ML20138M871
| ML20138M871 | |
| Person / Time | |
|---|---|
| Site: | Point Beach, Sequoyah, Pilgrim, Haddam Neck, Cook, 05000000, Shoreham |
| Issue date: | 10/25/1985 |
| From: | NRC COMMISSION (OCM) |
| To: | |
| References | |
| REF-10CFR9.7 NUDOCS 8511040460 | |
| Download: ML20138M871 (80) | |
Text
ORIGINAL.
UNITED STATES OF AMERICA
/
NUCLEAR REGULATORY COMMISSION In the matter of:
COMMISSION MEETING Discussion of Exemption Requests Environmental Qualification (Public Meeting)
Docket No.
Location:
Washington, D.
C.
Date:
Friday, October 25, 1985 Pages:
1 - 76 MN RILEY & ASSOCIATES Court Reporters 1625 I St., N.W.
Suite 921 9511040460 851025 Washington, D.C.
20006 10CFR (202) 293-3950 PDR
's 1
D I SCLA I M ER 2
3 4
5 6
This is an unofficial transcript of a meeting of the 7
United States Nuclear Regulatory Ccemission held on a
10/25/85 in the Commission's office at 1717 H Street, 9
N.W.,
Washington, D.C.
The meeting was open to public 10 attendance and observation.
This transcript has not been 11 reviewed, corrected, or edited, and it may contain 12 inaccuracies.
4 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 epinion in this transcript g
17 do not necessarily reflect final determination or beliefs.
No 18 pleading or other paper may be filed with the Commission in 19 any proceeding as the result of or addressed to any statement 20 or argument contained herein, except as the Commission may 21 authorire.
22 23 24 25
I 1
2 UNITED STATES OF AMERICA 3
NUCLEAR REGULATORY CCMMISSlON 4
5 DISCUSSION OF EXEMPTION REQUESTS o
ENVIRONMENTAL QUALIFICATION 7
8 PUBLIC MEETING 9
10 Nuclear Regulatory Commission 11 Room 1130 12 1717 "H'
- Street, N.W.
13 Washington, D.C.
14 13 Friday, October 26, 1983 16 17 The Commission met in open session, pursuant to 18 notice, at 10:03 o' clock a.m.,
NUNZIO J.
PALLADINO, Chairman 19 of the Commission, presiding.
20 CCMMISSIONERS PRESENT:
21 NUNZIO J.
PALLADINO, Chairman of the Commission 22 THOMAS M.
ROBERTS, Member of the Commission 23 JAMES X.
ASSELSTINE, Member of the Commission 24 FREDERICK M.
BERNTHAL, Member of the Ccumission 25 LANDO W.
- ZECH, JR.,
Member of the Commission
2 1
2 STAFF AND FHESENTERS SEATED AT COMMISSION TABLE:
3 4
S.
CHILK 5
M.
MALSCH e
W.
DIRCKS 7
H.
DENTON 8
C.
GRIMES 9
10 AUDIENCE SPEAKERS:
11 12 H.
CANUSO 13 D.
WIGGINTON 14 W.
SHIELDS 13 J.
ZWOLINSKI 16 B.
LaGHANGE 17 G.
KNIGHTON 18 M.
THADANI 19 H.
HERMANN 20 V.
POTAPOVS 21 22 23
- 24 25 l
l l
3 1
P R OC E E D I N G S 2
2 CHAIRMAN PALLADINO:
Good morning, ladies and 3
gentlemen.
Today we meet with members of the statt to discuss 4
the environmental qualifications of electrical equipment 5
important to safety for a number of specific plants.
o Section 50.49 of the Code of Federal Regulations 7
allow the director of the Ottice of Nuclear Reactor Regulation j
8 to grant extension for finalization of environmental 9
qualifications to a date no later than November 30, 1985 11 10 good cause is demonstrated.
11 Beyond this date the Commission itself may grant 12 extensions in exceptional cases.
I 13 By generic letter in early August licensees were i
14 advised of the Commission's intention to grant extensions only 15 in rare circumstances and that enforcement action will be 16 taken against licensees that continue to operate their plants 17 with unqualified equipment beyond November 30, 198b without 18 approved extensions.
19 Justifications for continued operation have to be 20 provided to the statt and extensions will have to be approved 21 by the Commission.
Fines may also be imposed.
However, the 22 generic letter indicated that some mitigation of any penalty 23 may be considered.
i 24 To date the statt has reviewed the licensees
- l 25 submittals and has provided recommendations to the Commission
4 l
1 regarding required extensions for nine plants.
Of these, two, i
2 Brunswick 2 and Nine Mile Point, the Commission has taken 3
action.
Tne remaining seven before us for discussion include 4
Shoreham, Sequoyah Units 1 and 2,
Palo Verde Units 1 and 2,
5 Haddam Neck, Point Beach Units 1 and 2,
D.C.
Cook Unit 2 and J
6 Pilgrim Unit 1.
l 7
The stati will summarize their basis for the 8
recommendations for each of these plants.
The objectives at 9
today*s meeting is to attord the Commission an opportunity to 10 obtain the information necessary for Commission decisions on 11 tne staff's recommendations.
12 No decisions are expected to be made at this j
13 meeting.
However, at the completion of today's meeting I urge 14 my fellow Commissioners to vote on the subject recommendations l
id as soon as possible.
j 16 During the presentation I would also appreciate 1
17 having the statt identity how many more exemption requests 18 remain to be addressed and for which plants.
le I have been informed that arrangements have been i
20 made for Region I to listen to the discussion by telephone.
21 Do any of my tellow Commissioners nave any additional J
i 22 opening remarks?
l 23 (No response.)
i 24 CHAIMMAN PALLADINO:
All right Then let me turn j
)
25 the meeting cver to Mr. Dircks.
5
)
5 1
MR.
DIMCKS; I think the way we are going to handle 2
it today is Mr.
Grimes is going to go down the Itst of the 4
j J
items on your agenda today and I think there are two more 4
plants that are coming in, Fort St.
Vrain and Millstone.
i 5
CHAIRMAN PALLADINO:
Will that complete the list?
o MR.
DIRCKS:
That will complete the list.
?
CHAIRMAN PALLADINO:
All right.
8 MR. GR:MES:
Good morning, gentlemen.
My name is 9
Chris Grimes and I am chief of the systematic evaluation 10 program branch and outside that responsibility I am acting as i
11 coordinator for the EO extension requests that were submitted 12 in response to generic letter Bb-15.
13 As you know, there were 11 extension requests 14 submitted by licensees presenting cases for exceptional i
15 conditions to request extensions to the 50.49tg) schedular i
16 requirement to complete environmental qualification of their i
]
17 equipment by November 30, 1985.
18 These 11 extension requests apply to 13 units.
They 19 requested anywhere trom one to 12 months of time to complete i
20 their environmental qualification.
In reviewing tnese 21 extension requests the statt all of the attected project 22 managers, the people who have been working on the equipment I
23 qualification reviews, got together collectively to review the 24 material presented by the Aicensees in order to try and make a 25 Judgment about whether or not they nad made a sutticient case t
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i 6
1 for exceptional circumstances.
2 We carefully considered the specific circumstances 3
associated with each particular licensee and the equipment 4
Involved for which they have requested the extensions.
5 We generally tried to determine the extent to which 6
the circumstances that the licensees presented were within the l
i 7
licensees
- control based on our knowledge and understanding of 8
the course of the equipment qualificatzons for each of the i
I 9
units involved.
10 As a result of those meetings the statt developed 11 the Commission papers which you have before you and we have 12 tried to describe the historical evolution for the particular 4
13 equipment involved, the circumstances that the licensee faced 14 in terms of achieving qualitication and responding to test 15 results and then we have developed a recommendation based on Ic wnat we felt were either exceptional or not exceptional I
l 17 circumstances and that is what is presented in those papers.
18 As a result of our ettorts to date we have forwarded i
19 Commission papers recommencing approval for six units and 20 denial for tour units.
21 On our recommendation for Pilgrim Unit I we 22 characterized it as a denial but noted that the licensee's 23 extension request may be premature because the actual need 24 will depend on test results that will come in between October 25 28 and November 22.
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If tnose tests are all successful the only tning i
t 3
2 that would be lacking for Filgrim 1 would be documentation to
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3 complete the program.
4 COMMISSIONER BERNTHAL:
Do we have that one?
COMMISSIONER ASSELSTINE:
Yes.
Keep digging, it is 6
there.
?
COMMISSIONER BEMNTHAL:
A11 right 8
MR. GkIMES:
We are continuing our revtew on 9
Millstone Unit 1 and Fort St.
V a.s a n.
The exceptional l
10 circumstances presented by Northeast Utilities for Millstone 11 Unit I were not amenable to the review approach tnat we were 12 trying to accomplish and so tnat one has taken longer than we i
13 anticipated.
4 l
14 For Fort St.
Vrain that is clearly a unique plant l
15 design and also other unique circumstances that need to be l
16 carefully weighed.
l 17 We expect to complete those reviews very snortly.
I 18 tnink we have indicated that we hope to have Fort St Vrain to 19 you by November 15 and I expect that Millstone Unit I will be 20 coming down early next week.
I 21 COMMISSIONER ZECH:
I was under the impression that 22 perhaps Hatch made a request.
Was I mistaken on that?
.i 23 MM. GRIMES:
So far as we have been able to determine 24 from telephone calls to each of the licensees., status reports i
j 25 coming in from the regions and the licensing contacts that we
]
1 1
_ ~,
i 8
I have, all of the plants except for these expect to achieve 2
qualification by November 30.
In the event that something 3
comes up between now and then related to those ettorts, it i
4 something happens before November 3U that would change the l
5 circumstances that they are ctrrently working under then there o
may be licensees who make later requests for extension based on l
7 those particular circumstances but we know of none right now.
3 COMMISSIONER ZECH:
Fine.
Tnank you.
9 MM.
DhNTON:
You may know something, C ontmi s s i o n e r,
10 that is ahead of us.
We haven *t focused on Hatch.
11 COMMISSIONER ZECH:
You haven't had a request from 12 them?
]
13 MR. DENTON:
Not that I am aware of i
14 COMMISSIONER ZECH:
- Fine, 15 MM. DENTON:
We have down today the project managers lo or their supervisors for each of the 11 plants that we intend 17 to discuss.
We had not planned to go into them in great le detail but I did want Chris perhaps to just walk through the
)
19 list and say a few words about each one but not-go into tne 20 details and then we would be prepared to discuss any of them 1
21 if you preter.
1 1
22 CHAIRMAN PALLADINO:
Have you completed what you 23 were going to say about Pilgrim?
24 MM.
GRIMES:
Yes.
25 CHAIRMAN PALLADINO.
You didn't mention their long
t i
9 1
deadline time.
2 MM. GRIMES:
I am sorry.
For both Pilgrim and 3
Sequoyah we presented our recommendation with a schedular 4
caveat.
In Pilgrim *s case I have explained it.
We think that 1
5 they are premature and we characterized it as a denial 6
primarily because we did not think the utility was being i
f 7
responsive in asking for a blanket extension for a year in 8
order to complete the qualification.
]
9 We recommend that limited extensions may be 10 appropriate depending on the results of these tests and so we 11 are suggesting the Commission later consider once the test 12 results are in --
13 CHAIRMAN PALLADINO:
Later consider what?
14 MR. GRIMES:
Later consider once the test results 4
15 are in some limited extensions for Pilgrim depending on those 16 test results.
17 MR. DENTON:
I think we were trying to indicate a 18 denial based on what they have proposed.
19 COMMISSIONER ASSELSTINE:
Correct.
20 MR. DENTON:
Which is a limited extension but l
21 indicate a willingness to reconsider when the test results are 22 available in case they are encouraging.
23 Eut based on the record we would recommend a denial.
24 COMMISSIONER BEMNTHAL:
Shoreham is in a somewhat i
25 similar situation.
10 1
MR. GRIMES:
Yes.
Shoreham is in a similar situation 2
depending on the test results for their hydrogen recombiner 3
panels.
They could be in compliance by the end of December and 4
that is what we recommended that the Commission approve.
5 Both Shoreham and Palo Verde are in a similar 6
circumstance having relied on Rockwell to achieve qualification 7
tor their recombiner system as a whole and they are now l
8 awaiting test results to demonstrate conformance with the 1
9 environmental qualification requirements.
10 COMMISSIONER BERNTHAL:
Since Shoreham at least now 11 has no immediate prospect of running at a b.J V e tiVe percent 12 power anyway, is it essential or appropriate for the Commission 13 to take action on that issue in any case betore December 31st?
