems to me that what the Stati is 13 telling us is that perhaps you have considered thou separately 14 from all the other plants.
l 15 You know, we*ve asked other plants, have they really '
16 made their best ettort to meet the EQ quali11 cation. Even 17 asking that question of this plant, I think, has to be a 18 little different. Apparently, they've telt all along, or told j 19 you all along untti very recently, that they really have telt 20 they*ve met the qualifications and you have not, as far as 1 21 can tell, challenged them until very recently.
22 So those are all things 1 think we've got to think 23 about. But I guess the special plant itself, and the proposal
'. 4 that you*ve brought torth with the licensee to remain below 35 25 percent completely --
you konw, it a the only one Itke that.
l 1
55
. 1 All the rost of the plants aro, BWRo, LWRs cro ecmplotoly 2 different circumstances.
3 So I just do think we have to try to apply -- 11 4 we're going to apply the EQ provisions to this plant we really 5 have to recognise it*s different.
6 On the other hand, I can't help but feel, I don *t 7 know it what the licensee responsibility or the Stati 8 responsibility, that we might have attempted, in hindsight at l 9 least, to get this thing resolved at an earlier date than we j 10 have, 11 So I'm going to have to think about it a little more l
12 myselt But it does seem to think -- it does seem to me that 13 it the provisions for equipment qualitication are applicable l
14 to this plant, then we must do something about it.
15 For example, is it going to operate at 35 percent 16 forever? I know you*ve told me 31 May *80 to be in tull 17 compliance. But what it they decide that they don *t ever want i
l 19 to operate above 30 percent, then what would we do? Is the 31 l
19 May date a commitment that they*re going to have the equipment 20 qualilled by that date? Or is it just a date that we*re i
! 21 shooting for?
20 MR. DENTON: Well, I think one other point that 23 bears on the questions that have been raised, A few years ago l 24 the continued operation of this plant was not even certain, 25 going to your --
l
, 1 COMMISSIONER ZECH: Hight.
2 MR. DENTON: It was a -- it was being -- or questions 3 being raised as to --
4 COMMISSIONER ZECH: Another reason is -- l 5 MR. DENTON: -- what it*s actual useful lite was.
6 And that sort of thing tactored in.
7 COMMISSIONER ZECH: Right. l l B MR. DENTON: And I think that*s still a question you 9 might like to explore with the utility.
I e 10 . CHAIRMAN PALLADINO: Yes, I was going to suggest l .
1 11 that's a good question to discuss with Public Service.
12 COMMISSIONER ZECH: All I'm saying is it's a very 13 ditterent plant and it*s hard to apply the EQ provisions to l 14 this plant, i
l 15 On the other hand, it we're going to apply them, 16 then we ought to, I think, have some degree of confidence that 17 they're meaningful and they're purposeful. It they're not, 18 then probably we ought to exempt the whole Fort St. Vrain from l l
19 the provisions. But it we're going to apply it, it seems to '
l l l 20 me that we*ve got to really consider it as a separate plant.
21 And I think that*s what you*re trying to do. And I 22 guess they have too. But it's unfortunate, I.think, that we l
23 haven't brought this to a head before now.
24 COMMISSIONER ASSELSTINE: Yes, I agree with that, 1
i l 25 Lando. And I also agree with the notion that because of the i
i 1 l
l l
i
- $7 1 diftoront noturo of this plant wo cught to tako C hard lock at 2 what requirements ought to apply to it. And where those 3 requirements don *t make sense, how they ought to be modified 4 as they lit this particular plant.
$ In fact, going back a couple of years ago, I remember 6 that that's one of the things that was supposed to come out of 7 the regionalisation of this plant. Everybody was going to give 9 it more attention. We were going to toous on just those kinds 9 ot questions. We were going to get closer to the licensee, i
l 10 And we were going to get all those questions answered. It l
11 doesn*t appear that that's the way the process worked.
12 Where I have a ditticulty though is in saying --
13 when we have a regulation on the books -- in saying that 14 perhaps because of the differences we're prepared to tolerate 15 a laxer attitude, less of a commitment to doing things right
- 10 by this licensee than light water reactor licensees. And 17 quite frankly, I think that's where this particular plant has IS gotten in trouble in the past.
19 I think we ought to be fair about what's required of l
l 20 it. But then we ought to insist that this plant be run on a 21 professional, business-like basis, and insure that that's the 22 way it goes from now on.
