ML20149E942
| ML20149E942 | |
| Person / Time | |
|---|---|
| Issue date: | 01/07/1988 |
| From: | Advisory Committee on Reactor Safeguards |
| To: | |
| References | |
| ACRS-T-1634, NUDOCS 8801140063 | |
| Download: ML20149E942 (45) | |
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o UNutD STATES NUCLEAR REGULATORY COMMISSION
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IN THE MATTER OP:
DOCKET NO:
333 ACRS GENERAL MEETING LOCATION:
WASHINGTON DC PAGES: 151 - 191 DATE:
JANUARY 7, 1988 pj g+s es f*
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MR. MARSil:
My name is Tad March.
I'm in the Me -
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chanical Engineering Branch.
And this is Ted Sullivan, also 3
in the Mechanical Engineering Branch.
We gave a presentation 1
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4 to the Subcommittee on Reactor Operations two days ago con--
5 cerning in-service testing of pumps and valves on safety-6 related pumps and equipment--pumps and valves.
7 And the purpose of that presentation was to give 8
a status of the IST programs and to give an assecument of the 9
problems that we see.
I'll be summarizing the presentation 10 that we gave two days ago.
11 The basic purpose of the in-service testing of 12 pumps and valvea in to assess the ope Ttional readiness of 13 the safety-related pumps and valves.
(v) 14 You may or may not know that IST progranc are re -
15 quired by the regule.tions, 10 CFR 50.55A and they are also re-16 quired in technical specifications and they have as the root 17 the ASME Code Section XI.
18 MR. EBERSOLE:
Tad, can you mention when they were 19 invoked as a requirement as contrast to the ISI progrem?
20 MR. MA RS fi :
Sure.
The ASME code,Section XI, was 21 modified in approximately 1974/75 time frame to include in-22 service tecting.
And if you are familier with the Section
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23 XI of the code, the vast majority of Section XI cealn with n
21 in service inspection to the order of hundrede of pages.
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m 25 iiherean in.:orvice testing of pumps and valven is on the Acme Reporting Company
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order of tenu of pages.
There's quite a comparison in terms 2
of volume and also in terms of substance.
3 After the reorganization in April of last year,
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x-4 new management came to NRR and there was an increased empha-5 sis on in-service testing.
We conducted a number of surveys 6
of operating plants and of the current state of in-service 7
testing.
8 We tried to put into five discrete categories the 1
i l
9 problema that we face.
And it's not totally possible.
You'll l
l 10 see a lot of overlap, but it does give you some idea the l
l 11 types of problems that exist in these programs.
12 There are a number of technical problems associated
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13 with in-service testing.
There are inadequate and deficient 14 testing requirements in the code itself.
15 For example, the code requires that MOVs and other 16 power-operated valves be stroke time tested.
And we know 17 that for motor-operated valves, torques, stroke time test-18 ing is not a good diagnostic tool for assessing the health 19 of an MOV.
It only tells you whether the valve went from 20 one state to another state within a time.
It doesn't say 21 what's going on within the valves.
It doesn't say whether 22 it's capable of doing its job.
(,i LJ 23 DR. SHEWMON:
Now, if you know the valve is clos-fs 21 ing, that tells ycu comething about what's going on, doesn't t
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MR. MARS!!:
Certainly, certainly.
It certainly 2
does.
I'm not saying that stroke time testing is zero. But 3
in terms of what you'd like to know about the valves, stroke
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4 time testing is a small parameter.
The parameter is that it 5
does in fact move.
And that's not meaningless, it's some-6 thing to know.
But there's many more things that you need 7
to know about a valve other than it moves.
8 Another problem in the ASME code is pump testing.
9 Pump testing is basically done by vibration amplitude and by 10 testing some hydraulic parameters.
Not by any means a full 11 cpectrum of pump curve, but only at a discrete point.
12 We know that vibration--the state-of-the-art vi-
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13 bration testing of rotated machinery is to take velocity 14 profiles on the shaft itself and do spectral analysis and 15 trend the spectral analysis, first and second harmonien.
16 The ASME code only requires at chis point, however, 17 displacement and that's on the bearing housing.
It's not 18 even on the shatt itself.
19 What I'm trying to give you is a flavor,for some 20 of the inadequacies of the code.
And there are many and 21 although the code very recently has been starting to improve--
22 and I say starting to by working on the lastest standards
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V 23 OM-6 and 10.
There are still many inadoquacies in that docu-24 ment itself.
U 25 DR. KERR; IIow do you decide what it is that you Acme Reporting Company
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I need to know about pumps and valves if the ASME code is in-
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2 adequate?
3 MR. MARSil:
We rely on the code and the code re-V 4
quirements to tell us the health of the valves and this is 5
a basic reliance that started ten or twelve years ago, and 6
as our knowledge and as the deficiencies became evident in 7
testing requirements by the code--for example, it only re-8 quires stroke time testing for, example, pump testing.
P There's an increased state of knowledge that it's deficient.
We try to work with the code to get it to im-i 11 prove, but--
l 12 DR. KERR:
I guess I didn't word my question very
)
13 well.
Given that the code is inadequate, how do you decide 14 what is adequate?
15 MR. MARSH:
Okay.
There are many things that we 16 know we want now compared to what the code currently tells 17 you.
It comes about by looking at data.
It comes about by 18 looking at the very problems that have occurred, I don't' 19 mean to say that we know exactly what it ought to nave in it.
I 20 But we know that there are many inadequacies i-the code l
l 21 itself.
l 22 I'm not sure I've answered your question.
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23 DR. KERd:
I'm not sure you've answered in a way r
21 that is understandable to me.
It may meie complete sense to (3
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,v 25 people who know a lot about pumps.
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MR. liARSii s.Ask me another.way.
The flavor that
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we are trying-to.give you--
3 DR. KERR:
I'm willing.to concede.that.the code-O' 4-is inadequate, but' you are looking for something to: replace 5
it I assume.
6 MR. MARSil:
Yes.
t 7
DR. KERR:
Ilow do : you know what should be < used to 8
replace it?
9 MR.'MARSII:
Well, we know there are deficiencies 10 in certain areas of the code, and we know that we need:to
-i 11 improve certain areas of the code.
And those areas we can
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12 work on.
Beyond that, we have to wait for' experience to 13 show us how else the code is inadequate.
I'can only'tellT 14 you the known areas of inadequacy as opposed to the unknown 15 areas.
16 MR. EBERSOLE' Bill, I can relate:this to one of7 17 your favorite topics which is ATWS.
Remember we uncovered-18 the absence of margins of force in ATWS.
_It's a bistable, 19 function.
There's no laeasurement of margins of function to 20 operate under duress or wear or whatever.
And this is not i
21 known when it goes from red to green.
Whether you barely 22 made it or not or whether you had an excess of function to 23 overcome bad grease, bad settings or packings or whatever.
21 The -.movats system has gone a long way, i
25 MR. MARSII: Movats.is much'better..
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MR. EBERSOLE:
But therc are other matters.
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2 MR. MARSH:
There are other things that are still 3
3 deficient other than movats'itself.
n5Y 4
I think the best way to answer your question is 5
given the code requirements, the code is promulgated, the 6
utilities are membern of the code.
