ML20154D859
| ML20154D859 | |
| Person / Time | |
|---|---|
| Issue date: | 09/08/1988 |
| From: | Advisory Committee on Reactor Safeguards |
| To: | |
| References | |
| ACRS-T-1693, NUDOCS 8809160157 | |
| Download: ML20154D859 (351) | |
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A *\AL UNITED STATES O NUCLEAR REGULATORY COMMISSION ADVISORY COMMITTEE ON REACTOR SAFEGUARDS In the Matter of
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341st GENERAL MEETING )
)
O I Pages: 1 through 220 Place: Bethesda, Maryland _
September 8, 198 DAte:
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t-L PUBLIC NOTICE BY THE 2
UNITED STATES NUCLEAR REGULATORY COMMISSION'S.
() 3 ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 4
5 6
7 The contents of this stenographic transcript of the 8
proceedings of the United States Nuclear Regulatory 9
Commission's Advisory Con.mittee on Reactor Safeguards (ACRS),
10 as reported herein, is an uncorrected record of the discussions 11 recorded at the meeting held on the above date.
12 No member of the ACRS St,aff and no participant at 13 this meeting accepts any responsibility for errors or 14 inaccuracies of statement or data contained in this transcript.
15 O 16 17 18 19 20 21 22 23 24 25 Heritage Reporting Corpo' ration (202) 628-4888 1
l i UNITED STATES NUCLEAR REGULATORY COMMISSION 2 ADVISORY COMMITTEE ON REACTOR SAFEGUARDS
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\_) 3 l (
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4 In the Matter of: )
)
5 341st GENERAL MEETING )
6 0
) e 3 l Thursday, September 9, 1988 9
Room P-ll8 720 Norfolk Avenue to Bethesda, Maryland 11 ,
12 The above-entitled matter came on for hearing, 13 pursuant to notice, at 8:30 a.m.
1
! la BEFORE: DR. WILLIAM KERR l
Chairman l$ j Professor of Nuclear Engineering l Director, Office of Energy Research 16 hl University of Michigan 0, Ann Arbor, Michigan 17 h ACRS MEMBERS PRESENT:
18 h h DR. IIAROLD W. LEWIS 19 Professor of Physics h Department of Physics j
20 j University of California l' Santa Barbara, California 21 4 h MR. CA9LYLE MICllELSON g- 22 [ Retired orinciral Nuclear Engineer j (,) j Tennessee Vniley Authority 23 4 Knoxville, Tennessee, and, Retired Director, Office for Analysis & Evaluation d
24 y of Operational Data l
- U.S. Nuclear Regulatory Commission hl 25 Washington, D.C.
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1 ACRS MEMBERS PRESENT (CONTINUED:)
2 DR. CHESTER P. SIESS [
Professor Emeritus of Civil Engineering l' 3 University of Illinois Urbana, Illinois MR. DAVID A. WARD 5 Research Manager on Special Assignment !
E.I. Du Pont de Nemours & Company !
6 Savannah River Laboratory T Aiken, South Carolina ;
7 !
Mr. CHARLES J. WYLIE j 8 Retired Chief Engineer Electrical Division f 9 Duke Power Company ,
Charlotte, North Carolina 10 MR. JAMES C. CARROLL [
11 12 i ACRS COGNIZANT STAFF MEMBER I3 ,
Raymond Fraley, Executive Director i 14 Paul Bochnert 15 NRR [
16 Bob Jones f Hal Ornstein 17 Warren Minners Tom King 18 NRR Presenters l'
Warren Lyon Al Spano q
Moni Dey 21 0 23 24 O >>
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2 DR. KERR: We go to the first item on the agenda, j 3 decay heat removal. And Mr. Ward is responsible. ;
4 MR. WARD: Thank you, Mr. Chairman.
3 Generic Issue 99 is the title, Improved Reliability 6 of Residual Heat Removal Capability, Pressurized Water Re-7 actors.
8 Originally when this was identified as a Generic 9 Issue, as I understand it addressed loss of RHR pumping that 10 might be caused by spurious closure of suction valves. Later after a number of things that occurred, first there was this 12 included in AEOD study of events where RHR pumping had been 33 lost or degraded. And then in particular an incident at the g4 Diablo Canyon plant. When was that, two years ago or so.
I The perception grew that loss of RHR suction during so-called 15 I
16 mid-loop operation actua'lly posed more risk than the original l
concern ny spurious closure of section valves. During mid-l 37 33 loop operation the RCS is open and the level of the vessels that is down mid-way halfway, this contributes to the problem, I
g, 20 Particularly that there is low inventory available if connec-l tion of the heat is lost temporarily.
l 21 l- After the Diablo Canyon event which the Committeo 22 O
23 heard quite a bit about, but if you recall in I think both the subcommittee and the full committee meetings, it became 24 23 apparent that there really had been quite a number of Herttoge Reporting Corporation m m.m
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I incidences such as the one at Diablo Canyon. It really.wasn't 2 all that singular. Perhaps it was kind of the straw that O 3 broke the camel's back and brought more attention and resourcea 4 to address the problem.
5 But in some of these events the unavailability of 6 the heat sink or the loss of the R11R heat transfer system 7 was actually for a period extended enough so that there was 8 boiling of the inventory in the reactor vessel. So it's not 9 a trivial occurrence.
10 So PRA studies conducted indicated in fact that the 11 risk of core melt, that is, the likelihood of core melt under 12 circumstances such as these during shutdown operations, that "d * =*tet1r **e **e O >> <t x vetue c "ta de =e ri x core 14 melt failures that are calculated for full-power operation.
15 .Now, most PRAs that have been conducted, the two dozen or 16 more PRAs that have been conducted on U.S. plants, very few 17 of them, perhaps none of the standard PRAs actually deal with 18 shutdown operations or shutdown conditions.
I 19 So Generic Issue 99 now addresses--seems to concen-20 trate on these two classes of events. The original concern 21 and now the loss of pump suction during mid-loop operation.
22 As you hear the discussion, I'll leave it to you whether you 23 think this is conclusive enough.
24 We held a meeting of the decay heat removal system O >> ubco==ittee oa 3"tv 2'** "a we heerd ai cu to" --we ata Her!toge Reporting Corporation ti 3 m
5 4 I devote the whole meeting to this. And we heard a discussion l 2 of the general problem. But at that time the Generic Letter O 3 had not been drafted, or at least.there was not a letter O 4 draft available. Although we were given by NRR representa-5 tives some indications of what the Generic Letter was going 6 to say. I think some of us at that time had some problems i
7 with some of the things that were indicated.
8 So we've asked the staff to coma in today and to 4 9 brief us on their proposed resolution of Generic Issue 99.
l
- 10 And particularly on the Generic Letter addressing the issue i
l 11 that has now been drafted and which was I think made avail-1 12 able to all of you. The one I have is dated August 10th. I
() 13 think it was actually distributed to the Committee probably
! v 14 last week as I understand.
i 15 Well, today we are going to hear first from Mr.
1 16 Warren Lyon of NRR who will talk about the resolution of
.I 17 Generic Issue and I think particularly of the Generic Letter i
i 18 that's going to go out.
19 And then later Al Spano of Foscarch will describe--
j 20 aummarize for us the risk analysis that RAS had made at Brook-1 21 haven National Laboratory and which has been documented in l
) 22 this NUREG which I think most of you have seen. This was just j
1 23 issued a little earlier this year.
24 I see a number of you were at the subcommittee
() 25 meeting on July 27th, I guess it was, if you can remomtcr Heritoge Reporting Corporation (let) 6M det
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I back that far. I invite you to make any comments before we 2 go to Mr. Lyon. >
3 Okay. And we welcomo Dr. Lewis to the table.
O 4 DR. IEWIS: I found the' place. What are you com-t 5 plaining about. !
6 MR. WARD: We are ready then. Warren.
i 7 MR. LYON: Gocd morning. Can everyone hear me? .
f 8 Because I'm going to go without the microphone if that's !
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9 workable at the back. We don't have a throat mike and I have ;
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r 10 a choice of trying to speak with everyone or shuttling back i L
11 and forth or getting someone to change these slides. Whatever !
12 is the best.
i 13 MR. WARD: You have a slide man coming right now.
14 A real good one.
l >
15 MR. LYON: Great. ,
l 16 Good uorning. I'm Warren Lyon, and I will be pre- '
1 l 17 senting the staff information--
! 18 DR. KERR: Mr. Lyon, these mikes have to be fairly l close.
19 20 MR. LYON: Is that better? !
21 MR. WARD: Yes.
, 22 MR. LYON: I will be presenting the staff background :
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i 23 information associated with the forthcoming Gen.oric Letter ;
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.4 on the decay heat removal issue. We are not directly address- [
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- h 25 ing Generic Issue 99 ir this Generic Letter. What we have i
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7 1 done is examined the entire background of decay heat removal 1
2 with emphasis upon the lowerud inventory condition, because 3 that is where most of the risk and most of the experience 4 tells us_the difficulties lie. We do have some differences s between what we are covering and the Generic Issue 99, but we 6 have coordinated closely with the Research people and we be-7 lieve the actions which will be accomplished as a result of 8 this Generic Letter will encompass Generic Issue 99 and allow 9 Research to close it out.
10 MR. WARD: Warren, when you say you are not directly 11 addressing Generic Issue 99, I guess what that means is you l 12 aren't attempting to comprehensively address nI 99 but just 13 this part of it. Is that what you are saying?
f 14 MR. LYON: We believe that we have encompassed, as Is I say, everything for practical purposes that is within Generic l
i 16 Issue 99, but there have been some differences.
17 I'll give you one example, but I don't want to go 18 too far into the PRA investigations because I also want to 19 talk about that in a little while. The originhl PRA work was 20 conducted essentially prior to the time of Diablo canyon and 21 prior to the time of our learning a lot-as a result of inves-22 tigating Diablo Canyon. As a result, some of the PRA work 23 does not really address the new information such as the shor-24 tened times before core uncovery. And the Generic Issue 99 23 as originally envisioned did not address those things as well.
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,' 3 Now, we felt it was best to examine the entire range h
[ 2 of Operations and pretty much.take it from there leaning ;
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3 heavily on what had already been learned from Generic Issue 99. i
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4 The basic issue as stated here is we are concerned L s that a lot of decay heat removal can give us a reasonable 6 likelihood of a core damage accident. And as opposed to full q
- s 7 power operation where one has an isolated containment in many a instances, particularly during lowered inventory operation,
!i 9 we do not have a closed containment. And our investigations !
i l 10 have led us to believe that there may be soma difficulties in gj getting containment closed prior to the time of an accident (
12 if it should actually occur.
i I 33 So this basically in a nutshell is the problem that t
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14 we are addressing.
l May I have the next slide please.
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1 l 16 Before we get into this, I'd like to spend just a [
f 17 moment on some definitions. We have invented some new terms, d l gg if you will, to differentiate between various conditions. We l
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} g, refer to a reduced RCS or reactor coolant system inventory as l
! I l 20 a reactor vessel water level that is lower than three feet
,' 21 below the reactor vessel flange. This differentiation between i
i 22 what we normally think of as mid-loop and a somewhat higher iO
} 23 level was selected because if the level is above this three-j i
24 foot level, our technical judgement and our experience out in l
i i
h 25 the plant tells us that the likelihood of encountering short-I l Heritoge Reporting Corporation !
me. [
9 1 term problems is low. Whereas as one goes lower in level, 2 that likelihood increases significantly.
O. 3 We've also defined a mid-loop condition which may 4 be a little different than some of you are used to. We say a 5 mid-loop condition exists anytime the reactor coolant system 6 water level is below the top of the hot-leg flow area where 7 it joins the reactor vessel.
8 Then we define a term that is also new and different 9 that we call closed containment. This is not a traditional to safety kind of isolated containment. We define that as a 11 containment condition that provides at least one integral 12 barrier to the release of radioactive material. What does 13 that mean? In the case of the equipment hatch, for example, V y it means an equipment hatch opening that is closed usually 15 by the actual equipment hatch, sufficiently that there is no 16 gap between the equipment hatch and its mating flange on the 17 containment.
la can I have the next slide please.
19 The way one could establish no gay might be a couple 20 of means. You could physically put the hatch in place and 21 then examine it visually to make sure that the mating surfaces 22 were closed around the entire periphery, or one could bolt it 23 in place with however many bolts one would like to choose, and 24 then pressurize between the dual seals and see if it holds The idea behird this is that if you encountered an
(]) 25 Pressure.
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10 I accident condition where there was some containment pressure l
2 in most of the equipment hatches that would tend to increase O 3 the force of holding the hatch against the containment and t
j O 4 if you didn't have pressure, you would have an essentially i 5 leak-tight seal. l 6 We never have subscribed to the usual tech spec ;
i definition that has been traditionally used in Mode 6 of four 7
f 8 bolts because we didn't really know what that gave us. And i 9 in talking with people out in the plant it gives very dif- l 10 forent things and in some cases, for example, you may not have 11 a real good mating of the two flanges. You may have a leak 12 condition. So we didn't go with that. ,
13 MR. WARD: So you see this as a more rigorous re-14 quirement? !
i j 15 MR. LYON: Absolutely. [
i 16 MR. SIESS: Do you take into account the pressure? :
- I 17 MR. LYON: The no-gap condition-- f I i I 18 DR. KERR: Excuse me. I don't think the Reporter I l !
19 got youi' question, Mr. Siess. L r l
' 20 MR. SIESS: Do you take into account the pressure l l
21 acting on it?
22 MR. LYON: No. The no-gap condition woilld be with ;
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) 23 no pressure in the containment itself so that if you then l l
24 pressurize later on with the general equipment hatch coming O >> rro= the i= iae, vou wouta teaa to auee=e it rurther- we :
i i Heritoge Reporting Corporation l iman .= l
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/ haven't addressed the detail yet of an equipment hatch that l 2 would be attached from the outside.
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3 MR. SIESS: Then I'm confused. Aren't there double l
4 O rings in that-- f
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5 MR. LYON: Yes, sir. That is correct. !
6 MR. SIESS: The no-gap is what? How can the mating I l 7 surfaces be in contact if the O rings are there and there's I
l 8 no pressure? i l 9 MR. LYON: The bolts that hold the equipment hatch 10 in place, typically--I don't know, the order of two or three l
l 11 doren bolts would hold those two surfaces in contact. {
l 12 MR. SIESS: Is that normal that the O rings are !
l t 13 designed so that you get metal-to-metal contact on the mating !
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14 surfaces?
15 MR. LYON: To my knowledge, we're not talking metal-16 to-metal contact. The O rings would still be in place in the i
17 equipment hatch or if a licensee wished he could use seal (
I l 18 material. I I l 19 MR. SIESS: What do you mean by no-gap? No gap j 20 between what? !
21 MR. LYON: We mean no gap between the containment f I
mounting flango and the seal and between the seal and the I
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23 actual equipment hatch. In other words, essentially no pas- [
24 sage for the flow of material.
() 25 MR. SIESS: That I understand. But by seal you mean Heritoge Reporting Corporation
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12 1 the O ring?
2 MR. LYON: The O rings would be in contact continu-
,.m 3 ously around the periphery.
73
'd 4 MR. WARD: But not necessarily crushed.
5 MR. LYON: But not necessarily crushed. That is 6 correct.
7 MR. SIESS: That's not what I understood him to say.
8 MR. LYON: Apologies for the misleading on the no-9 gap. Thank you for the correction.
10 MR. SIESS: There are some recent tests that have 11 shown that even with very badly degraded O rings if you have t
12 metal-to-metal cor+act there's no leakage through penetration.
{} 13 I don't know if that applies to an equipment hatch. It sure 14 applies to pipe, electrical penetrations.
l$ MR. LYON: In taking a step back and look at the 16 situation and whether one needs to take action, there are a 17 number of areas in which one can draw experience. I won't l
la address the PRA because Al Spano will do that later. I will 19 address briefly several exampics. For example, experience 20 as was pointed out in the introduction to the session a num- ,
l 21 bor of incidences have occurred. The Diablo Canyon incident ll g 22 y although it really never put the plant in any jeopardy, led V !l 23 { to raising the flag, if you will, and we've Icarned a lot, 24 some of which we'll share with you today.
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il Sinco Diablo Canyon, there are in.~is.nts that h Heritage Reporting Corporation m us a.e I
13 I continue to occur. We had two in May. We had one in July.
2 t.osses of decay heat removal. Nonc put the plants in jeopardy 3 but they are incidences which did occur and tell us that we
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4 still have a problem to address. One of the positive aspects 5 was these three were addressed in a manner which may have been l
6 different prior to Diablo Canyon. Such things as if they 7 encountered difficulty with residual heat removal, they didn't 8 They set about getting some simply try to start another pump.
' water back into the reactor coolant system first so that one 10 didn't encounter the difficulty of taking both pumps out, which 11 so often would have happened prior to Diablo Canyon.
12 l MR. WARD: They got water back in by what means?
13 MR. LYON: Various means, and over various periods O 14 l t
of time. For example, Sequoyah lost water because of mis-18 i understanding between an ox operator and an operator and they 16 proceded to open the wrong valve and pumped water from the 17 reactor coolant system. They got it back by gravity flow.
i 18 ! They were in a loss of RilR condition for approximately three ln 19 and a half hours. By the way we judge things now, frankly o
20 ll that was a "no, never mind." They had core exit treble cou-21 ples operational. They hadn't been a power operation for d
22 about three years, two and half, somewhere in that ballpark.
23 1 And during the time RilR was off, the temperat'are went up by J
24 2 degrees F. That is a "no, never mind" in a risk space, and O >>
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f I aspect is an initiated did' occur. I think they han'd led it ,
2 well and they took their time, but plenty of time was avail-O 3
able.
O 4 N6:f I have the next slide please. ;
5 While you are going to the next MR. CARROLL: i slide, the equipment hatch issue, you indicated that the four-
' 7 bolt concept that's in the standard tech specs is questionable 8 Are steps being taken to revise the standard
- in your mind.
tech specs in that regard?
10 MR. LYON: One of the issues which I'll ac .. a s 11 briofly inter is the technical specification issue. To jump i
12 ahead just a little bit, we have one item that is addressing r
. O >> e11 tech spec kinds of imp 11cetions which are coming out that 0 84 I would expect that to be reflected. l I5 Another example that leads us into reason to believe j 36 there's extra work is the phenomena which take place. At the l
j 17 time of the Diablo Canyon event which was in April of 1987, j i
! I8 we were in a position of believing that really there isn't
> I' much happens in here. As a result of that event and studies l
M' which have been initiated, we learn there is a lot going on.
I 21 There are a number of phenomena which previously had not been i
l 23 recognized. The Westinghouse owners have flagged some of !
23 i those very vell in which they put out a communication in May f i 24 i of this year to all of the Westinghouse members and they also [,
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! O u eent cepiee to the oth- vene r own- s erougs in e uh they l
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15 I showed that some of these kinds of phenomena could lead to 2 pushing water out of the reactor coolant system and out of
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b) 3 the reactor vessel very rapidly. Whereas prior to Diablo n
U 4 Canyon we believe we typically had of the order of four hours, 5
l we now know that we have of the order of perhaps fiftcon 6 minutes before you get into a core uncovered Condition under 7 certain configurations and that woulo put one on an idiomatic 8 heat-up conditim: We also know that should that situation 9 be occurring, the traditional methods of adding water into 10 the reactor coolant system may not work. And one might have 11 to use a different method such as hot-leg injection. So we've 12 still got some work to do here.
{') 13 May I have the next slide please.
14 With respect to the Diablo Canyon event, we put out is a Gen 9ric Letter which asks all licensees with pressurized 16 Water reactors to tell us how they operated in lowered in-17 ventory or at that time what we were calling mid-loop. The 18 results were disappointing. We broke things down into twelve ;
19 categories for purposes of evaluating the answers. Some li-i 20 consees were unsatisfactory in every category that we evalu-21 ated. None were satisfactory in all categories. And some
~s 22 l responses reflected an essentially complete lack of under-(d 0 standing of the things that we were learning from Diablo 23 3
24 hCanyon.
J C 25 May I have the next slide please.
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- DR. LEWIS: Just out of curiosity, did the licensees 2 know how you were going to evaluate their responses? Know v 3 your twelve categories?
4 MR. LYON: They did not. We asked a series--
5 DR. LEWIS: So you de.:ided on the questions on the
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6 ! test after you had the test taken?
l 7 l MR. LYON: In a sense that is correct. We asked a 8 series of questions regarding the operation of the plant from 9 the viewpoint of what we knew immediately after Diablo Canyon 10 because we got this Generic Letter out quite quickly. We 11 fthenwentbackandasked,now,howdoweevaluatethosere-12 sponses? What are the real technical issues involved? And O 13 l we broke them down into various categories. For example, if n 1 34 the licensee understand and address pressurization of the
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15 l reactor coolant system, we provided in invlosures with the i
16 Generic Letter information regarding the phenomena and the 17 i pressurization behavior. Many licensees didn't even touch I
is ] base on that. Or they would provide a response which indi-19 cated that they did not understand a low pressure phenomena
- o which concerned us.
i ;
21 Now, during the Diablo Canyon and since, we've l
22 jseensomeexcellentinsight into various aspects of the pro-O 23 s
blem.
DR. KERR Excuse me. In this cont.ection, did these 3h b
25 same licensees also disregard the Westinghouse advisory?
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1 MR. LYON: I have no feedback on' response to that, 2 sir. That came out in May of this year and I have no specific
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3 feedback on that. ,
O 4 DR. KERR: But it's possible that by now they do f
5 have misunderstanding that you assumed they did not have when f i
6 you sont out your letter? ;
l 7 MR. LYON: Absolutely correct.
8 DR. KERR: Which apparently you didn't have either 9 when you sont out the letter.
i l
MR. LYON: At the time we sent out the letter, we i
) 10 11 had recognized many of the phenomena. We had recognized that i i 12 a pressurization issue was (twolved which could force water [
l(]) 13 out of the reactor coolant system and take you down to about the mid core level in a typical Westinghouse plant, but we had
)i 14 I 15 not recognized the implications of a hot-leg nozzle dam that 1 !
! 16 was improperly installed and since that time they have inde- ;
j 17 pendently recognized in three different areas, to my know- ;
i
) is ledge. The San Onofre people recognized it.