23 COMMISSIONEH ZECH: And I realise that.
l 24 CHA!HMAN PALLADINO: And I have no exception -- I l
25 mean, I don *t take any exception with that.
l
, $8
. 1 COMMICSIONER ZECH: But porhaps wo should havo, you 2 know, provided more guidance too.
3 COMMISSIONEM ASSELSTINE: No doubt about it. I 4 think that's exactly right. But my biggest concern now is 5 that we don't undercut the message that I think Harold is 6 trying to give this licensee that from now on we expect a 7 e professional, business-like operation from this plant, and 8 we're not prepared to tolerate anything less than that. I 9 think that message has to be reinforced.
l l 10 CHA!HMAN PALLADINO: Any other questions or comments?
l 11 COMMISSIONER ZECH: No.
12 CHAIMMAN PALLADINO: Let me see what questions we l 13 have for the licensee, and I don't know it he wants to make a l
l 14 statement or not. Can we have them --
15 I do want to come back then to the question of i
16 guidance to the Stati relative to their proposal But I 17 thought it might be helpful to get some of the questions 18 answered.
l 19 Jim, you had --
l 20 MR. WALKER: Let me introduce myselt Nice to see 1
21 you again, Dr. Palladino.
22 CHAIMMAN PALLADINO: Nice to see you.
l 23 MM. %).L K EM : I'm Dick Na&ker. I'm chairman of the 1
24 board and president and chiet executive otticer of the Public 25 Service Company of Colorado. And I certainly have a direct l
1
- 59
. 1 intorost in the Fort St, Vrain plant, having to11cwod it 2 through many of my engineering days with the company.
3 I would say at the outset, we certainly recognize 4 the Statt*s position and I agree wholeheartedly with it. And 5 I think the attention they're giving us in the last six to e eight months has been helpful for all of us.
7 And it*s true we did, over the years, feel because l 8 of the difference we could operate at 100 percent. We now l
l 9 don *t feel that way anymore. We feel that we do need to meet 10 -' the environmental qualifications which we intend to do. And 11 we're relying on this leak detection system, which we probably 12 should have thought up two or three years ago. But we believe 13 that will certainly cut the time, to cut it down to a minute 14 or so before you can cut the thing on.
15 So in talking with the Statt and with Harold, I'm 1
to perfectly comfortable with the 35 percent and the May 31 i
I 17 date. And we'll certainly resubmit whatever we have to do 18 legally, a r. d application for that, and withdraw the other 19 ones. So lhe 100 percent one is no longer on the table as far 20 as I'm concerned. And I'm in a position to say that as the 21 CEO of the company. I 22 CHAIMMAN PALLADINO: You had a question, Jim) 23 COMMISSIONER ASSELSTINE: My question was the 24 operating histo.y during -- since the EQ rule was adopted.
25 What level the plant had operated at in that period of time.
r l 60
. 1 MR. MALKER: You havo to go back in '79 when wo wont 2 commercial. And to refresh your memories on that, there were 3 -- we did accept the plant trom our vendor at 70 percent of 4 its capacity, the 200 megawatts. And that's what we count on 5 it in our system capability.
6 Cur license -- we were limited to 70 for awhile in 7 the early years, and then were allowed to go --
8 CHAIRMAN PALLADINO: 70 what?
9 MR. WALKER: 70 percent of power. We were allowed
( 10 to go to higher levels. And my operating people -- and we did 11 have one period where -- 60 hours6.944444e-4 days <br />0.0167 hours <br />9.920635e-5 weeks <br />2.283e-5 months <br /> -- where we ran it at near l
12 full load. And that's the only time.
13 CHAIRMAN PALLADINO: And that was when? '79) 14 MR. WALKER: I think it was probably -- no, it was 15 probably '82, '83, I think somewhere in that realm.
16 As you know, we were down for refueling in -- well, 17 maybe you don't -- in '84. And when we came back trem l
18 refueling and started the reactor back up, that's when we had 19 the problem with the control rods, as I recall. That was June ,
I l 20 of '84, wnere we had the moisture on the control rod 21 mechanisms, and we had the stress corrosion with the cables.
22 And we shut down, and obviously had to because six of the r o d --
23 didn't insert automatically. They had to be put in manually.
24 When we looked at those control rods and then 23 finally made the determination that there was stress corrosion l
t L
i .