I i
14 MR. GRIMES:
We believe that we should take action 15 on Shoreham simply to maintain the license that they have now 16 tor five percent.
17 COMMISSIONER BERNTHAL:
I see, yes.
18 MR. GRIMES:
Absent that, they would have a tive 19 percent license and would be in violation with the regulations.
20 COMMISSIONER BERNTHAL.
I see.
All right Thank 21 you.
22 CHAIRMAN PALLADINO:
What was the Shoreham date to 23 which they wanted an extension?
24 MR.
GRIMES:
They requested an extension to November l
25 30, 1980.
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I COMM I S S I ON k:.R ASSELSTINE:
It is another one of those 2
long ones.
4 3
CHAIRMAN PALLADINO:
You say approve extension 4
through when?
5 MR. GRIMES:
Through December 31, 1985.
o CHAIRMAN PALLADINO:
What will that enable them to
?
Co?
8 MM.
GRIMES:
It the test results fail it is going to 9
force the licensee to react rather quickly, to take action to J
10 either obtain alternate equipment or to take some other o
11 immediate action in order to establish qualitication.
12 They have already purchased the equipment so they l
13 elected 14 COMMISSIONER ASSELSTINE:
They are doing that right i
15 now, aren't they?
Io MR. GRIMES:
Yes.
Tney are putting it in during an 17 outage that is occurring right now.
So they have already 18 committed themselves on the basis of the test coming out 19 tavorable.
20 So on that basis we recommend that they be granted 21 an extension for that time that it would take for them to pull 22 the documentation necessary to complete the record.
23 CHAIRMAN PALLADINO:
Jim, did you have some other 24
' questions you were going to bring up?
i 25 COMMISSIONER ASSELSTINE:
That's okay.
If they want
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12 1
to go through the list first, then yes, I have a bunch of l
2 questions but they can go through the list first 3
MR. CARUSO:
Excuse me, I am Ralph Caruso.
I am the l;
]
4 Shoreham project manager and I wanted to update one thing that l
5 Mr. Grimes might not know.
The Shoreham hydrogen recombiners
]
6 have passed the equipment qualification test We just received 7
that word verbally in the last day or so.
9 So right now it is just a matter of completing the i
9 documentation and the licensee expects to be able to do that 10 by the end of this year, by December 31, 1985.
John Leonard, 11 the LILCO vice-president is here to answer any questions you
)
12 may have about that documentation completion or about wnether 13 the plant really needs the extension until that particular i
l 14 time.
15 CHAIRMAN PALLADINO:
Our plan today was to hear from 1
16 NMR and 11 there are requests for appeals we might consider 17 those later.
i 18 MR. GRIMES:
All right.
I will go down each of the i,
19 extension requests and try to characterize each of the cases 20 as we viewed them in developing a statt recommendation.
I had 21 planned on not speaking about Nine Mile Point or Brunswick i
22 unless you have any particular questions on those two cases 23 because they have been previously addressed to the Commisston.
24 Going through the other ones, on D.C.
Cook Unit 2,
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25 the licensee originally requested an extension on five items i
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that included 50 individual pieces ot equipment and upon i
2 reviewing the licensee's submittal and trying to determine the l
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acceptability of changes in the justifications for continued i
4 operation the licensee subsequently revised his extension 5
request to eliminate one item which constituted 43 pieces of o
equipment.
i
?
Based on that revision to their extension request i
4 8
and the circumstances associated with their attempts to try to 4
9 quality three types of cables and the limited number now 10 required ter the extensions, we concluded tnat the licensee's 11 extension request for a three month period should be approved.
I 12 We feel that the circumstances associated with their 4
13 etterts to demonstrate qualification for submergence were not i
1 l
14 completely within their control a
a 1
15 On Haddam Neck the licensee had requested an 1
I 4
i lo extension until January 4,
1996 for 14 motor operated valves 4
17 and 20 resistance temperature detectors.
In earlier times 18 they had attempted to address those issues as a part of ISAP.
19 In parallel the licensee has already procured the equipment, l
4 20 has it ready to install and were it except for a reactor
-l 21 cavity seal failure at their last refueling outage their i
j 22 planned outage would have occurred before November JO and they i
J 23 would have achieved qualification.
24 COMMISSIONER BdMNTHAL:
Maybe Just a procedural
(
25 question nere.
Are we planning to go through on a bullet by
14 1
bullet with a briet summary and then come back to these in 2
detail?
It seems to me that a better way to go at this may be 3
to plant-by-plant and have everybody ask questions on one 4
plant because it we try to go back and each of us go through 5
every plant separately with a series of questions, we are o
going to have great disconnect At least, that is my view-7 CHAIRMAN PALLADINO.
I agree with you.
I thought 8
that is wnat we were coing.
9 COMMISSIONER ELRNTHAL:
It sounds good to me 10 CHAIRMAN PALLADINO:
Why don't we agree at each 11 plant to stop and solicit Commission questions.
12 MR.
GRIMES:
All right Then I will go back to l '3 D
C.
Cook Unit 2.
14 COMMISSIONER ASdELSTINE.
All right Tnat is a good 15 one to start with.
16 CHAIRMAN PALLADINO:
All right You are asking ter 17 Commissioner questions.
18 Now your proposal is to grant them an extension to 19 2/28/86, is that correct?
20 MR. GRIMES:
Tnat is correct 21 CHAIRMAN PALLADINO:
Any Commission questions on 22 D.C.
Cook'3 23 COMMISSIONER ASSELSTINE.
I had a few.
One question 24 I had, could you expand a little bit on how -- it struck me in 25 contrast with some of the other plants, for example, Point
4 s
e 4
i 13 1
Beach. that the equipment that is involved here was fairly l
2 significant That is, the functions that are performed by the 3
equipment these cables are involved with were fairly 4
significant.
5 In each instance, could you describe precisely how l
l i
6 they intend to accomplish the safety function without relying
?
at all on these cables or the equipment connected to these 8
cables?
j I
j 9
MR. GRIMES:
I will give you a general answer and I
10 then I will ask Dave Wigginton, the project manager, for 11 D.C.
Cook to provide more specifics, i
12 COMMISSIONER ASSELSTINE:
Great i
13 MR. GRIMES:
All of these cables involve 1
?
4 j
14 instrumentation that the operator would use to respond to an i
i 15 accident.
The licensees developed temporary procedures to i
16 instruct the operators on how to recognize that this equipment t
17 is not qualified and therefore is undependable in the event of l
I 18 an accident creating the environment which could potentially
)
i l
i 19 damage the equipment and they are relying on those temporary i
1 I
20 procedures until the outage three months from now at wnich l
21 time they will relocate all of the cables for this l
22 instrumentation so that they will be within the envelope for I
i 23 which they are now qualified.
24 Do you want any more detail in terms of the i
25 procedures?
i l
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i j
16 I
1 COMMISSIONER ASSELSTINE:
In each one of them, i
l 2
please.
I guess what I would like is an understanding first i
3 o f.
the safety function that each of the sets at instrumentation
)
4 provide and how they are providing a clear indication to the l
l operators of that condition without relying on that equipment.
f
]
6 MR. WIGGINTON:
My name is David Wigginton.
I am i
i 7
tne project manager for D.C.
Cook.
The first item deals with j
8 the hot and cold leg resistance temperature detectors.
The l
9 cold leg detectors and two at the hot leg detectors are i
j 10 attected by these cables being routed under the flood up area.
J 1
11 For the qualification to be in question you must i
f 12 first have the lar2e break LOCA or some accident where you 1
4 j
13 wi11 ilood up inside the containment.
Ii you get to that i
14 point the resistance temperature detectors are used to keep 4
j t
15 track of the temperature conditions in the reactor itselt 1
1 i
16 With two of the hot legs available and with the i
i 17 pressure in the steam generators known, you can use the I
l 1 53 saturation tables to determine the average temperature in the 1
i 19 steam generators.
This gives you the average temperature in j
20 the loops and from that you can get the cold leg temperature i
j 21 of at least two of the tour loops That is sutti:ient for us t
22 to be able to determine the conditions in the reactor as far i
i 23 as the temperature is concerned, i
24 COMMISSIONER ASSELSTINE.
A11 r1 2ht.
But it wi11
)
1 25 involve manual calculations using the saturation tables i
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1 MR. WIGGINTON:
Yes.
2 COMMISSIONER ASSELSTINE:
a11 right 4
3 MR. WIGGINTON:
That would be involved also somewhere 4
tairly well down into an accident at some time.
3 COMMISSIONEH ASSELSTINE:
All right 0
MR. WIGGINTON:
As far as the narrow range steam l
7 generator level transmitters are concerned, the function here 1
H is to keep track obviously of the level in the steam generators J
i l
9 to know wnether or not you are getting enough flow to the steam i
10 generators to maintain your decay heat removal capability.
t 11 Again the flow transmitters on the aux teedwater 12 system will still be available to determine and from j
13 calculations whether you are maintaining level or that sort of 14 thing in the steam generators so that you are maintaining your j
15 decay heat removal capability.
i 4
l lo COMMISSIONER ASSELSTINE:
All right.
I 17 MR. WIGGINTON:
You also use the temperature f
18 detectors that are remaining in the loop to determine whether l
19 or not your decay helt is decreasing within the reactor.
So 20 these things all are used.
There are other means that they I
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21 could use that get into additional instrumentation and that i
i 22 stuti to continue backing that up.
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4 23 Those would be the primary means to keep track of i
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25 The third item is the high range area radiation t
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monitor.
The qualification problem there is also the same 2
that the cables are routed below the flood up level Sometime i
3 after an accident of the nature they are talking about the i
l 4
qualification there would be questionable.
4 5
There are several things that Cook could do in order 6
to make up this.
The primary one that they have come to use 7
is a sample line att the HHH system.
If yoit have a flood up l
t j
8 level that high, ycu are going to be on HHH tor your decay i
9 heat pretty quickly.
10 So they would use a sample line then to draw liquid i
l 11 samples and from this go through calculations again in order 12 to determine the radiation inside the containment as well i
i 13 I
- t. ink they are also taking a look at adding some i
i 14 monitors outside containment which would also be able to back l
15 up the sample line on the HHR.
I f
16 They obviously would have the post accident sampling L
17 system but as it turns out that is not qualified to the same i
18 environmental qualification standard and was not required to 19 be as a result of the NUMEG-737.
20 COMMISSIONER ASSELSTINE.
When you add these three i
j 21 things together, is this a manageable burden if you had an
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t 22 accident that involved the flooding in these particular l
23 araas?
Adding the three elements together, is that a 24 manageable burden that the operators can handle in terms of I
25 the additional work, the additional calcul'ations, the use of i
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additional equipment that they would have to rely upon?
4 i
2 MR. WIGGINTON:
We believe so.
At the time for an 3
accident, a worse case accident, and flood up to that level 4
inside containment you are going to be away from the immediate 4
j 5
action stuff that is required for that kind of an accident and i
6 you will be into the long term cooling decay heat removal and i
?
that sort of thing.
J I'
8 So it should not be a burden to the operators to be 9
able to carry out t,h e s e functions at all at that point.
I
]
10 COMMISSIONER A S S E i,S T I M E :
When did the 1icensee 11 identity each of the problems?
I notice that at least one ct 12 them is identified in the letter as having been identified i
13 this past summer.
l 14 MM. WIGGINTON:
Hight.
This is a combination i
I 15 problem here.
They knew that they had to have the t
16 qualitication on all of these items.
However, they qualified i
17 them to an environment where the transmitters and the 18 containment penetrations were located assuming of course 19 that the cable ran directly tror the transmitter to the i
1 20 penetration.
f 4
j 21 But in May ct 1984 they determined that items one 22 and three, that is the RTD's and the high area monitor was l
23 routed below the flood up level.
So the qualification required i
.4 there was a sequential water and radiation and they did not I
I i
25 have the data for that particular situation.
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1 So they notitied us a m o r. t h later on June 12th that 2
they had the problem.
Then when they went through to determine 3
what kind et program that they could get to solve this, they i
4 either a test program which they could run which would take
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i 5
some period of time and something we think is preferable to 1
I l
6 relocate the cables and not have that problem at all and not I
i 7
have to rely on qualification tests at all i
B So when they made that decision, the decision came t
9 after the July 1984 start-up but to relocate would have to
'i 10 wait until the next outage of sufficient duration or refueling 11 which they had planned to do.