1 i j 19 UR KERR: Okay. That's an example. l i
l
. 20 MR. LYON: We've learned a lot since that time. f I
l 21 DR. LEWIS: I was only responding to the term [
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! 22 "satisfactory" and "unsatisfactory"--that you learned about l ( ,
i 23 as you do your job. !
! My 24 MR. JONES: If I could just respond to that.
li ,
name is Bob Jones from NRR. The purpose of the Generic
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18 i Letter 87-12 was not really to find out whether licensees were 2 addressing specifically every issue. It was to try to get a 3 picture at that point in time wherever licensees were and what V
o i l plans they had, if any, for the future to respond to the spe-4 5 cific Diablo Canyon event. From there we were then going to 6 decide what, if any, further actions the staff should take.
7 Yes, we did try to break things down into phenomena, et cetera.
8 We also provided a lot of information with the Generic Letter 9 so that they could understand the phenomena, could understand 10 j that the NRC staff thought that the issue was serious. And l3 in essence, the initial Generic Letter was to try to prod 12 them into taking an initiative to go forward and take steps C 13 to respond to the issue.
34 The Westinghouse Owners Group, for example, has gone is ; forward with an analytical program to address this. We com-16 mend them for that. The CE Owners Group and the B&W Owners 17 l Group have done nothing. So it was really to get a snapshot l
38 l to decide how bad were things, do we have to immedintely have l
39 l to run out and do something? Could we look at it and get an d
20 l} idea as to whether people were seriously considering the event h
- l and make a decision as to where to go forward. And that's 22 h really where we're at now. Is we've evaluated it. We've O 23 i c recognized that some of the licensees misunderstood the intent 24 g of that letter. But we've had a lot of discussions. We've l
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I .think that this letter represents a good snapshot of where 2 the industry was approximately a year ago. We know that's O 3 not where they are today. But we think that appropriate 4 action is needed at this time.
- 5 DR. LEWIS: You know, I don't.know whylyou are 6 so defensive about this but just let me pursue it for a moment
(
l 7 I think you've missed my point.
4 8 Nobody objects to your collecting information, for 9 God's sake. This is a subject you want to pursue. It was the i 10 use of the word "unsatisfactory." When you say some of the i
11 licensees misunderstood the intent of your letter, really i
j,' 12 you should say you didn't state the intent of your letter O vou were cottecties
>> deceu e voo reetty weree's suite oteer-i 14 information. Collecting information.is unexceptionable, of j 15 course. The point is if you ask somebody his name and he i
! 16 tells you his name and you say, "That's unsatisfactory be-a
! 17 cause you didn't include your middle name," that's not his 3 la fault. That's your fault for not saying what you want.
19 I was only reacting to the te*tm "unsatisfactory,"
20 which taken out of context means that there is something 21 dreadful out there and that isn't true. You are trying to i
22 find out what happened. You are learning together and i 23 there is nothing wrong with that.
24 MR. LYON: Can I have the next slide please.
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25 As I mentioned in my introductory remarks, we
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l 20 I consider the reduced RCS inventory situation to be where most 2 of the problem lies. Traditionally loss of decay heat removal n
3 is a frequent occurrence under that situation. It doesn't
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kJ 4 happen as often if one has a higher water level. And about a 5 third have been down around the mid loop or reduced inventory 6 situation, but that one third contributes of the order of 7 seven eights of the risk. So that's really where we have put 8 our emphasis to start, 9 As you will see, we expect that addressing this will 10 provide benefit under other circumstances as well.
11 May I have the next slide please.
12 As Bob said, he covered part of this for us already,
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13 we had a number of meetings and dis;ussions with the various
(_) 14 owners groups. The Westinghouse Owners Group undertook an is extensive analysis program of the conditions associated with 16 lowered inventory operation back last fall. We expect a re-17 pcrt on this momentarily, but they've covered a lot of ground is and we've all benefited from it. They have scheduled a work-19 l shop later on this month for two days in Pittsburgh to cover l
20 many of these thing! and we have been invited to participate s
21
]inthatworkshop. But despite all of this, we feel we must I
22 continue and make progress and so we are addressing the issue.
23 l May I have the next slide please.
24 We have reached a decision to issue a Generic Letter
() 25 t as tne next step. We have discussed the general content of Heritage Reporting Corporation l .
21 l 4 h i
i this letter with the industry. There are people'out there i 2 now who are entering or have entered a shutdown condition O 3 which are already addressing a number of these issues. I i
' 'O 4 think they deserve a pat on the back for being ahead and look- [
} !
j s ing forward towards things. j 6 The Generic Letter contains a number of recommenda- [
7 tio.ls and I will go through each of those with you~. And it i l I s requests each licensee to inform us what actions they arn 9 going to take in response to-those recommendations. The in-10 dustry as a whole understands that we consider this to be a
- 11 high priority issue and we anticipate a good positive response t
,' l 12 to this letter.
)
O 13 May I have the next slide please.
14 The recommendation contained within the letter
. j i is breaks things down into two categories. A short-term or i 1 t 16 what we call expeditious actions which will accomplish an '
17 immediate ar'd ef fective reduction in the likelihood of a i
la release if a core damage accident should occur. And some j
j i, work towaru reducing the likelihood of a core damage acci-1 i
20 dont. The entire purpose of the expeditious actions is to l (
l 21 accomplish a reduction in risk immediately. So you won't see 1 i
l >
any real long-term things here. And an emphasis has been to l 22 O 23 do it in a practical manner. Simultaneously we recommend the j
i . I i $4 I initiation of what we call program enhancements. These are I
i h 25 things that will take a longer time of the order of a year I
i !
- Heritoge Reporting Corporation j
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22 I and a half, perhaps longer in some instances, to fully accom-2 plish. We expect those to be phased in as the work progresses (n)
3 and it becomes reasonable to factor that information into the
/ 4 operation of the plant.
5 May I have the next slide please.
6 The expeditious ections are eight items basically 7 and I will go through each of these in more detail. We want 8 to have the Diablo Canyon implicationn and what is learned 9 discussed. We want a reasonable insurance of containment to closure. We want temperatures level. Stay away from pro-11 turbing the reactor coolant system. Additional equipment 12 to assure that one can put water into the reactor coolant
(') 13 system should it be needed. And the real short-term coro
) 14 uncoverings can be associated with inappropriate use of nozzle I
15 dams or loop stop valves, so we're requesting people to take 16 a look at those usages.
17 MR. MICHELSON: Can you tell me a little more about 18 the independent RCS level?
19 MR. LYON: Could I postpone please until I discuss 20 each one in detail?
21 ( MR. MICl!ELSON : Oh, if you are going back then--
22 hl l MR. LYON: Yes, I am going to go back and discuss 23 heachone. Thank yoa.
U 24 [ The longer term program enhancements encompass in-1 strumentation and alarms, procedures, better usage of equipmen;
({) 25 h
h j Heritage Reporting Corporation h m .a a
23 I and we're not anticipating new equipment here. We are anti-2l cipating better planning of existing equipment. We feel that 3 is completely adequate. And understanding addressing techni-O 4 j cal specification and some additional work on avoiding pro-5{ turbing the RCS.
6 May I have the next slide please?
7 Now we'll go through each item in a little bit more 8 detail. As I mentioned several times, we've learned a lot 9 l from Diablo Canyon. We've learned a lot just in the last two i
10 or three months. Notable being the Westinghouse work, for il example. We want to make sure that that information is dis-12 f seminated by each licensee to the appropriate people at the l
lO i> ! eta t- Taet i=c1=ae obviouetz ene overetore, but e aumber or 14 other people as well. Maintenance personnel, for example, 1
15 can casily proturb the reactor coolant system and initiate 16 a loss of decay heat removal.
I, i 17 Supervisory personnel need to understand the impli-18 cations of the ordering of events and taking certain equipment 19 We believe all of this information should loutofoperation.
20 l be widely shared essentially by anyone associated with or 1
21 lpotentiallyimpactingtheoperationofthereactorcoolant s 22 i system while in a lowered inventory condition.
pO l 23 j Containment closure. This is an important one.
24 j This is really the item in the near term that will accomplish h
25 a significant risk reduction. One that can be taken. It is 4
h Heritage Reporting Corporation im> u.
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24 I one that can be taken. It is also potentially one which 2 could have a significant impact on plant operations. We've b) x- 3 been looking at that quite closely and we intend to continue (O ) 4 to look at it.
5 I'll come back and touch on that later on when we 6 l close with cost benefit kinds of things.
t 7 We are recommending that procedures be implemented 8 for the Westinghouse and combustion plants that reasonably 9 assure closure of containment following a loss of decay heat to removal prior to reducing--and these should be implemented is prior to the reduction in reactor vessel level lower than 12 three feet below the reactor vessel flange. And the proce-a"re "re '" * 'he c "'et"=e"' t- "ed O '> " " a re== ""'tv i4 if one cannot get decay heat removal capability back and if 15 one cannot add any inventory, then you want the containment 16 closed before core uncovery. A lot of implications there.
17 MR. CARROLL: Closed before reaching core damage?
l i
18 l MR. LYON: No, sir. Closed before uncovering the I
19 top of the core. A big difference. Once I uncover the top 20 of the core, if I'm in a boiled down condition, I've got 21 quite a bit of time yet, l
i MR. CARROLL: That's not what I'm getting at.
22 h O 23 q g
MR. LYON: I'm sorry.
MR. CARROLL: Do I have to assume in this analysis 24 25 ,
that I incorrectly put in, say, a hot leg nozzle dam?
U
.I h Heritage Reporting Corporation
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25 1 MR. LYON: If the configuration of the plant were 2 such that that were the case, then you would have to make that U 3 assumption. If on the other hand the configuration of the m
4 plant were such that you did not have nozzle dams installed, 5 then you wouldn't have to make that assumption?
6 MR. CARROLL: I'd have a much longer time to re-7 spond?
8 MR. LYON: Conceivably yes.
9 MR. MICHELSON: Why is the B&W four inches below to hot leg and the other is considerably higher?
11 MR. LYON: Thank you. 1 was coming to that.
l 12 Very appropriate.
(') 13 As we just pointed out, in the B&W case we ask 14 that these procedures be in place prior to lowering the re-15 actor coolant system level more than four inches below the 16 top of the hot leg. Quite a different criterion. Bluntly 17 put, the B&W machines are less suspectible to many of the 18 problems in this mode. The internal event valves in the re-19 actor vessel essentially prevent a differential pressure be-20 I tween the top of the core and the top of the downcomer anulous ,
21 l Many of the phenomena of concern do not even apply. Further, 22 the B&W machines are configured with a cold leg that slopes 23 j downward into the reactor vessel. They rarely go to this d
24 condition. In a typical refueling outage, they would not.
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I situation in which they were replacing reactor coolant pump 2 seals, one would encounter a similar condition. Operationally .
O 3 if one looks at the data, they haven't had anywhere near as j i ;
j 4 much problem either. They had quite a bit.of problems in one I
(
5 or two plants sometime back. Recently we don't see those y i
6 kinds of difficulties. ]
i l 7 So we feel that this essentially accomplishes a [
i 8 similar degree of benefit in the plants and perhaps this is
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l 9 systematic of the approach that we are following. We want ;
, r
! 10 it to be reasonable, but we want it to be practical. We do i
'l 11 not want to impact.upon the operation'of the plants unneces-
)
i 4 12 sarily and in fact, as I'll point out a little bit later, ,
i l '
13 where one can relax some of the conditions that are presently t
14 proposed, we want that to occur as well. Some of that can be is quito beneficial to safety in actuality.
I 1 -
t
{ 16 If the condition of the containment is such that j I I l 17 you could not close it prior to our stipulated condition, j i
j 18 then we say you shouldn't open it in the first place. And i
! I f 19 by the way-- (
l l 20 Yes, go ahead. ;
21 MR. WARD: Well, I'll let you finish. But I want I 22 to ask you a question about this topic. !
O 23 MR. LYON: We've discussed the equipment hatch.
t J L There is much more to closure of containment than the equip-
) 24 Q 25 ment hatch. A myriad of penetrations. My judgement and I i
Heritoge Reporting Corporation i
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27 1 really haven't--we haven't pursued this far enough yet so that 2 it perhaps represents the entire staff yet, but we're gettxr.g b 3 there.
('v) 4 A judgement there right now is based on preliminary 5 information. It looks like the other penetrations may be 6 equally demanding to those of the equipment hatch.
7 Yes, go ahead.
8 MR. WYLIE: This is the requirement that kind of 9 pu2210s me, the position you've taken puzzles me. I mean 10 I can certainly think of a more conservative position which 11 would be simply require that containment be closed. But I'm 12 sort of struggling with the justification for not doing that.
13 You know, the risk of--if we believe the risk of core melt
(%-
14 numbers that have been generated--I'm talking about probabi-15 lity of core melt--you know, some of the numbers show that 16 during shutdown operations, they are almost as high as in 17 power operations. It's not a kind of reactor year basis.
18 So that must mean that per hour--and since much of the shut-19 down contributions come from the time spent in mid-loop opera-20 tion, that must mean per hour that the risk of core melt--the 21 i{probabilityofcoremeltduringmid-loopoperationismuch l
22 l much higher than it is at full power operation. Yet we re-23 quire that containment be locked up during full power opera-h 24 !j tion, but not during mid-loop operation.
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28 I MR. WYLIE: Now, maybe the thing is that you can 2 make a case that the public health risk is dominated by short-G V 3 life fission prcducts. I'm not sure that's the case. I don't 4 see that you've made that, that you can use that as an argu-5 ment.
6 MR. LYON: Theti are excellent questions. And you 7 hit the nail upon the head very well.
8 MR. WYLIE: The used the cost benefit analysis--
l 9 MR. LYON: Not really.
10 MR. WYLIE: Well, okay. Well, maybe, maybe not, 11 But I suspect you could make the cost benefit argument that 12 containment doesn't have to be buttoned up during power opera-13 tion. That only if you get into the beginning of some event
(}) (
14 then you slap the cover on it, tighten up some bolts, or look l
15 to see if there are gaps or something like that. You can 16 probably make that sort of argument. !
17 MR. LYON: I suspect you are correct. We haven't 18 used that approach however. We've reached this decision by 19 examining a number of facets at length and discussed it among 20 ourselves quite a bit.
l 21 The judgement is that the protection of the health l
22 and safety of the public will be accomplished by using this 23 4 approach essentially as well as though the containment were Y
24 h closed during the operation. There are a number of aspects i
() 25 l that go into that and there are a number of aspects which Hl l Heritage Reporting Corporation I = u.
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29 l apply between the full power operation situation and the 2 cutdown condition. Full power operation you have a hot re-3 actor coolant system, typically 600 F. You have high pres-o O 4 sure obviously. You have in the first minute after initiation 5 of some kind of an accident a heat generation rate that can 6 be of the order of, say, 2, 6 percent of full power. There is 7 i a tremendous amount of energy to deal with. It will run into a a large number of phenomena which can cause high pressuro 9
I j within the containment almost instantaneously.
ll to q We would never recommend using the kind of criteria 11 d' that we're using during shutdown for full power for these 12 kinds of reasons. During shutdown conditions at a minimum
) 13 ,
you will have been away from full power by about a day, and 14 in the real practical world, at least most of the time, by is ftwoormoredays.
I 16 i The reactor coolant system will be at low pressure.
17 And it will be essentially cold. One doesn't have a lot of the phenomena to protect against. One doesn't have that high 18 l I
3, >
energy content either in the sensible senue of high tempere.- !
l 20 ture, high pressure, or the high dc.my heat rate to deal with. !
21 !] We at this point understand-- I h
22 [ Go ahead.
O 23 a
l- MR. WYLIE: Warren, I guess one of the concerns 1 i I
24 about the effectiveness of containment is that the real high 25 pressure you are concerned about is not necessarily from the L ,
[ Heritage Reporting Corporation l m as
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30 i blow down in the primary system but from whatever results from 2 the core damage scenario.
3 MR. LYON: Precisely. The high pressure of blow I
(3 x.> 4 l down is the concern that has ocen voiced in many quarters of 5 finely atomized fuel giving you a pressure pulse in addition 6 to a hydrogen burn and a few other things.
7 We don't--
8 DR. KERR But even before the DCA was postulated, 9 i it's not the large breaks that produce the risk. It's a 10 variety of things that could be fairly close to the kind of
- core melt that you get when the vessel open, it seems to me.
l 12 I don't understand--well, I'm listening, but I l
13 don't thoroughly--and indeed, the way those accidents develop, 34 core melt doesn't occur frequently until hours or even days 15 after the reactor has been shut down so that the same sort 16 of heat removal requirements exist.
17 ,
MR. LYON: Yes.
I 18 DR. KERR: And indeed heat removal may be similar in some cases than it is in an open vessel situation. It's 19
- o a loss of the power that causes you problems frequently, d
23 p MR. LYON: And in a situation--let's take the loss 0
- 0 of power example that you raise. In a typical plant as you O c 23 !j correctly point out, you've got a number of hours in which to n
24 react. In a shutdown condition, you also have, if you stay
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31 I to react. In a condition originating from full power such as 2 a loss of all AC, one has time to take other protective mea-O (V 3 sures and most containments would be expected to provide pro-t 4 tection over some time in addition, ,
5j In a shutdown condition, if we can be assured that
, i 6 containment is sufficiently closed to prevent a significant 7 release, then there is that same additional time in which to 8 work and what we are about is providing a reasonable assurance 9 j that that protection will be available. ;
l 10 1 Can we have the next slide please.
I ll j Reactor coolant system temperature. One of the i
12 difficulties many times occur with a loss of a decay heat Q 13 removal system is one is depending upon the temperature mea-14 l thermodynamic i y{surementwithinthatsystemtodescribethe ,
is state of the reactor coolant system. So once you lose decay 16 j heat removal, you lose temperature.
] 17 ! A number of people have suggested, well, we still i
is have things like the hot leg RTDs. They are not responsive l i,! in a condition of no flow. They simply do not follow the i
h
- o !i behavior of the reactor coolant system at the Icoations where '
h 21 [ it counts. Namely, in the vicinity of the core, So one of the things we are requesting is that we 22 f] ;
'O '
23 L have at least two temperatures representative of the core, i
24 the temperature immediately above the core.
25 DR. KERR: What would that enable one to do that one ,
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32 I cannot now do?
2 MR. LYON: I'm sorry. I didn't hear.
3 DR. KERR What would that information on that m
4 temperature permit one to do in an actual situation that onc
$ j cannot now do?
I 6 MR. LYON: One has a number of things. You have a 7 real time indication of the state of the reactor coolant sys-8 h tem when you also have reactor vessel level, if you will. One h
9 can then use that information in a number of ways. Perhaps 10 most importantly if you initiate mitigative measures to try Il to recover from a loss of decay heat removal, you have a mea-l l 12 p
sure of the effectiveness of those mitigation measures. You l 4 l O
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13 don't have that if you can't measure the temperature.
l ( !
j I4 DR. KERRt My very simplistic approach to this d
is q would be if you lost the ability to remove decay heat, you'd 16 . begin working on trying to restore that ability independently ill 17 ;l of what the temperature was.
0 18 ! MR. LYON: Yes, sir. This is correct.
n 19 , MR. CARROLL That's true, Bill. I guess to see I I
!l 20 how offective your mitigation is, to see il you are getuing 21 water back in. ;
L 22 h DR. KERRt You might not put water in as fast as O d 4
23 0 you would otherwise, t
i n 1 24 MR. LYON: Let me make one quick comment and Hal is ;
t O :s !! 3"=ei=9 "e "a aow=- - te eeex with ome i=torm tio# were- !
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33 i Go ahead, llal. I'll hold it.
2 MR. ORNSTEIN: I'm Hal Ornstein from AEOD. I just 3 want to interject some past experiences that we've soon in the
\ Essentially there have 4
lareaofdecayheatremovalevents.
5l been many events in which there was a loss of decay heat re-l 6 l( moval systems. And during the period of timo that those eventa r 7 occurred, the operators had information at all as to what the 8
h course of the event has taken. They did not recognize the ,
i i 9 heat up rate. They did not know how much time they had before i
10 they could start boiling. Risk has occurred because of the l
t II l deficiencios that Warren was talking about.
12 l! DR. KERR: I guess I didn't make my question clear. !
- y l C 13 My question was not aimed at the fact that they would not l 14 know what the temperature was. I recognize that. My question i
15 L is what would they have donc differently had they known what f
16 l the temperature was?
1 17 j MR. ORNSTEIN: Well, for examplo, in the case of t
la L Diablo Canyon, the heat-up rate that was anticipated was one-ij' 1, third what it really was.
20 f DR. KERR No. Again, my question is what would i
il 21 they have dono differently had they known what the heat-up
[
22 f rate was?
I E 23 1 MR. LYON: Let ne giva you a specific example.
L 24 4 If an operator knows the hea .et's start vith your as-
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l 25 ;
sumption--
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l 34 1 DR. KERR Let's take the Diablo Canyon case. It l Ol ts 2 was the one that was brought up. And my question is what n
3 would they have donc differently had they known what the heat-I 4 up rate was?
I
$l MR. LYON: Put water in sooner in Diablo Canyon.
6 MR. CARROLL: That's right, Bill. Because they 7 were misled based on the existing tech specs that say, hey, 8 you've got at least an hour, and the plant showed--
9 DR. KERR They didn't realize that when they lost i l
10 l decay heat removal capability they should start doing some-l l 11 thing. '
12 O[! MR. CARROLL: That is correct. l 13 MR. LYON: Nowadays I believe--we believe that la ! most leople out thcre will have heat-up rate information 15 L available to them. Nonetheless, that could be incorrect il 16 j depending upon what was going on and the instrumentation
'l backs it up.
17 j J
la y Let me come back to your question specifically.
One tries to get it back and 19
[4 One loses decay heat removal.
- o L perhaps you 1 carn it's going to be a half an hour before it b
- l h comes back. Now the question is, should one initiate, say, U
22 h safety injection and dump a lot of water in containment or 23 can one wait? If temperature is unavailable, the prudent L
L 24 thing to do would be to start pumping water into the reactor i
25 coolant system to make sure the core remains cool and suffer i
l]
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35 I the cicanup consequences later.