. 01 1 cracking thoro was only ono thing wo could do, was to roplaco l 2 all 37 control rods. Which, we entered into a year program, 3 very extensive program -- these are radioactive piecea of 4 equipment -- and did replace all of the cables, refurbish the 5 shim motors. The cables are now Inconel We finished up that i
1 6 work in -- it was about June of this year, Oscar?
l 7 MR. LEE: Yes.
8 MR. WALKER: Around June ci this year, ready to come 9 back --
10 COMMISSIONER BENNTHAL: What was the -- a matter of 11 curiosity. I'm still intrigued by what might have been with
(
l I
12 the Fort St. Vrain facility. What was the cost of replacing 13 all the cabling there?
14 MR. WALKEN: About 10 million. I believe, roughly.
l 15 Don't pin me down to the figure exactly, but it was 16 approximately 510 million, which has been charged oli as an 17 operating expense to the company.
l 18 COMMISSIONER BERNTHAL: Another hardware question, 19 11 I might. As I understand it, this moisture ingress is a 20 consequence of the seals that you have in the pumps; is that 21 right?
22 MR, WALKER: Well, you.see our circulators are steam 23 driven and they have water bearings. Rather than oil bearings 24 they have water bearings.
24 COMMISSIONER BERNTHAL: I've forgotten --
1 i
l
\
, 62
. 1 MR. CALKER: That was an ocrly dosign docision on --
2 and the fear at the time that decision was made, with oil in 3 the beat ings ~and you got oil into the core, and you get oil in 4 the insulation, you cannot get oil out of the insulation 5 that's there. So the decision was made to go to water 6 bearings.
7 COMMISSIONER BERNTHAL: Well, now today though, with 8 today's knowledge and technology --
l 9 MR. WALKER: What would you do?
10 COMMISSIONER BERNTHAL: --
there are substances 11 other than oil and water, I guess. But, is it practical, let j 12 alone economical, to make changes to that system, fundamental l 13 changes that --
or is that simply neither practical nor 14 economical?
l 15 MR. WALKER: That's fairly ditticult. We have, I
l 16 since we accepted the plant from the vendor, made some l
17 modifications in some of the auxiliary systems, split the
- 18 loop and added some things to try to minimize what we call the l
19 water ingress problem.
20 If you're starting with a clean piece of paper 21 designing your reactor today you*d look very hard at magnetic l
--k 22 - ' bearings. Of course, you're looking at a very large size for 23 magnetic bearings. But 11 you really were convinced they*d 24 work in this configuration, then you don *t have to worry about 25 oil, you don *t have to worry about water. And you also have a l
I
63
. I littlo -- ocma tolorenco for difforonco in alignmont.
2 And there is some work going on and --
3 COMMISSIONER BERNTHAL: There's been a -- that's a 4 rather --
5 MR, WALKER: Tricky.
6 COMMISSIONER BERNTHAL: -- highly refined technology 7 in other areas these days.
8 MR. WALKER: Right. And I would hope as the nuclear 9 technology develops, particularly in the modular size, that 10 that could well be with magnetic bearings, which would --
11 CHAIRMAN PALLADINO: You are shut down now?
12 MR. WALKER: Yes, when we --
13 CHAIRMAN PALLADINO: And how long have you been shut 14 down?
15 MR. WALKER: Let me continue the chronology, 16 Dr. Palladino. After we got the control rods done, and then 17 we were In the throes of this environmental qualification 18 work. And we had worked extensively with the Staff And wo 19 did want to come back on the line so we could begin to get the 20 moisture out of the helium. As you know, that's a function of 21 temperature. As helium resides -- or moisture resides in the 22 helium, just the decay heat is not adequate to dry the moisture I
23 out.
24 So in working with the Staff we came up -- they l
25 allowed us to go to 8 percent, no more than 8 percent power.
i l
l 64
, 1 And that was for 45 days, wasn*t it, Oscar?
2 MR. LEE: Yes.
3 MR. WALKER: And that was in October. So we came 4 back on the line in October and ran --
5 CHAIRMAN PALLADINO: This year?
O MR. WALKER: Yes. We ran up in increments of 2, 4, 7 and 6 and then just below 8. And of course, as you raise the 8 temperature, then more moisture came out. And we did that up 9 until last Thursday, wasn*t it -- I think. And we*ve gotten 10 out about as much as you can get out. It finally plateaus on 11 you wher. you get up -- you run at 8 for quite awhile.