12 On the second item wnich was the narrow range steam 13 generator level indication, they found this problem in the 14 spring of 1985 when they were reviewing some of the 15 documentation, going back over their documentation, to make f
16 sure they had everything.
They notified us on June 28, 1983.
17 Again the solution there was the same as with the 18 others.
It would require a shut-down of sutticient duration.
19 COMMISSIONER BhMNTHAL:
It I could interject a broad 3
i j
t 20 question here, I guess it is not clear to me wnether there is 21 a parallel or a non-parallel between this case and the 22 Brunswick case.
There are obviously many non-parallels but it 23 seems like the essence of the argument rests on the fuel 24 outage not being appropriately timed to complete their i
25 environmental qualitication work.
. - ~
_ _ - - _ _. _ _ _ _ - _ = _...
1 i
1 21 i
{
1 Could you convince me why this is a valid argument i
2 here and was not in the other case?
j 3
MR. GRIMES:
I would like to make the general 4
4 observation that the distinction that we saw in a number of i
5 these cases where the licensees have proposed
- o go to the 6
refueling outage was where they have had opportunities during t
t 7
unscheduled shut-downs to quality equipment.
B When they have done so, we view that as a diligence 1
9 tnat was lacking in the case at Brunswick whe*e they simply 10 would hold it.
11 In this case, in D.C.
Cook *s case, wnen they had to 12 shut down 1or steam generator tube leaks, they made eiiorts to I
13 achieve qualification and that has reduced the number of items 1
i 14 involved and they have also committed that should an 15 unscheduled shutdown occur of sutticient duration to do this, 4
16 they would do it at that time, i
i
~
17 So we saw a larger commitment on the part of i
18 D.C. Cook and some of the other licensees that we saw in i
l 19 Brunswick *s case.
i 1
20 COMMISSIONER ASSELSTINE.
They had three unscheduled i
21 outages because of steam generator tube leaks, Why didn*t 22 they do the cabling work $
23 MM. WlGGINTON:
The steam generator outages, none of j
24 them were planned to be as long as it wound up being and 1
25 obviously the three items left will take about six weeks to i
.~.-
. _ _ -. - - -. _ _ _. ~..
22 1
complete once they are down.
i 2
Unit I was down for a ten-year outage.
Unit 2 was 3
down with the steam generator problems, They also had the
}
4 problem of the number of people that are available to be able 5
to do the work.
I would imagine that tney probably had some l
6 problem with the exposure limits on quite a few of those i
t 1
7 people.
f 8
MR.
DENTON:
We don't want to be on the side of 9
making excuses for why they didn't do it and we haven't had a
}
}
10 lot of experience in interpreting your criterion for 11 exceptional and rare cases.
What we did was try to make a t
j 12 preliminary call hased on the facts and describe the facts but l
13 we assumed that 11 you wanted no extensions beyond that you i
14 would have said so.
So we didn't assume you wanted none.
We
.1 15 have just tried to call them in between and so when we talk 16 about distinctions we are otten talking about pretty fine I
i 17 distinctions within this 12 or 13 plants because we are up to 18 90 percent of all the plants met the date to began with.
i j
19 So we have searched ourselves to try to find the I.
20 difference between Brunswick and Cook and Nine Mile and i
}
21 provided that information to you.
f 22 I think we all would have preferred that they all t
j 23 met the deadline obviously.
I 24 COMMISSIONER ASSELSTINE:
That is a valid point, 25 Harold, but 1 think at the same time it is still worth asking i
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23 i
I as Chris said were there opportunities during time period from 1
2 when they discovered the problem and decided what change to 3
make until the present time.
Were there opportunities to do f
4 the work?
I think that is what I was interested in 1;
{
understanding.
{
6 MR. WIGGINTON:
No.
There were no shutdowns irom I
?
the time they determined what they were going to do until they j
d got to the steam generator outages.
.I 9
COMMISSIONER ASSELSTINE:
That*s right.
How 1ong f
10 were each of the steam generator outages?
We have the starting J
11 dates here.
12 MM. WIGGINTON:
they were very short.
The first two i
j 13 were very short because they only plugged just a few tubes in l
4 14 each one of those.
4 5
)
15 MR. DENTON:
I don't want to appear argumentative i
1 l
16 but any of these plants could meet the criterion if you so 17 desired because they could
- a. l l shut down today and put it in.
i 18 COMMISSIONER ASSELSTINE:
Yes.
19 MR.
DENTON:
So it is trying to reconstruct their 20 reasons to see it it appeared valid.
I guess here we thought I
l 21 they did make a good faith ettort to use the outages they had d
22 whereas in Brunswick, they appeared to have decided a priori J
l 23 to deter everything to a later outage.
24 Dave, did you complete your statement?
25 MR. WIGGINTON.
Yes.
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24 1
COMMISSIONER EbHNTHAL:
The Commission may end up i
2 being skewered on its own words here but I noticed that our 3
criteria were somewhat different from what you stated in a 4
number of your SECY papers here.
2 3
COMMISSIONER ASSELSTINE.
Tnat's right i
6 COMMISSIONER BERNTHAL:
I think ours read events l
?
entirely beyond its control and in several cases you say that i
8 the events were not entirely within the control i
9 COMMISSIONER ASSELSTINE:
that's right.
10 MR. DENTON:
We had trouble, I think, trankly with I
]
11
- entirely beyond the licensee's control.'
In theory nothing j
12 I guess is entirely beyond his control because he still has an i
13 opportunity to meet that date.
He doesn't have to operate 4
14 beyond that date.
I don't know wnether our legal advisor here 15 would like to comment on how we tried to interpret that 16 standard.
i l
t
^
17 MR.
SHIELDS:
I would point out that that portion of 18 the generic letter, that was following an
'e.g.",
a for i
19 example and that was in fact the only criteria that really 20 appears in the generic letter by way of an example.
i 21 It is very ditticult to apply legal criteria when 22 the only one you are really given is an "e
g.'
23 COMMISSIONER BERNTHAL:
I agree.
In iact, it is not i
1 24 worth quibbling over the words, I guess.
It is not clear 11 25 you read the plain words whether that means each event ei trely I
m 25 1
beyond the control or events generally speaking some of which i
2 were entirely or one el which was entirely beyond the control l
3 4
So there is some room for interpretation.
I just 5
noted the difference.
6 CHAIRMAN PALLADINO.
All right Any more questions?
7 COMMISSIONER ASSELSTINE:
Just a couple more.
9 Going back to the three cable problems, you say they I
9 discovered items one and three in May of 1984 and I assume i
10 June of 1985.
Is it because they basically had assumed that 11 the cabling ran directly to the equipment, between the 12 equipment and the penetration?
13 MR. WIGGINTON:
That is our understanding.
r 14 COMMISSIONhH ASSELSTINE:
Is it the hallmark -- I 15 mean are you comfortable with the approach that they took?
16 Was it a good faith effort to understand and identify the EQ i
17 problem that they had, that they simply assumed that the 18 cables ran straight without looking at the plant to see where i,
19 the cables ran and are you comfortable with the fact that they l
20 didn't identify these things until 1984 and 1983?
Should they 21 have identified them earlier?
22 If they had an effective program back in 1982 and i
23 1983, should they have identified these problems much earlier 24 such that they could have been resolved and corrected during i
25 the 1984 outage?
}
i j
20 4
1 MM.
WlGGINTON:
Within the statt we have nad some i
2 oiscussions along that line and we feel that it is nice now to i
3 be able to look back and say they should have done it.
It 4
they had done it right, they should have done it But then we f
5 look back in 1983 when we were meeting with them and quite e
trankly we didn't do it either.
7 So it is sort of a tailings on everybody's part.
It t
8 appears that we possibly did not include that as an item 9
although in 1983 I am sure we would have told them that we did
-i 10 mean for them to include that.
1 j
11 I guess it is very easy for us to look back and say, I
j 12 "Yes, they should have caught it and they should have been a
13 diligent about looking for it.*
Then we could also look back i
i 14 and say that we are thankful that they did find it when they 15 did and did notify us.
9 16 The other_ point to be made is that the tix that they 17 are proposing to do is one that we would agree with.
We would i,
l 18 agree to pull those things up above the flood up level That 1
19 will require an outage i
20 ME. GRIMES:
Commissioner Asselstine, I would also 21 like to make a general observation.
The fact that the program 22 during the course of implementation identified the problem we 23 think is a measure of the ettectiveness of the program.
You 24 can't expect a program of this magnitude to instantaneously 25 define the scope of tne ettort that yo have.
i l
.u.
27 1
In making these judgments about whether or not the 2
Itcensee*s.were being effective in their process we looked for 3
reaction in an ongoing or continuing ettort as opposed to 4
point in time statuses.
5 If it had turned out that the process had been o
turned around so that they looked at it in a different way, 7
they could have identified it earlier or later.
It was just a 6
matter of the way that their program ended up being I
9 implemented, they discovered it at a given point in time.
10 They reacted at that time and we telt that that was a good 11 taith ettort 12 Certainly in any of these cases we apply hindsight 13 and say that the licensee made a wrong decision and that is t
i 14 wnat got him into this problem.
It we want to entorce that, 15 then we would have recommended denial on all of these.
J 16 COMMISSIONEW ASSELSTINE:
Yes.
I guess the concern
)
17 or the question that I have when I read the ditterent ones of 18 these and let me contrast this one, for example, with Point 19
- Beach, i
,20 The impression I get from reading your analysis of 21 Point Eeach is that the licensee had a diligent program right l
22 from the start, was aggressive, kept you informed all the way 23 along the process and then you have the item left over at the 24 end which despite really good faith and best efforts on their 25 part remains.
28 q
1 I don't have any trouble with that one at all The i
j 2
sense I had from this a little bit giving the wording was that 4
3 in the case of D.C.
Cook you had much more of an evolving 4
program.
It wasn't everything that you wanted it to be to i
5 start be.
It began to get better.
Clearly when they i
6 identified the problems in 1984 and 1985 you are pretty 7
ccmiortable with the follow-up tnat they took on them after e
that and you think that they have been fairly aggressive since 9
that point in time.
10 What I am trying to decide is wnether that 11 characterization is accurate and then how to weigh that in the 12 balance of whether this is truly an extraordinary case a
13 justifying an extension or not.
14 MR. DENTON:
I think the two that we have brought to 15 you first bracketed all the others, a
16 COMMISSIONER ASSELSTINE:
Yes, that is right 17 MR. DENTON:
That was partially to get guidance from 18 the Commission on which side and one was quite easily handled.
19 Brunswick was a difficult one.
I think you will find all these i
20 tall between Nine Mi.le Point and Brunswick.
21 You will find every one of these is on a continuum l
22 somewhere at least in our view between those two cases.
We 23 have tried to push some one way and push some another way.
i
'4 CHAIRMAN PALLADINO:
Let me make an observation.
l i
OS This is a matter of udgment in many cases and I appreciate
I, 29 1
your trying to understand the basis for their recommendation.
i i'
2 I think we also need to look at the amount of 1
3 extension and use also the number ci items as an indication of i
j 4
how diligent they have been as well 5
The other observation I wanted to make is it we 4
O spend this long on each one, we are going to be here quite a 7
number of hours.
8 I am not trying to thwart questions but asking when
- l_
9 you reach a point where you have as much information as it 10 appears we are going to get, we probably ought to go on.
4 11 COMMISSIONER BERNTHAL:
I would just say that in my 12 judgment tne objective for me at least here is to get a broad 1
13 sense now and the Commission has already decided on the two 14 poles here and for me to get a broad sense now of how that 15 rule or how the staff's interpretation of the Commission's i
le decision on those two cases is being applied here.
j 17 Unless there is some pretty convincing evidence or l
18 flaw that surprises the staff perhaps as much as me that shows 19 up here, I am inclined to accept the stat 1*s judgment on most 20 of these things because they clearly have been much closer to 21 each individual case and everything from the personalities 22 involved to the objective evaluation of the hardware than any i
4 23 of us possibly could have been.
24 On a broad glance it looks to me like there has been 25 a fairly eran handed approach here but I am interested in
= -
_=-.
29 i
1 your trying to uncerstand the basis for their recommendation.
1 i
2 I think we also need to look at the amount of 3
extension and use also the number of items as an indication at 4
how diligent they have been as well 5
The other observation I wanted to make is it we o
spend this long on each one, we are going to be here quite a 7
number of hours.