The NRC endorses the 7
code.
The utilities then take the code and say, "I'm going 8
to make a program out of it."
Then programs are de'reloped 9
and submitted to the NRC for review and approval.
10 We look at those programs and we see that there 11 are things that are not right.
Inspectors that inspect the 12 plant see that there are things that are not right.
So s
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13 there are a host of probleu areas and the implementation of x>
14 the code requirements.
And we try to work on those to make 15 them healthy, to make them better.
16 DR. KERR:
From what you've told me up to now, 17 one can, as an individual inspector, decide that we wanted i
18 to not get some information out of the code requirements and 19 maybe another individual inspector will decide he wanted i
20 something different.
What I'm trying to determine in whether 21 the NRC staff as an organized body could write a set of re-22 quirements vi
_f it were in the code would satisfy the
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23 testing that
.arovide the information that you think l
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25 MR. MARSH:
We are headed down that path.
We are Acme Reporting Company
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not there yet.
We are getting various organizations to assist S
2 us in doing that, in getting the code or getting the code 3
plus our own requirements to tell us what we want.
For ex-('\\
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ample, we don't have confidence in the frequencies that equip-5 ment is tested.
For example, pumps are tested on a quarterly 6
basis unless they cannot be, in which case they may have to 7
be tested on refueling guidance basis.
8 We don't know whether that's the right frequency 9
for pumps.
There may be some pumps that need to be tested 10 more frequently and some less frequently.
We don't know.
11 OR. KERR:
Do you have in mind a way of finding 12 out what the right frequency should be?
(s) 13 MR. MARSli:
We've started down the path.
And one v
14 thing to start at is at least with the data.
Let's find out 15 what these pumps are actually doing.
Let's target a certain 1G type of pump.
Let's look at what its operational experience 17 has been in the industry.
Find out what it's failure rate 18 is.
Based on its failure rate, look at the appropriate fre-19 quency to test it.
20 Right now the code says test all pumps on a quar-21 terly frequency unless you cannot because of operational f3 22 problems.
In which case you are allowed to do it on either V
23 a fueling outage or some other frequency.
The code made a j
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25 frequency.
We know that that iu not an approriate acsumption.
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Some pumps are operated contirnally.
Some pumps need to be
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For 3
example, the--
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3 DR. KERR:
That's enough.
Thank you.
I'm holding 5
you up.
6 MR. MARSH:
Part of the problem is jumping into 7
3 Presentation in the middle.
If we went through a long 8
presentation and described the background here--and I'm 9
ckirting through the -.ekground.
I'm jumping right to the 10 problem areas as we see them.
And it's going to be a little 11 disjointed for you.
12 DR. KERR:
I'll listen for awhile.
)
13 MR. MARSil:
Okay.
V 14 Given that the code has inadequate and deficient 15 testing requirements, one thing that could have been done ic la for the staff to issue supplemental guidance on what it 37 wants so that in cddition to the code, the code plus the gg staff guidance would then result in an acceptable testing l
39 frequencies, acceptable testing parameters, what you want.
1 20 Alco the staff--the staff didn't do that.
The 1
21 staff could have said, "This is what we want in IST programs
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programmatically.
This is what we want the format to be, l
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This is how we want to handle the relief requests.
This is 23 r-21 what we want in terma of program revisions."
The staff L) 25 didn't do that.
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The code--if you are familiar with the code,
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is divided' down into a group of subsections.
One 2
Section XII 3
of the subsections is IWA.
And IWA sayu "You will have cer-q\\'
4 tified inspectorn."
Now, the IST is in Section IWV and IWP.
5 And so because it's all under Section XI, IWA, IWV and IWP, 6
it implies that there are certified inspectors for the IST 7
area.
There are no certified inspectors.
There's no train-8 ing program.
There's no level of certification.
There's no 9
uniform way of ensuring that the people that are doing the 10 testing and are signing it are in fact up to the same level.
11 It's all done based on experience.
Operational experience 12 and training is done at the plant without their beiag a (ow) 13 uniform industrywide way of testing pumps and valves, 14 Those are some of the technical problems.
And 15 there are more.
16 DR. SHEWMON:
When you cay certified inspection 17 procedures, you have implicit in that knowing what it is 18 you want to test for also.
19 MR. KARSH:
Wait.
I didn't say procedures.
Cer-20 tified inspectors.
These are inspectors.
21 DR. SHEWMON:
Well, part of my problem though is e
22 you don't know what a certified inspector is until you know (mJ 23 what you wunt him to be able to look for.
(3 21 MR. MARSH:
Well, we know that we want the in-Q) 25 spectors to look at pumpu.
We know the code way of looking Acme Reporting Company
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at pumps.
The code may or may not be deficient, but there
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2 at least isn't that.
The code doesn't even say what these 3
things may not be the right parameters to look at, but we c's
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4 are going to require a uniform way of looking at these para-5 meters.
It doesn't do that.
6 We know that there are a whole spectrum of ways 7
of looking at MOVs.
You can look at them in movats.
You 8
can look at them in stroke time testing.
The code doesn't 9
recognize the various ways and say, from an inspector's 10 standpoint,an ANI, an authorized nuclear inspector, "This is 11 the way we want you to look at valves."
It doesn't do that.
12 The code spends a lot of effort and a lot of 1
./mi la training of manpower, time frame, on giving levels of certi-v 14 fication for an ISI inspector.
He wears a patch.
It's a 15 matter of pride.
There is no equivalent level.
16 Another perspective here is this is the active 17 mitigation equipment we are talking about.
This is accident 18 mitigation equipment.
This is the stuff that you need given 19 if the passive equipment fails on you.
The pipes fail on 20 you.
21 The code spends a vast majority--but let me-- I'm 22 cure everybody else got that same point.
Section XI has this x_-
23 much stuff on it, on the passive equipment.
And levels of 1
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l 25 it spends that much time and energy on the active equipment.
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DR. SHEiiMON:
Part of what they could do is sort
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2 of take that from the ASNT, whereas I suspect you haven't 3
got a professional group whose stuff you can have them write Y'
4 in.
5 MR. MARSH:
That's true.
6 In addition to the technical inadequacies of the 7
code and the lack of staff guidance in implementing the code, 8
there are other problems in IST program.
For example, there 9
are legal problems.
10 CFR 50.55A is inconsistent with the 10 technical specifications.
The technical specifications say 11 "You should not implement any relief requests at the plant 12 until they have gotten explicit written approval from the 3
(w) 13 NRC staff."
It's a tech spec requirement in about 90 percent 14 of the plants.
There is no wording like that in the regula-15 tion.
That's not to say that--you can go beyond the regula-16 tion in writing the technical specification.
But there is 17 that first level of inconsistency.
I 18 The regulation doesn't imply written relief prior i
19 to.
In fact, it implies the opposite.
The regulation implier 20 that you are supposed to have your relief request submitted 21 within twelve months of entering the program without saying
,eg 22 anything about explicit written relief.
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23 MR. EBERSOLE:
Tad, I just got today a copy of the
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21 interim policy statement on maintenance of nuclear power wi 25 plants.
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MR. MARSH:
Right.