- I 2 If on the other hand one can measure temperature k') 3 and see that perhaps the temperature is increasing at, say, 4 a half a degree a minuto, and there is three hours before L
5l boiling based on actual information, one can hold off and '
6 try to take less drastic measures. So I think there is a r l
l 7 I real implication here. ,
I 8 I MR. MICHELSON: One can't tell what the water level ;
9 is, is that--so one doesn't know when to start putting water I
10 in? We're not talking about a case where--
l 31 l MR. LYON: Some of the level indicators do not go l
12 down into the vessel itself. They are more out in the legs l
C 13
{ so if you are at a level that is down near the bottom of the 14 heart of the flange, you may be off scale.
!! r 15 l MR. MICHELSON: So this is not for refueling. This i
16 ,
is shutdown with the vessel. ,
l I
17 f MR. LYON: That is correct.
18 l MR. MICHELSON: Which level indicators do not go b
19 h into the vessel? Which vendor?
6 20 j MR. LYON: I would have trouble with specifica at i
i 21 this point.
22 MR. MICHELSON: I think the B&W is only a hot-leg
[
t i 23 . indicato:; .
l 24 MR. LYON: Well, Diablo Canyon, for example, was 25 relying upon a measurement taken off the bottom of the h Heritage Reporting Corporation tm g
i 36 I
1l crossover bito between the reactor coolant system and the
(*, I V 2 0 steam generator. Once the icvel in the vessel drops below h' 3 h
the level of the lip at the exit of the reactor coolant pump, 4 you no longer have a representative reading.
5q MR. MICllELSON: What you are saying is that not j
6 : all PWRs besides the B&Ws have vessel level indicators.
7 MR. LYON: That go down in the vessel, that are N - used during shutdown.
9 MR. MICllELSON:
j By definition, vessel level means b
to q you know the water level--
ti 11 MR. LYON: That is correct. Some of these are not l
12 h used during shutdown.
13 MR. MICl!ELSON : I didn't realize that other than 14 B&W that that was the case. It wasn't the case in fact and h
that's why I am surprised to hear it here.
is [
16 pi MR. WARD: Well, not all B&W level indications are 17 h the same either.
0 18 h MR. MICl!ELSON: That's right. But some are only b
19 g hot leg. The only exception to vessel level indications in 0
20 j this country--
i!
21 l MR. LYON: I am about an hour into the presentation.
22 .
According to the schedule, I have five minutes left and we 23 bave conc about a third of the slides. What is your pleasure?
, 24 MR. WARD: No, you actually have until 10:10 25 so you have another half an hour. l t !
Heritage Reporting Corporation 1 < wna J
37 i MR. LYOb' I at. If we're going to meet the n
ii V 2 schedule we will h ,
Scea up significantly.
3 MR. WARD: Okay. I think we need to meet the !
4 schedule.
5 i MR. LYON: Okay.
l 6 DR. KERR: Ycu can try reading overy other word on 7 ,
the slides.
8 MR. LYON: Okay. Well, we've talked about this one.
9 Let's try the next one, i
10 l We want two indications. Either in the control 1
11 j room or being read and recorded every fifteen minutes if out-12 side of the control room.
13 Can we have the next slide please?
(] ;
O i4 We don't went geeg1e te ceese en erset which can is i lead to a loss of decay heat removal.
16 Let's go to the next one. Flying right along here.
17 We want additional equipment available to mske up 18 J and cool the core if decay heat removal is lost. Typically i
19 ; at the time of Diablo Canyon one would find perhaps one make-20 up pump available and it was kind of hit or miss what else h
21 might be around. We feel that at least one high pressure 22 injection system and a minimum of one other system should be 1
23 h available as backup. And we have an additional stipulation a 1 -ause of some of the phenomena which can occur that the 25 water provided by those systems must be effective in reaching f Heritage Rep.orting Corporation j imm.
38 I the core.
[U 2 f\l can I have the next slido please?
O'- 3 1 I havo lumped the use of nozzio dams and the use of 4 loop stop valves into this one statement. Basically it says
- ,I 5
l do not block all of the hot 1 cgs if by doing so you could i
6 create a condition such that if you reach boiling it would 7 push water ossentially out of the reactor vessel and com-8 pletely or close to completely empty the core. We do not 9 believe that would be a prudent situation to bo in.
10 Those are the short term. The expeditious actions.
11 The longer term or the program enhancement. We want--
l 12 MR. WARD: I'm sorry. But on the last one, it's 13 certainly a sensible instruction, but I mean is it obvious Ou t 14 if you let some engineers who are desianing or planning the I
15
] shutdowns, is it really obvious how this direction can i
16 be followed? I mean it sounds like you could get into some 17 l tricky situations.
P 18 f MR. LYON: Once we understand the behavior and the le phenomena, I believe it is obvious what configurations can 20 I get one into trouble. The perhaps tricky part might be i
25 totally staying away from those configurations. I believe 22 h it is obvious that one can avoid the condition by providing h
23 e suitable vent pass. Such as taking a manway off of a pres-0 24 !! surizer is going to keep one from building up a significant 25 pressure for most situations in the reactor coolant system.
I
[ Heritage Reporting Corporation mv m e
39 i Whether that relief path was sufficient to effectively removo n
V 2 any kind of a pressurization concern phenomenalogically re-O 3 quires a little bit of analysis. Essentially what is the 4 h pressure drop betwoon the upper vessel and the containment 0
$j as steam at the rato of the order of 15,000 cubic feet per
)
6 minuto flows through the surgo lino, the presssurizer heaters 9
d 7 and out through that manway.
8 f MR. WARD: Well, I guess what I'm driving at or 9l Worried about maybe is this is sort of typical, but there's 10 h a lot of attention being given to this problem. And you say 0
si h you've learned a lot and you think licensee members have k
12 learned a lot about this and everybody is kind of sensitized Q 13 to it. And I'd expect from all the activity that's going on O i. ; thet there is ee ne to be en imgrev - nt. eet it isn't c1eer is how this is going to get passed on to the next generation.
4 h
16 I mean as long as these people are now involved with this and 17 d sensitized to it art. in their current jobs, there pr Aably d
is won't be any more problems. What about five years from now?
h 39 y Or ten years from now? It isn't clear how this is getting h
a 20 g institutionalized or systemized.
p 21 MR. LYON: Of course, the Generic Letter itself will c
- L be on the record. We anticipate a follow-up program of re-views and publications. The actions will be reflected in the 23 [
24 procedures,which I'll come to in just a moment, in all the 25 1 plants, and all of this information basically should be 1
[ Heritage Reporting Corporation m.
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40 I , permanently embodied in the operation of the plants. With
('
2 )
i respect to the new plants that are being designed, we antici-O 30 4
pate this information will be applied not only with respect j!
4 q to procedures and instrumentation and items of that nature, h
s but we anticipate the plant designs themselves to roficct I]l 6! this relatively new insight, if you will, and to stay away l
70 from some of those conditions.
I h
aj Let me jump to the next slide, if I could please.
i 9 n We want reliable indications in the control rooms li 10 0 and this is what we are recommending as one of the longer f
Il term items. And we've got a qualifier. If one has no eradi-d ated fuel in the reactor vessel cooling it, there's not a 12
[ f j
13 fconcern. So there is no sense in having those kinds of re- ;
14 quirements or recommendations, if you will, which a licensee 15 [ might turn into internal requirements, in place if one 16 [Hdoesn't have the potential.
il 17 1 Dy reliable we mean an item can be reasonably l
N is q expected to perform its function.
h DR. KERR What does that mean?
39 [
1 l 20 MR. LYON: That's a good question. We know there h[ I 21 [ is a lot of information-- ;
L i 22 [ DR. KERRt Well, suppose you give me an answer 1 i 23 then. !
24 L MR. LYON: I'll try. l.
(
25 t DR. KERR Don't tell me there's a lot of (
L Heritoge Reporting Corporation a ns I
41 I information. Tell me what it means. I mean does it mean T
(~J K 2 l
a numerical critoria, for example?
l 3 ; MR. LYON: A what?
40 DR. KERR A numerical critoria for reliability?
4 fl 5 'i MR. LYON: No. A reasonable judgement that an i
6 instrument will provide--
j h
7 l DR. KERR: Whose reasonable judgement? Yours or 8H theirs?
9 ,
MR. LYON: In the end result, the staff.
10 h DR. KERR How does the staff--what criteria, what i
si kn is the sta.ff going to use to determir hat's reasonable? <
I 12 h MR. LYON: We have rot yet evvived the specific *
() 13 criteria, s 14 OR. KERR So when a licensco gets this letter, l.
a 15 L neither you nor he will know what that means?
4 16
] MR. JONES: Hold on, Warren. Bob Jones. We havo l h
17 provided some guidance in the Generic Letter. Or in the
[
d is J attachments to the Generic Letter which defines reliable.
19 t One of the things we mean by reliable is, for example, in-20 strumentation. If you've got a measure--
i 21 DR. KERR We all want equipment to be reliable 22 and accurate, but unless specifications are more specific ,
23 than that, nobody will knew how reliable and how accurate. !
\
r l
24 MR. JONES: We are asking licensees to look at the {
I l
25 accuracy requirements for this instrument. Then demonstrate j s Heritage Reporting Corporation
,ne as
- O) 42 f f-I that the instrument needs it. That's part of the reliance.
- - 2 DR. KERR In effect, you don't know how reliable O 3 you wa,t them to be but you want--there's nothing wrong'with us.
4' You want the licensee to make a judgement and you won't 5 second guess him.
6 MR. JONES: I don't want to totally say that. What 7 we are recognizing is--
8 DR. KERR: If you can't say that, then what are 9 the standards?
10 j MR. JONES: Let me try. In the case of a B&W 11 plant, if I'm going to measure one level in the hot leg, why 12 are we measuring that one level in the hot leg? We're mea-
., () ,,-
13 suring it in order to provide assurance that we know what the U 14 level is and that we can measure it accurate enough that it 15 will not cause--that you can monitor and prevent a loss of 16 decay neat removal due to low level.
17 Now, in a B&W plant they run basically with a full 1
18 hot leg pipe. They have substantial margin between that level 19 and what would probably cause a loss of RHR. Therefore, 20 their accuracy requirements for that instrument may be less 21 stringent than a Westinghouse plant which in a mid-loop 22 configuration may meet the control level on the order of 23 three inches. So we are allowing licensees to set their
. 24 accuracy requirements based on their plant specific configura-25 tion and what causes the problems for them.
l l
3 Heritogo Reporting Corporation
!l- <mna.=
43 1 DR. KERR: And you are not going to second guess (sl 2 them?
.(
3 MR. JONES: We will look and make sure that they 4 are considering the appropriate things in setting those re-5 quirements. So in a sense you can say second guessing but we 6 cannot;be specific at this point in time what is the specific 7 level that will cause loss of RHR at any given time. I can't i
8 specific at this point.
- 9. DR. SIESS: I'm confused. The slide refers to re- .
10 liability and you referred to accuracy. Is there a relation- :
. r 11 ship?
12 MR. JONES: Notice I said that was one of what we ,
mean by
(]) 13 reliability. I didn't go into a litany on the !
) 14 items. We do not mean, for example, reliable means you must 15 have a silently qualified piece of equipment. We do not 16 believe that that is necessary.
i 17 DR. SIESS: Reliable means that it must work and ;
18 it must be accurate enough. ;
i lo MR. JONES: That's right. That it has appropriate 20 quality assurance.
21 DR. SIESS: Does it have to work or just a reason- ;
22 able expectation that it will work? ;
23 MR. JONES: A reasonable expectation.
i 24 MR. LYON: A reasonable expectation with two in- l I
25 struments. And it's easy to give examp: a of what is not j
- Heritage Reporting Corporation imi m
44 I reliable. Like a piece of tubing strung across the control 2 room floor.
3 DR. KERR: We used to have a basketball coach at 4 the University of Michigan who said, "Save me the details.
5 All I want to know is the score." And what I'm tryii.g to 6 get is the score. I can't get it. Okay.
7 MR. LYON: We can't give you a numerical score 8 today, sir.
9 MR. WARD: Let's see. Mr. Jones said something to about quality assurance requirements. But on your slide 11 it says something about the core grade will generally meet 12 the requirements.
13 MR. LYON: Yes, sir. When the procadures and ad-U 14 ministrative controls that we discuss in some of the enclo-15 sures to the Generic Letter are essentially providing guidance 16 that when one installs an instrument one has to have suffi-17 cient control over that installation and sufficient quality 18 to reasonably achieve an operability situation. One doesn't 19 simply hook up an instrument, do a quick qualificatioa, and 20 go away.
21 MR. WARD: I guess I'm trying to find out in light 22 of that control grade in the general sense, the control 23 grade instrumentation is not safety grade.
24 MR. LYON: That's correct. It usually--
25 MR. WARD: It doesn't require a formal quality Heritage Reporting Corporation (MI) 4M 4000
45 I assurance program.
2 MR. LYON: But it does require by administrative 3 control and various internal pipe controls sufficient review 4 and sufficient maintenance that--
! i 5 MR. WARD: What are those? Does the NRC have any-6 thing to say about that? You say sufficient administrative 7 pipe controls. This may be perfectly fine. I'm just trying .I 8 to find out what, i
9 MR. LYON: On existing instrumentation, I can't !
. 10 address that one for you.
4 11 DR. KERR The reason I asked this question is f
! 12 because after TMI II we said that all plants should have an 13 SDDS system. And nobody said exactly what it should do or
- V I4 what it's reliability should be. Just install one. And then is once they were installed, they were reviewed rather rigorously 16 it seemed to me, so apparently in the meantime somewhere in-
! 17 side the system criteria have been developed. I don't know i
i is whether you need critoria but if you aren't going to use cri-19 teria then it seems to me you shouldn't second guess it. If L L
20 you are going to use it, if you are going to have criteria, l 21 it seems to me you ought to tell people what they are.
22 MR. LYON: We are not in a position of having speci-j O 23 fic criteria for different plants. liowever, there is a rea-i l
24 sonable judgement criterion that is reflected in our conver-
[
1 C 25 sations with the licenscoe and in our written communication.
Heritoge Reporting Corporation i imi .u.
E ~
46' I For example--
2 DR. KERR: Well,'now, are you going to be'the one O. 3 who has all these conversations so it can be one point of O 4 judgement?
5 MR. LYON: No, sir. Those have been staff'conver-6 sations with a number of staff participants and these kinds 7 of things are also written. As I said, we provided some of 8 this written guidance in the Generic Letter. We are providing 9 additional written guidance by way of instructions to the 10 residents, to the regions and to other staff members. Some 11 of that is in our office right now being prepared.
12 MR. WYLIE: Let me ask a question. You use the terms O " **" *" " "' """ '" "" "* ' **"" " * **"' "'
n v 14 says "provide improved instrumentation." It doesn't say a 15 thing about reliability.
16 MR. LYON: In which part of the Generic Letter?
l 17 MR. WYLIE: Well, I'm looking at page 12, Recommenda -
l l 18 tion 1.
I 19 MR. LYON: Is that in the program enhancements or j 20 in the expeditious action? I'm lost.
21 MR. WYLIE: Well, I'm lost too. Requirement B.
22 It's under Requirement B.
23 MR. LYON: Okay. This is in inclosure 2 to the 24 Generic Letter. That is in the plans, longer term items.
() 25 Now, what did you say the item was again please?
Heritage Reporting Corporation q t mi ...
l
47 1 MR. WYLIE: Well, it says Recommendation 1, provide 2 improved instrumentation to do the things you outlined.
O 3 MR. LYON: I've got a different page 12. I'm in a 4 different section than you are.
5 The guidance that we provide, early on is we anti-6 cipate what one would truly call an improvement. In the 7 longer term, we want really good permanent installations.
8 Whereas at present a number of licensees will use tygon tubing ,
9 for example, and because one just can't overnight install 10 quality kinds of instrumentation, the staff will accept the 11 continued use of tygon tubing subject to essentially continuou a 12 monitoring and recording of that information.
(]) 13 In the longer term we would consider that inadequate, f 14 MR. WYLIE: I guess--what puzzles me is they pro-15 vide improved instrumentation which is based on the assumption 16 that what's there now is not adequate.
17 MR. LYON: That's correct. i i
18 MR. WYLIE: But that's not the case in all cases, 4
19 is it?
20 MR. LYON: In some plants they wouldn't have to 21 do anything to comply with the long-term recommendation.
22 It's already there. Others haven't done anything and some are
- 23 in the process of improving today.
24 MR. WARD: I think Charlie's point is if it says
() 25 you've got to improve instrumentation, even if somebody has
{
Heritoge Reporting Corporation ;
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48
, I got some that's already good enough to follow your instruction 2 they've still got to improve it.
)
3 MR. LYON: The guidance specifically states, as I 4 recall, that if a plar,t has certain equipment installed', that 5 is good enough.
6 DR. KERR: So if it's already been-improved, it 7 doesn't have to be improved further.
8 MR. LYON: Not improved necessary. Is it there?
9 We're not in a mode of specifically approving recommendations 10 at this point.
11 MR. WYLIE: Well, it seems lit.e to me, Recommenda-12 tion 3, for example, uses the terms "provide adequate relia-13 ble equipment." Why is that not good for Recommendation l?
14 "Provide adequate instrumentation." Rather than improved.
15 MR. LYON: What are you on? I'm sorry.
16 MR. WYLIE: Well, this is the attachment, page 12.
17 MR. LYON: It's in the script in the bottom or 18 what?
19 MR. WARD: See the handwritten numbers in the 20 bottom right-hand corner?
21 MR. WYLIE: Okay. That's 26.
22 MR. WARD: That's Recommendation No. 2. Recomenda-23 tion No. 1 also.
24 MR. ORNSTEIN: I would like to comment. Recogni20
() 25 that those are recommendations. We are asking licensee to Heritoge Reporting Corporation (MI) 4M 4000
49 I tell us how they believe they meet or will meet these recom-2 mendations and that they think they meet the intent of the O 3 . recommendations, we've told them please just tell us that.
4 So while we may have been a little loose on our words on the 5 specific item that you're addressing, if somebody has taken 6 action and has operated the equipment or has already had that l
7 kind of instrumenta. ion installed, just basically make us r, fully aware of that.
9 DR. KERR: So it would be adequate rather than to improved? Or more reliable?
11 MR. LYON: We will make a pass through the document.
12 MR. ORNSTEIN: Generically we think the situation 13 needs improvement. That was kind of where the word improved 14 came from. And this is a generic communication which is 15 difficult to catch every specific licensee situation. i 16 MR. LYON: Your word is frankly better than the ,
, 17 one we used, at least in most circumstances. So we'll change [
} 18 it. i 19 Let's see. Level we've pretty much discussed. T l 20 Temperature, the longer term, rather than just being asso-21 ciated with certain conditions, we're asking whenever the head 22 is located on the reactor vessel, to give good coverage.
23 Decay heat removal monitoring. We're very general 24 on this one. Plants are quite different and we haven't really provided specific definitions. We do however provide
(]) 25 Heritage Reporting Corporation ;
(MI) 6N 4000
- . - _ _ _ - _ , - - . _ - - - - - . . . , - _ ~ -
1 50 I guidance and we are expanding that guidance in the instruc-2 tions that are in preparation. The intent is that'one know O 3 what is happening with the reactor coolant system. And one 4 know what is happening early enough to take corrective action.
5 For example, monitoring of the pump motor current, monitoring 6 of noise at a decay heat removal pump. They are both quite f 7 sensitive indicators of air ingestion or cavitation and will i
8 normally be encountered before one runs into a loss of flow 9 situation. A complete loss of flow situation comes later.
H) If you catch it early enough, many times you can prevent the il loss in the first place.
12 DR. KERR: If that's what you mean, I would suggest O >> 1r you hea ene wora "aireceir moattoriae" beceu e wee -
U 14 suming that, for example, monitoring the temperature of the 15 reactor coolant would provide an indication of--but it's an 16 indirect one, and I think you are really intending to ask for 17 a direct indication.
18 MR. LYON: Would one call the inlet pressure to the 19 decay heat removal pump a direct or an indirect?
20 DR. KERR: No. I don't know enough about the de-21 tails to know, but my first reaction was if you measure the 22 temperature of the coolant that gives you an indication that 23 the thing is working or not, and it would--
24 MR. LYON: Yes, it does.
() 25 DR. XERR I think what you are snying is you want Heritoge Reporting Corporation imm.
l
. 1 - ,
51
\
l a direct indication--
2 MR. LYON: We want an early indication.
O e
V 3 DR. KERR: And evcn an anticipatory indication--
O* . 4 -MR. LYON: That is correct.
5 DR. KERR: That something is going wrong. I hope 6 in reading what you meant on that would make it true that 7 that's what he has in mind.
8 MR. JONES: We believe that Generic Letter and the 9 guidance spells that out. That that is our intent.
10 MR. WARD: Warren, I realize it's not your fault, i 11 but we have to close up your section in about five or six 12 minutes. Is there some way--what would you suggest? Is
((( 13 there some way you can highlight the most critical items?
14 MR. LYON: Certainly. Let me digress for just a 15 moment.
16 Procedures is the place we anticipate most of the 17 effort. And it depends upon a number of things. But the i 18 equipment is basically there. The understanding is being 19 developed. Procedures in administrative controls will cover
, 20 the usage of that understanding and that equipment, and in our 21 judgement essentially eliminate the problem.
I 22 DR. KERR Eliminate which problem?
23 MR. LYON: Of loss of decay heat removal and of 24 responding to such a loss if it should occur. This is further ;
() 25 improvement of the short-term item.
Heritoge Reporting Corporotion o.n .a t
52 1 Analyses we have discussed to a degree. The objec-f 2 tive is to understand the behavior of the plant under all O 3 reasonable shutdown conditions. And to provide a basis upon
'O N/ which to build procedures and administrative controls.