8 I am not trying to thwart questions but asking when 9
you reach a point where you have as much information as it 10 appears we are going to get, we probably ought to go on.
j 11 COMMISSIONER BERNTHAL:
I would just say that in my 12 Judgment tne objective for me at least here is to get a broad 13 sense now and the Commission has already decided on the two 14 poles here and for me to get a broad sense now ci how that 15 rule or how the stafi's interpretation of the Conun i s s i o n ' s 10 decision on those two cases is being applied here.
17 Unless there is some pretty convincing evidence or r
4 18 tlaw that surprises the staff perhaps as much as me that shows i
19 up here, I am inclined to accept the staff's judgment on most 20 of these things because they clearly have been much closer to 21 each individual case and everything from the personalities 22 involved to the objective evaluation of the hardware than any 23 of us possibly could have been.
4 24 On a broad glance it looks to me like there has been 25 a fairly even handed approach here but I am interested in
29 1
your trying to understand the basis for their recommendation.
1 2
I think we also need to look at the amount-of j
3 extension and use also the number of items as an indication of 1
4 how diligent they have been as well l
5 The other observation I wanted to make is it we i
6 spend this long on each one, we are going to be here quite a
?
number of hours.
l 8
I am not trying to thwart questions but asking when 9
you reach a point where you have as much information as it 10 appears we are going to get, we probably ought to go on.
11 COMMISSIONEM B E k( N T H A L :
I would just say that in my 12 Judgment the objective for me at least here is to get a broad 1
13 sense now and the Commission has already decided on the two 1
1 14 poles here and for me to get a broad sense now of how that i
15 rule or how the stati's interpretation of the Conuni s s i on ' s i,
i 16 decision on those two cases is being applied here.
i 17 Unless there is some pretty convincing evidence or
(
l 18 flaw that surprises the staff perhaps as much as me that shows I
1 19 up here, I am inclined to accept the stait*s judgment on most I
i 20 ci these things because they clearly have been much closer to i
21 each individual case and everything from the personalities 4
22 involved to the objective evaluation of the hardware than any j
23 of us possibly could have been.
3 f
24 On a broad glance it looks'to me like there has been f
26 a 1airly even handed approach here but I am interested in
29 1
your trying to understand the basis for their recommendation.
2 I think we also need to look at the amount of 3
extension and use also the number of items as an indication of 4
how' diligent they have been as well.
5 The other observation I wanted to make is it we 6
spend this long on each one, we are going to be here quite a
?
number of hours.
8 I am not trying to thwart questions but asking when I
9 you reach a point where you have as much information as it 10 appears we are going to get, we probably ought to go on.
i 11 COMMISSIONER BERNTHAL:
I would just say that in my 12 judgment the objective for me at least here is to get a broad 13 sense now and the Commission has already decided on the two 14 poles here and for me to get a broad sense now of how that 15 rule or how the statt's interpretation of the Commission's I
16 decision on those two cases is being applied here.'
17 Unless there is some pretty convincing evidence or 18 flaw that surprises the stati perhaps as much as me that shows 19 up here, I am inclined to accept the statt*s judgment on most 20 of these things because they clearly have been much closer to i
l 21 each individual case and everything from the personalities 22 involved to the objective evaluation of the hardware than any 23 of us possibly could have been.
24 On a broad glance it looks to me like there has been 25 a fairly even handed approach here but I am interested in f
i y
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30 1
having some specific questions answered yet on one or two.
2 CHAIRMAN PALLADINO:
All right.
Anything further on 3
D.C.
Cook?
4 COMMISSIONER ZECH:
Frankly, I wasn t sure that we 5
needed this meeting at one time but as I received the packages 6
it became clear to me that there were a number of questions 7
and I don't know it this meeting is the right forum but as far 8
as I am concerned I need more information on the things that i
9 they have sent us.
I do.
a 10 What I am saying is that I am trying to put together 11 each one of these things you send me in kind of a package like 12 this and the SECY letter is important, of course, your 13 recommendation but also the references are important I am 14 trying to dig them out.
Some of them I am digging out from 1
15 the daily stait notes and things like that but all the 16 references that you use even the letter requesting the 17 exemption is important.
18 I trankly had a hard time pulling them together.
So 19 what I am requesting is that the staff work that you send us 20 perhaps be a little more complete.
It will be easier to dig 21 into it and you have all that information and it is certainly 22 available but gathering it together has been rather ditticult.
23 As I say, I am trying to have my people put together 24 for me a package like this so it highlights the thing.
So 25 frankly I have a number at questions and I don't know it we
31 i
1 can answer them all here today.
2 CHAIRMAN PALLADINO:
Could you give us an example or 3
two of some of the questions you have?
4 COMMISSIONER ZECH:
Here as we go into each plant I J
)
5 could go over and talk about the questions.
D.C.
Cook is 6
frankly the only one I haven't gotten to of the seven in great 7
detail.
But the others I can tell you all kinds of things I 8
have here.
9 CHAIRMAN PALLADINO:
Well, when we come to them you 10 have an opportunity.
I 11 COMMISSIONER ZECH:
We can try it but as I say, it 12 may take all day and I con't know that that is really the best 13 use of our time.
But there are questions and I could submit 14 tnem in writing or we could talk about it today.
I 15 CHAIRMAN PALLADINO:
I was going to suggest identify 16 the nature of a few as we go through.
17 COMMISSIONER ZECH:
But it would be helpful, too, 11 18 you could send out the materials, 19 CHAIRMAN PALLADINO:
Unfortunately, we are working 20 under a time constraint.
l 21 COMMISSIONER ZECH:
I know that and I think the
)
22 staff has done an excellent job frankly in a very unique and 23 important matter.
I don't mean to be critical I am just 24 trying to say that it would be very helpful for me to have a I
26 completed package so that when I go through I could follow I
s j
e i
1 32 1
your reasoning and your judgment perhaps a little bit easier 2
than I have been able to do so far.
3 COMMISSIONER ASSELSTINE:
I would second that 4
comment.
- 1. a n d o.
Before i had gone out of town I had sent a list of items that I thought ought to be reflected in the 6
paper.
I
?
I was somewhat disturbed that Bill sent back a memo J
B saying that we just can't get this information, we don't have 9
it even after five years of working on this problem and it is 10 going to delay the process along while to get it.
11 I have to say that I am pleased to see the most 12 recent papers that we got because it appears that a lot of i
13 that information has been tolded into the more recent papers.
14 I think that they are a step ahead of the couple of early ones 1
15 that we had and I appreciate the efforts that the statt has 16 made to dig out some more of that information.
17 Some of that i s still missing.
Joe, as you said,
]
18 one of the things that was of concern to you was how long the 19 extension request was for and how does this tall in the total 20 universe of equipment.
21 How much equipment did they have to quality and how 22 much is left over after all of their ettorts?
Looking at the i
[
23 D.C.
Cook one, for example, the total number of equipment, the 24 items that they had to quality I didn't find in there although j
25 the number that they are left with is in there.
l n-.
ne.
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. ~ ~ ~ - - - - ~
33 1
I think the statt has made an effort to provide some 2
additional information and I appreciate that but I would agree 3
with Commissioner 2ech that there are still a few gaps.
4 CHAIRMAN PALLADINO:
I would like to remind you why 1
5 we are going through this exercise.
We are not going through this exercise to find who we want to punish or who we don *t 7
want to punish.
We are going through this exercise to get the 8
equipment qualified.
9 We have to put a cut-ott date.
Otherwise, we are 10 never sure that there is a program that is going to bring l
11 about the qualification.
12 We put the cut-ett date to encourage people and 13 urge the people and make the people go do something.
Now 11 14 they failed, we say, "Well, was it because they were diligent 15 or was it because they were not diligent?"
16 COMMISSIONER ASSELSTINE:
that*s right t
i 17 CHAIRMAN PALLADINO:
We are trying to make a 18 judgment.
We are not trying to make such a close call that we 19 don't get the motivation that needs to be gotten.
I would 20 suggest that maybe some of the answers we desire aren*t as 21 necessary as they first appear.
22 Each one has to make his own judgment on it.
But i
23 keep in mind what we are trying to do by this whole process is 24 to get the equipment qualified, get it qualified soon and 25 avoid the kind of situation that we have had in the case of I
l
_..., _ _ _. _ _ _. - _.. _ -. _ _ _ _ _ _ _ ~ _ _ _ _, _ _ _, _,. -. _ _ - - _
I 4
r 34 1
Appendix R.
2 With that, I am not sure how many cases we have 3
covered so far.
I put a dot at D.C.
Cook now.
Actually I put i
4 it earlier.
5 COMMISSIONER ASSELSTINE:
I think we have covered 6
one.
7 CHAIRMAN PALLADINO:
I am going to suggest that we a
8 close D.C.
Cook and go on to another case.
9 COMMISSIONER BEENTHAL:
I just want to make a 10 comment that it sounds like we are going to have two different 11 philosophies on this thing because in my own judgment I am at 12 this meeting and I am sampling what the statt has done to give 13 them policy guidance.
i 14 Neither I nor my stati are going to try to get 15 behind every piece of equipment and every decision the statt 16 has made on a matter like this.
I don't intend to do that.
I 17 am going to go through.
i 18 We have seen pretty much the two extremes.
I have 19 some questions as well but I consider myself an auditor on 20 this thing and as long as the broad policy guidance is 21 understood, it seems to me for example on D.C.
Cook, I don *t l
22 know what those cables are and whether they can be qualified 23 or not but it seems to me that broadly speaking that statt has 24 made a reasonable call there.
25 Let's get on with it.
But I seem to have a rather
- - - - - - - - - - ~
35 1
ditterent perspective on this, I guess, than one or two of my i
2 colleagues.
3 COMMISSIONER ZECH:
Ii I may say, you have a 4
ditterent perspective than I have.
5 COMMISSIONER ASSELSTINE:
Yes.
I 6
COMMISSIONER ZECH:
I think it is important and I
?
respect what the statt has done.
I think I have tried to home 8
in on my review of what they have given me on the key things 9
tnat aren't done yet.
I think it is important.
1 10 We are involved in very important decisions as to 11 whether we need in scme cases perhaps shut a plant down or 12 not.
That is a very important decision.
I think we have to 13 get into that and dig in with the statt and try to understand 1
14 exactly what we are doing it we come to that decision.
15 So I think it is important that we dig into these 16 things, at least I want to anyway from my standpoint, before I 17 make a judgment.
I really want to feel reasonably confident 18 that I am doing the right thing as well as respecting the 19 stati's judgment.
20 So I really intend to look at these in some detail 21 At least I am going to make the ettort to do that.
4 22 COMMISSIONEW ASSELSTINE:
I agree with that.
I 23 CHAIRMAN PALLADINO:
Let me also point out that we 24 generated the dates.
We imposed the time constraints.
We are 25 the ones that want to see equipment qualification done.
We
- - - ~
O 36 1
are the ones that ought to try to meet our end of the bargain 2
with regard to the dates.
4 3
I think it is going to have to take some reasonable 4
balance but each one will have to make his judgment 5
I am going to suggest that we try another case, f
6 COMMISSIONEN ASSELSTINE:
sounds good.
i
?
CHAIRMAN FALLADINO:
Did we complete Haddam Neck'*
8 COMMISSIOFEH EERNTHAL:
Sounds good and I will worry j
9 about policy.
10 MR. DIRCKS:
I think the view of some Commissioners, I
11 we have these files quite extensive and I think some of them 12 were sent directly.
The company made submissions directly to 13 the Commission but there may be back-up.
i 14 COMMISSIONER ZECH:
I am just asking either you or i
15 SECY that when they send us a package that requires a judgment 16 that we have it all together.
If that is too much, then I 17 v'i l l work it out myself.
18 MR. DIRCKS:
No.
I think we can do that.
19 COMMISSIONER ZECH:
It seems to me that we ought to 20 be able to expect the completed statt work.
It is a lot 4
1 21 easier for me to go through it when it is all in one package.
7 22 I will be happy to dig it out myself That is wnat I am doing 23 right now.
l 24 I am just saying that it would be easier for me it I i
25 could get it presented to me in a manner that would perhaps i
. ~.
37 i'
I best use my time.
2 MR. DENTON:
We can certainly provide it to you.
I i
3 had the same aitticulty when I saw them.
All the requests for 4
extensions originally came to the Commission because only you 5
can grant the extension and forwarded them to us and we tried l
6 to base our recommendation merely on what the licensee said.
l 7
It he didn't provide much of a rationale we didn't 8
invent it for him.
So we might not be able to answer all your a
9 questions because we have read his statement, big or little, 4
10 and then based on what we knew about the case came to some f
11 Judgment.
I 12 But basically the case was tried 11 you look at it 13 that way on the licensee's submittal plus what we and the 14 regional folks thought about the licensee *s submittal.
i l
15 MR. DIHCKS; I think that is an important point i
i j
to Harold made.