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2 MR. EBERSOLE:
Are you moving--isn't this under 3
the cloud or whatever, that covered that ge'neral topic?
4 MR. MARSH:
Very definitely.
We've[had. input into 5
the maintenance policy statement and we've got some' things 6
in there that will improve it.
This is all the area of 7'
maintenance.
And there are industry, incentives to try and 8
improve IST from'the standpoint of maintenance, from the:
9 standpoint of' plant life extension and other ongoing generic 10 industrywide activities.
But the industry is not there,yet.
I 11 If you read what INPO said in.the attachment to, 12 that letter.
INPO sent a big document that was attached-to j
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13 the Commission paper.
It talked about what.they are doing.'
14 And there is precious little stuff there on IST.
I don't 15 think IST is even mentioned in what INPO is~trying to do.
16 So there really isn't--there's a discontinuity in 17 a level of consciousness difference in what we want.
18 The regulation itself is not a clear document.
It i
19 is self contradictory.
If you try to read it you'll see that 20 it was not written for IST.
It was written for ISI.
IST.
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21 was an afterthought.
It was added in parenthetically-almost.
i 22 And the technical specification--we've already O
23 talked about that problem.
It requires staff approval prior 24 to implementing relief requests and the reality of this j
25 situation is that because of the vast backlog in IST programs,
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and that means about 70 or 80 percent of the plants do not
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2 have approved programs, plants have to implement relief 3
requests without their being approved by the NRC staff, r'N (ic i
4 MR. EBERSOLE:
Well, those programs are,even in 5
their deficient condition as represented by the present 6
codes, it's difficult to even get that much done.
7 MR. MARSH:
That's right.
8 DR. S!!EWMON :
Mr. Ebersole, I'm sorry.
I can't 9
hear you.
10 MR. EBERSOLE:
I say he's talking about it being 11 difficult to get the little that is required already, which 12 is insufficient.
He's already having trouble meeting an in-(
13 adequate code compliance in Section XI.
w.)
11 MR. MARSH:
There are administrative difficulties 15 in the way we do in-service testing and the way the induntry 16 does in-service testing as well.
Because of this legal 17 difficulty, we have had to on many occasions issue interim 18 relief, and that means that if a plant happens to have an 19 inspector, a resident inspector, that's particularly con-20 scious of this technical specification, he may say, "You get 21 written approval from the NRC that this tech spec has been 22 met or that your relief requests are all right."
And in fact 7U 23 because of the backlog and you are not being done looking at
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21 the entire program, you issue interim relief until you are V
25 done looking at the program.
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into about four or five years ago and it's a pill.
It's 7._
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2 a bad way of doing business because it perpetuates the pro-3 blem.
It means that I'm going to get over this little hump i/
4 and in fact many cases the interim relief is either expired 5
or it was not issued at all.
There is a spectrum of that 6
type of problem in the utilities right now.
There are many 7
plants that have no interim relief from the NRC.
For those 8
that don't have safety evaluations, I'd say about half don't 0
have interim relief and a half do have some sort of interim 10 relief which may or may not be valid.
Because again, the 11 current state of affairs, the utility can spend its time ano 12 its effort writing an IST program.
It can submit the IST
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The Agency can take years to review that program.
15 Then the utility is left with having to make changes in 16 plants.
Having to make testing modifications and they will 17 have to change the program, so implement a new program with-18 out that even being submitted in some cases.
19 DR. KERR:
But somewhere in the organization there 20 must be a feeling that this is a fairly low priority activity 21 if what you are saying is true.
gg 22 MR. MARSH:
It was and it has changed now.
It has L) 23 a significantly increased consciousness.
And it's because r~3 21 of the management in the regions who are much more conscious 4
Q.)
25 of the problem that have come to NRR and said, "This has got 1
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to be fixed.
This has got to be changed.
This vhole situa-2 tion."
3 MR. MICl!ELSON:
I thought it was the valve situa-()
4 tion that really turned this on.
5 MR. MARSH:
The PIV problem, precsure isolation G
valve problem.
The MOV problem.
The check valve problem.
7 MR. MICHELSON:
The valve problem in general is 8
what I meant of course.
But I think that's what finally 9
turned it around.
When they suddenly had a rash of--they 10 developed a very good understanding all of a sudden of how 11 bad off their testing was to valves.
12 MR. MARSH:
I am going to go quickly through here.
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l (v) 13 You can get a feeling for the administrative pro-14 blems being aware there are 107 plants and there are many 15 programs and many revisions, all of which have come and 10 have many relief requests in them that have to be tracked, 17 reviewed and approved.
18 There are resource problems associated with that.
19 The problems are not eany problems.
There are things that 20 you have to think carefully about.
Review the systems.
21 Review the safety analyses.
So there's that part of the
-s 22 problem.
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23 We have a large contract with EG&G, a group of (m
21 very expert people who review the programs for us and with I
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25 us.
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DR. KERR:
Is this contract to help you eliminate
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2 that backlog of requests for interim relief or something or 3
other?
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4 MR. MARSil:
Yes, it's two parts.
The major part 5
of the contract is reviewing programs, getting rid of the 6
backlog and also keeping up.
Once you review one, there's 7
going to be another one coming in the door for this plant.
8 So it's to review that, and it's also to write guidance.
9 It's also to take the technical positions that have been 10 developed, to articulate them, to give a bases for them so 11 that we can go on.
12 One source of the problem has been--you ask the (sv) 13 ASME code, what is the basis for this requirement?
Why do 14 you apply testing on this frequency?
Why do you require 15 testing in this way?
There is no basis.
There is nothing it; there.
You can't find out why, technically why it was done 17 in this way.
)
18 So when you have to entertain relief requests, 19 you don't know where to turn.
You have to use recent judge-20 monts and you do not know the bases for the original.
21 DR. KERR:
Doen EG&G know where to turn?
22 MR. MARSil:
EG&G knows the basic--the technical
-s e s LI 23 logic that they use, that has been developed informally ad g3 et hoc to assess programs and relief requests.
But that's a C
25 starting point.
They can write that down and articulate.
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That's never been done.
But that's a starting point.
We n
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2 may not know the bases originally for the ASME code require-3 ments.
But at least we know where we are now as a starting O
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4 point.
5 And you can understand there's the enforcement 6
problem associated with technical specifications and the 7
lack of SERs.
The SER is relied upon explicitly in the 8
technical instruction for the inspector.
That's what they 9
use for their inspections.
And if there's not a safety 10 evaluation done, they have nowheres to turn to use as the 11 basis for inspection.
12 MR. WYLIE:
Let me ask a question.
Under "Admini-(,,)
13 stration" in the first bullet up there, interim relief ex-x_.-
14 pired.
That's "or nonexistent" is it not?
15 MR. MARSil:
Yes.
16 MR. WYLIE:
From your knowledge of what exists in 17 the industry, how would you say that the percentage of relief 18 requests compare to those that don't exist?
They just 19 simply go ahead and do it, 20 MR. MARSil:
I would say--Ted, can you help with 21 that?
In terms of a fraction?
22 MR. SULLIVAN:
T would say at One time or another
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21 approvals.
But many of them have not been made current and C)/
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program, the interim approval that was given before is really 2
out of date with respect to those items that were changed.