4 ,
5 Technical specifications. We realize a number of 6 technical specifications are going to be impacted or poten-7 tially impacted. For example, many of the tech specs today 8 require a decay heat removal system flow rate of, say, 9 typically 3,000 gallons per minute. That's fine when you have 10 a high decay heat removal rate. When one has a lower rate ,
11 and one goes, one doesn't need that higher flow rate. And 12 when one goes through a mid-loop condition, that high flow 13 rate changes the level at which one can lose decay heat re-14 moval due to air ingestion by several inches. It doesn't make 15 sense to require a high flow rate which jeopardizes the loss 16 of decay heat removal. We anticipate that be changed.
i 17 We presently have specifications relative to the 18 auto closure interlock, a Generic Issue 99 item. We recommend 39 that that be re-examined and probably eliminated. Auto clo-l 20 sure interlock is inconsistent with--that malfunctions as 21 often as these do, is inconsistent with reliable equipment.
t 22 DR. KERR: Excuse me. What is an auto-closure
- 23 interlock?
24 MR. LYON: That is the pressure--the interlock
() 25 system that ties into the Rl!R in the Westinghouse plant Heritage Reporting Corporation (Mt) 4M atte
53 I drop line valve or valves'and prevents over-pressurizing the 2 low pressure decay heat removal systems.
3 D R '. KERR: Thank you.
O 4 MR. LYON: The Diablo Canyon people have already 5- done an excellent review of tha't and in conjunction with 6
funding some Westinghouse work have shown us that they can 7 not only remove that interlock and hence significantly in-8 crease the reliability of decay heat removal, but they can achieve a slight decrease in the likelihood of LOCA outside 10 containment at the same time.
Il This one we've discussed to a degree. Let's jump 12 to the next one.
33 Okay. We already know that we have a Generic Letter 14 coming. Can we have the next one please?
15 The Generic Letter went--we reviewed it with CRGR 16 on August 24th. They requested certain clarifications regard-17 ing applicability to the overall operation during shutdown 18 versus a lowered inventory condition. We made those changes.
19 They requested a cost benefit analysis which was specific to i
20 the actions we were recommending and we had been using a l
j 21 Generic Issue 99 cost benefit analysis that had been prepared 22 by the Office of Research. We have generated that cost bene-l 23 fit analysis. And this work is now being reviewed.
l 24 The cost benefit analysis itself, there are signifi-O 2> cent differencee netween the Generic 1esue 99 ceet beeefit Heritoge Reporting Corporation
<=>
1 54 s ,
't I analysis that the Research people did and the ones that we 2 did. Two aspects basically. The actions which we are recom- !
O 3 mending in our judgement will cost approximately twice the
'fT 4 investment cost in labor and equipment in contrast to the 5 work that Research did. The programs are somewhat different.
6 And we believe the Generic Issue 99 works pretty much encom-7 passed within ours. But we ask for some different kinds of 8 things.
9 The other one is the containment clocure impact.
10 The assumption was made in both the work to support this and 11 the work that Research accomplished that $400 per day in 12 charges would be incurred if one lengthened the time of a Og 13 shutdown. Basically by that containment recommendation.
f' v 14 DR. KERR: !!ow many dollars?
i l 15 MR. LYON: $400,000 per day.
f
, 16 DR. KERR: Oh, I thought you said $400.
l 17 MR. LYON: That would be a good number. I'm sorry. .
' 18 Thank you. That would be a good number. [
L We assumed that there would be a one-day core re- I 19 I 20 fueling outage lengthening of the shutdown outage. The Re-
- 21 search work was based on the assumption of three days por i i
l 22 reactor year. The difference in good part we believe is be- !
l i 23 cause of more recent information that we are continuing to ;
24 obtain from industry as we continue to do the work in this j () 25 area. And I could go into the specifics of that if you'd !
l Heritoge Reporting Corporoflon -
l im> m.m
1 55 I like.
2 MR. WARD: No, you don't have to. But the more O 3 recent information indicates which is. correct? One day or 4 four days?
5 MR. LYON: The one day, sir.
6 MR. WARD: One day.
MR. LYON:
~
7 Of the plants that we have sampled, 8 most are indicating essentially no impact or up to the order 9 of one day. t 10 DR. KERR: Earlier you said you thought following 11 your recommendations would virtually eliminate this risk.
12 MR. LYON: If the containment is--
13 DR. KERR: I'm not sure if you meant risk to the U 14 public or core melt probability. If it will virtually l i
15 climinate core melt probability, then it seems to me the 16 containment thing is a moot point.
17 MR. LYON: Not totally from the viewpoint of the 18 defense in depth philosophy and just-in-case kind of coverage. ,
I I
19 On a probabilistic basis, you are correct.
i 20 DR. KERR Well, you've discovered this problem, 21 or I should say identified it on the basis of the PRA. I :
l 22 think that was--
23 MR. LYON: No, that's not correct. The PRA was one ;
24 of many indicators that there was a problem. The first real l i
() 25 indicator that I'm aware of was the history of the operations v
Heritage Reporting Corporation [
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56 I and llal Ornstein's been very active in'that-and has been-identifying we've had a problem in this area for quite some o
2 1
3 time.
4 DR. KERR: I said you've identified the risk.on 5 the basis of PRA. I think that's what'you said.
6 .MR. LYON: I misunderstood. The specific quantita-7 tive value, yes. That came from the PRA. And that is a high 8 uncertainty area in part because a lot of personal inter-9 actions are involved.
- 10 DR. KERR Surely you aren't doing this with the it idea that there's not much risk but it ought to be done any-l 12 way. J (T 13 MR. LYON
- That is correct.
v 14 DR. KERR: So you must give some credence--I i
15 think earlier I was told that this just about doubled the 16 risk of core melt compared to what one would get from a 17 conventional PRA. ,
i I 18 MR. LYON: The order of magnitude, the numbers that l 19 Al will provide are of the order of 2 to 4 or 5 times 10-5 (
J 20 likelihood of core molt. They do not address quantitatively 1
21 the likelihood containment will be opened, but wo estimate l I
22 that to be high.
23 DR. KERR: This will just about double that.
r l 24 MR. LYON: Yes. [
([) 25 DR. KERR And that's fairly significant. One of Heritoge Reporting Corporation
- < mi .
57 the things that puzzles me is I've seen some things that may 2 eliminate or decrease this, but if it is really that big,
() 3 something that virtually doubles. Maybe that's not very big.
l')
k> 4 It appears to me that one might do something a bit more dras-5 tic to eliminate that. For example, have you considered 6 prohibiting this lowcr reaction vessel level operation with 7 fuel in the reactor. After all, people can wait. If the 8 risk is really that great, one could shut the reactor down 9 and wait until you take the fuel out and then do whatever is 10 necessary with the reactor.
13 MR. LYONr We have considered that, yes. We do not 12 believe it is necessary in most circumstances. There are some plants out there that effectively follow thct policy. I'm
[]} 13
() 34 aware of one that follows it not with respect to the level 15 but with respect to whether they take their equipment hatch l
16 off.
l l
17 DR. KERR: Have you looked at the relative risk 1
l
! 18 production of that compared to what it is you are proposing?
i 39 I
MR. LYON: On a quantitative basis, no, sir.
20 DR. KERR: Well, I don't see how you can look at 21 it other than on a quantitative basis.
22 MR. LYON: I think engineering judgoment and ex-l 23 ! perience are excellent indicators.
3 24 MR. JONES: If I could try to address that. For h
example, in looking at the containment closure issue in the
([) 25 Heritage Reporting Corporation i e. > ... a l
58 [
f I instance. The requirements'of expeditiously closing the i 2 containment. We figured.out what would reduce the release ;
3 from a high population sight, I think from a thousand-man '
- ()
j 4 rem per reactor year down to on the order of ten.
r That's a ,
i l i
5 very eignificant reduction and we don't see, for example,
[
t 6 them having to take the core out-to the fact that we got a l 7 zero. We don't think that's cost beneficial.
i 8 But we both know that the uncertainty in predicting l t
9 ontainment performance--the big uncertainty is the risk .
l 10 assescment. Much greater than the uncertainty, I think, in i 11 predicting core melt.
t 12 That is one of the reasons why we are pursuing on 13 a longer-term basis. And then also incorporated on the l
14 shorter-term basis actions that will tend to eliminate the ,
15 initiator and will attempt to mitigate the problem--an event, l
16 before core damage event occurs. That is why the emphasis l 17 on the longer term is in that vein. So wo don't have to ,
la l
- particularly rely on the containment. -
! 19 In looking at the short term, we've got somo upgrade a i
20 in instrumentation that could be accomplished. Some short l
) 21 term procedural equipment identification actions that could I 22 be accomplished immediately. We would have a real risk ro-(:)
j 23 duction. Wo will try to quantify that. But the containment !
f I
24 closure being our defenso in the term short, we are request-l l
l.
() 25 ,
ing those long-term actions to be completed on the order of [
i l Heritoge Reporting Corporation l
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.___~________ _ , _ _ . _--_ - _ _ - _ _ - -
59- '
o L i
I the year and a half to two years. We think that that is a }
l 2 reasonable way to go. l O 3 DR. KERR And even though you did quantify the ;
i 4 risk initially, the situation, you don't think it's worthwhile c 5 to ask yourself, now how much is risk reduction or,how much ,
6 say reduction in core melt probability have we achieved by v
7 these. changes? !
8 MR. JONES: We have estimated those. I think they 9 take us from 10-5 I don't know. I think you are going to !
10 , hear that next.
Il MR. WARD: One question. The cost of the contain- !
12 ment closure. The one day for shutdown. That's for contain-13 mont closures as you discussed earlier. You closed up where t i
14 you can't see a gap in it. I l
15 MR. LYON: That's for the equipment hatch. The
(
16 containment closure criterion per se is essentially one 17 integral barrior.
18 MR. WARD: Oh, okay. What would the cor;t be of l
19 requiring this complete toch spec containment closure?
20 MR. LYON: We haven't addressed that.
f f
21 MR. WARD: Do you have any guess? [
\
22 MR. LYON: I will make a guess that it would be t O 23 of the order of a week at least.
I f
24 MR. WARD: Okay. Thank you very much, Warren. !
25 Mr. Spano.
l Heritoge Reporting Corporation (Mf) 6M asse
60 I MR. MINNERS: Before Al gets up, let me make a 2
, couple of comments about containment closure. I don't have 3 the answers but the Committee might--I've kind of thought 4 about thic problem.
5 As everybody knows that when refueling is being i
done that part of the containment would be closed. I don't 7
think the risk to the public is as high from that operation 8 The probability of some core as it is to the -- operation.
9 damage or fuel damage, I don't think the risk--investigating to low temperature over pressurization, we're getting numbers
!! a little below 10-5 from the core melt probability, and the 12 containment is allowed to be opened in those situations.
O >> The fue1 goo 1 is confined, bue if you hed e fire O 14 the fuel pool confinement would probably be ineffective and 15 we're calculating by 10-6 probability.
16 MR. WARD: Okay, Warren, that's interesting. Thank 17 you.
18 Al, we've eaten ten minutes into you' time, but i
19 '
we will--I think the chair is going to insist ;..ac we end 20 at 10:45. So I apologize.
21 1 gg, spANO: Well, Warren has reviewed the staff 22 concerns you brought into issue and has discussed the proposed 23 ij short and long-term actions which would intend to reduce the ll 24 i'4 assessed risk.
O >>
H Whet 1 wou1d 11xe to do in chie eresentetion 1 to 1
h Heritage Reporting Corporation ll ino.a
61 focus on some aspects of the regulatory analysis we did and 2 let's see, may I have the first slide.
p)
'- I'd like just to very briefly touch on the back-3
/~
(~)T 4 ground. Discuss some of the PRA findings that we obtained, 5 and the resolution approach which was essentially a defense-6 in-depth approach.
7 Some of the proposed requirements in the schematic s form and then the cost benefit results.
9 The Generic Issue 99 specifically dealt with two go modes of Rl!R failure, both common cause modes. One had to
- do with the excess lowering af water in the hot leg during 12 mid-loop operations. And secondly the auto closure interlock
(~ 33 related to spurious closure of the suction valves in the RifR
'd 34 drop lines.
15 The event frequency for the spurious closure of the 16 valves is perhaps 50 percent greater than that of the mid-loop 17 losses, but the mid-loop losses pose the significantly greater gg risk hazard as I'll discuss next.
g, And this is because of a number of reasons. The 20 reduced inventory provides the operator much less time to 21 recover;the recovery of the air bound R11R pumps may be dif fi-22 cult. If you get air ingested into the RIIR system, especially
) I 23 [ into the Rl!R system, especially into the long horizontal runs t
24 f piping, it may be difficult to get that air out.
() 25 In particular, if you look at the statistics of the Heritage Reporting Corporation
< m, m
62 I recovery time to--the mean time to recovery for both the ,
2 mid-loop loss of RHR and for the spurious closure of the ;
O 3 suction valves, failure mode, the first is something like one 4 hour. This is for something like for the events. Whereas l 5 the mean time to recovery for the p, imp suction is more like 6 fifteen minutes.
7 There is a core damage frequency of about three 8 times 10-4 associated with mid-loop' losses. And this is high.
9 I'll discuss that in the next slide. And of cou'rse there is to the problem that the RCS and containment are typically open i
11 or may be typically open during mid-loop operations. ,
12 The PRA study that was done by Brookhaven and is j 13 presented in NUREG 5015 was based on an EPRI study that was i'
14 done specifically for the Zion plant. And except that it was 15 modified. Some of the modeling of the plant operations was 16 modified and generic data was used on the loss of RHR. And i
17 on component failure, failure rate data, i f !
i is The core damage frequency results that were ob- i' l l
) 19 tained show that overall one gets a number like 5 X 10-5 for l
20 shutdown operations. This includes not only the main contri-l j
butor of loss of cooling, which is something like 80 percent, 21
(
i 22 but also two other initiators, LOCA and loss of outside power. l l
j O 23 This high number was not quite obtained in the Zion study.
i l
l 1 l 24 It was more like 2 X 10-5 but in the specific Zion study the l O >> coatrid"tioa e totei core a ee tre9"eaev ometata9 tixe l t
i Heritoge Reporting Corporation !
I imi m l 1
63 (
l one fourth.
2 I might also mention that we understand the French O 3 have done two studies recently to look at the risk for shut- '
4 down operations. We haven't seen these reports or some of the s reports as yet but one report--one study deals with their 6 900-watt standardized plant. And a paper which referred to t 7 some tech spec requirements that they were going to impose j s was g'iven last year and it indicated that the core met fre-9 quency for shutdown operations was something like 4 times ;
- i to 10-5 and that through these procedures that they were proce-l 11 dures in tech specs that they were proposing'they would reduce j 12 that to less than 1 thnes 10-5, i
13 Some representatives of NRC and Brookhaven were in I
ja France in June and they did meet with some of the EDF people is who are doing a PRA study on shutdown risk for their 1300 ,
16 megawatt plant. And it was indicated at that time that the shutdown--some of the preliminary results that they are ob- !
17 la taining indicate that the shutdown risk could be about equal [
3, to that from power operations. [
20 MR. CARROLL: The core damage frequencies indicated r l
21 up there are for the situations prior to issuance of the [
l 22 Generic Letter? !
23 MR. SPANo: Yes. These are base case results. And ,
24 I'll indicate in one of the later slides just how those core [
h 25 damage frequency numbers could be reduced. i Heritoge Reporting Corporation
- m. j
64 1 MR. CARROLL: Okay.
p 2 MR. SPANO: There are some uncertainties associated
( )
3 with the PRA calculations and one problem is that the PRA l',
(/ 4 calculation is a generic calculation and yet many of the im-5 portant factors that go into that calculation are rather plant 6 specific. For example, the annual time spent on RilR opera-7 tion. If you look at the statistics of down time where the 8 plant is on RHR operation, you'll notice that from the grade 9 book, for example, that these time could vary from something to like twenty-five days per year up to something like one hundred 11 and fifty days. The average being something like a hundred 12 days.
() <~
13 l
DR. KERR: Are you saying that the average time ks la which Ri!R is used for plants in the U.S. is likely to be a 15 hundred days a year?
16 MR. SPANO: Yes, yes, yes, d
17 MR. CARROLL: That's simply shutdown.
l b l 18 MR. SPANO: That's during shutdown operations.
, 19 i DR. KERR: More than 25 percent of the time they i i 20 l are shut down?
t 21 ! MR. SPANO: Yes. This is reflected in the plant h
22 Y capacity numbers that are obtained.
23 J DR. KERR: I'll bot you that that is exaggerated d
24 [ because there are six or eight plants that aren't operating at all. And if you look at those, the decay heat in them is so (l]) 25 1
I j
Heritage Reporting Corporation ii.:: .i.
1 65 I small the risk is negligible. If you really look at operating 2 plants I can't believe that that number means much. Look at 3 the number of plants that are completely out of operation now.
k_) 4 They are the ones that give us the 60 percent number. And 5 their risk contribution is--
6 MR. CARROLL: If you take that away, Bill, you still 7 aren't talking 70 percent.
8 DR. KERR: Well, have you done the arithmetic?
9 MR. WARD: Yeah, I have. I mean 70 percent is 10 pretty good.
11 DR. KERR: For the ones that are in full operation?
12 MR. WARD: Yeah.
() 13 MR. SPANO: It's up around 82 percent.
. 34 DR. KERR But there are some that are significantly 15 there. Also the risk must be significantly different for a 16 long shutdown where the decay heat goes down.
17 MR. CARROLL: Sure. That's one problem. The other is problem is the risk isn't very high once you get out of mid-39 loop operation. Once you get into non refuel. The total 20 amount of time on RHR is not really the risk determinor in 21 my mind.
fS 22 MR. SPANO: The Zion plant, for instance, comes V right up around the average number. And this is over a period 23 24 l of ten years of operation.
I An additional factor might be the corrective measures
(]) 25 l
l Heritage Reporting Corporation m..
l
.C.
66 I that have been taken by plants to approve for their prevention 2 of such kinds of losses. A lot of this information is not
('~ 3 readily available. The scheduling of plant shutdown, refuel-g
'> 4 ing maintenance operations is also something that tends to 5 bloody up the calculation. And the conduct of shutdown opera-6 tions on the availability of plant safety and support system 7 equipment. When they shut down they tend to disable certain 8 kinds of equipment which may be impcrtant in trying to recover 9 from an extended loss of RHR.
10 other large uncertainties are associated with the 11 human error probabilities. The recovery actions are very l 12 much dependent on what the operator does. And the cognitive
(]) 13 error modeling is a difficult proposition and is still being
) 14 developed.
15 The cost benefit results also reflects some tacit j 16 conservatisms which prevent the--there is incomplete modeling l
17 of the spectrum of recovery actions that one might consider 18 i to be available.
0 19 l DR. KERR: What does conservatism msin in this con-l 20 text?
21 j MR. SPANO: Well, conversatism--
l 22 DR. KERR: Cost is estimated to be greater than you O 23 4l l
j think it is? Or less?
J 24 MR. SPANO: No. This would tend to make the core damage frequency higher,
({) 25 h
8 Heritogo Reporting Corporation i,.....
j
67 i DR. KERR: The fact that you don't take potential 2 recovery actions into account would make it higher? I would 3 think not taking them into account--okay. So that would also 4 make the cost of the accident higher, Js that right?
5 MR. WARD: No, it would give you more cost benefit 6 in terms of dollars per man ren, I guess, isn't that how you 7 do it?
8 Yeah, but it's the core--
, DR. KERR:
10 DR. KERR: Yeah, it'll make the cost of the accident 11 bigger.
12 MR. WARD: Yes, that's expressed as man roms, not
- 33 i as dollars.
34 DR. KERR: So conservatism means a bigger number of 18 man rems?
16 MR. SPANO: Yes, yes.
17 DR. KERR: But then down below it says if you can i
18 { suo the end results tend to be nonconservativo, it would seem 19 to me that they might be conservativo for the same reason 20 t rather than non-conservative.
21 MR. SPANO: These were the calculations that woro i
22 mado for the regulatory analysis. There woro cortain rapid 23 l accident scenarios which were not considered in the original 24 calculations performed by Brookhaven. They woro not--
O >>
1 DR. xERR These seme recovery overetio#s mentioned Heritage Reporting Corporation l
68 I above also were not considered, were they?
2 MR. SPANO: Right. If you were to consider other 3 recovery actions that could be taken, that would tend to reduce n
(' s) 4 the core damage frequency.
$ DR. KERR So the core damage frequency might turn 6 out to be conservative or non-conservative? Again, non-7 conservative here means that you expect that they are too 8 low.
9 MR. SPANO: That's a bad word to use. I think I 10 should say that incomplete modeling of recovery actions would 11 tend to make the calculated core damage frequency higher.
12 It might realistically be if you consider what might be avail-f^ ) 13 l able to the operator on an emergency basis. Or if you have 14 4 cmcrgency operating procedures available to them.
15 l MR. CARROLL: Well, in your second bullet, for ex-16 ample, refers to the leaving the hot log or having hot log 17 nozzles dams in place. That kind of situation, is that right?
0 18 MR. SPANO: Well, in the second bullet with regard i
19 to core uncovery, we used core uncovery in the sense of un-20 l covering down to the core of mid plan.
21 ! MR. WARD: He means the last bullet.
l ;
22 ! MR. SPANO: Oh, the last one. Yes. We did not
(
23 include that kind of a scenario where you could uncover i
I 24 ,
rather rapidly within ten, fifteen, twenty minutes.
() 25 MR. WARD: So these two bullet items here would tend I Heritage Reporting Corporation l
- mo..
69 I to sort of trade off against one another.
2 MR. SPANO: Sort of trade offs. Right. Neverthe-O 3 less, if you do have core uncovery, if you simply consider l O
^
4 l the core sitting in a' pot of water and gradually the v.;ter 8 is boiling away, the time it takes to reach--for the Aevel to !
' get down below the core mid plain and to a point where the j 7 fuel rod temperature might get up to a temperature of 1700 l i
! t 8 to 1900 F. Where the oxide react.on really takes off-- j l
MR. WARD: We understand that. I'm sorry to have t
! l 10 brought you to-qou have just five more minutes.
l j ll MR. SPANO: The resolution approach was simply to 3 12 I
! try to prevent loss of RHR, prevent core damage, and assure 1
j 33 that containment protection is'availabin,,and this is shown l
- t l 14 in the next slide.
f i
l 15 The Fix A is very,'very'important because it means e u 16 that the operator has the information he needs first to tell l
j 17 him that he's about to have a loss of RHR and secondly how to :
I
- la deal with that through alternative procedures, through ad- !