We were not going to supplement the licensee's I
f 17 record.
He made the case directly to you and what we were
}
18 trying to do is to synthesize that material and give you our 1~
19 view of what he submitted.
20 We were not going to submit other documentations to i
l 21 support the licensee's case.
)
22 COMMISSIONER ZECH:
All I am asking for is the i
i 23 completed statt work.
24 CHAIRMAN PALLADINO:
All right.
I think you have an l
25 agreement to have the statt do that.
1
-. - - ~. -, - -
4 38 1
Again I am going to suggest that we leave D.C.
Cook.
2 We had been in the process of Haddam Neck.
Are there questions 3
or comments on Haddam Neck that we did not address'!
i 4
COMMISSIONER BERNTHAL:
Yes, I have one question on 5
Haddam Neck.
One of the things that troubled me a little bit i
6 I have to say about the although again I am inclined to i
I 7
think statt has made the right policy judgment here because j
j 8
that really is what a lot of this is.
9 One of the things that troubled me was the licensee's 10 relying on participation in ISAP as one of its major arguments 11 and I understand that in a way.
I am troubled by the reliance j
12 on it but 1 also think that we should give some credit for the 13 utility's willingness to step forward in a voluntary program 14 and one that is valuable to our safety ettorts, to its own J
15 safety ettorts.
16 Maybe you can just comment a little bit on that.
It i
17 seemed like when it was all said and done that it was this 18 ISAP Program that made us late and you ought to give us the 19 extension because of that J
20 MR. GRIMES:
I would like to respond to that.
I l
21 have a vested interested in that program since that will be my 22 responsibility in the future.
We reviewed the licensee *s 23 presentation and we understand that the Itcensee feels that he
{
24 is receiving conflicting policies from the Commission, 1
25 We did not take ISAP into account in terms of our 4,
39 1
Judgment his diligence to try and accomplish environmental 2
qualification despite the delays in getting ISAP started.
3 Se our view was recognize that that was his concern, 4
the licensee's concern, but we looked at it from the historical 5
point of view in terms of -- I personally was involved in at 6
least three screening review attempts on the Northeast plants 7
that looked at satety significance and the basis for deterring 8
action on specific pieces of equipment.
9 While I can't recall those specific pieces of 10 equipment I know that we looked at detail in terms of other 11 qualified means to achieve the safety function and the kinds 12 of things that would warrant the extension request that they 13 made repeatedly in order to try and evaluate these pieces of 14 equipment in ISAP.
15 Ultimately the licensee had a parallel course that 16 eventually caused them to procure and they will now install 17 all of the equipment to achieve qualification.
18 MR. DENTON:
Perhaps you would like to hear tram 19 John Zwolinski who is present who presently has that plant 20 within his branch.
21 MR. ZWOLINSKI I am the branch chief for the Haddam 22 Neck plant and my name is John Zwolinski I think you should 23 be aware Commissioner that much of the paper was founded not 24 on ISAP but on their diligence in pursuing an equipment 25 qualification program outside of the ISAP.
- - _. _. - - -.. _~
_ = _ - _ _
l i
40 l
i 1
I think you will note that the equipment has been l
j 2
purchased, is on their site and will be installed at their l
3 refueling outage to begin on January 4,
1986 should they have i
4 the opportunity to get to that particular date.
j 5
We mentioned ISAP in the paper as another piece at 1
4
]
6 the entire puzzle which was presented to us in their
?
presentation.
{
8 CHAIRMAN PALLADINO:
All right.
Any more on Haddam
[
4 i
9 Neck?
i 10 COMMISSIONER ASSELSTINE.
Yes, Just a couple.
I I
i l
11 would say that I agree very much with Fred's comment on the
]
12 interrelation with the ISAP Program.
I think that program i s i
t i
13 a good program and it has a lot of benefits and a lot of
't 1
1 14 teatures.
I personally have never viewed it as a mechanism
}
j 15 though for saying something like equipment qualification where 16 the Commission had a specific deadline saying, Well, we are I
17 prepared to deter some of those items perhaps for an extended 18 period of time."
i l
19 I felt that those things would be built into that j
20 process or at least absent some strong Justification that we I
(
21 are going to as part of ISAP make a major improvement in an i
i 22 overall system and therefore we prefer that approach than 23 qualifying an existing system that may not be as good.
'l 24 I had the same kind of reaction I think as Fred did l
25 about seeing ISAP offered as a justification for tailure to i
l
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i 1
quality the equipment by the deadline.
2 MR. ZWOLINSXI Commissioner, you might realize and i
l 3
be aware that Millstone Unit I was not brought to the table 4
today and Haddam Neck was.
In fact, this is the very point l
5 that the statt is struggling with is the reliance on ISAP as I
)
6 ene of the principal reasons to perhaps delay the EO work.
I 7
For Haddam Neck I think we have constructed a 8
ditterent argument and I think Haddam Neck would have stood on 9
its merits without even mentioning the ISAP program.
i 10 COMMISSIONEH ASSELSTINE:
All right.
For myself at 11 least that is the way I would view it as separating out the i
i 12 ISAP Justitication as not a valid justification looking at the 1
13 merits of the proposal other than that, 14 In that regard let me ask you about the valve motor l
15 operators.
It says here that the licensee was pursuing i
16 ditticulties since 1980 with the valve motor operators.
1 l
17 I understand that they have had lots of problems 18 with the suppliers.
Are you satistled that they really have i
r 19 made a good faith ettort to identity those problems and get 1
I 20 them corrected notwithstanding their inability to get the job l
l 21 completely done by the deadline?
It is tive years, i
l 22 MR. ZWOLINSKI I understand.
It is kind of the l
23 same type of question that you addressed on D.C.
- Cook, It the l
f 24 program was really working in a first-class manner back in l
25 1981 and 1982 we should have realized that we had problems and
_ - ~ - _ _, _., _ - - - _. _ _ _. _ _ _ _ _ _ _ _. - _ _
42 1
got things corrected.
We would have been qualified in an 2
outage in 1984.
3 COMMISSIONEN ASSELSTINE:
In fact the sense I got j
4 trom this is that they did understand they had qualification i
5 problems as early as that and the problem was in getting those 1
6 corrected.
4 l
7 MR.
ZWOLINSKI.
If you will note they did make 1
8 purchasing agreements in June of 1984 and they simply could 9
not get delivery in time.
It was a 34-week lead time for the i
10 components.
When the components were delivered and these are i
l 11 the motor operators by the way they went through the Northeast 12 Utilities QA program and were found to be unacceptable and 13 Northeast turned around and reissued a purchase order for 14 those components and have been accepted now at the site.
I I
15 COMMISSIONER ASSELSTINE:
When did they get both the 16 motor operators and the RTD*s, the ones that were acceptable?
17 MM.
ZWOLINSKI:
When did they physically arrive at i
18 the site?
19 COMMISSIONEW ASSELSTINE:
- Yes, i
l 20 MM.
ZWOLINSKI I am sorry.
I don't have that 21 answer.
I can turnish it 22 COMMISSIONER ASSELSTINE:
Do you know when the i
23 outage was for the cavity seal failure?
24 MR. ZWOLINSKI The outage began in August of 1984 25 and if you recall, we did have the seal failure shortly after
4 43 1
the outage began and that was a delay of about two months to
]
i 2
clean up after the event and respond to that event.
3 So it delayed their outage planning by about two 4
months over a five year period.
As you are aware outages are planned typically three to five years in advance and the 1
6 original outage in 1985 was seneduled for November 1st
?
COMMISSIONEM ASSELSTINE:
Do you know it they could B
have put either of these two parts in during that outage as a 9
result of the extended outage or did the equipment come in 10 after that?
4 11 MR.
ZVOLINSKI The equipment was not available.
)
12 COMMISSIONER ASSELSTINE:
It was not available?
13 MR. ZWOLINSKI That is correct.
4 14 COMMISSIONER ASSELSTINE:
All right.
15 CHAIRMAN PALLADINO:
Anything further?
16 COMMISSIONER ASSELSTINE:
I think that basically l
I 17 covers my questions on that.
18 CHAIRMAN PALLADINO:
All right i
19 COMMISSIONER ASSELSTINE, Let's see others have l
?
l 20 any?
Lando, did you have some?
i 1
21 CHAIRMAN FALLADINO:
Lando.
l 22 COMMISSIONER ZECH:
I just had a couple 11 you want l
l 23 them now.
24 CHAIRMAN PALLADINO:
Yes.
An example would be 25 helpful
I 4
44 1
COMMISSIONER ZECH:
The ISAP question has been 2
answered.
I had that same question.
I think it is a good 3
program too but I do think that it should be considered on its 4
own merit and not necessarily as a substitute for the equipment 5
qualification program.
But that has been brought up.
6 The other question I had concerns the qualified j
7 replacement RTD's.
My question was why did the licensee 8
believe that those qualified replacement RTD's were unreliable 9
and had the potential for common mode tailure?
If that is 10 true, how do they get them qualified?
11 MR. GRIMES:
I was involved in that particular i
12 ettort.
The licensee had installed these dual element RTD's 13 in Millstone Unit 2 and even though they are qualified in 14 accordance with IEEE standards in actual use the RTD*s were i
)
15 not operating the way that they had thought they would.
16 COMMISSIONER ZECH:
These are the replacement RTD*s i
17 you are talking about?
18 MR. GRIMES:
That is correct.
19 COMMISSIONER ZECH:
All right.
20 MR. GRIMES:
The operating characteristics of the 21 elements causec them operational difficulties so they viewed--
22 COMMISSIONER ZECH:
If they are unreliable and had i
23 operational ditticulties, what were we doing about it?
24 MR. GRIMES:
Tne reliability has to do with the 25 interrelationship between the element and the instrumentation
-. ~ - - - _.
l 45 i
1 that it works with.
2 COMMISSIONER ZECH:
Were they still considered l
1 I
3 qualified replacement RTD*s?
]
4 MR. GRIMES:
That is correct.
They satisty the 5
requirements for qualitication and they satisfy the 6
specifications with respect to their response times and other 7
teatures.
8 COMMISSIONER ZECH:
Why did they believe they were J
I 9
unreliable then?
I think they made that statement.
10 MR. GRIMES:
Because it caused a shutdown in 11 Millstone Unit 2.
j 12 COMMISSIONER ASSELSTINE:
So they put them in one i
1 13 plant and had problems with them and then didn*t want to put 14 them in the other plant until they sorted out the problems.
l 15 MR. GRIMES:
They had to work out tha details of the i
16 system's response to the RTD's so that they would not cause i
l 17 operational ditticulties.
i 18 COMMISSIONER ZECH:
But they found it out in the 19 other plant that they were satisfactory so they considered 20 them qualified and reliable then.
r l
21 MR. GRIMES:
Reliable from the standpoint that they 22 would survive the accident and operate the way that they were 23 intended but unreliable with respect to the response 24 characteristics as they pertain to operating the plant It 25 they are going to cause spurious trips you want to solve the
. - - - _ ~ _ -.. -. ~. _ -. - -
l i
j i
I 46 1
related instrumentation problem.
2 COMMISSIONER ZECH:
Is somebody warking on that?
i j
3 MR. GRIMES:
That has since been rescleed.
I 4
COMMISSIONER ZECH:
It has been resolved.
I 5
MM. GMIMES:
Yes.
6
{
6 COMMISSIONEW ASSELSTINE:
In fact I gather from the j
7 paper that what they have done is upgrade the whole system.
8 MR. GHIMES:
That*s correct,
)
9 COMMISSIONER ASSELSTINE:
So that it is a much
't j
10 better system than it was before.
l I
11 COMMISSIONER ZECH:
The only other thing that I had
)
t l
12 on this one was on the TMI Action Items, how are we resolving 4
}
l 13 those with respect to the EO deaditne date?
It seems to me 14 that there was some discussion of that and there might have l
l j
1i been a little bit of confusion.
I hope those Actions Items i
j 16 are not being used as a reason for putting ott equipment
'}
i l
17 qualification.
18 MR. GRIMES:
It is not an excuse for putting ott I
19 equipment qualitication but any of the plant modifications i
20 resu.ang trom a TMI Action plan have to be it they require i
l 21 qualified equipment then that equipment has to meet the I
f 22 environmental qualitication requirements.
1 23 CHAIRMAN PALLADINO:
It it is new equipment, you are j
3 24 not going to say that it has to be done on the date that 1
25 precedes their installation?