3 MR. WYLIE:
Does that imply then that 60 percent
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t/
4 of the plants are illegal?
5 MR. SULLIVAN:
I would put the number lower than 6
that, because remember we have a certain percentage somewhere 7
in the neighborhood of 25 to 30 percent that do have SERs.
8 Now, about half of those SERs are out of date.
In that some 9
additional relief requests have been submitted.
So it's 10 really quite a mixed bag.
You could say that at some plants, 9
11 some of the relief requests are legal and others are not.
12 MR. WYLIE:
I sort of get the feeling in listening
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13 to all of this that we've got a large number of plants out 11 there that are just ignoring the toch spees.
15 MR. MARSil:
I do want to say that the cituation 16 has been developed jointly by the industry and by the NRC.
17 The NRC is deficient in not having gotten the programs and 18 the relief requests done.
19 MR. WYLIE:
Oh, I understand.
20 MR. SULLIVAN:
Oh, I understand there is fault on i
21 both sides.
Because the situation is what it is and it's so
,3 22 voluminous that you haven't been able to handle them and V
23 we got into this situation.
r'S 21 MR. MARSil:
And, you know, legally speaking, the 25 resident inspector and the regional staff are allowed to use
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discretionary enforcement.
So although the technical spe-
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2 cification may say X, we are allowed to deviate from X if 3
the regional administrator says that's acceptable.
If it n
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4 is evaluated in that way.
So although there is clearly a 5
problem that way, I don't want to say that--in some plant 6
levels it may have been explicitly evaluated and thought to 7
be all right.
8 MR. EBERSOLE:
Tad, I would like to make a comment 9
about the safety implications of what you are talking about 10 which I think is a major issue for us.
I think it's this.
11 The plants run on everyday and they make megawatte and they 12 look like they are running pretty good.
()
13 And the PRA boys happily work with the statistics L-14 of valve and pump operation that they see unfolding from 15 normal operations.
Yet we have no real knowledge of how the 16 pumpc and valves will perform if they are mot with a duress 17 situation of emergency flows and pump requirements and so 18 forth.
In short, we don't know whether they will rise up and 39 meet the safety challenge.
20 MR. MARSH:
We have some assurance.
We don't have 21 the assurance that the IST program ought to be giving them, o.o MR. EBERSOLE:
Yes.
~
G' 23 MR. MARSH:
In my opinion the IST programs are
(~
21 not giving what they were intended to give.
\\
v' 25 Let me go on.
After trying to first understand Acme Reporting Company
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all of the problems that there are, and I don't want to imply
/
2 that we do understand all of them.
Everytime we sit down 3
and collectively go through IST programs with experts and r~)
'KJ 4
with the industry with the ASME code, more problems come to 5
our knowledge.
6 There are a number of policy procedure changes that 7
we are considering.
And in another session, in a closed 8
session with the subcommittee we did talk more explicitly 9
about where we are on these proposals.
There are some of 10 these that are further along in terms of internal concurrence 11 and internal management decision making than just the forma-12 tive stages, so this is just a list of potential policy m(v,)
13 procedure changes, some of which are further along than 14 others.
15 Because of the deficiencies in the O&M and in the 1G section--O&M is Operations and Maintenance subgroup of the 17 Section XI.
Because of the deficiencies on Section XI IWV 18 and IWP, and the lethargy of development of codes and to standards in IST and there is that, there are administrative 20 problems within the code itself in trying to get things 21 to move along, and the fact of the matter is the code hasn't 22 changed in the IWV/IWP area since s development.
There
-)
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23 have been minor changes, but nothing substantive at all.
24 Because of that lethargy, one question that we are consider-V 25 ing is should the NRC continue to rely on that code-making Acme Reporting Company
171 I
MR. MARSil:
Process?
or shojld we develop our own-l tO 2
code for puups and valves, ISP standards which may be based on DB, IWP i
3 supplenented by our own technical guidance documents.
O.
4 DR. KERR:- Do you think the NBC is capable of doing _this?
MR. MARSil:
I do, I certainly do.
I do because I'm 6
very vamiliar with the requirements in the code itself.
I am 7
familiar with OH-6 and OM-10 and I am familiar with the defic-8 iencies there and I think I am familiar with the expertise that i
9 that is available both here and at the contractors and I-'cer-10 tainly do.
.I think we have--I think we're capable of that and 11 I think we are very capable of doing that.
12 What-do'you mean?
13 DR..KERR Well, the ASME coce development, actuall}
14 I believe code. development and other kinds of developments arc 15 rather complicated processes and they involve edpertise on the 16 part of the corporations and individuals, I assume.
I didn't 17 realize that sort of expertise was available within NRC, but 18 it may be.
I was just curious if you were capable of develop-19 ing standards superior to the ASME code.
20 I don't doubt that, but I didn't realize it.
21 MR. MARSil Please understand, it's not very diffi-22 cult to go be. yond the code requirements right now. It does 23 not take a great deal of expertise to build upon what--upon 24 what's there.
25 DR. KERR:
I thought you had told me earlier that Heritoge Reporting Corporation j
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you.really were't quite sure of what the recuirements.should 2
be, you were'on the road to gettina there, but you didn't know 3
what they should be.
O MR. riARSii:
we don t--how con 1 enewer thet2 we 5
know what is wrong with the code, we know what we want today.
j 6
Other things may be developed further down stream.
7 DR. KERR:
Okay.
~
)
8 DR. S!!EWttON :
If you did this, would these go out
)
9 for public comments or would we' staff the branch technical, 10 position, which is now unreviewed and becomes law by default 33 or--
l 2
12 MR. MARSil:
One thing'that is being considered 13 is to change the regulations, MTFR 55-A, to explicitly 34 endorse the latest code version, which is not INB and IWP, is but OM-6 and oft-10, which is better than IWB, it is better.
I t j
16 still has deficiencies in it. We would supplement OM-6 and 17 Ot'-10 by our own technical guidance and recuirements along with I
i is some explicit cuidance on hcw to implement the code recuire-39 ments.
That would be in the' form of regulatory cuide or some 20 other regulatory document and yes, that would have to go out 23 for rule making, it would have to go out for public comment.
22 DR. KERR:
But not the regulatory guide?
4 O 4
23 MR. MICl1ELSON :
But not the regulatory guide?
24 MR. MARSil:
The reg guide would go out for comment i O 23 too.
1 i
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MR. MICHELSON:
But not for rule _ making.
There's_no O
2 approval process.
It can be issued immediately for that matter.
3 MR. MARSH:
True.
If you reference,it directly in 4
the rule, and one thought is to do just that and then we'would s
send that out for public comment =too because we really do want 6
comment on that type of process.
It would not be done in the' 7
dark.
8 MR. EBERSOLE: I wish the full committee in hearing 9
this would be listening to what should the full committee do l
10 to endorse this, whichever way we go because I think this is 11 a collaborative situation.
12 MR. MARSH:
It's clearly that and we do need your
{
13 comments and your thoughts and your feed back on this approact 14 MR. EBERSOLE:
At this time, you're not looking for i
is any letter but you're going to be looking for one in due timei i
16 MR. MARSH:
We'll be talking with your as things ao We will need your feed back then as we need it now.