10 ministrative controls so that someone in the containment is -
! i 20 not opening the velve and intending to upset the reactor I
! e 23 coolant system.
I
[
i 22 The Pix B is primarily to try to fix tha problem of
)
23 the inadvertent spurious closure of the suction valves by i i !
24 removing the auto closure interlock.
l 1
O >$
~
rix c is the test one.
l r
, Heritogo Reporting Corporation i 1 m. i l t i-
70 1 The next one, the next slide, simply shows the p_.
2 cost benefit numbers that were obtained and there was a
) {
I 3 sensitivity study done for different kinds of sites. A high l
4l site which is something like the Zion site and characterized l
5 i by some 800 persons per square mile. A generic site, a 340, 0
6 and a low site of 100. And one gets different numbers for 7 the cost benefit ratio.
8 hl For the containment closure cost benefits, there l
0l 9 d the dollars per person rem, it changes radically as soon as I
10 j you can put the core reduction fixes in place. Fix A in 11 11 j particular. So that the core damage frequency would be re-2 12 duced by a factor of ten. From about three or four times (t'~l 13 10-5 to a factor of ten below that.
'7^T ly k_) 14 l DR. KERR: That is accomplished by Fix A, did you 15 say?
l 16 MR. SPANO: Fly A, yes. This is the one that in-17 volves good instrumentation, good proceduren, control of the i
18 l situation. In many instances in the past maintenance people 19 have gone out--
l 20 DR KERR: If you were just worried about--if you l
21 [ were just using quantitative risk, you probably haven't done f,
,- 22 that, you wouldn't worry about obtaining closure. But you d
2J ;l do that in defense-in-depth, is that what I heard?
l' i MR. SPANO: I've got another slide here that would i 25 tend to show that. But--
p Heritogo Roporting Corporation L , = u.
l.
71 1 MR. WARD: Well, I think this shows it.
2 MR. SPANO: All right.
O 3 DR. KERR I just want to make sure I understood 4 what I'm hearing.
3 MR. WARD: I mean if you are using a thousand 6 dollars a man rem as a standard, obviously you don't justify. ,
7 containment closure if you've got A or A plus B. I don't [
I g believe we're arguing with you. !
9 MR. SPANO: I might say that the numbers that are 10 given here for the costs we think are on the high side for a j 11 number of reasons that were pointed out before. [
12 DR. KERR Well, if they are on the high side, why I 13 are we seeing them?
14 MR. SPANO: Oh, come on. f r
I 15 DR. KERR: It seems to me you ought to use numbers 16 that you think are real and not on the high side.
17 MR. SPANO: We use the numbers that are based on i l
is information that was available to us. I think that if one ;
i l
i, wants to get a good number, one has to do a plant specific !
1 20 study. Much depends on how the plant does its shutdown 23 operations.
i DR. KERP.: Do you think they are high because they l
()
22
- 23 are generic rather than plant specific? j i h
- < MR. SPANO
- Well, this is one of tii .coblems that
]
are in the generic analysis.
f (]) 25 i
I l
4 Heritoge Reporting Corporation j i imnw 3
72 1 MR. JONES: This is Bob Jones. A direct answer to 2 your question, Dr. Kerr, yes, we are considering the contain-(' 3 ment closure in the long term as a defense-in-depth provision.
G 4 DR. KERR: Thank you.
5 MR. SPANO: And finally the final slide is simply 6 the conclusions that we reached on the basis of the analysis 7 that we would require implementation of Fix A, to reduce the 8 core damage frequency.
9 We would recommend but not necessarily require 10 removal of the auto closure interlock. It helps to reduce the 11 core damage frequency risk but the cost benefit numbers are 12 different. And that we would require implementation of a O >> coat tameat cio="re reautre e=t ee atas ea eneroeriete imete-14 mentation of the Fix A. That would reduce the core damage 15 frequency.
16 MR. MICllELSON: A question on your second bullet, 17 l you are proposing to remove the auto closure fe-ture. I 18 assume that was in there to accommodate some other accident 19 situation. llave you evaluated that situation to see what i 20 '
the effect is?
21 l MR. SPANO: The auto closure interlock--it's to C
i 22 f ensure that when the operator goes up power, the both suction l
23 values are closed. It's a backup. And--
q ,
24 MR. MICHELSON: What is it interlocking on?
O 25 1
h MR. WARD: I think what he's asking though is the
[ Heritage Reporting Corporation im: m I :
73 i fact that you remove that means presumably that you are in-2 creasing the risk in some other scenario.
3 MR. SPANO: Yes.
4 MR. WARDi r d have you quantified that? Isn't 5 that what you are asking?
l 6 MR. MICHELSON: I was kind of wondering what the 7 scenario was--
8 MR. WARD: We've only got time for--
9 MR. SPANO: It's an analysis of that particular 10 problem which has to be done by Westinghouse for Zion and 11 ; they have also done a--I'm sorry. Not for Zion. For Diablo 12 Canyon. And they have also prepared a more general study showing that the reduction in risk through cutting down on
( 13
- 14 loss of RHR would be greater than that given in increasing 15 the interfacing systems LOCA risk.
16 MR. JONES: If I could quickly put this same sub-17 ject--we are not saying remove it at this time. We are asking 18 the licensees to take a look at it. We believe that removal 19 of the auto closure interlock can be accomplished in a way 20 that will actually decrease the risk for the LOCA outside 21 containment issue with maybe some instrumentation. As a 22 result though, since it can increase risk and since it is O 23 somewhat plant specific, we decided to recommend that they L
24 go ahead and look at it. But we didn't specify that they take
]c We think
(]) 25 l
this action at this time in the Generic Letter.
Heritage Reporting Corpor; tion ji < =: m .=
,1
74 3 it's the right direction to go but we're not dictating them 2 at this time because while it's a potential plant specific 7-() '
3 risk implication.
4 MR. WARD: Well, are you going to ask them to 5 ovaluate or somehow--this is the downside risk?
6 MR. JONES: Yes. We've asked them to consider it.
7 And specifically discuss in the attachments to the Generic 8 Letter.
9 MR. ORNSTEIT I'd like to give you a little bit to more histo.;r on that particular issue. That particular 11 issue was raised about four years ago when Sandia did an 12 analysis which we report in C 503 where they effectively
( 13 indicated that when a case is chosen in Sandia's analysis
' 14 if the risk overall would be lowered for the case chosen is from eliminating the auto closure interlock.
16 MR. WARD: The risk overall, was that including 17 crediting reduction of the risk that you are talking about l
18 here today? Or was that before that was recognized?
19 1 MR. ORNSTEIN: It was the perceived risk at that i
20 point. I i
21 [ MR. WARD: But there's some other safety advantage l
22
- in taking out that auto closure interlock other than what O 23 i
l we've talked about today?
ll 24 'l MR. ORNSTEIN : It was with some risk from RHR loss
() 25 against the event B scenario.
, c p Heritage Reporting Corporation g i,,,,.
l I __ __ _ _ _ - _ _
l I 75 i !
r i MR. WARD: Thank you.
2 Okay. That's all. Mr. Chairman, I would like to O 3 find out from the Committee, if we could just take a minute, ;
O 4 what the Committee thinks about this. Do we want to endorse [
5 the--the staff is going ahead with this Generic Letter. Do 6 we want to endort.c or comment or whatever? l l
7 Is the staff looking for anything from us?
8 MR. JONES: I don't think we need anything.
9 MR. WARD: Okay. All right. You might get some- $
10 thing. !
l 11 MR. JONEC: I understand that also. l 12 MR. WARD: Okay. Well, any guidance--if you want l
[
13 me to draft a letter saying somethiag-- >
t 14 DR. KERR If ther's something to say. The thing i 15 I think we should say and I don't think it's a contradiction [
t 16 of what the people here have told us, is that I personally 17 think--I believe and I think they said they were going to do j i
la this, there should be enough flexibility to take into account ,
19 plant specific differences and plant specific instrumentation (
20 that exists. And I think the people here--but I'm thinking 21 of the people who are going to be enforcing this, working f 22 with it later on that won't have the wisdom that this group ;
O 23 l
here has. I just think we ought to caution--that would be I
24 the main thing I'd say. l
' = *ae an w^ao' O => wett t 9"e t titt xt=a or see l
Heritoge Reporting Corporation !
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1
i 76 i
i containment closure thing. I find it a little hard to believe 2 that,'ou y know, scrambling around at the time an incident is 3 initiated to close the containment instead of trying to get f the water back in the core or in parallel with that is--it 4
f
{ $ would be kind of an exciting fact. I'm not sure how effective [
this is, but I realize there are apparently major costs 6
f 7 associated with regular containment closure during the most i a critical sort of operation. ;
9 MR. CARROLL: Well, what are you worried about. ,
10 Dave? Putting the equipment hatch back on or doing things 18 like closing the air lock door? The equipment hatch is the i
12 troublesome one. They're saying the way it works out is [
13 you are probably required to keep the eqiupment hatch in l
- 34 place, at least if you are talking about mid-loop a few days a i
- 15 after shutdown. !
[
l 16 The other things aren't that troublesome. They [
! I 17 are easy to put back on. Somebody has got to get on it. I'm (
]
} f
! la not that worried aLout it. !
l e I i
1, MR. LYON: If I may, if the word scrambling describen J t
j 20 the situation of ensuring containment closure, we wouldn't
(
21 be in favor of it either. But if one has well thought through {
l l 22 procedures in place and provision for assuring the necessary (
j O 23 equipment and manpower, then one has a situation in which f
l l 4 containment closure is reasonable assured.
23 MR. WARD: Mr. Chairman, that ends this session, j !
l Heritoge Reporting Corporation ,
! < =n *= a l l
l 77 i CHAIRMAN KERN: Mr. Michelson is Chairman of the 2 next subcommittee presentation.
3 MR. MICllCLSON: Thank you, Mr. Chairman.
4 The next subject for discussion is the Maintenance 1 5 proposal, package. The details are given in Tab 3 of your l
l 6 book. It's also a handout, I saw just a moment ago that is a i
l 7 status report and that would be a lose piece of paper in front 8 of your place.
9 You have heard the briefing, in detail, on this 10 subject at the '. a s t full committee meeting and the only purpos e II of the meeting today is simply to aive you any last ninute
\
l l 12 changes and to, perhaps, provide a brief refresher of what g 13 the package consists of because we will be required to prepare W 14 a letter this Saturday in order to rect the schedule of the is full Conmission to consider this matter in early October.
16 The staff presentation, I have already discussed, I
i 17 l I expect to hear a few remarks from NUMARC also to allow you t
il is i an opportunity to hear a little nore of industry's view on the i
19 subject and provide nn opportunity for you to ask questions I
20 on it, on the industry, as well as cuestions from the staff.
l 21 I think that about takes care of the preliminaries, f
,3 22 so with that I would like to ask that Moni Dey present the
( ) f 23 l staff's nosition on this pachace.
24 While Moni is getting ready, let me nake a few n
() 25 additional remarks.
Heritogo Roporting Corporation h
.p 78 3 If time permits, at the end, at the end of our 2 discussion this morning, I would like to get guidance from i
3 the Committee as to what they think ought to be in and whe-m e a w 4 ther--I am still working on a draft, but it does not incorporate 1
5 the views beyond that of the subcommittee which met yesterday 6 to consider this matter.
7 MR. DEY: Thank you, Mr. Michelson.
0 8 ll Today will provide a briefing. The first slide shovs l
9 l the outline of the briefing. We'll go over the schedule for I
30 the notice of proposed rulemaking and implementation of the l 1 rule; to present the conclusions and recome.endations and we i
12 would like to focus, bared on comment we received from the 13 .
full committee last meeting, what the purpose of the rule is, 34 Yl and what we have accomplished to chis point and I would like 15 l to indicate that the notes of the proposed rulemaking package
-l 16 :
i you have in front of you, is the result of work that was i
initiated the start of May, so this is the product of about 37 ll h
is !
4 months work and we do have plans for further work as will i, ! be indicated, b
- o ve definitely don't have all the answers, but we have h
21 j the plans for deternining those answers, b
22 :
So falling back, I will present to you the framework 7 ,)
(
u ,'
23 ,
of the rule, the contents of the Notice of Proposed Rulemaking 24 which includes in it the Attributes of Industry Standards and the Recomnendations for consideration for the development
() 23 ,
Heritogo Reporting Corporation
! xm b
1, 79 I of that standard.. I'll briefly go over the comments that we
-, 2 , solicited from the proposed rulemaking package and summarize
) t 3 the regulatory analysis.
I )'
-' 4 Today, we have our final meeting of the Notice of 5 Proposed Rulemaking with the ACRS and we request a letter.
6 We have a neetino scheduled with the CRGR on 7 September 14, and the Notice of Proposed Rulemaking is due to 8 the Commission on October 3rd.
9 I can't fit all of this niide en, but following, 10 we expect the Cor. mission to publish the Proposed Rulemaking 11 round about November 1st, following which there will be a 12 two month public comment period and we expect to have the 13 final rule, which would incorporate the comments we received 14 from the public, and have the final rule available to the 15 Commissionion by April 1 of 1989.
16 ,
The final rule would require th
- licensees to submit I
17 d a plan, within 19 days of issuance of the rule which would 18 give the licenseas' plan for full innlerentation of the rule.
f 19 The full implementation of the rule will be required 20 l
from about two years from the issuance of the final rule, il 21 l That will be about May of 1991 and the reason for that is that
! 22 we expect to develope a regulatory guide which is this second 7s
( %-
23 p line here.
24 [ In the notes of supplementary information for the
< I Notice of Proposed Rulemaking, we have given our approach to (m) 25 h
- Heritogo Reporting Corporation j = .n
ti i 30 g development of regulatory guide with an industry standard 2 and that is in the supplement for your information in the
(
)
3 proposed rulemaking package.
m) 4 We expect to solicit comments on that and we would 5 finalize that approach as supplementary information in the 6 final rule.
7 Following that, we expect to issue a REG GUIDE 8 to either endo.se an industry standard or provide specific 9 guidance if such a standard is not proposed, and we expect to 30 publish this by about April cf--about one year prior to re-3: quiring the full implementation of the maintenance rule by 12 the licensees. So they will have one year prior to issuance
(') 13 of the final REG GUIDE which our goal is to endorse the
(- 14 industry standard which is the third line. We also expect is that industry will propose developing such a standard as 16 ,
early as November and we hope to work with them on interim t
17 drafts of standards and have a draft standard along with the is I final rule and then we will provide final comments and d
19 finalize that standard a couple of months orior to issuing h
20 L the REG GUIDE.
l 21 !i l
So this is the schedule for the standard which fey 22 H
' coincides with the REG GUIDE being able to endorse the L) 23 ,
industry standard.
24 L Before I get into the purpose of the rule and what f the 5, t a f f ' s
[) 25 we hope to achieve, let me briefly go over Heritogo Reporting Corporation e a.r m ii
?
') 81 conclusions and recommendations.
.Ts you will recall from the last meeting we had,
()
2 3 we had develope rulemaking options, about 5 options which C') we wrote a paper on and that was submitted to the Commission
(_/ 4 3 and sent to the public, to people who were interested in com-6 ing to the workshop and we had a workshop which was success-7 ful and we received a lot of comments on those rulemaking a options and today I jumped to the staff's conclusions and 9 recommendations as a result of that work.
in The conclusions are that prescriptive rulemaking
- options have minimum flexibility and we have heard a lot 12 about initiatives industry is taking to improve maintenance and a prescriptive rulemaking option may impeded these
(-}
w s 33
(_) 34 initiatives.
15 We feel that rulemaking thouls encourage rather tha t 16 divert these initiatives, therefore, we conclude--we recommend 17 a rule which gives industry to develop a standard for a s..ain-18 tenance program, which the NRC could endorse in a Regulatory p, Guide.
20 The industry standard should include provisions 21 for performance assessment and feedback of results to improve
- the program. We feel this is an important critical part of O 23 the maintenance program.
24 The staff expects the industry standard to be
(} ;$ comparabel in scope and depth to the INPO maintenance guide-Heritoge Reporting Corporation
< => m j
b 82 1 lines.
,- 2 Now let me come to the important slide on the L) ~
3 purpose of the rule.
\m 4 Before I go ov2r the bullets, let me mention that 5 a question on how we expect the rule to achieve improve-6 ments, we have not, at this point, completely determined 7 the content of a maintenance progran, the criteria to make 8 that judgment.
9 What we have, up to this point, is the definition 10 of a maintenance progrzm and the definition includes in it, 11 a set of activities which are necessary to have an effective 12 program.
g 13 Now having those activities does not necessarily W 14 mean you will have an effective program, but we come to the 15 point where, in the proposed rule, we said that a maintenance 16 program should have these activities.
17 The next stage would be in the industry standards, 18 is to determine what the implementation of these activities--
19 ! in what matter can they be implemented to make a program l
20 l, effective and what are the criterias that one establishes 1
4 21 to make that judgment and that will be done in the next phase .
h b
~ 22 We don't have those answers now.
xs p 23 q The purpose of the rule is to improve licensee 24 h maintenance progrars, they're warranted and to maintain a 1;
s This is not based on (x- ) 25 q satisfactory level of perforrance.
4 Heritogo Reporting Corporation iat m m.
g
b 83 I an exact measure or threshhold of effectiveness. !!aintenance rs 2 includes a lot of areas including human factors and it's very
/\
\/
3 broad and interrelated with other aspects of the plant and q
'u/ 4 doesn't allow us to measure it quantitatively or exactly.
I s
l But the rule would set a comprehensive standard 6 which reflects those attributes of program which, from previous 7 experience and judgment, we find do contribute to an effective 8 maintenance program.
I 9 j The purpose of the rule is intended to insure 10 licensees in their programs those attributes identified in 11 the Policy Statement which are now in the definition of the 12 rules, and implementation which would be outlined in the g 13 industry standard.
W 14 l Qualitative judgment, based upon inspection and I
is audit of licensee's maintenance programs would be used as the l
16 l neasure of acceptability in compliance.
17 l The rule is not directly directly solely to today's d
18 h poor performers. Performance changes over time and the rule 1
19 will help ensure consistent performance and from good per-a 20 formance declining.
4 21 ,
And the: rule gives NRC a stronger legal basis to gs 22 require upgrades in licensee maintenance procrans, d We had a question from the subcommittee regarding 23 l 24 the legal basis. We have a representative from OGV, Stu
() 2s Treby who may with to make a few comments at this time.
l Herilogo Reporting Corporation aer .>s h
k 84 i MR. TREBY: My understanding is that there was a 7 2i question raised as to why do we need a rule on maintenance,
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~ l 3l isn't there enough basis in the Commission's current regula-
/3 i UY 4! tions that cover this subject and therefore makes the rule 5l redundant. It is our legal view that that is not the current i
6 l status.
I 7! If you review Part 50 of our regulations, there is a not explicit mention or requirements of maintenance. There 9 are some indirect references to maintenance such as require-10 ments for in service inspection under 10 CFR 50.55-A which ll is a constituient of maintenance. There is divisions in 12 Appendix B to Part 50 which deals with OA and which provides g 13 a requirement that there be a good QA program and that if you W 14 l aa sonething, you do it with quality, but there is no recuire -
1 I
15 jj nent that there be maintenance. There is some discussion of d
16 maintenance in other documents such as REC GUIDES and stuff 17 l like that and there is, of course, the policy statement, J
l lad' but none of these are requirements that are enforceable and b
19 if the Commission wishes to have a basis upon which to take 0
20 h action to require improvenents in the maintenance area, or L
F 21 5 if it wishes to set up something like maintenance performance gs 22 indicators be required or it states that you can there should 23 be a rule or a requirement to that effect. That, I guess is 24 the basis--the legal basis for such a rule.
[J How can you explain such a serious over--
25 DR. SIESS:
w Horitogo Reporting Corporation imm.
k I 85 sight by the Commission in relgating thousands of pages of 2 rules and saying nothing about something that is so important?
/
( 1 3 MR. TREBY: I guess I have no answer for that other C'x j (j 4 j than to say that this is our opportunity to correct that over -
l 5
sight.
l 6 DR. KERR: It could be implied, of course, that i
7d if you're required to have a device perform a certain functio: 1 0
g l
by regulation that you have to maintain that device in such 9 a state as for it to continue to be able to perform that func -
10 tion.
l DR. SIESS: I guess we just had a legal opinion gg [
I 12 that that is not true.
I g3 DR. KERR: h' ell, I think it's trying to tell me I
d that it isn't implied that once I bring in a device for 34 g 0
15 j a particular reason, I don't have to maintain it in the h condition that will allow it to perform that particular func-16 h h
tion throughout the life of the plant. I find that mind 37 f d
Ig boggling, d '.
g, MR. TREBY: There may be an implication--I guess 20 l my point was that, you know, it's not addressed exclusively.
This is an important subjecy. If the Comnission wishes that d maintenance be directed, that it shouldn't be doing it by
()
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33 L implication or indirection and it should say explicitly we 34 think maintenance is important, you will have a maintenance requirement.
C) $
Horitogo Roporting Corporation im, u.
9
j7 0 96 h We're not saying that we have no basis to take n
2 action now. We do take action, but through indirect means, I,- ',; 1 g
3 l not direct means.
r'N' Il l
t' _/ 4 dt DR. KERR: Surely the Comnission is not interested h
5 in Maintenance, per se. What the commission is interested N
6 in is the low risk plants and what you're saying is--
l' I
7 I MR. TREBY: That's correct.
I i
s DR. KCRR And what you seem to be saying is that li 9 p requiring low risk plants, they can't have anything to do with h
maintenance from a legal standpoint.
10 f 3: DR. LEWIS: I think he said it right. IIe said h
12 ll thsi is the legal basis for it. !!e said this is what we have d
f lll 13 [
to have if you want ot be able to take action against the 34 licensee and I don't think he said for a mcment that there 15 h is a safety issue there. I may have misunderstood him.
Il 16 F MR. TREDY: No, you're correct.