)
l 4
. _ =. -. _ -. - -. = _. - _ _ _ _. -.. - _..
_ _. - - _ -. _ _ ~ - _.
4 1
4 3
47 1
MR. GRIMES:
I would have to go back and check the i
2 details.
Our view was that it they were installing equipment i
f 3
to satisty the TMI Action F1an in the 1981 to 1983 time irame, I
4 we would expect it to meet the EQ rule.
1 5
It they are installing equipment in 1994 and 1985, i
l 0
new equipment, ii there are diiiisultles associated with EQ, 7
that we viewed as a separate issue.
1 8
CHAIRMAN PALLADINO:
Let's assume some new item and i
9 maybe not the TMI Action Plan but related, the Davis-Bessie I
10 situation where they are going to put in a new pump or piece I
i 11 of equipment and right now I don *t know it it is equipment 3
12 qualified or not or whether it needs to be, but I wouldn't 1
1 13 expect they have to meet the November 30 deadline.
They have 1
14 tu meet it to have it qualified in accordance with whatever we 6
)
l 15 decide we need for that, 16 MR. GRIMES:
That is correct.
I agree with your 4
l 17 view and that is what I was trying to explain.
I 18 CHAIRMAN PALLADINO:
I see.
Maybe I misunderstood l
1 19 you.
i l
j 20 COMMISSIONER ZECH:
That is all I had on Haddam i
I
'l Neck, Mr. Chairman.
l 22 CHAIRMAN PALLADINO:
all right.
I 23 MR. DIRCKS:
May we go hack to ISAP for a minute?
24 Am I getting a sen9e that any arguments they make that they 2$
dep=nded on ISAP should be considered irrelevant for this I
~ - _ - - -.
.i I
j 4
48 1
purpose?
l J
j 2
CHAIRMAN PALLADINO:
Not for me I think.
I think j
l 3
you need a balanced view.
I know we could go in and put every l
{
4 case under the microscope and try to decide whether this was
{
5 met precisely at that time.
I l
I 6
The Commission looked at the first two that set the 7
boundaries and then between I think there are some that are 8
easy and some that are going to be a little bit harder.
I t
9 think it is appropriate to ask these kinds et questions but I j
10 don't think that 1
a I
11 MM. GHIMES:
I would like to ask a question in that 1
i
]
12 regard and it is a claritication of the policy that was i
13 developed when we proposed ISAP.
l 14 At that time the Commission was very concerned about j
1$
the basis for deterring actions so that those issues could be 16 resolved in ISAP.
It the utility had instead of arguing about
]
17 the time trame of ISAP presented the case by which they
]
18 decided to fix some things and put others ott so that they had 19 in fact put together a sutlicient story of the lack of safety l
1 r
20 significance for the equipment that was being deterred, I f
21 would view that as satisfying conformance with 30.12 as is 22 required in the ISAP Policy Statement.
l 23 That is the issue right now that we have been i
i 24 looking into, whether or not underlying all of their arguments 25 about their ettorts to get these issues resolved in ISAP,
_____.-,-,.....,.---,.-_r-,-
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l 49 1
whether or not they have in fact developed in some place the 2
explanation of their conclusion that not tixing this equipment 3
does not jeopardize public health and safety because there are
)
4 alternative systems that accomplish the same function.
)
5 COMMISSIONER ASSELSTINE; But that sounds very much o
-- clearly there are differences in terms of the amount of 7
equipment involved but that sounds very much like the Brunswick j
B argument which was, "Look fellows, we were busy doing other j
9 things that were much more important to safety in terms of the i
10 operation of this plant and that is why we just didn't get to i
11 this equipment qualification business as early as we wanted
}
}
12 to."
13 MR. GHIMES:
But they were distinguishing EQ trom i
14 everything else.
I am saying that for EQ as a whole that you 15 could go through all of the equipment and rate its sa'ety 1
16 significance and then 11 you look at the stuff at the bottom i
17 of the list 11 there is something that can accomplish that 1B function that is qualified, that in fact is what we rely on i
19 for justifications for continued operation.
20 The issue as I see it is how long have we been i
21 riding on those JCO's and to what extent have we comprcmised 22 defense-in-depth.
If there is a case to be made for the 23 equipment that they have elected to deter to ISAP, there are 24 11 pieces that they wanted a continued extension for, I would 25 hope that that argument can be clearly presented to the l
. _ = -.. _, _ _ _ _ _ _ _ _ _ _ _ _. - _ _
I j
$0 i
1 Commission.
2 COMMISSIONER ZECH:
I think that the ISAP Frogram 3
has to be looked at It is a unique program.
It has to be 4
looked at very carefully here.
Everf judgment they have made 5
to postpone something beyond an EQ date which we have set l
6 should be justified not only by them but by you.
You should
?
understand and agree that that was a very sensible thing.
It 8
should not be used as an excuse to not comply with the EQ 9
program.
1 10 COMMISSIONER ASSELSTINE:
- Hight, f
11 COMMISSIONER ZECH:
That is all I mean.
12 COMMISSIONER ASSELSTINE:
That is exactly my point 13 as well.
l 14 CHAIRMAN PALLADINO:
I thought that is what the 15 statt is doing.
16 MR. GRIMES:
I understand and I agree.
17 COMMISSIONER ASSELSTINE:
In which case you will 18 look at the merits.
I agree with what the Chairman says.
You 19 will look at the merits of the justification for why they were t
20 not able to get this done in the centext of the items that we 21 had outlined in the generic letter.
Did they make a good 22 taith ettort to identity their problems, pursue them and get i
23 them resolved rather than well can they just otter ISAP as a 24 justification for why they didn't do it.
I 25 MR. GRIMES:
I understand.
i
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CHAIRMAN PALLADINO:
Are you through with Haddam 2
Neck?-
j 3
COMMISSIONER ZECH:
Yes.
4 COMMISSIONER BERNTHAL:
As long as we are talking j
5 about details here I thought that their cavity seal failure 6
was their fault.
Wasn*t that their screw-up?
?
COMMISSIONER ASSELSTINE:
It sure was.
8 COMMISSIONER ZECH:
- Yes, 9
COMMISSIONER BEMNTHAL:
There is another nail in the l
3 10 collin.
That was also by the way one of the points they j
11 oliered in their defense.
1 12 CHAIRMAN PALLADINO:
We had talked about Shoreham 13 and you said that you would recommend approving an extension 14 to 12/31 Does that give anybody a problem or are there other 1
15 basic questions?
16 COMMISSIONER ASSELSTINE; I have some questions i
17 about Shoreham.
18 MR. GHIMES:
For my own convenience, I would like to 19 talk about Shoreham and then Palo Verde because it is 20 essentially the same issue --
21 COMMISSIONEM ASSEL$ TINE:
Yes, same equipment.
22 MR. GHIMES:
and two dtiierent utilities 23 approaching the same problem from two dillerent 'vays, i
24 CHAIRMAN PALLADINO:
All right.
25 COMMISSIONEH ZELH:
When you talk about that it was s
,___,.._..m, m,
i 52 1
my understanding that there are a total of eight utilities 2
that have these same hydrogen recombiner units.
3 MH. GHIMES:
That is correct.
4 COMMISSIONEN ZECH; I would be interested to know i
how all eight of them solve this proslem.
6 MM. GHIMES:
In general terms Palo Verde and Shoreham 7
elected to go with Rockwell and rely on them because they had i
8 as a part of their contractual arrangements agreed to have the 9
equipment qualified.
10 COMMISSIONER ZECH:
Did the others as well?
11 MM. GHIMES:
The other utilities said, "No, we don't 12 think Rockwell is going to cut it."
So they went off on I,
13 separate qualification programs.
14 As it turns out the other six made it and Shoreham it and Palo Verde now are stuck in their situation.
16 The statt view when we looked at that experience was 17 that hindsight is perfect.
It could have turned out the other 18 way.
The six that had gone off on their own programs without 19 the kind of experience that the vendor had might have ended up 20 being in the position that the vendor is in today.
21 That was a major consideration in terms et judging i
22 the licensee's proposal.
23 COMMISSIONER ASSELSTINE:
It sure doesn't look slike
~
24 the vendor in this case was very responsive.
If the utility 25 was asking that the equipment be qualified beginning in May of
53 1
1980, authorised the testing in June of 1981 and they didn't 2
really identity this problem until mid-1985.
It sure looks 3
like that is where a lot of the problem is in this case.
4 MR. GRIMES:
You have to realize or at least one of 5
the factors that we considered is we are talking about a very 6
complex hydrogen recombiner system.
7 COMMISSIONER ASSELSTINE:
Yes.
8 MR. GRIMES:
Most of the efforts in terms of 9
qualification I personally expect focused on the recombiner 10 itself, the combustion device that is probably going to have 11 the most difficulty.
12 It turns out that as the qualification program 13 progressed they discovered the problem in the control panel 14 where they probably I would expect not have anticipated that 15 kind of ditticulty and also the combination of testing as it 16 comes together whether it is sequential or an integrated test 17 and the other features apparently caused the vendor difficulty.
18 I think that Bob LaGrange can talk some more about 19 the experience with Hockwell and wnat went on during that time 20 trame but ultimately our judgment was that we thought that the 21 licensee's directions and efforts to try to keep Rockwell 22 moving towards qualification were diligent.
23 COMMISSIONER BERNTHAL:
I am curious about the fact 24
-- not curious but I just note the fact that we, I think, have 25 a benchmark here on at least how early one utility got to work l
$4 1
on EQ and that is Shoreham.
2 In May of 1980 or in other words in early 1980 they 3
were on the problem and clearly about their business and this 4
is Shoreham now.
Some other utilities certainly did not respond as quickly, i
6 MR. GRIMES:
I think you should also realize that
?
Shoreham was an NTOL who knew what rules and design criteria 6
they were going to face.
I would think that May 1980 was 4
9 probably compatible with the purchase date of the equipment 10 for a plant that they hoped to eventually put into operation 11 as opposed to operating plants who were first trying to 12 develop a scope of what do they need to replace before they 13 can then go out with purchase specs.
14 COMMISSIONER BEHNTHAL:
But it is clear that at 15 least some folks were aware of what had to be done in May of 16 1980 whether they were in construction or retrofitting.
17 COMMISSIONER ZECH:
Those are all of my questions on 18 Shoreham, Mr. Chairman.
19 CHAIRMAN PALLADINO:
All right.
20 COMMISSIONER ASSELSTINE:
I just have a couple 21 more.
The first one I had was I gather that for the hydrogen i
22 recombiner, the part that they have had trouble with at least 23 recently, is the seismic qualitication part.
24 MR. GRIMES:
The seismic qualification in the 26 control panel 1
.----.-1
35 1
COMMISSIONER ASSELSTINE:
I didn't think that 2
seismic was part of the EQ rule, was it?
3 MR. GRIMES:
Seismic is part of their licensing 4
basis.
5 COMMISSIONER ASSELSTINE:
All right.
In this case 6
that portion of their qualification problem isn't so much tied 7
to the EQ rule itself as it is to the licensing base for the 8
plant.
9 MR. GRIMES:
It is the licensing basis and it is the 10 interrelationship between meeting your licensing basis and 1
11 meeting the EQ rule at the same time.
12 COMMISSIONER ASSELSTINE:
All right.
I was a little 3
13 puzzled about why 11 that was the particular problem that that i
14 was a concern as far as the extension.
15 COMMISSIONER BERNTHAL:
We are talking about Palo 16 Verde now I guess, right?
17 COMMISSIONER ASSELSTINE:
Shoreham, but it is the G
18 same problem.
i 19 COMMISSIONER BERNTHAL:
It is the same problem but 20 my impression was at Palo Verde and it is a border line case 21 but at Palo Verde it looks like they are trying to meet a 22 seismic criterion that is rather rigorous compared to what 23 they really needed to make and that that is part of the reason 24 for their ditticulty.
Is that not the case?
25 MR.
LaGRANGE:
Bob LaGrange, Equipment Qualifications
s 56 1
Branch.
To clarity why tne seismic failure impacts the
{
2 environmental qualification, part of the test sequence that the 3
equipment goes through prior to -- in fact, the seismic is 4
prior to the accident simulation.
5 What they do is they test the prototype.
They age 6
it.
They put mechanical wear on it.
They do the seismic 4
7 testing and the accident sequence.
So what it did was it i
8 failed prior to reaching the accident simulation.
It is just 9
part of the test sequence to environmentally quality this.
i 10 COMMISSIONER BERNTHAL:
Is it your impression that 11 Palo Verde at least has set for itself a seismic goal and 12 criterion and one might say that it was overdesigned in terms 13 of seismic requirements.