- 12 Also, we were ready to do some of the work that 13 needed to be done in the reactor. So we shut down last 14 Thursday. And so, except --
we did have that run at 8 15 percent. You don *t make any electricity at 8 percent, but 16 that*s what we've been running at. ,
l 17 CHAIRMAN PALLADINO: Lando, you had a question?
18 COMMISSIONER ZECH: No.
i 19 CHAIRMAN PALLADINO: You*re satisited. You have a l
20 question?
{
1 21 COMMISSIONER ROBERTS: No.
22 CHAIRMAN PALLADINO: All right. .Well, if there are 23 no more questions. I would make a comment. I haven *t visited s 24 Fort St. Vrain.
25 MR. WALKER: We wish you*d come out, Dr. Palladino.
I 65
. I 1 CHAIRMAN PALLADINO: !*d liko to. I'd liko to 000 l
2 all the plants, but I don *t get to see them all. But the 3 feedback I get trom the Stati is that the plant could benefit 4 trom a higher level of professionalism in its activities. And 5 I think this is a matter that, in addition to EQ, you probably 6 want to give it some more of your personal attention. I think
? management attention has already resulted in benefits to 8 plants where there are ditticulties.
9 MR. WALKER: Absolutely.
10 CHAIRMAN PALLADINO: And I'm sure Fort St. Vrain is 11 no exception.
12 Now, are there any other comments or questions for 13 the licensee?
14 COMMISSIONER ASSELSTINE: No, ! Just would agree i 15 with that comment, Joe.
, 10 MR. WALKER: Yes, we recognize that. We've been l
l l 17 told that by the Statt and by INPO, and we're dedicating more 18 resources and more time to it. It's an area we need to j 19 improve, and I*d be the first to admit it.
l l
l 20 COMMISSIONER BENNTHAL: Is there any prospect that 21 that plant is ever going to run smoothly at, let's say, 22 comparable capacity tactors to~other plants? Do you envision 23 that as a realistic --
24 MR. WALKER: Well, we're sure -- keep working on l
l 25 things that we believe will improve its reliability. It still l
1 I
1
, 0%
. 1 is ocmowhat of a first-of-a-kind plant. And'the only 2 experience in this type of thing comes from our plant for 1
3 helium circulators and these kinds of things.
4 COMMISSIONER BERNTHAL: but this moisture problem is 5 really the critical problem.
6 MM. WALKER: That*s been a critical problem. And 7 we*ve, as I say, made some changes in auxiliary systems, and 8 trem time to time look at maybe some of these more exotic 9 things to do. But those are major changes to contemplate trom l
10 an engineering standpoint. And it's not completely out of the l
i 11 realm of possibility, but you'd have to look very carefully j
12 at what you do to try to get those stuck into this kind of a l
i
- 13 vessel.
l l 14 CHAIRMAN PALLADINO: Any other comments or questions l 15 for the licensee?
16 MM, WALKEN: We appreciate your time. Dr. Palladino.
i 17 CHAIRMAN PALLADINO: Thank you.
i l
19 COMMISSIONEM BERNTHAL: Let me just make a quick, l
19 naive point here. But there's been around for a long time a i
20 group called -- what do they call themselves, HTOR Associates' 1
21 CCMMISSIONEN ASSELSTINE: I Oas Cooled Meactor ,
l l 22 Associates.
i 23 MM. WALKEH: I happen to be the chairman of it l 24 COMMIS810NER BERNTHAL: Well, they focused heavily i
! 25 --
Jim had asked on the side here a low minutes ago -- they l
. _ _ _ . _ _ _ _ _ _ _ _ - - _ _ _ _ _ _ - _ - _ _ - _ _ - _ _ - _ _ _ - - - _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ . __ _ _ __0
l 67
. 1 tosusod hoovily en noxt gonoration ana what cight happon long
[
2 atter Fort St, Vrain. The question arises whether a similar l 3 design is still behind, at least the larger plant that they 4 were working on until recently. And one wonders whether more 5 attention to making Fort St. Vrain a viable plant, whether or i t
j 6 not it takes substantial modifications to the existing plant, 1
1 7 may not be in their interest. Just a thought.
l r
8 CHAIMMAN PALLADINO: Okay. Well, thank you very I 9 much, 10 MM. WALKER: Thank you, Dr. Falladino.
4 11 CHAIRMAN PALLADINO: Now, I would like ta got irom f
12 the commissioners guidance for the Stati I expressed my 13 willingness to entertain a proposal such as the Statt has l 14 made. That doesn't mean I'm committed to voting in one 15 particular direction when I get it, but it does imply that it 10 sounds fairly good at the present time, t
i 17 I wonder it -- and I think, Fred, you expressed your 18 opinion. And I wonder it others would express their opinion.