17 on.
18 What I tried to leave you with today more than any-i 19 thing else is a feeling of the problem rather than of a feel-20 ing of the way we're going to go.
21 DR. KERR:
Is that list up there intended to give i
22 us a feeling for the problem?
23 MR. MARSH: I'm'sorry..
24 DR. KERR:
Is the list up there intended to alve us 25 a feeling for the problem?
Heritoge Reporting Corporotion imen===
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'MR. MARSil:
The previous slide is intended to give
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2 you a feeling for the problem, the five problem areas as we i
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3 saw them, the technical, legal,administ'rative, resources q
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and the enforcement, those are the areas of concern.
a s
DR. KERR It would appear to_me that you would want il 6
and could expect to get, meaningful advice from the ACRS only 1
I 7
on the technical part.
The others are important, but I don't i
~
8 think the ACRS has any particular expertise'in this though..
j 9
MR. MARSH:
I agree.
10 DR. KERR: 'Okay.
4 1
11 MR. MARSH: I agree, but if there is rule making in-1 4
12 volved.
13 DR. KERR: So technical, there's inadeguate testing
()
-l' 14 requirements.
Is there general agreement among the ACRS that i
15 this is a valid statement?
I 16 MR. WYLIE:
I think so.
b a
17 MR. MICHELSON:
I think so.
i 18 MR. EBERSOLE: Want to take a vote?
We can take a 19 vote.
I'll vote yes.
20 MR. EBERSOLE:
I'll vote yes.
I 21 MR. MICHELSON:
Very valid, i
22 MR. WYLIE:
I think the code is out of date.
I i
23 MR. MICHELSON:
Totally out of date.
?
I 24 MR. EBERSOLE:
It's antique
(:)
25 4U1. MICHELSON:
It's ridiculous,
~
i Heritoge Reporting Corporation l'
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DR. KERR It sounds'to me as-if you're getting almo st 2
a 200 percent endorsement-for those 3 positions.
3 MR. MICl!ELSON:
The Code Committee's are well aware 4
of how poor this is.
The'y h'aven't gotten'the where with all 5
to make the changes and there are a few obstructionists out 6
there.
7 MR. MARSil:
There is.also the administrative problem s
in the code itself.
There was Section-11, Section 11 was 9
charged with the responsibility of pumps and valves.
Section 10 11 gave that responsibility to another group, O&M, Operations is and Maintenance, so O&M thought they had the respcnsibility 12 for the pumps and valves testing department.
They developed O
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34 look at it.
So now we end up with this problem, back and is forth between Section 11 and O&M.
Who has the responsibility 16 for pumps and valves?
17 And if you know, code committees meet plurally and 18 if you're locked in, going from one group to another group 39 to another group, there really is--
20 MR. WYLIE:
Again I would think this is'a problem 21 in which the ACRS can't provide much help.
I don't see how 22 we can.
23 MR. MIC11ELSON:
I think we can.
24 MR. WYLIE:
I think we can tell you that we agree 25 that new requirements are needed and--
Heritoge Reporting Corporation m s sm a
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g MR. MARSH:
There's'more--there's more here than O
2 just the technical too.
j 3
DR. KERR:
I agree.
4 MR. WYLIE:-
I am trying to. separate that part of 5
the problem with which ACRS can provide assistance.and that' 6
part with which it can't..
Maybe I'm wrong.
.q 7
I think the complexity of the situation and the fact 8
they are unable.to cope with all these interim requesto has
)
i 9
got the situation to where 'the plants weren't even built in
.l 10 some cases to be'able to conduct the tests.
33 MR. MARSH:
That's true.
1 i
I 12 MR. WYLIE:
They've got into the situation and they 4
()
33 need a procedure and I think that's what he's leading up to.
34 MR. MARSH:
A new method.
15 MR. WYLIE: A new method of handling these things 16 that will be more efficient for both the utility and the 17 NRC.
1 18 DR. KERR:
As I.said, maybe I'm wrong, I see all of 39 these as serious problems.
I'm trying to pick out those to 20 which the ACRS can address itself and provide some assistance, 21 MR. WYLIE:
I sort of see it on the basis that i
22 you've got a bunch of plants out there that are-in violation
()
i 23 of their tech specs because they got'into this situation.
i i
24 It's an unsafe situation--
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25 DR. KERR: 'The mere fact that they are in violation 1
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3 of the tech specs 'doesn ' t!' m'ean to fue.~ that they 're ~ unsafe.
2 MR. MICl!ELSON: It does in this case.
3 DR. KERR:
You can't conduct the. tests.
4 MR. MARSil:
There'is a problem--
5 DR. KERR:
Mr. Steindler is trying to get a word 6
in.
7 MR. EBERSOLE: Just because he's polite.
8 DR. STEINDLER:
Are there enough data available 9
to put a rational code together?
10 MR. 1%RSH :
My opinion is-yes.
11 DR. STEINDLER:
Are'there statistically valid testir g 12 Procedures based on information that exists either in the 13 literature or in experience?
14 MR. MARSil:
I believe there is.
The reason I is believe there is, we know several things.
Fe know strobe 16 testing of MOVs doesn't afford you the kind of assurance that 17 you need.
There are other diagnostic tools available to look 18 at MOVs and that's state of the art.
19 MR. MIC11ELSON: And that's where the arounent starts, 20 There are ways to do it, but they're not easy and they're not 21 cheap.
22 DR. STEINDLER:
I'm familiar with--valves and pumps O
23 are not my forte'.
I am familiar with the testing standards 24 for other kinds of equipment and the generation of rationalized 25 data that leads you to reliable standards so that you can Heritoge Reporting Corporation (att) Meet
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3 determir e the relationship between: the testing procedure and O
2 the subsequent, presumed improved performances.
That's a very I
3 long and time consuming proposition, especially in diverse-services and diverse designs that you might-have here..
4 So my cuestion--that's the basis of my' question..
5 6
I think that's available
)
7 MR. MARSH:
I think that's available.
1 g
DR. STEINDLER:
But I think we have how many hun-i 9
dreds--thousands of reactor years of experience including 10 valve performance, pump performance do we have?
11 I'n looking, not for the performance, bllt the' -
12 relationship between testing and the diaonostics that you 13 get out of that and the subsecuent perfornance.
I DR. KERR Mr. Moeller wants to get in'at least two 34 l
15
- words, g
DR. MOELLER:
I need some help because I have just 17 finished reading, this morning, the Commission's interin 18 policy staterent on maintenance and it says that it is the objective of this Commission that all nuclear power plants
]
39 shall be maintained in perfect working order, particularly any 20 21 safety related components and se forth.
Now is testing part of maintenance?
If testing is 22 O
part of maintenance or if you test in order to tell if this
)
23 i
pump or valve needs some maintenance, then we're in a heap of 24 O
trouble because the first sentence up there said that inade-25 Heritoge Reporting Corporation l
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quate and deficient testing requirements exist in ASME code
,y 2
and then you're coina to correct that,-but you're confident 3
then you can correct all of this in time to implement this
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interin policy statement on maintenance?