14 MR.
LaGRANGE:
That is very possible.
15 COMMISSIONER BERNTHAL:
I am not sure that is all 16 bad.
17 MR.
LaGRANGE:
That is one of the drawbacks if you 18 will on generic qualification programs.
You want to envelope 19 everybody's conditions and there is always somebody whose 20 conditions are much lower than the envelope conditions and you 21 run the risk of failing.
22 MR. GRIMES:
I am not certain that Shoreham doesn't 23 have that same situation since there is such a close parallel 24 In the Shoreham case the licensee's argument did not present 25 that clearly and if I had been a better coordinator, I might
9 0
U 'l 1
have seen that disconnect and made those two points consistent.
2 COMMISSIONER BERNTHAL:
But for Shoreham we are now 3
looking at paperwork between now and December 31, right?
4 MR. GRIME 5:
That is correct.
Based on Mr.
Caruso's 5
update I would presume that all that is left now is pulling o
that material together.
?
CHAIRMAN PALLADINO:
What about Palo Verde?
Any 8
turther questions on that?
9 COMMISSIONER ASSELSTINE:
I have one remaining on 10 Shoreham on the actuators for the dampers.
11 CHAIRMAN PALLADINO:
All right 12 COMMISSIONER ASSELSTINE.
I take it what they did 13 was since the other ones were obsolete they ordered new ones, 14 tested a prototype of the new ones to see it they were okay 15 and once they found out they were okay then decided to put to them in, is that right?
17 MR. GRIMES:
I will deter to Mr.
Caruso.
18 COMMISSIONER ASSELSTINE:
All right.
19 MR. CARUSO:
When they decided to quality the 20 original dampers you are right, they determined that they were 21 obsolete.
They decided to quality the new ones and the 22 qualification test program was started for the new ones.
23 They were procured I think earlier this year or late 24 last year based on the assumption that they would pass the 25 qualification test in an attempt to avoid delays due to y-
-m
-,------,-a p.-,.--w..mor-.+. - -. -
--,.--i..---%~,
=,
58 1
procurement because as you saw with Haddam Neck there are 2
sometimes 34 or 52 week lead times on these items.
3 They have been procured.
They are at Shoreham and 4
they are being installed during the current outage.
Shoreham 5
is in a shutdown right now to replace sources and the actuators 1
6 and the hydrogen recombiners, new qualified recombiners, will
?
be installed during this outage before they intend to start up.
8 What is lett to be done right now is to complete the 9
qualification paperwork for the test that have been completed 10 on both of those components.
11 COMMISSIONER ASSELSTINE:
All right.
When is the 12 outage scheduled to end?
13 MR.
CARUSO:
Mid-December, I think.
14 COMMISSIONER ASSELSTINE:
Mid-December, all right.
15 MR. CARUSO:
Yes.
16 COMMISSIONER ASSELSTINE:
You are talking about a 17 deadline of the end of December for getting all the 18 documentation.
19 MR. CARUSO:
Yes.
The utility agrees that it can l
20 get the paperwork done by the end of the year.
21 COMMISSIONER ASSELSTINE:
All right.
Both for 22 Shoreham and for Palo Verde, could you talk about the 23 interrelationship between the license condition since I gather 24 those are the only two cases where you have a license condition 25 on EQ and the extenstor request.
Maybe OGC needs to talk about l
l
59 1
that, too, what the significance is of the extension request in 2
the context of needing either a license amendment or can we 3
just not enforce the existing license condition.
4 MR. SHIELDS:
I think it would be a better policy 5
and I think we noted this in the Palo Verde package, I am not 6
sure that it is noted in the Sequoyah case, that we issue a
?
license amendment.
8 So in this case we would be asking for your 9
authorization for Harold to issue such an amendment prior to 10 November 30th.
On the Palo Verde Unit 2 case I think that 11 would just involve inserting an appropriate term in that 12 license.
13 COMMISSIONER ASSELSTINE:
All right.
So in those i
14 cases what you are proposing is both approval of an extension 15 and a approval of a license amendment?
16 MR. SHIELDS:
Hight.
I think we can issue the j
17 amendment with your authorination.
18 COMMISSIONER ASSELGTINE:
All right.
19 COMMISSIONER BERNTHAL:
May I ask a generic question 20 here that is not specific to a plant before we lose all our 21 time here?
22 How have we assured and I hear tne drippings of a 23 little bit of this in comparing Shoreham and Palo Verde, how 24 have we assured that there is uniformity here in the way you 25 considered the extension requests?
There is not much l
l
~_
60 1
uniformity on the size of our statt with respect to the t
2 microphone over there.
How do we make sure that there is 3
uniformity in the way you treat these extension requests?
j 4
MR. DENTON:
We tried the bottoms-up approach to it 5
to get all the project managers and the residents who were 6
involved in this and tunnel them through Chris so that we had 7
one person making in the initial instance a recommendation to 9
me on what to do with them and then they were reviewed by 9
myself and Bill and others as well as Bill Shields whose }ob 10 is to see how we come toward meeting the criteria.
11 Basically Chris is the person who is assuring 12 continuity across them in terms of putting them in their 13 position on this continuum and I think that is basically wnat 14 we have tried to do and then we have tried to draw the line on 15 the continuum as to where it should be.
16 COMMISSIONER BERNTH%:
But you are satisfied that i.
t 17 you have had enough time here with all of these recommendations l
18 now that you have come in with, that you have had the time to 19 do that cross-cut and make sure that you are being even-handed 20 across the board?
l 21 MR. GRIMES:
You received two packages yesterday 22 morning.
Those were intended to be delivered to you the 23 previous Friday.
That is a measure of the time that I took to 24 make sure that I felt comfortable that there is a rationale 25 explanation for any of the ditterences between the plants and
)
i 61 J
1 our recommendations.
l 1
2 I am prepared to explain any difference that you can i
3 find.
In some cases I note that I could probably have done a 4
better job of explaining it or required that the project 5
managers do a better job of explaining it so that you could o
have found the answers for yourself.
i
?
But we sacrificed that time.
I would also like to 8
point out that there were at least two occasions when we had 9
all of the affected project managers in one room and in one 10 case Hugh Thompson directed the meeting and I imagine that 11 11 you got them all together and asked them, they probably 12 would explain it.
We didn't take any rash actions.
We beat 13 it around and a number of these positions changed from one day 14 to the next until we were confident that we had that 15 explanation.
16 MR. DENTON:
I guess we are in a bit of an 17 uncomfortable role arguing for why should one be granted an 18 extension in the first place.
You are putting us in an j
19 uncomfortable statt role to try to argue their case.
20 Typically we make the licensee argue the case.
We 21 were just trying to give you some advice on our view about it l
22 but in the ultimate it seems like it is the licensee's burden 23 to prove the case and not the statt's.
24 COMMISSIONER ZECH:
That is why it is important as 25 tar as I am concerned that we do indeed review the licensee's I
{
62 1
1 letters and their words very carefully.
2 CHAIRMAN PALLADINO:
Oh, yes.
3 COMMISSIONER ZECH:
I think that is very important 4
and I agree.
5 CHAIRMAN PALLADINO:
No question about that.
Any 6
more questions on Palo Verde?
7 COMMISSIONER ASSELSTINE; Yes, I had a couple on 8
Palo Verde.
I will try to get through them pretty quickly.
9 I take it in the case of Palo Verde the tests have 10 not been completed unlike Shoreham where the tests of this new 11 panel are not done?
12 MR. GRIMES:
Falo Verde may very well be able to 13 tell us today that their tests are completed, too.
I think 14 they were the same testing programs but I am not certain.
15 COMMISSIONER ASSELSTINE:
I gathered it was a 16 different problem with the panel, seismic question but a 17 different part of the panel that was of concern.
18 MR. DENTON:
Why don't we see it anybody in the 19 audience has an answer to that question?
20 COMMISSIONER ASSELSTINE:
All right.
21 MR. GRIMES:
George Knighton, branch chief for 22 Palo Verde will explain it.
l 23 MR.
KNIGHTON:
As you mentioned earlier Palo Verde 24 is a member of the owners group that was developing the 25 hydrogen recombinar.
It I understand correctly the tests that
63 1
they were looking for had been successful completed.
2 COMMISSIONEM ASSELSTINE:
all right 1
3 MM.
KNIGHTON:
On that basis the schedule would be 4
that they wouli have the new panels to be put into place by 5
the end of October and that they could have them in place with 6
the first unit on November 31st and the second unit because 7
you can't take both units out at one time by December 13th.
8 So it would be consistent with the Shoreham date 9
that I believe you find in the Shoreham paper.
I 10 MR. GRIMES:
That raises an interesting question 11 from the standpoint of the staff recommendations.
We noted 12 that Shoreham had requested a year to wrap up a year and we 13 had recommended December based on our understanding that they 14 had already purchased the equipment and put it into place.
j 15 Palo Verde on the other hand had developed two 16 alternative approaches and that is when one tails, they will 17 go to this othes-approach.
18 It in fact they can finish the documentation by 19 December 31st based on our understanding of their situation 20 today should we rovise the staff *s recommendation and make 21 that De c etab e r 31st as well because right now we are 22 recommending that they get the March 1986 date they asked for.
23 COMMISSIONER ASSELSTINE:
But you think now based 24 upon new test results that they could get it done by the end 25 of December'd i
. ~.
04 1
MR. GRIMES:
I would have to check.
The two 2
explanations between Shoreham and Palo Verde seem to indicate 3
that they might have to do something different.
4 COMMISSIONER ASSELSTINE:
Yes.
5 MR. GRIMES:
We can certainly get representatives 6
from Arizona Public Service to explain to us what their
?
current situation is.
8 CHAIRMAN PALLADINO:
If you are going to change your 9
recommendation, you are going to have to give us another piece 10 of paper.
I was ready to act on your recommendations or 11 address your recommendations but it it is going to be different 12 I don't want to act on that one until I know what it is.
13 When would you have the new recommendation?
14 MR. DENTON:
We will have to look at the test result 15 that has been satisfied and r e c o r. s i d e r it, I guess, but we are 16 cutting the bread awfully thin.
We are just trying to make 17 sure that you are aware of these fine dist!.netions.
18 CHAIRMAN PALLADINO:
11 you are going to go back and 19 tell us that it should be December 31st rather than the other 20 date --
21 MM. DENTON:
I think we were happy with the first 22 recommendation but I think Chris was saying that 11 you want 23 consistency, you could apply the same test that you did at i
24 Shoreham but I don't know what the impact on the licensee 25 would be.
i i
65 1
CHAIRMAN PALLADINO:
Could you check it?
2 MR. DENTON:
Yes.
3 CHAIRMAN PALLADINO:
Then let us know.
4 COMMISSIONER ASSELSTINE:
It sounds like 11 they are 5
going to put the two units in by the end of November and by 6
the middle of December then from that point forward they are
?
in the same position that Shoreham is in.
8 MR. DENTON:
We will c r. ak.
i 9
CHAIRMAN PALLADINO:
Lando, did you have any 10 questions?
11 COMMISSIONER ZECH:
No.
My Palo Verde questions 12 have been already asked.
Thank you.
13 CHAIRMAN PALLADINO:
All right.
Now which one do a
14 you want to go to?
Is Point Beach an easy one?
15 COMMISSIONER ASSELSTINE:
Yes.
16 CHAIRMAN PALLADINO:
Any questions on Point Beach?
17 COMMISSIONER ASSELSTINE:
No.
18 CHAIRMAN PALLADINO:
All right.
Sequoyah.
I 19 COMMISSIONER ASSELSTINE:
That is an easy one, too.
i 20 CHAIRMAN PALLADINO:
For me, it is an easy one.
21 (Laughter.)
f 22 MR. GRIMES:
I have Sequoyah on two lists.
I have i
I 23 them on the extension request list and I was also informed by 24 the Operating Reactors Assessment Branch that on the latest 25 poll they said that they are going to stay shutdown until they
_ _____.__,___.i
J 66 1
do whatever they have to do in order to receive permission to 2
start up.
3 It wasn't too ditticult for us to recommend a denial 4
on Sequoyah.
5 CHAIRMAN PALLADINO:
All right.
Let's see.
I 6
Sequoyah, Point Beach we talked about, Palo Verde, Shoreham,
?
Haddam Neck, D.C.
Cook and there is Pilgrim on the list.
8 COMMISSIONEH ASSELSTINE:
Pilgrim, yes.