DR. KERR: So if you want maintenance, you had 17 ]
n is ? U better specify maintenance.
li MR. TREBY: What I'n saying is if you want to take 39 q L
20 [
enforcement action against a licensee for not having those f
21 attributes of a maintenance program which the Commission 22 thinks are appropriate, then you need to have a legal casis i
v r1 23 for doing that.
24 R. LEHIS: 1:e 's saying that if you want to enforce rules, you have to have rules to enforce and that has nothing (v) 25 Heritogo Reporting Corporation x, .n n
h/
87 1
l to do with safety. I find that anazing, but he said it rather l
,- 2 j clearly.
! ) h 3 ij MR. MICl!ELSON : Appendix B is not a sufficient basis,
~'
8 0 i l 4 h you know, your quality programs does not have to include l
5 j I
maintenance.
t 6 j MR. TREDY: Well it does, but again you're doing it l'
> indirectly. What you look st is not whether or not the a maintenance program has certain attributes, but if you set up 9 j requirements in your program that you have a certain number of s
inspections and that there is a OA to insure that those inspec -
to !
11 )I tions are valid and then what the enforcement action is, is a 12 l failure to follow through on your QA program, to do the number l
13 p of inspections you caid you were going to do and not that you d
14 0 have a particular attribute or a maintenance requirement that I
15 L is not being met.
16 MR. MICl!ELSON: Is the quality of the people doing d
17 I the maintenance work a consideration under Appendix D/
e is [ MR. TREBY: Yes, I think so.
L e
19 [ MR. MICllELSON: I think so. I would be surprised if h
20 I it weren't. I think it is rather inplicit in Appendix B.
21 Many aspects of this maintenance is covered in a comparable em 22 fashion.
(v )
23 MR. TREBY: I thought I began ny statement saying tha t, 24 you know, these things are covered, but in an indirect way.
() 25 The inplication being that you have to have a quality program Heritage Reporting Corporation
,m sus
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0 through Appendix D. But, if you want to enforce specific cs 2 requirements against maintenance, then you should have a g s 3 maintenance reauirement.
o a V 4 DR. SIESS: I see something strange here. The 4
5 L inspection program is being reoriented to look at r,erformanc e h
I 6 j and only after looking at performance and finding it bad, 7
I
, do they expect to go back and look at the programmatic a ! issues and yet, what I think I heard is that the whole approach 9 to maintenance is going to be a prograrJnatic approach.
I We are going to lay down rules as to what the pro-10 h
n 3: 'i gram should look like, like Appendix B and then go in and b
12 N inspect the procran, look at that paper, is that richt?
I 13 11R . DEY: In a sense, I think that is correct.
0 l4 j However I--
15 DR. SIPSS: Is that consistent with the recent 1
16 change in approach to inspections being performance oriented?
O 17 1 !!R . DEY: Well the inspections are performance is g oriented. The aim of the rule is also perfornance oriented.
19 Now, rather than going into details of reliability, perhaps, 20 maybe similar to what the FAA or other industries which had 21 standardized plants. We're taking the approach, find out p 22 what ara the effective practices and approaches in maintenanc e V and if one includes, in a maintenance programs, those actions 23 24 and effective means to inglerent it, then one should achieve (n) 25 the performance.
Heritage Reporting Corporation an ..
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! 89 i
1 4
h DR. SICSS: You said to find out what the l
,x 2L effective attributes are. Does that mean you don't know I ) U 3j now what the effective attributes are, but you think there r3 n
- 4 h are sone plants out there that have them and you're going to h
3 try and find out which ones those are and then see that every -
n 6 body does that?
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L 7 MR. DEY: As I rentioned earlier, at this point in n
a H the Notice of Proposed Rulemaking, we have, in the definition ,
L.
91 those attributes that are necessary, that each maintenance u
to q program should have those attributes, but we haven't, as yet, i
said, you know, what are the effective means of implementing 12 L those attributes and that is the next phase, where in the n
9 13 1 industry standard, we would define them.
34 DR. LtuIS: There's sorething here that I am very
(
15 ,
naive about. First of all, as far as the FAA having standard -
o h
16 [ 1:ed practices, there are more different kinds of aircraft 4
17 [ out there than there are nuclear power plants and that will is always be true, so it's really a very diverse area, ig L Dut usually the reasons you make a rule or take
- o some kind of regulatory action, is one of two things. Either
- you know more about the subject, whatever the r.ubject is,
- 22 than the people you're regulating and you want to give then O the benefit of "our wisdon and the other reason is that if 23 24 they senehow know as much as you do about it, they are sone n
() 25 how less rotivated to their iob than you think they ought to Heritogo Reporting Corporation o.r u.
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, i I j be and therefore they need to the ruler across the
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2h knuckles. In there an element of either or both of those?
I i j
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i
( .
3 I'm tryihn to understand why the rule is needed, other than iT U
- 4 [ the fact that the Commission has apparently said so. Am I l 1 5 ;) being overly simplistic about this?
l l 6 MR. DEY: The purpose of the rule and the reason why h the rule is needed is to insure that the plant have effective i 7 a j I ah maintenance programs.
J 9 I; DR. SIESS: But is it that they don't because they 10 don't know how and you do or that they don't want to even though 1:
R they know how? It's got to be one or the other.
ll 12 [ MR. DEY: It's just clear from the material present ed I
h 13 to the Commission that there some plants with programs, f
14 h and that is one of the reasons for initiating--the reason for 15 , initiating rulemaking.
16 p DR. LEWIS: So there are some plants that even 17 ' though they know how to do it don't want to and there are not 18 sufficient enforcement means to get at them now, that this is 19 h being done to everybody, is that what is going on?
20 MR. DEY: I think that that is what the intent is, l is to insure that those plants will improve.
<s 22 DR. LEWIS: It strikes me as a very haphazard--
_) I think though, Hal, I think we heard 23 MR. WYLIE:
24 yesterday in the subcormittee that things have improved and there there is only one, maybe a couple o:' plant s out there, (a') 25 Heritogo Reporting Corporation n.t u.
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h q h 91 1 that have poor maintenance programs. I think we heard that 2
l yesterday.
3 h DR. KERR Taat's right.
(- g U 4 h DR. LEWIS: And that is because they don't want n
5 to.
h 6 j MR. UYLIE: No, they are improving. It's my under-a 7
I standing that they are impcoving--there are industry initia-8 l tives which are in place and are progressing, they are improving.
9 PR, CAIGOLL: Tllere's a tin
- constant to the inprovarnt prco"is .
10 You made one statement up front that is very true, 11 hl that somebody has decided they need a rule.
I 12 l DR. SIESS: Well Jay says there's a time constant.
f 13 ! Is this rulemaking going accelerate that?
i y MR. CARROLL: I think from what I have pieced i
15 g b
together from yesterdays discussion is two years ago or so, we h
16 had something like 30 plants that were regarded as maintenance 17 outliners on the basis that they had SALP ratings au a 3 in h
la l the maintenance area.
19 Currently, it's either zero or one plant in that h
- o i category. Is that wha
- I heard yesterday? There has been l.
21 1 marked improvement.
22 h
DR. SICSS: So they did that without a rule from (g) 23 the NRC and the NRC decides that's not the way to deal with it ..
MR. WARD: Well maybe the threat of the rule--
24 DR. SIESS: The threat of the rule probably
) 25 Heritogo Reporting Corporation lM1' 636 ette m_
jV 92 l
l g accelerated the process.
.-- 2 DR. LEWIS: Why were they reluctant in the first 3 l place? Is it that they didn't understand the importance of g) 1 4 l maintenance?
t 5
f tR. CARROLL: I think they understood the importance
, of maintenance, !!al . I think that a lot of it is that to f many utilities, this is a new technology, it's more complicated ,
7 3 l they didn't really realize how tough it was to maintain the 9 nuclear plants. There's an educational process.
MR. MICl!ELSON: There's also the SALP program 10 gg which presumably is addressing maintenance. A couple of the 12 ,
SALP considerations are maintenance and surveillance and g3 ,
we seem to use the SALP process to improve the poor performers ,
l Why do we need a ru'e when we have the St.LP prograr. I g4 have never heard of any presentation that says the SALP Program 15 is ineffective.
16 j DR. SIESS: That's interesting. I thought the
,7 ll gg original idea of the SALP Program was to allocate NRC resource s 0
and somebody got a 3, that meant he put more inspectors on 20 it. You got a 1, you put fewer inspectors on it. Now we
- g have--somebody is using the SALP Program to decide whether g N a plant is good or bad. Is that a change or was that inherent
(\
at the beginning?
33 MR. MIC!!ELSON : I don't know--I'm not sure by what 3
,3
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Heritage Reporting Corporation a sa
l l 93 I guess, one who is getting a category 3 rating.
I 2
DR. SIESS: A 3 rating, I believe, is watch him more ,
(
--I Watch him more.
3 MR. !!ICllELSON : And that has been l
(I 4 a fairly effective tool, as I gather, to improve the maintenance programs.
6 DR. SIESS: Everybody wants to be l's.
{
I y MR. !!ICllELSON: Or at least 2.
8 DR. SIESS: They certainly want to be l's and
, if everybody is 1, I don't know what happens to the 2's and Il 10 3'8' gg MR. MlCl!ELSON : We did want to hear OGC's view on g; this because the quention keeps coming up why the need for 0
13 a rule and I l' lieve OGC is saying they would like it to pro-l I
g4 vide a better basis for legal matters, g3 DR. SIESS: Am I correct that the Commission is i
16 l the one that directed the staff 'o do this rulemaking or did 37 - it originate with the staff?
I gg MR. DEY: The Commission directed the staff to
^
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1 develop a rulemaking.
20 u DR. SIESS: That's the beet reason I can think of
!i
- for the staff coing it.
2 DR. KEnn: !!aybe we should get an opinion as to
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23 whether it's legal for the Commission to direct the staff to 34 do this?
MR. MICHELSON: Oh, I'm sure that's legal.
x_ -
Heritogo Reporting Corporation (Mii 624 eM4
f, 94 I
h I DR. LEWIS: You know, I rather doubt that the
- 2! 5 Commissioners showed up at the office one morning and said,
( '
) l 3
ffwell,what shall we do. Let's have a rule on naintenance.
i 1 V 4 There's got to be nofe history than that to it and I would be 5 very surprised if it didn't originate in the staff somehow, h
6 1; but I may be wrong.
t 7 !!R . MICllELSON: There certainly has been a number i
8 d, of events in the last couple of years relating to maintenance 9 ! defects and I am sure that got the attention of the staff as l
10 ! well as the Commission.
O DR. SICSS: I wonder if the number is any greater, li p u
12 ifperplant, than it was 15 years ago, 13 !!R . !!ICIIELSON : We had better preceed now.
l' 14 il !!R . DEY: To bring sore history for the Conmittee, h
15 9 in response to a cuestion. I brought a copy of an Appendix H
16 0 to NUREG 1212 which really is a study that evaluated the 0
17 1 effectiveness of maintenance programs. It's a 1986 report 16 $ and the Appendix B has a discussion on current NRC regulations J
19 of maintenance in comrercial nuclear power plants. It also 20 includes a discussion on FAA regulations.
21 DR. LEWIS: What's the date of this/
22 MR. DEY: '86, v
23 ?!R . ?1IC111 LSON: It's says 1985 on ny copy. It's in 24 great big letters on the title, f3 Okay, it was published in '86, I'm sorry.
() 25 MR. DEY:
Heritogo Reporting Corporation m
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I 95 i
I l ttR. MICHELSON: The basis of the regulation hasn't 1
2 l changed, I guess, since '85. There aren't any addition--
! ,)
3l MR. TREBY: The question is that there has been i
[ l b (s 4 j a policy statement issued.
(.
5 ?!R . LEWIS: Yes.
U 6 MR. !!ICI!ELSON: Yes, but that doesn't have the same
[
h 7 1 weight--
i
.l' a MR. TREBY: Oh no, right. A policy statement does 9 j not have the same weight as a--
h H) !!R . SIESS: I'm not sure how to to weigh a policy 0]
Somebody said that 11 statement versus the threat of a rule.
12 [ maybe that was the reason why maintenance went through uith f
13 i that, b
o la !!R . CARROLL: That's one reason. I think there's 15 a hell of a lot of industry initiatives that--
16 DR. SIESS: I think INPO has been involved.
n 17 MR. !!ICl!ELSON: We'll hear f rom NU1' ARC next la l indicating what their views are on this.
19 h !!R . DEY: I just wanted to mention that the conclusion h
- o n of this. study was that NRC regulations did not provide a 21 1
basis for a court hearing approach to reculating nuclear power
$$ : plant maintenance.
7s
(
v) 23 MD. CARROLL: I think I agree what what I have 24 heard, but I also know from my own personal experience, that a lot of notices of violations have been issued over the years (v) 25 i Heritage Reporting Corporation e ns l
h 96 for maintenance practices of one sort or another and in g 2 general you can find something in Appendix B that allows you V to justify an NOB. In that a fair statement?-
3
/
kl 4 !!R. SIESS: What was the legal basis for shutting s down Peach Dottom?
6 !!R . DEY: The question was, what was the legal ,
7 basis? I guess I wasn't involved in writing the order. We a all know that the--
9 MR. CAPROLL: We all know that the activity--
10 DR. SIESS: I just think that somebody said l
- you're doing a lousy job, you're going to shut down until we 12 think you're doing better. I wonder if it's any more specific Do they have to oite somewhere in the Code of O l3 than that.
34 rederal Pegulations in order to shut down Peach Botton? !
15 MR. TREBY: I would have to look at the order. Iam 36 sure that there is some language in the order though that ,
17 says there is no reasonable assurance that the plant can l Is continue to operate safely, DR. SIESS: lias any utility ever challenged an ;
i, f
I !
- o , order like that on legal grounds? !
2l MR. TREDY: I'm not aware of any. (
y MR. WYLIE: Well I think you're just missing the ke y l 22 0 r
l li l 23 point. I think the basis on which the Conmission has shut l 0
I down is on the basis that the continued safe operation of the i 24 ]
O => h, e ^ " ' ' " " ' " " " " " * ' " " " = " * " ' " * " * <
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j Heritage Reporting Corporation l i
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safo operation of the plant or the unsafo operation of the 2
plant and if you look at the plants that have boon shut down 3
, t or throatened to ho shut down, the SALP ratings have been 4
most ofton as the means in which they woro judged to be unsafo 5
and therefore they shut them down and I just would like to ask: Is there no*, adequato tools already to enforce the 7 '
maintenance if it manifests itself in the unsafe operation a
of a plant?
DR. LEWIS: Tho to surely .nust be, Charlie , in 10 l terms of just the general, as yc.a said the continued safo II operation of the plant.
12 Any licensing agency, as far as I know, and that O I' g inc1udes the rAA, hes the rieht to shut down an at=11ne or O I4 j an ir.dustry or a type of airplanc.
38 i It's understood that when you issue a licenso on h
I*
hthebasisofsafety, though the law may not be explicit, but I7 b qI suspect that it is and what the FAA has dono in the past.
[
is and I know of nany such cases, when it finds a pattern et I' bad maintenance, a pattern of maintenance falsification or :
h 20 something like that, then it will question the ability of the I) [
ll 23 aarline to run and it will shut down the airline until things q
22 are imp oved and surely the NPC could do the c.,ame thia.g.
23 L So the rule is presumably--it presumably is aimed at l L
24 something more detailed than that, I would assume. I'm really 25 having trouble understanding it.
Heritage Reporting Corporation a (ms .a .a la
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V PA 4
- MR. KING: This is Tom King, Research Staff.
2 I think that we're talking maybe about the wrong O 3 thing here. I don't think there is any disagreement that
( 4 everybody in this room thinks that maintenance is importance i y to safe operation o2 a nuclear power. plant. <
4 I think wha'.,this rulemaking is trying to do is, 7 instead of--we may have some words in the regulation that we g could tie back to an,important national maintenance event j 9 or whate.ver. I don't think that's th- point.
g I think the point is that the Commission believes that maintenance is important to safe operation of the nuclear 12 power plants and we ought to set forth what our expectations-i l 33 hia in maintenance. t
[}
() 4 Maybe we can quibble over how'the rule should be 15 worded exactly, how you would approach that rule, but I don't 16 think it's unreasonable to have the Commission put for the ;
17 direction that they want a rule of maintenance to state their lg expectations.
g9 MR. MICl!ELSON : Well, there must be a problem then l y with the present state of affairs that prompted you to write 1
21 a rule. I felt that finding of a good identification of
! 22 that problem ought to be, at least, presented to us.
L } +
DR. LEWIS: I think what he just said was that even 23 24 if there wer9 not a problem, correct me if I'm wrong, that i
y even if there were not a preblem, and you said nobody in this l
1
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99 1
room disagrees'and you're certainly right about that. I 2 suspect ti.at there are very few people outside of this room
- 10. who disagree also.
3
( ~
4 So, if the purpose of the' rule isn't to accomplish ;
5 something, then it may be just to set the regulatory house-in 6
order because there should have been such a thing at the very i 7 beginning. .That.'s what I read into what you . just said.
8 DR. SIESS: That's what I asked to begin with.
9 Ilow did we make this' horrible mistake.
10 DR. LEWIS: But it seems not to have'been such a
- gg big mistake, but the argument is that you ought to set it righ b 12 anyway.
13 DR. SIESS: Is a rule the way.the Commission states i
g4 its expectations? That was the term that you used, Tom.
15 I thought a policy statement would be a way to state their 4
1 16 expectations. A rule is the law of the land.
17 14R . KING: A policy statement certainly states the n
gg expectations and putting it into the form of a rule turns [
g, it into a requirement.
20 In addit!.on to telling industry what the requirements 21 are, it also prov;'es guidance for the staff as to what the i
22 stann.rd is of acceptability and I don't think it is un-E5h 23 reasonable for the Commission to set forth such a standard.
!!R . l'ICl!ELSON : If there are no other questions, 24 i i
' I would like to proceed because of the time constraints.
( 2$
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,, 100 1 MR. DEY: If I'may proceed with the contents of 2 the Notice of Proposed Rulemaking.
03 -
3 General form and content of the rule, it's a
( 4 general rule that requires each licensee to implement and 5 document a maintenance program which includes the provision
-6 for the licensee 1to .conitor its inspectors and make improve-7 monts. -
~
- ~
8 A's I mentioned', the' rule includes in the attributes ,
9 a definition of' maintenance program in the policy statement.
10 The staff does not recommend reporting of maintenan :e 11 Performance indicators to the NRC at this time. Compliance wi th 12 the rule would be verified by NRC audit and inspection.
13 this is basicalP hat is in the notice. The l V 14 requirements for the pre 7nsou rule are each applicant or 15 licensee, applicant for a license to operate a nuclear power 16 P l ant shall establish, implement and maintain an effective 17 and documented maintenance program, and (2) assess the is offectiveness of performance of this program and, based upon 19 this assessment, make improvements.
20 The implementation, I went over earlier. The 21 licensees wmild be required, within 90 days to send in a plan 22 for full implementation of the rule within 2 years of publica-23 tion.
24 In our earlier presentation, a couple weeks back, we presented the results of our view of foreign and other
(]) 23 Heritoge Reporting Corporation m.
.7-101 I agency maintenance practices. The Commission tasked us to 2 looked at these other countries and industries to determine 3 their effective apractices and approaches. And, in the Noticia 4 of. Proposed Rule Making, we have included our recommendations 5 and the result of this review.
6 MR. ~MICIIELSON: Let me ask Moni a question.
7 In looking attall the other countries, did you a find any of them have a standard _ comparable to what you 9 envision,for compliance with'this rule?
10 MR. DEY: Well certainly, the FA7., the--
11 MR. MICl!ELSON: I was thinking of nuclear foreign--
12 other nuclear countries.
g 13 MR. DEY: The French have a standard. Of course p@ 14 thm do have standardized plants, but they do have a standard is maintenance program, 16 MR. MICl!ELSON: It's a documented prograu abot.t the 17 kind you're thinking of here?
18 MR. DEY: Yes. It sets both criteria for 19 individual plants and--
20 MR. MIC!!ELSON: to the Japanese have one?
21 MR. DEY: The Japanese, I believe, also have 22 such a document which gives guidance to the licensees in 23 preparing their 10 year plans.
24 MR. WARD: Moni, is the document that the French h 25 have, is that an EDF, a utility plant or is it something Heritoge Reporting Corporation v.n m ,
h 102.
I else?
2 MR.-DEf: That is an EDF document.
~'
3' MR. WAPD: Okay. So that's hardly the same thing.
4 MR. DEY: That's the industry, I guess there, one 5 utility. Certsinly, the regulatory body plays;a part and 6 is involved in that document, but it was primarily developed 7 by EDF.
a 8 DR. KERR So indood, the trench system would be 9 more l'ike like o6 parallelito the system in this country
~
10 with heavy industry setting up the standerds?
11 MR.IDEY: That's correct.
12 Befo:;e I get into the recommendations as a result 13 of these reviews, some attributes, we think are necessary,for 14 an acceptable standard, which I should define as the scope o :
!! a plant systems and structures included in the maintenance.
16 programs. It isn't intended to cover BOP systems, structures 17 and components where failure of those could impact public 18 health and safety.
]
l 19 It should provido clear and specific programmatic 1
! 20 requirements that can be practically implomonted by the 21 licensoos.
]
i j 22 MR. MIC!!ELSON: Moni, you added a few clarifying 23 words on the question concerning BOP. Are those going to be j 24 in the rulemaking packago or were they already tgero?
25 MR. DEY: We intend to clarify the whole package.
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'l MR..MICHELSON: You're going to add those--
2 MR. DEY: I do want to make that clear. !
.\
3 HR. MICIIELSON: Okay. Because those make it 4 conservatively more palatable.
5 MR. DEY: It should also be comprehensive in 6 addressing the activities in the policy statement and the d
7 rule.
8 It should reference other standards or guidelines 9 such as that.evolv'ed by ANS and'others including INPO and 10 EPRI whyre practical, to provide more specific programmatic 11 guidelines fdr further guidance for the maintenance of {
j 12 specific equipment.
We'think the standard'should be kept or it should
_O 13 i
14 have provisions to allow flexibility for adoption of new 15 technologies. We are not thinking of a regimented standard.