5 MR. MARSH:
The interim policy statement, it's the 6
1 statement that says you should go out and you should be assured 7
that you have got programs and procedures in place to make 8
sure--
9 DR. MOELLER:
Yes and you want every utility to have 10 written procedures for the maintenance of every safety related component or piece of eauipment.
How are you going to do that 12 if they don't know how to test them in order to tell whether
()
13 they are performing adequately, either before or after the l
14 maintenance?
15 MR. MICllELSON :
They do know how to test through 16 many of the tests, particularly on valves, but they are not 17 simple, they are not--they're expensive, they're complex, thes 18 don't want to set up the--they don't want to close certain 19 valves and pump sections of pipes so they can do rea;orwble tests, 20 MR. MARSH:
I'm not coing to take those valve proh-21 lems, I'm not going to take them, 22 MR. MOELLER:
This then is intertwined with the f
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policy statement on raintenance?
23 24 MR. MICHELSON:
Absolutely.
,(
25 l MR. MARSH:
Fe had input into it and--please look j
Heritage Reporting Corporation ino.a.
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at.the attachment to:it,'the Commihsion paper, where they talk O
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2 about--where they test the INPO letter.
3 MR. MICHELSON:
One-of the big nroblems, Dade, is
!O efteryddewemeineensncehowdeyouxnewthee2uipmentis 4
l 5
now going to do what it is supposed to originally- -
6 DR. MOELLER:
Right.
i 7
MR. MICHELSON:
It is supposed to originally--
1 i
R DR. MOELLER:
Correct.
That's what I'm'saying.
i 9
DR. KERR:
Does that answer your cuestion, Mr.
i i
10 Moeller?
il DR. MOELLER:
I think so.
12 MR. MARSH:
I want to give you a specific example, j
t 13 In the Davis Vessey event, they had difficulty re-opening the-14 containment isolation valve in the of f speed water syster:..
15 Three weeks before that--a month before that, the inspector f
16 witnessed an in service test on that. valve, strobe time tested 17 it.
He wrote it up in his inspection report.
i 18 Strobe time tasting is not going to make sure that 1
19
alve opens against the differential pressure, however, be-j 20 cause it meets the code requirements, it's basically a closed 21 item.
22 Have you seen the statement that he made?
And that 23 was the very valve that did not open during the event.
It's i
1 24 a deficiency in IST, it is truth.
!O 25 MR. MICHELSON:
Just like we believe that on after 4
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water clean up, if we ever bust one of those non safety grade
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i'l pipes out there, that those two valves would close, but there 2
3 is no test to prove it, no periodic test to prove it, nothing
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to prove it.
It's our faith that if you do a nominal load 4
m 5
test, it's also a full load test.
6 DR. KERR:
Please continue, Mr. Marsh.
7 MR. MARSH:
A possible menu of things that can be 8
done and as I said some are further along in process.
9 You can read, should we continue to rely on the 10 codes to develope its own status for in service testing?
11 Should you recuire prior written approval on these reauests?
12 To what extent should up dates to the latest code wording be
()
13 required?
Given that the code, in its position stated, U
g4 has not even progressed, should we continue to recuire ten 15 year updates to a code that hasn't progressed.
To what l
16 l extent should the interim release be utilized?
I 17 l I'm going through these auickly.
The important oner 18 here are this one, the first bullet,should we continue to rely
)
19 on the codes.
Should the updates be reauired?
Should the 20 NRC in service testing methods be more inspection oriented I
thus the program relief would be oriented.
2:
22 One thing we're thinking seriously about doing is oN]
23 re-formatting--revamping the IST process after better techni-7_s 24 cal guidance is developed on how to do testing, how to evaluat e i
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Whether they're reviewi ng Heritage Reporting Corporation na u.
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1 a lot of programs to make.sure what's in the plant level is O
2 being done properly.
In,other words,_ turning it from an offic a 3
- review to a planti review.
Shonld licensees _ be allowed--this:
O 4
is another important one too.
5 We find.there is a very big. spectrum of. quality and 6
knowledge of IST across the industry.
There are big utilities 7
some of which have devoted a lot of resources and a lot of 8
money developing good technology for testing equipment.
It 9
goes beyond the code requirements, it clearly does, but-they-do-10 it.
Il Those other small utilities that don't have that 12 capital investment, can't put that dollar knvestment into it, 13 that symposium and a regional counterpart could give informa-14 tion across the industry, something that could mutually be 15 beneficial for all.
It would also help us in developing new 16 requirements.
~
17 There are some short terms changes that we are 18 thinking about doing and that is generic letters and other 19 processees to try and get control 07 the more immediate prob-20 lems, that is the technical specification problems and the 21 licensees being able to change the programs without any ksow-22 ledge of the NRC at all, without any concurrence.
23 MR. MICHELSON:
Well, one of the bullets that is not.
24 there that is fundamental to this business and that is, shoulc 25 we allow nominal load testing where full load testing is Heritage Reporting Corporation m sn
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MR. MARSH:
Right.
2 3
MR. MICHELSON:
The code does not' require full, load 4'
te s t ing.
You can takelEhatever point you want-to do your-3
' test, nominal load, interm'ediat'e load, full load, whatever, 6
but it is' basically impractical, to put full differential pressure'on or to put* full fl'ow 'the devi'se and why ' don't we 7
test them under:the worst condition that we could practically 8
9 apply.
10 MR. MARSH:
That's.the cuestion of the adeo.uacy of 11 the of the testing procedures.
12 MR. MICHELSON:
It's inadequacy of.the code really.
13 The code simply doesn't reouire it--
14 MR. MARSH:
Right.
15 MR. MICHELSON:
--so,they don't do it.
16 MR. MARSH:
Nor do we.
17 MR. EBERSOLE:
Let-me give an example here.
Carl 18 just used the reactor clean up valve as a case in point where there is some jeopardy.
I'm going to use an ancient 39 20 model some 20 years old which is the HPSI 10 inch main steam d
21 supply line and the ancient old problem where this interfaces 22 with the machinery room of 3 units at Browns Ferry.
O Here again,'we don't'know whether these valves are 23 shut or not and we know if we have a pipe breach and they don 't 24 close, very likely we will lose all 3 units.
25 Heritage Reporting Corporation
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Now I'get back down to who is responsible for this
- q-D state of affairs.
We push it on the industry.
The industry 2
3 says, oh, I've complied with the regulations and it comes up
'4 and it floats around and everybody points at everybody.
Whose 5
baby is it?
6 MR. MARSH: I'm not sure it's importantLto say_who 7
is responsible but--
8 MR. EBERSOLE:
I know, but somebody has got to say 9
who referred it. to me, I'm= going,to fix it.
10 MR. MARSH:
The in service testing is inadequate, 11 MR. EBERSOLE:
I'm saying ability to fix is based 12 primarily on the party who is the who.
O 13 R. KERR: if th se pe p e wh have been responsible 14 for nuclear design at TVA, when the-plants were built, had 15 been in on the fall, this situation would not exist.
16 MR. EBERSOLE: It's universal.
That was one of the 17 reasons I ain't there.
18 DR. MARK:
There was a rather spectacular-situation,
~
which I think bears on this at San Onofre about a year ago.