19 At least give guidance as to how the Statt should proceed.
20 COMMISSIONER HOWERTS: My inclination would be, by 21 and large, to accept the Statt recommendation.
22 COMMISSIONER ZECH: I guess I'd like to see the 1
23 Stati recommendation on a p6ece of paper. And I think that l I
l 24 they've given a reasonable recommendation, but I would !!ke to i l
l 25 look at it, and think about it a little bit.
l i
t l l
. 68 l .
l .- 1 CHAIRMAN PALLADINO: I wasn't making o ocamitmont to i
2 absolutely vote for it I'd have to depend on the paper also, l
l 3 COMMISSIONEN ASSELSTINE: 1 think the Statt ought to 1
4 present the paper. Just as they've done in the other cases.
! 3 Some of their recommendations I've agreed with, some of them 6 I*ve disagreed with. But I think the Statt ought to give us 7 their recommendation in writing.
t
( 8 COMMISSIONER ZECH: That's what I think too.
l l 9 COMMISSIONEM ASSELSTINE: Just as they*ve done in 10 the other cases, and address the factors for this plant.
1 11 CHAIMMAN PALLADINO: Could I get a feel from the 12 Statt what time trame we're working in? And let me point out 13 that for quite some period of time, things tall apart here i l
14 around 11/26 -- on the 26th. So that's perhaps the last day 15 at whtoh we could attirm, although I think one or two may be to --
there may be enough of us here another day, bu6 1 don't i
17 think --
i 19 MM. DENTON: I don't think it would take us very 19 long to put together a paper that summarises our views. And 20 it would be subject to these confirmatory actions coming in.
21 But we're fairly certain it's going to turn out that way 22 because of our interactions.
I 23 MM. MINAOLIA: I think we can probably get the --
24 MW. DENTON: If you wanted to wait until we had the OS review innished, then I guess we're two or three weeks away. 1
t.
69 1 But it you'ro willing to hoor what the plans cro, absont scuo 2 startling new discovery, we would have that in a tow days.
3 MR. MIMAOLIA: Yes, I think we can get the utility l 4 to modity his request, and then indtoate when he's going to 1
5 have his confirmatory analysis in. And on that basis we could o prepare a paper saying that, you know, the Commission would i
7 grant the extension subject to the Statt reviewing the 8 contirmatory analysis and approving operation at 34 percent.
9 I think we can dratt something ==
10 CHAIMMAN PALLADINO: Well, how many days does all 11 that take? Friday is the 22nd, and that only leaves --
! 12 COMMIS810NEW ZECH: That's plenty of time for them 13 to do that. ;
14 [ Laughter.1 15 CHA!NMAN PALLADINO: I was suggesting cutting it i
16 down because that only leaves us --
17 COMMISSIONEM WEMNTHAL: How about 8: 00 ton 12ht?
le CHAIMMAN PALLADINO: That only leaves us Monday --
l 19 the weekend to evaluate and Monday, and on Tuesday we'd have l
l 20 to attirm, the 26th. Wo I'm going to urge, see il you can't l
l 21 get it to us no later than noon on Friday, sc at least it we
! 22 have some initial questions we have a chance to interact l
l 2 'J before the weekend.
24 COMMISe!ONER ASSELSTINE. That's good, 25 COMMIS9tONEM ZECH: dounds tine to me.
l 1
70 ,
l , 1 CHAIMMAN PALLADINO: And thon w3'd hado to teko 2 actics by Noverabe r 20th, and I don't know it that means having, 3 the order approved as well Let me ask general counsel, it we 4 made a deoiston by the Zeth, would we in order to comply with 5 our own rules, would it require that an order by approved by
- O that time?