9 CHAIRMAN PALLADINO; Any comments or questions on 10 Pilgrim?
11 Here you are giving us a recommendation that would 12 permit reconsideration.
I don't know how you would handle the i
13 reconsideration?
14 MM. DENTON:
We didn't mean to confuse anyone 15 there but we recommend denial period.
That is it.
- However, 16 their test is underway and we wanted to recognize that it the 17 test is successful they will be in full compliance.
18 We just wanted to make you aware of the fact that 19 there is some time between now and then.
So I think we will i
20 have to await the test results.
We said that based on what l
l 21 they had submitted --
22 CHAIHMAN PALLADINO:
When will the test results be 23 available?
24 MR. GHIMES:
The last test is November 22 but all of 25 them except that one on November 22 will be available I think l
l l
67 1
the first week in November.
2 CHAIRMAN PALLADINO:
Then what is holding them up in 3
getting either do they have to make any changes that 4
require an outage?
5 MR. GRIMES:
It the tests are unsuccessful and the 6
first test result won't be available until October 28th, but I
?
it the tests are all successful they may only require an 8
extension of two weeks to a month in order to put the i
9 documentation together.
10 It the tests are unsuccessful and we can go back and 11 look at the history of the testing ettort and what caused this 12 most recent test failure, we would recommend that that specific 13 extension be considered on its own merits.
j 14 COMMISSIONER ASSELSTINE:
Although then they have a I
15 really longer term problem, don't they?
The sense I got from 16 your paper was that they didn't see a lot of good alternatives
)
17 to these particular items, that when they looked at the 18 alternatives they didn't pay out very well 19 MR. GRIMES:
Yes.
For five items I think it was two 20 or three et them don't have good alternatives.
21 COMMISSIONER ASSELSTINE; Yes.
22 MR. GRIMES:
So it depends.
It it turns out there 23 are test failures for those two or three wi' out the viable 24 alternatives they may have a serious problem.
25 MR.
DENTON:
I think that one again is where we
68 1
looked at what they submitted and they asked for something 2
that we would recommend you deny.
3 However, you should recognize that the situation may 4
change but it it does I think the duty is on Pilgrim to notify 1
i us that suddenly they are complete.
So we haven't tried to i
6 get beyond their proposal 1
7 COMMISSIONER ASSELSTINE:
all right.
B CHAIRMAN PALLADINO:
Other questions on Pilgrim't 9
COMMISSIONER ZECH:
The only other thing I had and 4
10 trankly my sense of reading what you sent us was that we are i
11 really not quite ready to make a decision on Pilgrim yet 12 MR. DENTON:
It depends.
They made a case and they 13 would like your opinion on that case, I guess.
They would 14 like to see the extension granted based on what they submitted.
15 MR. GRIMES:
Their request was for a year and I 16 would like to point out that we have recommended that both for i
l 17 Shoreham and Pilgrim where they requested a year that that a
J 18 aspect of it be denied and that under those circumstances the 19 longest that we would recommend is about tour months.
20 COMMISSIONER BERNTHAL:
Yes.
I think you have 21 drafted a letter which looks pretty good.
It lets them know i
22 that they can come back it this test works out.
1 j
23 COMMISSIONER ZECH:
They mention in their letter it 24 I recall that there were other tests that would be ongoing 25 after November 30 and I don't think you mentioned that in your
69 1
SECY paper.
Was there a reason ter that?
2 MR. GRIMES:
We will have to go back and check.
3 My understand is from the project manager and it Mr. Thadani 4
would like to add his own views, that is line.
Our 5
understanding is that they will have all the tests they need i
6 to achieve qualification by November 22.
?
COMMISSIONER ZECH:
The one test that I remember and 8
I think there were several but one was a 40-year aging test I
9 and that might have been one.
It seems to me that they were 10 asking in their letter that they wanted to go beyond the 30th 11 of November and my only question is why didn't we put that in 12 the SECY paper?
Maybe you had a good reason for it.
j 13 MR. THADANI:
They wanted to use the 20-year test as 14 an interim measure until the next outage and by that time they 15 would have their 40-year aging test completed.
i 16 COMMISSIONER ZECH:
But you didn't mention that in 17 your SECY paper.
My question really is what is your comment 18 or recommendation on that position that they have taken?
i 19 MR. THADANI' We didn't have any problem with that 20 particular position.
21 COMMISSIONER ZECH:
All right.
It would have been i
22 helpful to me 11 you had put it in your SECY paper so at least i
I
.l 23 I would have known that you had considered it.
I had a l
24 question in my mind.
That is why I suggested that perhaps we 25 were not ready yet and maybe you were still looking at l
l
)
70 I
something although your recommendation was clear and I could 2
understand it.
3 It just seemed to me that t r.
J e were some things 4
that were left unanswered.
5 MR. DENTON:
Let me be sure we clartty this point.
o MR. GRIMED:
I just talked to Mr.
LaGrange.
Their 7
proposal to quality it for 20 years we would consider qualified 1
8 tor 20 years ano if they complete the 40 year by the next 9
refueling cycle then we would say now it is qualified for 10 40 years.
11 So we did tail to clearly explain that we considered 12 their proposal acceptable and that by doing this amount of 13 work that they could quality all of the equipment by November 14 22 it all the tests are successful 4
15 MR. DENTON:
So that additional test was not germane 16 to the question of being in compliance on tnat date.
It was t
17 more germane to 20 versus 40 years of operation.
18 COMMISSIONER ZECH:
I see.
Fine.
It would have 19 been helpful to put that in is all.
Thank you.
That is all I 20 have, Mr. Chairman.
21 CHAIRMAN PALLADINO:
Thank you.
I think we have 22 discussed every item on the list unless there are more 23 questions..
I 4
COMMISSIONER ASSELSTINE:
I have just one other one 1
I 25 and I realize that everybody else has voted on Nine Mile Point
71 1
but I had just three questions that I wanted to ask on that 2
one it I could.
a 3
The first one was when did they find out about the 4
problems with the valve actuators that are involved here?
MR. GHIMES.
I will ask Mr.
Bob Hermann who is the 6
project manager for Nine Mile Point to respond to your 7
question?
8 MR.
HERMANN:
I am Bob Hermann, the project manager 9
for Nine Mile.
I believe there was a letter from Niagara 10 Mohawk on August 16, 1985 that provides a chronology.
11 COMMISSIONER ASSELSTINE:
So that is when they --
12 MR. HERMANN:
No.
It provides a chronology of the 13 events you are asking for.
October 1980 is *he time.
14 COMMISSIONER ASSELSTINE:
All right.
The second 15 question I had, I guess I just have two, is when we did the 16 audit for Nine Mile Point you said that the paper noted that 17 there were deficiencies that were identified for a number of 18 items.
19 Could you describe a little bit the nature of the 20 deficiencies and compare the inspection results or the audit 21 results of that audit with other audits that you have done i n 22 terms of judging have they had a fairly ettective program as a 23 general matter in getting their equipment qualified or were 24 there basic flaws that you tound when the audit was done?
25 MR. HERMANN:
I think I would probably deter that to i
e
.,y
.-m
72 1
Mr.
Fotapovs from I&E who is the section leader.
2 COMMISSIONER ASSELSTINE:
All right.
3 NH. FOTAFOVS:
I am V.
Fotapovs from Inspection and Enforcement.
We did complete the audit of Nine Mile Point 5
That report has not been issued at this time.
The results are 6
being assessed.
7 As far as the overall findings of that inspection, 8
there are several specific deficiencies identified in the 9
equipment files relating to the equipment.
Some corrective 10 actions were indicated at the time of the inspection by 11 Niagara Mohawk and I understand that those corrective actions 12 are being completed.
13 There was some additional testing required wnich was 14 contracted for and is in progress.
As far as the overall 15 program, we found the program that they had in place was in 16 basic compliance with the 50.49 rule as far as the programmatic 17 controls.
18 COMMISSIONER ASSELSTINE:
How would you compare the 19 results of that audit say with the results of the inspection 20 or audit that was done at Point Beach that you described in 21 the Point Beach paper?
Were they better or worse or about the r
22 same?
23 MR. FOTAFOVS:
I would say overall the results were 24 not as good as at Point Beach.
25 COMMISSIONER ASSELSTINE:
All right.
But say better
73 1
than some of the ones that we have done over the past year and 2
a half or so where you found fairly significant problems?
3 MR. POTAFOVS:
We have not really attempted to rank 4
them very accurately but I would say that they were probably 5
around the middle.
6 COMMISSIONER ASSELSTINE:
All right 7
MR. DENTON:
We didn't see this finding as a har to 8
granting the extension recognizing that any of these plants 9
might be found on subsequent inspection to have deficiencies 10 that should be enforced against them.
11 COMMISSIONER ASSELSTINE:
I was just interested 12 because you gave the results of the Point Beach one which were 13 very strong among the best that you had seen and it did seem 14 to me at least for myself that it was a factor that I wanted 15 to take into account.
i j
16 If you had a program that was fairly seriously 17 flawed, that would influence my judgment at least on whether 18 to give them an extension.
I 19 CHAIRMAN PALLADINO:
All right.
Thank you.
20 COMMISSIONER BERNTHAL:
May I ask one question for 21 comparison here?
I am really asking for a summary to refresh l
22 my memory on what you said.
23-You have recommended'the disapproval at Shoreham 24 given all the things that we talked about 25 MR. GRIMES:
It is a conditional approval j
l y
,.-_,p w---
,-.v.--.
.m
o 74 1
COMMISSIONER BERNTHAL:
All right, whatever, December 2
31st.
You recommended an approval for Palo Verde.
Did I 3
understand you to imply though that parallel treatment of those 4
two would be pretty much justified?
MR. GRIMES:
We believe so.
What I committed to do e
on behalf of the statt is go back and review Palo Verde's case 7
to determine whether or not there is any specific difference.
1 8
COMMISSIONER BERNTHAL:
So you will get back to us 9
then on that.
10 COMMISSIONER ASSELSTINE:
To see it they can meet 11 the earlier date that you recommended for Shoreham.
12 COMMISSIONER BERNTHAL:
All right 13 CHAIRMAN PALLADINO:
Is that something you can do in 14 couple of days?
15 MR. GRIMES:
I hope that between George Knighton and 16 myself we can have an answer this afternoon.
i 17 CHAIRMAN PALLADINO:
That is very good.
l 18 COMMISSIONER BERNTHAL:
I just want to compliment i
19 the statt on what I think is a careful and very conscientic.us 20 job here.
As I look at the sweep of what you have done here, 21 it hasn't always been easy and you are slicing the bread 22 pretty thin here and there.
I think you by in large have made l
l l
23 good calls.
24 CHAIRMAN PALLADINO:
Let me observe tnat they are 25 slicing the bread very thin and I think they are doing a good
75 1
job.
They are using a very good knife and I don't have many 2
problems with what they are doing.
3 I do point out that we are talking about an extension 4
in a number of cases that go beyond November 30, 1985.
That is b
just s a little over one month from now.
We ought to be able i
6 to tell these licensees the answer to their request certainly 7
by the middle of November.
j 8
I would urge you to try to get your votes on these 9
in just as soon as possible and I would hope to get mine in by 10 about the first of November.
11 We now have two more coming up.
.e have a meeting 12 scheduled for the 31st, I believe, on this.
Will we be 13 getting the information in time enough to go ahead with that 14 meeting?
15 MR, GRIMES:
You will get it for Millstone but not 16 for Fort St.
Vrain.
17 CHAIRMAN PALLADINO:
When will we hear on Fort 18 St.
Vrain?
19 MR. GRIMES:
Fort St Vrain we plan to have to you 20 by the 15th of November.
It is a very ditticult job and even i
21 there I am not sure whether or not we are going to be able to 22 do as good a job as we need to, but we are working diligently 23 now to accomplish it by that date.
24 CHAIRMAN PALLADINO:
All right.
To my memory we do 25 not have another meeting scheduled.
We are going to have to
a 76 1
find time it we need a meeting.
2 Anything else?
3 (No response.)
4 CHAIRMAN PALLADINO:
Thank you very much for your 5
valuable input and unless anybody has some other comment they 6
would like to make, I will say that the meeting is adjourned.
7
[Whereupon, tne Commission meeting was adjourned at 8
11: 45 o' clock a.m.,
to reconvene at the Call of the Chair.]
9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
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9 Name of Proceeding: Discussion of Exemption Requests Environ-mental Qualification (Public Meeting) 10 11 Docket No.
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l 13 Date: Friday, October 25, 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.
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