19 20 MR. MICHELSON:
Yep.
21 Dx. MARK Has anything happened since then that 22 removes the rather frightening thing that was discovered there?
Ov 23 MR. MARSH:
You're talking about the check valve 24 incident?
25 DR.
MARK:
The check valve--
Heritage Reporting Corporation
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MR. MARSH: I don't want to saythat things have
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2 gotten much better but after the check valse phase at San 3
Onofre, there was an INPO SOER, I'm sure you're aware of that.
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4 INPO developed some guidelines for testing and inspecting s.
check valves and systems, all types of systems, in that SOER.
6 In fact, there is a commission paper that is being 7
developed now to address what we have found out since that 8
SOER was = developed and 'is supposedly implemented: at ' plants.
9
'We have done some inspections.
10 DR. MARK:
So there is an example where there 11 probably has been or is in the-course of becoming some improve 12 ment.
()
13 MR. MARSH:
Some improvement, but there is much more 14 to be done.
is MR. MICHELSON:
Was there any improvement?
16 MR. MARK:
In some plants, yes, in some plants, no.
17 Plants that were inspected were Millstone, St. Lucie,. Trojan, 18 Zion.
Of those 5, there was some that had.done pretty well i
\\
l 19 in implementing the SOER requirements.
1 20 MR. MICHELSON:
Many of the valves involved in that 21 event aren't even required to be under this program.
22 MR. MARSH:
That's true.
23 MR. MICHELSON:
They simply aren't even in it and g
were not deemed safety related.
23 MR. MARSH:
And in that--
Heritage Reporting Corporation n=> m
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DR. MARK:
It always struck me that it was something 2
about which something'should happen.
3 MR. MICHELSON:
But so far, they're.still-outside
- m 4
the program unless Philly decides to stick them in their pro-5 gram as a--
6 DR. SHEWMON:
When you say, "outside the program,"
7 you don't mean outside Tad's program but outside--
8 MR. MICHELSON:
It's'outside-Tad's program.
9 9
MR. MARSH:
Some of these valves may be outside
~
10 our program.
11 DR. KERR:
'I'm. convinced that things are in lousy 12 shape at the present time.
What I am interested in is what do 13 we do to correct them.
14 MR. MARSH:
Okay.
We're working on that.
I don't 15 have all the answers, but we have some' things under way.
16 DR. KERR:
What can ACRS do to be helpful'to you?
17 MR. MARSH:
I think I need your feedback.
Probably 18 now, at this point in the process, it's too early in the pro-19 cess.
When we talk commission paper and rule change and 20 things of those sort, making sure you're abreast of it and 21 that I keep you informed of what's going on.
22 We are talking to the code extensively.
We are in-23 volved at the Ot.M in its Section 11.
We carry this message 24 that we're very concerned about in service testing and they're 25 carrying that message up to their management team.
We're also.
Heritoge Reporting Corporation von m a 4.
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working through research making sure they carry the message O
2 to the highest levels of the industry, and the code as well.
j 3
DR. SHEWMON:
If I kept quiet, would you add-INPO to'that or not?'
4-5 MR. MARSH:
Yes, sir.
INPO was at'the O&M meeting, 6
NEWMARK was there, EPRI was there and we through basically the 7
same presentation that I have gone through here today, but in 8
more detail, and I said, this is an overlapping concern.
In 9
that meeting we had service testing people, we had plant 10 life extension peohle,'we had INPO..'with check valve problems.
11 We had NEWMARK on industry oversight issues.
12 There'is a tremendous opportunity for the industry 13 to form a group,in some collective way, to address these prob-14
' ems and to address the policy statement the commission is 15 concerned with.on' maintenance. This'is a window of opportunity 16 if you will.
17 MR. EBERSOLE:
Even now, couldn't you stick a little 18 life in the glacial response of the code writing groups by 19 sA.aing if you don't move before x date, we will have moved.
20 MR. MARSH:
That's exactly what we're going to do.
21 MR. EBERSOLE:
When are you going to tell them that.
22 MR. MARSH:
We're not giving them dates at this 23 point because that is not right yet internally.
When we have 24 considered this to the extent that we're going to make that 25 statement.
What I mean by that is that when we get the Heritage Reporting Corporation
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1 management concurrence that says, yes, this is the way we O,_
2 want to go, in other words when it becomes public, then we 3
can say.that.
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4 Al Orlotto who is on the Eberd of. Nuclear Codes and l
5 Standards can say and.is saying now that the NRC is very con-6 cerned about Section ll,'IST testing.
There are things that 7
are being considered like taking it away from you, like not 8
endorsing it, like doing our own and if you want a standing
-l 9
endorsement'for developing business, get hot.
10 MR. MICHELSON: There isn't any disagreement, is 11 there, on the technical--issues?
The. disagreement, I think, 12 is coming on how to accomplish it.
()
13 MR. MARSH:
The'best way-to go forward.
14 MR. MICHELSON:
I think everybody tha't I have talket 15 to on this issue seems to have no problem with the needing 16 correction.
But how to go about, there is quite a differencc F
17 in opinion there.
18 MR. MARSH:
Even the CodefCommittee, even the people l
19 that are responsible for writing OM-6 and 10, the working 20 group, they completely agree.
21 MR. EBERSOLE:
That's why I was asking, who bears 22 the brunt, the point responsibility for this state of affairs
. (:)
i 23 DR. KERR:
I detect so much harmony in this group,
(~N 24 that I am not sure we're getting anywhere.
d 25 DR. SHEWMON:
Will there be a letter at this meeting?
Heritage Reporting Corporation m.
.f 189 I
DR. KERR:
No.
O D
2 MR. MICHELSON:
No.
3 DR. KERR:
What I heard was that he didn't want a 4
letter until he got-to some point where he could say this is' s
what we plan to do, what do you think.
Did I misunderstand 6
you?
7 MR. MARSH:
No.
A' letter of endorsement would be 8
fine.
A letter of endorsement saying--
9 DR. KERR:
What are we endorsing, that the ASME 10 code is in lousy shape?-
11 MR. MICHELSON:
I don't think we should endorse.
12 anything because you haven't proposed'anything yet.
Ithink'aketterisprobably~ premature O
13 MR. MARSH:
14 at th is point.
We want to keep you aware of the problem and 15 where things are and as we get to the proposal stage, the 16 generic letter, the commission papers, the plans and the 17 endorsement of those specific approaches, we could present 18 it at that time, would be better.
19 DR. KERR:
Okay.
20 MR. MARSH:
There are things the industry can do 21 and obviously improve the code, over which a group could be 22 lormed, they were never formed, but it's not too late to do-23 that.
NEWMARK, a high profile group could be involved.
24 One thing we noticed, when ue go to these utilities 25 that have spectrical plants, we say let's talk to your IST Heritoge Reportir.3 Corporation oon m a
' Q) 190 1
. coordinator, let's find out where you are in separation.
2 The first thing they do, they say,.you mean ISI.-
We.say no, 3
we mean IST.
IST, you mean maintenance.
All right, let's' 4
talk to your maintenance coordinator.
5
'They get together with us and we have several-times, 6
IST people from the plant, and this is the first time they 7
have gotten together.