? MN, PLAINE: Well, I think you could approve, since I
- you are making this a sort of special order of business. In 9 otteet, excepting it from the ordinary requirements. -
I 10 CHA!HMAN PALLADINO: No, I'm thinking though about 11 the mechantos of preparing an order, it we don't make a 12 deotston on whether we go with this or not until kne 20th --
13 MM. PLAINE: Wouldn't this te a direction simply to 14 the Statt?
- 15 COMMitstCNEN ASSELSTINE: No, we've had orders in 16 all --
l l tt CHAIMMAN PALLADINO: We've had orders --
l l
l 14 MM. PLAINE: You've had orders in all these others.
I 19 All right.
20 CHAlkMAN PALLADINO; So it may be necessary tor 00C ,
l 21 -- what I'm getting at is, it may be necessary for OOC to i 22 anticipate how this might go and have some dratt order ready .
2 *J tor the 26tn. I 24 MR. PLAINE: All right.
25 COMMISWlONEW AWWELWTINE: Statt and OOC could work i
i
l
, 71
, 1 en tho ordor at tho semo timo tho Otait is working on tho l
2 paper.
l 3 MM. PLAINE: All right, we*11 work on it.
I I 4 CHAIRMAN PALLADINO: I was just trying to get
[
4 attention to the mechanics so that we have a chance of meeting o the 20th. Otherwise we're going to miss the 30th of November, l
7 because people will leave, including myselt, leave for 8 Thanksgiving. And there will be Thanksgiving.
9 COMMISSIONER ASSELSTINE; There will, you're right. >
e 10 CHAIMMAN PALLADINO: Anything more to come before us
! 11 this attornoont 12 COMMISSIONEW ZECh: No.
13 CHAIMMAN PALLADINO: Well, thank you very much. Oh, 14 let me ask a question of the Commission. I'll adjourn this 15 meeting.
16 EWhereupon, at 3:30 p.m., the commission meeting was 17 adjourned.]
l 18 I
IN l
20 21 22 1
23 I l
l 24
- l i
20 l
l 1 CERTIFICATE OF OFFICipL REPORTER 2
3 4
5 This is to certify that the attached proceedings 6 before the United States Nuclear Regulatory Commission in the 7 matter of- COMMISSION MEETING S
9 Name of proceeding: Discussion of Environmental Qualification Exemption Request - Fort St. Vrain (Public to Meeting) 11 Cocket No.
12 place: Washington, D. C.
13 Cate: Tuesday, November 19, 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 g
(Signature) g,jk (Typed Name of Reporter,) s,(/Panela Briggle 20 21 22 23 Ann Riley & Associates. Ltd.
24 25
Q
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FORT ST, VPAIN EQ EXTENSION REWEST e PETEST SLD11TTED SEPT 9EER 24,1985
- EXEPTIONAL CIRC 17ETANCES
- JtETIFICATION FOR INTERIM OPERATION o STNF LMABLE TO CONCLt0E INIERIM OPERATION AT 100% JUSTIFIED o IOGER, OPERATION AT 35% POWER IS JUSTIFIED BY UNIQUE hTGR DESIGN e LICENSEE HAS CtPttI1TED TO COPPLETE ALL EQ BY PAY 31,1986 ,
.. i
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JUSTIFICATION FOR INTERIM OPERATION AT 35% POWER e NO ELECTRICAL EQJIPENT REQJIRED TO BE QlALIFIED o ADEQUATE TIE AVAILABLE FOR MANUAL ACTION e .W ORST CASE PEAK CORE TEW ERATURE 2900*F AT 80 HOURS !
l l
e NO SIGNIFICANT FUEL DAMAGE
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e DOSES - A SMALL FRACTION OF 10 CFR 100 e INDEPENDENT STAFF CONSULTANT (0PNL) VERIFICATION
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REMAINING NRC STAFF AND LICENSEE ACTIONS TO 00PPLETE 35% POWER OPERATION REVIEW e LICENSEE FOLLOWUP
- CORETE FIML CALCULATIONS TO COWIBM PRELIMINARY FINDINGS
- APPf0XIMATELY 12 SEPARATE AREAS REQUIRE CONFIRMATION
- PRNIDE THE RESULTS OF FINAL CALCULATIONS ON THE FSV DOCKET e NRC STAFF FOLLCM P
- C09LETE D0EF90ENT C0WIWATORY CALCULATIONS (CRNL)
- EVIEW RESlLTS OF LICENSEE'S CONFIWATORY CALCULATIONS e SCEDULE
- TWO TO THREE WEElG DEP90 LNG ON WHEN LICENSEE PROVIDES CONFIRMATORY Iff0R% TION Y . - - .
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