16 It should allow for innovation and changes for more effective {
l 17 maintenance inspections. '
la And it should provide guidance, put sufficient '
- 19 documentation so compliance with the requirements of the 20 standard can be evaluated. ,
t j
! 21 Now as a result of the review of maintenance
' l 22 approaches and practices in other countries and industries i O 23 which you are tasked to do by the Commission, we included j 24 in the Notice of Proposed Rulemaking, in the supplementary ;
information, some recommendations to be considered in the h 23 i
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.n 104 3
development of the standard.
2 Some of the important things we determined were:
it should require--should look at a systemat3 evaluation, 3
4 "a systems approach" of the functions and objecrives of 5
the plant systems and components to determine what maintenanc e 6
activities are necessary and the requirements.
7 We found that a lot of the other countries do a focus on long term objectives to try and establish a 9 correct maintenance program as opposed to reactive main-1 10 tenance, excessive corrective maintenance, including con-gg cepts.such as reliability centered approach. Of course the 12 FAA has adopted that~ approach, to some extent, and the French
- - 13 also in their approach includes reliability in determining
~ .
y maintenance rcquirements. ,
!!R. CARROLL: Now this Roman II item, am I under-15 I
16 standing this correctly, you're saying that this industry 37 standard ought to consider the benefits of reliability 18 centered maintenance, prescribing t. hat reliability centered i
g, maintenance has to be a part of every utility maintenance 20 program?
e MR. DEY: That's correct. It's an item for l 21 l 22 consideration in the development of the industry standard.
O 23 Romand III which prov ides guidance on how to 24 select appropriate parameters for monitoring the effective- l r
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105
- A lot of the programs emphasize maintenance
-~ 2 technician training, a certification program.
3 Roman V - should provide guidance on planning,
(- '
(_/ 4 scheduling and use of overtime.
5 The sixth item is having engineering support in 6 the evaluation of the failure data to determinn that a 7 maintenance program approach should be changed and feed that 8 back to insure that that support is included in the program.
9 Number 7 - the concept of improving or insuring 10 that the environment and the motivation of the maintenance 33 technicians. There are various ways to do that and a 12 couple of examples are cross training. The Japanese use that concept. The military, which is a different type of
( 13
(_) 34 program or industry utilizes a crew chief concept.
15 Number 8 - that the interface between maintenance l
16 and other activities in the plant should be defined and 17 insure the other areas are--the other organizations are:
l 18 engineering support, operations, corporate offices. These i,
interfaces are necessary that the whole program fits well and 20 is effective and lastly, 21 Number 9 - the industry standard should take a look 22 at the appropriate--the results or plant aging studies of O 23 appropriate maintenance from recommendations from those 24 studies.
() 25 i
In the notice we ask, in addition to comments, Heritage Reporting Corporation m m am
P g6 106 contents on the proposed rulemaking, 3 specific quessions:
2 (1) - Will industry commit to the development-of O 3 a such a maintenance standard; 4 (2) - What level of detail should be included in the 5 indust.ry standard? and 6 (3) - Is two years a reasonable time to develop an 7 implement this rule and standard.
s My last slide is a brief summary of the regulatory ,
, analysis that accompanied the notice and we have done some 10 calculations which we seek comment on and we estimate the 11 economic impact of the. proposed requirement on licensees shou Ld 12 be negligible.
13 We bolive, for' somet plants, initia'. investments,
({)~T y financial investments, will be required to establish a 15 systematic and comprehensive. program, but the savings due to 16 decreased corrective maintenance and increase plant 17 availability, we have estimated should outweigh those invest- ,
la ment costs.
19 And that concludes my presentation.
l 20 MR. MICllELSON: Questions?
e 21 (No response) 22 If not then NUMAr.C, a representative of NUMARC 23 Bill Coldan, who has been before us a number of times would 24 like to make a few remarks concerning NUMARCs views on this (
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,% }3 107 MR. COLDAN: I am Joe Coldan, Executive Vice 2 President.of NUMARC and I'thank you for the opportunity to 3 appear before the full committee and speak to you on 4 maintenance.
3 I spoke to the full committee on August 12th and 6 provided you an in depth briefing on the industry initiatives 7 on maintenance and sca.r.e. 4 "? results that we have achieved a with those initiatives as well as where we believe the 9 industry is progressing and proceeding.
10 I also attended the ACRS subcommittee on m31ntenance 11 yesterday and listened to the staff proposal then, provided 12 my reaction to the subcommittee and I would like to summarize sm O 13 f'th se t day f r the full committee and I think you 34 should realize that we had no prior review of the material 15 yesterday and I would like to maintain somewhat of a con-16 sistency in my comments.
17 I think the first question that we need to have is answered and is still unanswered, is what risk to the public 1, herith and safety will be improved by the rule anc' : -uoss, 20 in my opinion, that is a question that is still unanswered.
21 Will safety and liability improve or will we only 22 achirro detailed maintenance programs.
23 I think the industry position is and has been, that the rule is unneconsary. The rule would be disruptive to the 24 industry initiatives and progress would be costly to the O 25 Heritage Reporting Corporotion t m> m
$7 108 industry and in the end we would only achieve the desired
/ , 2 improvements of safety and liability. The industry has 3 implemented many initiatives in maintenance and maintenance O 4 is being improved. I think all the indicators that we have 5 clearly indicate that we are making progress in improving 6 maintenance.
7 The Commission has issued the policy statement 8 on maintenance and has put in place and shared with the 9 industry and with the staff, its desire for good maintenance 10 nd the essential elements it believes are important to gj maintenance.
- The questions that I believe are before the 13 Commission and before the ACRS is: What problem are we W ja trying to solve and. what results will be achieved with the 15 rule.
16 In reacting to the staff's proposal yesterday, in 17 the discussion, I guess I was troubled by the overall concept lg of h'ving a general role with an industry standard that re-39 ,
sults, in effect, in a very prescriptive approach to maintenance.
20 The concept of developing the industry standard 21 f
and putting in place or forcing a set of parameters on the
,m 22 I industry, lie went through some of the examples, a systematic
()
I 23 approach to maintenance, reliability contered approach, a 24 guidance on performance indicators, et cetera, really resulto I
h g in, I believe, a very prescriptive approach in maintenance
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109
. 3 and programmatic approach to maintenance.
t t I think the elements that the staff has said on O 3 their slides should be. considered, are in place at many 4 utilities in different utilities in the United States. I
-5 think.some utilities are clearly using. liability centered t 6 maintenance approach right now, EPRI is looking at that.
7 We have utilities that have used the systematic approach to a maintenance. We have utilities that use the crew chief i
9 concept, et ceters and so on and so forth. j
'10 So while those are good ideas and may work well 1 33- for some utilities, I guess I still question whether we 12 should take the approach to put those in place at all 13 utilities 34 The INPO maintenance guidelines are the industry 15 standard for maintenance. Maintenance guidelines provide !
16 the essential elements for maintenance programs but they do 17 not specify the detailed requirements in the same manner as is the regulatory guide or in the same manner as national 19 concensus standards, for example an ANS standard and "tPO f i
20 looks at the guideline, kind of in the following'lignt 1.nd f I
21 I quoted yesterday for the subcommittee and I won't go into l L
22 that again, but INPO tries to utilize the concept that each O 23 utility will' meet the intent of every guideline element and i
L 24 yet you don't have to meet every word in the guideline and 25 overy section in the guideline.
Heritoge Reporting Corperation
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110 I You need to look at your programs against the ;
2 elements of the guidline and determine if you have a ,
.O. !
3 performance problem and if you have a performance problem, O
4 then determine why you have a performance problem and deter-5 mine whether you ought to implement that portion of the 6 element--guideline element differently in order to improve 7 maintenance. :
I 8' And the focus of the industry initiatives are ;
9 really looking at trying to'pnt in place.the basics of.the 10 program and then look at whether or not they are programmatic --
Il performance proglems and take the next step and that is to 12 determine why you're having the problem and solve that speci-13 fic problem.
I l
- 14 And that guideline is in use at all utilities and ,
l 15 all utilitics by virtue of membership in INPO are committed ,
16 to meet tho' intent of that guideline and as we briefed the ,
! 17 full committ'ee on August 12th, each utility has completed
[
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18 a self assessment against elements of the guideline and i
l 19 reported the results to INPO.
I 20 Yesterday--I wasn't briefed today, but I thought i i :
l 21 I would make a comment on it. The staff providad a regulc- (
k 22 tory analysis on the proposed rule and without having a 23 chance to really go into detail on the regulatoty analysis, 24 and only having listened to the presentation, at least on the ,
face it appears to have many problems.
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- I think one of the basic problems that troubles ,
2 me was that it utilized in' formation from draft NUREG 1150 3 as its basis for an industry wide number related to risk--
- 4 the public risk to public health and safety. ;
3 If you read the draft, even in the draft NUREG 1150 ,
6 it says it only applies to the reference plants and cautions 7 the user against applying it to and using it in generic a-plications, t.
, Also, I t.hink the data which is in NUREG 1212 and 1
, 10 also which wasutilized in that analysis is really from the gg period 1980 up through 1985 and I think everyone in the indus -
[
12 .try would agree that we that data is correct. We have vrod e== x c't " t c rre ' '" =e
- O >> ="ta'a""" "4 "e '
- 34 and we are making improvements based upon the recent time i
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is frame.
i i 16 Yesterday the staff briefed the subcommittee on i
17 its maintenance inspecticns and that was discussed briefly (
l gg today. Tbc inspections, in my understanding, they were to bo
- g, used to provide input for future regulatory actions during th e 6 20 time frame of the initial policy statement from 1 to 2 years t 21 that the policy statement would run, yet my feedback from the 22 nuclear vice presidents from the utilities that were inspected,
! 23 was that they thought the results were pretty good. The i
! 24 staff gave them the impression that those results were good k and the reports are not issued yet, or at least 2 of the 3 O 25 f
Heritoge Reporting Corporation j sm>m m
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112 I I are not out and we are looking forward to hearing from the l
2 staff on what the results were and determinewhether maintenance
- 3 wcs or was not effective, I think that's the key question tha<. 1 4 needs to be addressed.
! 5 I made another comment yesterday that is worth re-l 6 peating. I think overall we're concerned about the staff's 7 intent to continue with detailed maintenance inspections and ;
?
f 8 they have 67 or so still to ccmplete because that really is ;
i 9 a significant impact on industry resources, i
10 In summary, we believe that the guidance that is 11 issued by the Commission in the policy statement han been i 12 provided to the industry and the staf f should actually con-13 tinuo. I think we're at a point in time where we haven't V 14 defined the problem we're trying to solve and we need time f 15 to define it, time to determine whether maintenance is or r 16 is not improving at this timo during this period and then determine whether futuro regulatory action is needed, i
~
17 18 That concludes my comments and I would be happy j t
19 to respond to any questions.
20 MR. CARROLL: Joe, what's your responso to the i a
21 concern of the staff earlier and the legal point of view l r
22 that wo nood to have something in the regulations, that it's e O 23 important to clear it up to inspectors and whatever they're i
f 24 supposed to be looking at. !
MR. COLDAN: Woli, not being an attorney and I
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A1 113 g certainly don't want to put myself and try to speak from a
,- 2 legal perspective.
3 I guess, from a management perspective, I think g\
U 4 the NRC staff, as they have indicated, has taken regulatory 5 action in maintenance against utilities and in specific areas, 6 I guess another key point is that the technical 7 spcifications currently require operability of the systems, g and they can't be operable unless they are maintained 9 properly. I think that clearly requires that.
10 Then you can question whether the scope of the 11 technical specifications and the scope, that both rule, 12 is the same. I guess, looking at what the staff has 13 indicated, I believe that is not the case, but we do have, O n within the rutee, the technica1 egecificetione, the edminietre-g3 tive procedures of the plant, all fall within that umbrella, 16 so I guess I don't see the need to proceed with that or 17 with the legal requirement, but not being an attorney, I guesa gg I couldn't answer that question from a legal perspective, g9 MR. CARROLL: And a second question. I said 20 carlier, remembering what you said yesterday. Is it your 21 understanding that April of 1988 there were zero plants 22 with a 3 SALP rating in maintenance and that there possibly 23 is one at this time as a result of this SALP report?
l MR. COLDAN: Yes, sir. I went back and checked that 24 l 2$ for you yesterday and today and currently, the latest Heritage Reporting Corporation w s,.
I
' ra 114 1 , information that we have from the staff as of yesterday 3 2 afternoon is that.in 1988, there are now 2 plants with a
\-] 3 SALP 3 category in maintenance. In 1987, there was one w/ 4 plant. Excuse me, that's incorrect data. I want to back
$ that up.
6 In 1988, for maintenance, there was 1 plant with 7 a category 3 to dato and in 1987 there were 2 plants with 8 a category 3 in maintenance.
9 It takes surveillance, which was the other 10 issue in SALP ratings that was discussed yest orday. In 33 1988, the data I have indicates that there were 2 plants 12 with a ALP 3 rating in surveillance and in 1987, there was
() -
13 one.
k_w) 34 Now, if you go back in time and that is--and 15 look at the data in the previous years, those numbers are 16 considerably higher. The numbers are 4, 5, 6, 8, probably 17 as a maximum, depending on what year you're looking at, back ,
la from 1980 to present, but clearly in 1987 and 1988 to date, 39 those were the numbers that we have based upon the NUPEG 20 1214, 21 MR. CARROLL: For purposes of a regulatory analysis ,
22 there were 30 plants being used.
23 MR. COLDAN: Yes, sir, I believe that is correct, 24 but again, I am not sure of the time period that that was based upon. If it was based upon the time period 1980 - 1985
(')
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I consistent with NUREG 1212, then that would be reasonable.
2 MR. MICHELSON: You think the regulatory analysis 3 talk about order.or inadegnato or something, it never really O 4 said thoro were 30 category of 3 plants.
! .5 MR. WARD: The gentleman who prepared that is 6 present.
7 MR. MULLIN: Yes, I would like to comment on that.
s My name is Bart Mullin from ENL. I was responsible for the '
- 9 regulatory analysis.
b 10 The number wo discussed yesterday was based on il 1986 information and it was obtained by going through the f 12 NUREG 1214, calculating the number of plants that had i 13 a scoro of 3 on'either maintenance or surveillanco in
?
j 14 that report. -
t 15 And the number, I don't remember exactly, it was ;
J 16 about 23. ;
17 Now, in the regulatory analysis, we took note of f a
f is and, in fact, included it in the calculations. Thoro has i
l 1, boon como credit for industry in.provement since that timo. ;
I 20 The calculation wo discussed yesterday indicated
[
1
> 21 that the improvement since that timo might reduce the number '
1 plants by perhaps a factor of 2, so we're talking 1
22 of j l
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! 23 on the order 10 to 15, based on the calculations.
i l
I think thoro is cortainly room for debate as to j l 24 i
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- MR. COLDAN: I was going to say that based upon es 2 our review yesterday afternoon, there were 8 plants with k.)
3 taaintenance 3, SALP operating in 1986. There wer 5 plants g)
( -
4 with a surveillance category 3, but two of those plants are 5 the same plant so really what you came down to was, in our 6 calculation, 11 plants based upon that information.
7 MR. MICllELSON: 11 in '867 8 MR. COLDAN: 11 in '86--11 plants, but I think agal:1 9 that is open to reviewing the data and I certainly--
go MR. CARROLLt A SALP rating of 3 may mean a lot
- of things other than a staff maintenance program.
12 MR. COLDAN: Just one other comment, if I might,
() 13 just one second.
( 34 Also, I think we need to remember that the SALP 15 is a retrospective look back in time for the period past 16 not forward looking, so even though it's 1986, that informa-17 tion is based upon plant operations and maintenance in 1985, is a prior time period.
39 MR. MICHELSON: So if there is a maintenance I
20 problem at the plants certainly, I guess, it would only 21 involvo 2 or 3 plants.
l 22 MR. COLDAN: I think it's hard to define.
l 23 MR. MICIILESON : Based on SALP.
l l assuming it's a
SALP 3 rating, it indicates maintenance is is 4 - unsatisfac-(]) 25 f
I Heritage Reporting Corporation an, s,s
117 g tory at whatever adjective used to describe that, then I 2 think that is correct.
/ N N) I guess I'm not sure personally whether that SALP 3
\_/ 4 rating of Category 3 is indicative of that level of poor 5 maintenance performance of if it's based on other elements.
6 DR. KERR: This sort of useage, of course, is made 7 oven more complicated by the fact that the staff already a says in the preamble to that SALP report that a 3 rating 9 does not mean that the plant is unsafe.
10 MR. MICllELSON: Any other questions? Charlio?
ig MR. WYLIE No.
12 MR. MICl!ELSON: Jay?
() 13 MR. CARROLL: No.
() l4 MR. MICHELSON: Thank you very much for your 15 additional remarks.
16 We have about 10 minutes of committee time left.
17 I would like to use this time to provide an opportunity for is Charlies or anyone else to give us any of their observations 19 on the subcommittee meeting yester. Do you have any addi-20 tional comments or concerns or whatever?
l l
21 MP. CARROLL: No, I don't think I have anythirig 22 to add at this time.
23 MR. WYLIE: No. I think you have fairly well 24 covered it.
I think the Staff and NUMARC did
() 25 MR. MICl!ELSON:
Heritage Reporting Corporation imm.
h 113 I a fine job of getting down to the real issues that were n 2 brought up at the meeting.
()
3 MR. WARD: Could I ask a question?
4 MR. MICI!ELSON: Sure.
5 MR. WARD: The policy statement on maintenance 6 was issued when?
7 MR. MICl!ELSON: A year ago now?
8 MR. KING: March of this year 9 MR. MICl!ELSON: March of this year.
10 MR. WARD: The question--insofar as a policy ll statement, I mean, does the staff know if that is 12 an adequate statement of the Commission's policy on
(] 13 what maintenance should be or is there some reason to V 14 believe now that it is something less that that?
l$ MR. KING: The Policy Statement lists 20 or so 16 attributes that they felt comprised the maintenance area.
! 17 What we ha"e done as part of this rulemaking is taken a is survey of some of the foreign countries, FAA, , military 19 maintenance programs, we have some additional things that 20 ought to be considered in developing a standard for maintenan ce 21 l program.
22 MR. WARD: So it's possible, based on nov 23 information, a possible alternative to rulemaking might '
24 be a revision or updated or something in the policy state-25 ment, is that fair to say?
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Heritage Reporting Corporation gl ....
b-119 3 MR. KING: Yes. I'll exploro that option of 2 just updating the' policy statement while pursuing the rule-3 making.
O 4 MR. WsRD, eue I meen, you de heve--you fee 1 you
> have some now perspectivos or now information now?
6 MR. KING: As far as guidance in the rulemaking--
7 or the policy statomont in developing rulemaking, based upon a the workshop and the additional surveys we have done, we
, fool that there may be some things that could be added 10 to enhance the rulemaking--it could be factored into the
- rulemaking, the standard or the REG GUIDE. ;
12 We're not looking at revising the policy statomont ,
13 at this point.
W g4 DR. KERR "!!as the staf f considered adding to its regulation, something called a "throat of rulemaking"? 'I 33 16 MR. MICl!ELSON: The rule itself, the proposed ;
37 rulo rather, contains a number of definitions which I gg believe were essential derived from the policy statomont? }
g, MR. KING: Right.
l ;o MR. MICllELSON: Woro there any additions--I didn't 2: have timo to go back and check it. Do you know if there woro 22 additions,or dolotions from the policy ate.tomont in this list O 23
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of definitions?
i MR. KING: The list of definitions in the proposed l 24 i
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I i Heritoge Reporting Corporation j i m. l
jlf 120 g MR. MICHELSON: And we did discuss some small con- ;
2 cerns with some of those and I guess you're going to consider- - -
3 MR. KING: We're going to consider some clarifica-i 4 tions to that.
5 MR. MICIIELSON: But, if I understand it, essentially -
6 this proposed rule is just a copy of the policy statement in 7 many respects becaue the definitions were the heart of the a policy statement. Is that correct?
t 9 MR. KING: In a-large measure it is. The I 10 ' additional things the way we have them set up now, are
~
!! factored into the industry standard and the REG GUIDE.
l 12 MR. MICHELSON: Now the thing, in the requirements 13 portion of the proposed rule, there is still a requirement lO 1
i4 15 thee the ue111ev se este to eseese the effeceiveneee in some form--I guess some reasonably formal manner so that they coulc
! 16 then determine where improvements are needed and so forth.
( 17 Again, would you again encourage performance ,
i !
j is indicators of some sort? t i
19 MR. KING: When it occurs, is that during the 20 requirement breach licensee, to monitor his own performance.
21 MR. MICl!ELSON: Right.
l 22 MR. KING: Performance indicators or some other l l
O 23 method may determine the satisfactor.
t
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l 24 MR. MIC!!ELSON: But that would be allowed to be I i
Q 2s tailored on licensee basis? {
l Heritage Reporting Corporation [
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121 g MR. KING: Right.
l
. 2 MR. MICIIELSON : And that is a stadnard that would L) 3 Probably only require that the licensee have such , but not i
4 prezcribe excactly which parameters have to be used in the 5
performance indicator and so forth.
6 MR. KING: That's correct.
7 MR. MICIIELSON : Are there any other comments, 8
clarifications or questions from the committee?
9 DR. SIESS: And why are they going ot issue a rule?
10 MR. MICllELSON: h'e l l , I'm not convinced in my own gg mind that a rule is needed, but that is something we need 12 to discuss.
Since our time is essentially up--
13 W 34 MR. CARROLL: Let me ask another legal question.
15 I'm still troubled by this--
MR. LEh'I S : Is this going to be a legal question 16 g7 or a question that requires a legal answer?
i 18 MR. CARROLL: A question that requires a legal I
19 anWor.
l There is no such thing as a legal answer, by the 20 i I
21 way, I guess it's a legal opinion, right.
Ill MR. TREDEY: That's right. Lawyers don't have 22 h 23 nsw rs.
MR. CARROLL: A somewhat parallel situation at 3
\
to this maintenance rule is the addition is that INPO had
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122 3 training and the condition is that NUMARK or whoever had
,- 2 it, fitness for duty. How did you approach the enforceability i 4 3 of those areas?