There is no corporate; coordination 8
for the utilities to have more than.one plant and that's 9
not a good state of affairs.
There is much to be gained 10 from a plan, from.a corporation standpoint.
Making their 11 programs uniform in developing one~ position.
It hasn't got 12 to that point.
And then can, of. course, improve their pro-13 grams and submittals.in timeliness.
14 We find a lot of leveraging in trying to respond 15 to what we are trying to do.
16 Conclusions, I think are obvious.
We have already 17 talked about them.
It's going to take some time, that's the-18 main thing, to improve this situation.
19 MR. EBERSOLE:
Are your own resources satisfactory j
20 to you with respect to this, the rapidity with which you will 21 get into this thing?
22 MR. MARSH:
Right now I have adequate people at the 23 NRC.
I have a Section, Ted'Su11ivan is.the Section~ Leader.
24 He hadr a complete section which is more than the NRC has ever 25 had for IST.
But, I have a special assistance probelem.
Heritoge Reporting Corporation m usa
191
.s The contract, that I referred to earlier has just q\\
been cut because of Gramm - Rudman and succeeding things, so 2
3 I am not sure how that is going to do at.this point.
(
One of the keys in this thing is developing technical 4
5 guidance, that is what do we want and if my contract assistance.
6 is cut to the quick where I can't do that, that hurts, that 7
hurts.
How.quickly I can get it done as well as the quality i
8 of what I get done.
Thank you.
9 MR. MICHELSON:
One other comment.
One of the thing s I thought the committee might want to do is when we talk to 10 NEWMARK we ought to solicit their views on this particular gg 12 Problem.
I think we're going to talk to'them tomorrow.
13 DR. KERR:
Will you take it upon yourself to make
(])
sure that we do?
g4 15 MR. MICHELSON:
Yes, I-will.
We obviously don't 16 have any position ourselves, but I think we ought to find out I-7 what they are doing and.how they are proceeding and if they 18 have any ideas.
I am sure they are well aware of the problem 19 and so that would be about the only thing that might help a 20 little bit at the moment is to bug them a little on it.
21 DR. KERR:
Next item.
22 (Whereupon, at 4:00 p.m.,
the committee concluded 23 this portion of the presentation.)
()
25 Heritage Reporting Corporation
<=>
_., ~.
a 1
REPORTER'S CERTIFICATE O
2 5
3 DOCKET NUMBER:
4 CASE TITLE:
333rd ACRS Meeting 5
HEARING DATE:
January 7, 1988 (3:00 to 4:00 p.m.)
6 LOCATION:
Washington, D.
C.
m 7
m V
8 I hereby certify that the proceedings and evidence 6
[
g herein are contained and accurately on the tapes and notes E5!
10 reported by me at the hearing in the above case before
+
h Nuclear Pegulatory Commission, ACRS 11
)
2 12 and that this is a true and correct transcript of the case.
J O 'E is 5
tl 14 Date:
15 s-n2n it
/2/?
t 16 Official Reporter 8
ACME REPORTING COMPANY, INC.
17 1220 L Street, N. W.
Washington, D.
C.
20005 g
18 19 20 21 5
22 23 O
Acme Reporting Company u..
t INSERVICE TESTING O
OBJECTIVE - TO ASSESS OPERATIONAL READINESS OF SAFETY RELATED PUMPS AtlD VALVES, PROBLEM AREAS TECHNICAL
- IliADE0VATE/ DEFICIENT TESTING REQUIREMENTS IN ASME CODE
- NO CERTIFIED INSPECTORS LEGAL
- 10 CFR 50,55A INCONSISTENT WITH TECH SPECS
- P0ORLY WORDED 10 CFR 50,55A (SELF-CONTRADICTORY)
- TS 4.0,5 REQUIRES STAFF APPROVAL PRIOR TO IMPLEMENTING Q
RELIEF REQUESTS ADMINISTRATIVE
- INTERIM RELIEF EXPIRED ON NONEXISTENT
- LARGE VOLUME OR PROGRAMS / REVISIONS / RELIEF REQUESTS
- LICENSEES IMPLEMENT NEW PROGRAM REVISIONS W/0 NRC APPROVAL OR PRIOR NOTIFICATION l
RESOURCES
- COMPLEX PROBLEMS / RESOURCE INTENSIVE
- LARGE CONTRACT - EG8G, 7 PEOPLE, $800K ENFORCEMENT
- TECHNICAL SPECIFICATION PROBLEM
- LACK 0F SERs HAMPERS INSPECTION EFFECTIVENESS O
)
)
f*4 l
NRC POLICY / PROCEDURE CHANGES BEING CONSIDERED
'O SHOULD NRC RELY ON SECTION XI/0FM TO DEVELOP PubP AND VALVE IST STANDARDS?
SH0J' LD NRC REQUIRE PRIOR WRITTEN APPROVAL OF RELIEF REQUESTS?
TO WHAT EXTENT SHOULD UPDATES TO A LATER CODE VERSION BE REQUIRED?
TO WHAT EXTENT SHOULD "INTERIM RELIEF" BE UTILIZED?
i SHOULD THE "EXIGENCY" POLICY BE UTIll2ED IN HANDLING EKRGENCY RELIEF i
REQUESTS?
l 4
O SHOULD NRC IST EFFORTS BE MORE INSPECTION ORIENTED AND LESS PROGPM AND RELIEF REQUEST REVIEW ORIENTED?
I SHOULD IST PROGRAMS BE REVIEWED BY NRR IN DETAIL?
SHOULD LICENSEES BE ALLOWED TO MODIFY /IPPLENNT IST PROGRAM REVISIONS WITHOUT NRC REVIEW?
SHOULD NRC HOLD REGIONAL AND INDUSTRY IST SWPOSIUBE? STRUCTURE?
HOW SHOULD NRC PROCEED WITH IST CHANGES? RULE OiANGES? GENERIC LETTER?
REGULATORY GUIDE? NUREG? SCHEDULES?
O
t P SSIBLE IllDUSTRY ACT10f!S O
IMPROVE ASME CODE ON IST TO INCLUDE MORE MEANINGFUL TESTING WITH TECHNICALLY DEFEllSIBLE FREQUEflCIES.
CORM owl 1ERS GROUP TO ADDRESS gel 1ERIC PROBLEMS WITH IST.
WORKIliG WITH NUMARC OR OTHER HIGH PROFILE IllDUSTRY GROUPS TO INCREASE AWARENESS OF IST PROBLEMS AND COMMITMENTS TO IMPROVE, BETTER CORPORATE COORDINATION OF IST PROGRAMS WITHIN THE
- UTILITY, IMPROVED IST PROGRAMS, SUBMITTALS, AND TIMELINESS, O
COnCtuSiONS CURRENT PROBLEMS WITH IST ARE DIVERSE, RESOURCE INTENSIVE AND ARE A RESULT OF PAST LACK 0F INDUSTRY AND NRC COMMITMENT.
MANY OF THE NEEDED IST IMPROVEMENTS ARE SIGNIFICANT AND WILL REQUIRE TIME, CONTIflUED NRC MANAGEMENT SUPPORT AND INDUSTRY COOPERATION, i
O e
-