4 MR. TREBY: My recollection is that with regard to 5 training, the Commission had in its policy statement, with 3 regard to enforcement that any enforcement action would have 7 to come to the Commission itself. The staff would not take 8 action without first going to the Commission itself.
9 I don't recally any direct communications with go the Commission on ditness for duty type things, but I would gg note that there is underway work on a proposed fitness for 12 duty rule.
() 13 MR. CARROLL: Yes, but for a different reason.
() 34 MR. TREBY: Right.
15 MR. CARROLL: Up to now, witn fitness for duty, if tbe 16 NRC didn't believe somebody was doing the right thing, how 17 would you enforce it?
gg MR. TREBY: Again, I would go back to Appendix B 39 and look at the program that it deals with--as I indicated 20 at the beginning of all of this, we can take enforcement ac-21 tion where we believe there is some risk to public health 22 and safety. Legal basis and public need to write citations 7-C' based on enforcement action. It's all indirect. It's not 23 l 24 Lased on a failure of maintenance, f or c:<araple , per so. It's h
I 25 something that we have tried as far as our QA programs.
(]) l I
i Heritage Reporting Corporation wm.
41 123 g MR. CARROLL: Okay.
2 MR. MICllELSON: I have provided a draft letter to r)
t-3 the members of the subcommittee. Af ter I receive their 7
' 4 comments back, I will prepare it as a subcommittee letter 5
and it will be ready sometima tomorrow so that you will have 6
a chance to look at it before Saturday.
7 DR. SIESS: It's like that 600 pound gorilla, g Nobody is going to challenge the NRC when they say they're 9 going to shut you down for safety reasons.
DR. KERR: So with that, we'll recess for lunch 10 11 and reconvene at 1:30 12 (Whereupon, at 12:20 p.m., the subcomittee recessed for lunch to reconvene at 1:30 p.m.)
] 13
([12) i4 15 16 17 IS 19 20 21
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Um77Qmo 124 1 AFTERNOON SESSION 2 1:30 p.m.
3 DR. KERR I have been asked to remind members that 4 your words get recorded only if they come through the 3 microphone with sufficient volume and clarity to reach the
.6 reporter. So if you want these priceless gems to appear in 7 print, be sure you lean close to the microphone.
8 The first item on the agenda this afternoon is a 9 review of the proposed restart of the Pilgrim Plant. The ad 10 hoc subcommittee on Pilgrim Restart met in Plymouth, 11 Massachusetts on August 26th. The subcommittee previously 12 toured the plant and the training center that Boston Edison 13 Company has on August 25th.
s 14 I remind you that the Pilgrim Plant which is a 670 15 net megawatt electric BWR with a Mark I containment and which 16 is operated by Boston Edison, is located a few miles south of 17 Plymouth, Massachusetts, and went into operation in 1972. In [
18 April of 1986, shortly after a number of equipment failures 19 had occurred and after an incident which resulted in over-20 pressurization of the PJ{R system, the plant was shut down by 1
7 21 Boston Edison for testing and maintenance.
22 Previous to 1.hutdown, the SALP ratings for the I 23 operating organization had sagged to a rather low point, and 24 after the occurrence of the last incident and the shutdown, [
l 25 the NRC issued a confirmatory action letter which confluned Heritage Reporting Corporation (202) 628-4888
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( 1 that Boston Edison must obtain NRC approval before restart.
2 The letter listed a number of actions to be taken 3 before restart could occur, and called for approval by the NRC 4 before restart began.
5 Later, as the effort tows.rd restart developed, 6 another confirmatory action letter was issued with further 7 requirements that must be met before restart 8 Since the 1986 si.utdown there has been a replacement 9 of more than half of the upper and middle level management 10 responsible for operation of the plant. A large fraction of 11 the backlog of maintenance that had accumulated before 12 nhutdown has been accomplished. An accumulation of 13 contamination in the plant, some of which resulted from
() 14 continuing operating with failed fuel, has been removed to the 15 point that 90 percent of the plant area is now said to be 16 accessible without special protective clothing or equipment.
17 Security and fire protection have been improved 18 markedly. A simulator has been purchased and incorporated 19 into their training programs. All of the training programs 20 have now been accredited by INPO, I think. That's the 21 impression I have. They have formulated and put in place a 22 symptom-based set of emergency procedures which go 23 significantly beyond design basis accidents. And they have 24 formulated and installed voluntarily a safety enhancement 25 program which includes both equipment and training not
() Heritage Reporting Corporation (202) 628-4888
126 O 1 currently required by NRC regulatior.s.
2 A major con.cern of the NRC staff at the time of the 3 issuance of the confirmatory action letter was what war seen 4 as inadequate management. The two top people now responsible 5 for plant operation, one a Vice President, ars new since the 6 shutdown. Both have Navy nuclear backgrounds, and both, since 7 retiring from the Navy, have been associated with commercial 8 nuclear power as consultants.
9 They have assembled a team whitb, although it 30 retains a few of the people who were witn plant operation when 11 it shut down, is an organization and operation completely new i
12 and is the making of these two top people. Many of the new 13 team members have Navy nuclear experience, some military and 14 some civilian. A few have commercial nuclear experience.
15 If the team has a weakness, at least from my point 16 of view, it might be a paucity of direct expe:lence ir.
17 operation of a commercial nuclear power plant.
18 During our tour of the plant I was impressed with 19 the cleanlinesti and orderliness of the place and with the way i 20 in which the current activities were being performed. I did 1
21 not visit the plant before it was shut down, but reports from 22 the NRC staff indicate a major positive transformation.
23 SJ.nce they did not ha's a simulator before the 24 shutdown, the one they have obtained is new, and is one of the t
25 more advanced simulators anywhere. It's capability is thought Heritage Reporting Corporation '
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1 to go considerably beyond the traditional design basis I
2 accidents. It is now an integral part of operator training }
3 and retraining.
(
4 As part of their SEP program they have addod an i
5 additional system for pump trip to mitigate against an atlas.
6 This systeta opens the breakers that supply power to the recirc l 7 pumps. It complements a system which breaks a circuit that
, 8 feeds the generator exciter.
t
) 9 They also will use enriched boron in the standby a
j 10 liquid control system, thereby increasing the neutron i 11 poisoning effect by a factor of almost three over a system t 12 that uses unenriched boron. ,
i i
13 Partly because of the history of loss of off-site v 14 power at the Pilgrim site, and partly I suppose in l 15 anticipation of the clackout rule, they have installed a third l 16 diesel generator which can be connected, as I understand it,
- 17 to either of the two safety buses. Although not safety grade, t j 18 it is kept on warm standby. The installation is not, however, !
L 19 desigt.ed to provide protection for seismic exposure, nor is 1 20 there protection against tornados and hurriaanes.
i :
21 The fire protection system is not what one would j i 22 find in a safety grade system. That is, a fire protection for j l ;
j 23 the third diesel. Nevertheless, this diesel undoubtedly 24 provided added protection.
25 They have also arranged for a system which can be L
() Heritage Reporting Corporation (202) 628-4888 i
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) 1 used to bring water from the fire fighting system into the 2 reactor heat renoval system in an emergency. The required 3 pumping power for this system is supplied by separate 4 dedicated diesel.
5 In order to protect against some postulated accident 6 sequences which would produce over pressure of the torus 7 before significant core damage occurs, they've added piping 8 and vr ves which would permit unfiltered venting of the torus 9 to the r ack. This system is not yet operational since it has 10 not yet been approved by the NRC staff. If and when approval 11 is obtained, they will make the system operational and will 12 install the associated procedures into the operator training.
13 The plant does not have an approved emergency plan.
() 14 Before shutdown it had a plan which had received interim 15 approval. However, since the shutdown occurred, FEMA, 16 following a self-initiated review, has revoked the earlier 17 interim approval. Boston Edison has made significant funding 18 and other support available to the surrounding towns ano other 19 government entities inside the ten mile EPZ to assist them in 20 developing an acceptable plan. However, an approved plan does 21 not now exist, nor is there a reliable estimate of when one 22 may be approved. This is clearly a sticky wicket and is a 23 situation which appears to be a source of major concern among 24 the local populac<>.
25 Boston Edison has recently completed a self-O Heritage Reporting Corporation (202) 628-4888
129 O 1 assessment of readiness to restart and has concluded that the 2 plant and its staffing are at a point at which restart should 3 be approved.
4 We received what I would interpret as favorable 5 reports from the NRC staff based on an extensive program of 6 review performed under the auspices of Region I staff, and 7 including a recent SALP report which showed major improvement 8 compared to the period before the plant was shut down; and a 9 report of an integrated assessment team, the results of which ,
j 10 were given to us orally and which are now available in written 11 form, and I think you have that copy. We do not yet have the
! 12 recommendation of the Director of NRR, although we do have a 13 copy of a letter from Mr. Murley which would seem to me at
, 14 least to indicate approval of most of those things outstanding
, 15 with the exception of the emergency plant.
I i
16 Mr. Murley will make a recommendation to the i 17 Commission and on the basis of that recommende. tion and
) 18 whatever other evidence the Commission has, they presumably 1
5 19 will make a decision.
20 At the meeting in Plymouth there were presentations 21 from a number of citizens of the area including the Chair of 22 the Board of Selectmen of Plymouth. A principal concern 23 seemed to be the lack of an appzvved emergency plan. We have l 24 a transcript of that meeting which includes those statements i
- 25 and includcs a set of documents which was also presented to us
! O rit e eerei e Correr tie-(202) 628-4888 l
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! 130 1 by a representative of the state government. One of those l
2 presentatiens was from one of the state legislators.
3 We also have received a letter from Mr. Charles 4 Barry, Secretary of the Office of Public Safety of the State 5 of Massachusetts. He pi.:ints to several. issues which he thinks 6 the committee should examine.
7 Those are my comments. Mr. Wylie and Mr. Carroll 8 also participated as a member of the subcommittee, and I'd ask 9 them for any comments that they want to make at this point.
10 MR. WYLIE I really don' t have any. I think you've 11 done an accurate job of predenting what transpired at the 12 meeting. I don't have any additional commer.ts.
13 DR. KERR Mr. Carroll?
14 MR. CARROLL Nor do I.
15 MR. WARD: You mentioned the simulator is new, but 16 that must have been on the books and ordered before the 17 shutdown.
18 DR. KERR I'm not sure when it was ordered, and I'm 19 sure Boston Edison coulo respond to that' . Is there someone 20 who can respond to that? The question was when the simulator 21 was ordered.
22 (Inaudible comments) 23 DR. KERR He said it was ordered about three years 24 ago. His name is Mr. Bird.
25 other questions?
O aerita. - rei , - raeien (202) 628-4888
l?1 O-- 1 (No response) 2 DR. KERR: We will then go to the agenda as 3 published. The first item is an NRC staff presentation. Mr.
4 Sam Collins from Region I will make opening remarks..
5 Mr.' Collins?
6 By the way, if I misrepresented any of those things ,
7 on which I reported, I hope you will correct me. Gently, of 3 course.
9 MR. COLLINS: Yes sir.
1 10 The one item I will mention is the status of the RRR
.1 system during the event, and I'll get into that during the 12 presentation.
13 (Slides being shown)
O 14 Thank you for the opportunity to provide input to j 15 the ACRS. We welcome the opportunity for an independent body 16 to review the activities. This is a follow on to the 8/26 17 meeting that took place at the site, j 18 I do have handouts that are available in the back of i 19 the room. Those handouts depict the slide presentation I i
20 have. It's a fairly ambitious slide presentation to ensure 21 that the ACRS Committee does in fact have the information 22 available to them. I do have a goal to addreas the issues, 23 licensee actions, and assessments and conclusions. .I can skip
- 24 the slides that are appropriate to ensure that those specific 25 topics are addressed.
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() 1 The agenda, as you indicated, runn for one hour. In 2 that one hour we anticipate my slide presentation is 3 approximately 40 minutes. That will in<:1ude ample time, we 4 hope, for questions.
5 (Slide) 6 I have a number of staff available here, as
'l indicated on slide number three. The majority of the staff 8 members present are also members of the Pilgrim Rectart Panel.
9 Additionally, the majority of the individuals represented vere 10 members of the Integrated Assessment Team Inspection.
11 (Slide) 12 Specifically representing NRR is Mr. Bruce Boger.
13 Mr. Boger is the Assistant Director for Region I Reactors in
() 14 NRR, and Mr. Jim Wiggins who is the Branch Chief from NRC 15 Region I has responsibility for the Pilgrim project.
16 (Slide) 17 I'd like to take a moment just to put the 18 presentation into perspective. This initial part of the 19 presentation is a look back historically at the issues that 20 existed from the 1986 through 1987 time frame. The purpose is 21 to prepare the ACRS Committee for nubsequent corrective 22 actions taken by BECO in response to those issues.
23 (Slide) 24 Slide five is the last of the background slides.
25 That indicates the informatien that is on the docket for the Heritage Report 3ag Corporation O (202) Ea8-4888
133 O 1 plant. For reference information it is pertinent to 2 acknowledge that the number of staff who are indicated at the 3 bottom of that slide number five are staff that are relatively 4 new to the Pilgrim project.
5 That plays both ways. We have a little bit of loss 6 of history of the issues other than the documentation directly 7 associated with the site, but we do have Mr. Jeff Lyash who is R s resident of the site, and has carried through that period of 9 time.
10 The new staff members do provide for a different 11 perspective on the site and some independence in the review of 12 BECO activities.
13 (Slide) I 14 Slide six is a milestone chart. In the milestone 15 chart I've tried to indicate sione of the pertinent issues ,
16 which led up to the shutdown. Specifically, the order to 17 modify the license was the result of previous problems in 18 radiological controls. The Cycle 6 SALP report, the results 19 of which I'll get into in just a moment. We did have an 20 independent headquarters inspection in late ' 86 which vsm a 21 safety system functional inspection. We did perform a i 22 diagnostic team inspection to try to understand better the l 23 reasons for the SALP performance in Cycle 6. Ultimately we 24 did have the plant shutdown in April. That shutdown took i 25 place on the lith and the 12th, and the confirmatory action
{
i
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() 1 letter and the confirmatory action letter supplement in August 2 which was referred to previously by Dr. Kerr.
3 (Slide) 4 Slide seven I mentioned a moment ago. That does 5 indicata the SALP performance. This is a Cycle 6 SALP. That 6 all basically started the process of the NRC reviewing and 7 analyzing the reasons for historical performance at Boston 8 Edison. Of note, you have operations, radiological controls, 9 fire protection, and the inability to maintain strong 10 performance. Category 1, of course, is outstanding 11 performance in the subjective assessment throughout the 12 history of the etation.
13 MR. MICHELSON: When you show a blank for a
() 14 particular item on a given cycle, what's the reason for the 15 blank? What's the usual reason?
16 MR. COLLINS: The reason .or the blank is that area 17 was not assessed during that period. There are typically two 18 reasons for that. One is there is no data. For example, if 19 it's an area of outage management, they may not have been in 20 outage during that cycle.
21 Secondly, and probably more predominant, is that the 22 SALT process has chanoad th:ooghout this period and there 23 have been functional areas which have been added anC taken 24 away from the process.
25 MR. MICHELSON: Let's take fire protection, for Heritage Reporting Corporation (202) 628-4888
135 l
() 1 instance, where you show a blank. Why would that be blank on 2 Cycle 6?
- 3 MR. COLLINS: That fire protection was not assessed 4 as a separate functional area in that time frame.
5 MR. MICHELSON: Is there a reason, I thought every 6 one of the functional areas were assessed each time unless 7 there was inadequate data or whatever.
8 MR. COLLINS: No sir. The SALP manual chapter has 9 changed, as has the Region I instruction concerning fire 10 protection. L 1
11 MR. MICMELSON: So even though you've got some 12 SALP-1 ratings whlch you did reexamine again, you've got a 13 SALP-2 rating whi:h you didn't reexamine again.
() 14 MR. COLLINS: No sir. If the input is available it 15 would have been assessed in conjunction with another 16 functional area such as engineering and technical support, but i 17 it would not have been assessed separately.
18 MR. MICHELSON: That wasn't evaluated either. . ,
19 MR. WIGGINS: Jim Wiggins of Region I. I think we 20 can clear it up. For the Cycle 6 SALP, the :e was insufficient !
21 data uvailable, insufficient inspection activity during that 22 period to address fire protection as a stand-alone functional 1 23 area. There was elements of the assessment of fire protection
[
24 that were folded into another function area, as Sam said, and 25 it was operations.
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() 1 MR. MICHELSON: It is interesting to note, of 2 course, that things were getting perhaps worse and not better 3 because it went from a one on Cycle 4 to a two on Cycle 5, had 4 been a three on Cycle 3, and then it was unevaluated. <
5 MR. COLLINS: No sir. We're not saying it was 6 unevaluated. We're saying it was unevaluated as a separate 7 area. Notice that operations went from a two to a three 8 during that period also. That certainly is not solely as a 9 measure of fire protection, but that information is included 10 in that functional area.
11 MR. MICHELSON: I just wondered why the trend seemed 12 to be going back towards the poor direction.
13 MR. WIGGINS: Let me addreau that, continuing. As I
() 14 said in that particular window, that one year window, we had 15 lasufficient inspection activity to, in our view, warrant a 16 full blown assessment to have it as a stand-alone functional 17 area. We did focus or fold what we did have in terms of 18 insights into operations. If you would see the next SALP 19 which is the Cycle 7, which is not on this chart, you will see 20 that we did have sufficient activity in fire protection to do 21 a stand-alone assessment and we did do an assessment.
22 HR. MICHELSON: You did to it on Cycle 7?
23 MR. WIGCINS: That's correct.
24 MR. MIChELSON: How did it come out on Cycle 77 25 HR. WIGGINS: I believe it came out Category 3.
Heritage Reporting Corporation O (202) 628-4888
137 1 It was one of the areas that the performance in that area was 2 continuing to decline,- which basically is the reason why the 3 utility agreed to shut down and keep the plant shut down until 4 they were able to improve their performance trends. That was [
5 one of the areas that was continuing to decline from that SALP 6 to the next one.
i 7 MR. COLLINS: That area is a Category three in Cycle 8 7 SALP, sir.
9 MR. WIGGINS: And it has been again reassessed in .
L 10 the Cycle 8 SALP and it's a two I believe.
11 MR. COLLINS: Any further questions on this slide?
12 (No response) 13 (Slide)
O 14 HR. COLLINS: Slide number eight indicates the 15 program issues leading up to the April '86 shutdown as a 16 continuation of Agenda Item 2B.
c 17 We have a history of poor performance at the site.
i 18 We have improvement programs inhibited by the four factors ,
19 mentioned on the slide. Those four factors were primarily the ,
20 result of a diagnostic team inspection which took place after 21 the '86 SALP. The references here at the bottom of the page 22 indicate the documents which these issues are addressed in.
23 These four factors are also mentioned in the SALP Management 24 Meeting for 1986.
25 (Slide) l t
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[')
\/ 1 I have a few backup slides here which I'll cover 2 briefly because they bear on the plant performance immediately 3 prior to the shutdown.
4 This graphic indicates, along with the next three 5 slides, the focus on the shutdowns of April 4th and April lith 6 through 12th which resulted in the confirmatory action letter.
7 (Slide) 8 The next slides will indicate the performance in the 9 technical issues which resulted in these periods of plant 10 shutd;wn.
11 (Slide) 12 I'll quickly go through the next two slides, and 13 then we'll concentrate on the April 4th and April 12th events.
14 Looking at performance from the first part of 1986 commencing 15 in January, I have a number of plant perturbations and plant 16 transients caused by technician error, equipment failure, and 17 operator error.
18 (Slide) 19 Here we see at the bottom of this slide the April 20 4th shutdown. The April 4th shutdown involves an oil leak on 21 the hydraulic system. It's a turbine secondary plant problem.
22 During the shutdown to facilitate repairs we had two events 23 which were precursors to the events of April lith and 12th.
24 That is the spurious PCIS isolation and the inability of the 25 outboard MSIV's to open.
() Heritage Reporting Corporation (202) 628-4888
139 1 (Slide) 2 Again here on slide 8D, the backup slide, we get 3 into the sequence which led specifically to the shutdown on 4 the lith and the 12th. Indicated leakage from the reactor 5 water recirc system into the B loop of the RHR. There was no 6 indication that the system was over-pressurized, but there was 7 indication that the system was being pressurized.
8 That took place over a period of time, of course.
9 There is an alarm on that section of piping which alarms at 10 400 pounds. The licensee in subsequent reviews by the NRC was 11 evaluated as performing conservatively. They did a number of 12 valve manipulations to try to arrest the leakage into the low 13 pressure system. As a result of the.t, the plant ended up in a (G_f 14 configuration with two containment isolation valves closed and 15 leakage continuing. Tech spec interpretation taken by the 16 licensee resulted in the plant being in limited condition for 17 operation which required shutdown.
18 (Slide) 19 They're under controlled shutdown. Again, once 20 reaching the low pressure inhibit point for the main steam 21 system 30 seconds after reaching that point they received a 22 spurious PCIS actuation. The MSIV's, outboard MSIV's were 23 again unable to be opened. The problem with not being able to 24 open the outboard MSIV's is strictly operational since the 25 PCIS circuit places the plant in that condition of course it
() Heritage Reporting Corporation (202) 628-4888
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() 1 is an analyzed condition. However, it takes away the 2 preferred method of plant cool down. Additionally, it 3 challenges systems which normally wouldn't be challenged i 4 during a plant shutdown, and of course it challenges the 5 operator who has to respond to this.
6 There is no safety concern involved either with, in 7 this particular case the RHR in leakage or the MSIV closure.
8 (Slide) 9 As a result of that plant shutdown the NRC response 10 was to issue a confirmatory action letter. A confirmatory 11 action letter, of course, is an enforcement tool used by the 12 NRC to confirm actions which have been agreed upon by the 13 licensee. In the confirmatory action letter issued on April
() 14 12th, the purpose of that confirmatory action letter was to 15 provide for review of the technical losues which led up to the 16 plant shutdown.
17 Basically we asked for BECO to freeze the plant 18 equipment, to provide for a review, to provide for a written 19 approach toward the resolution of those issues, and also to i 20 solicit their cooperation with a special inspection team which j 21 was sent to the site to perform an independent analysis.
1 22 (Slide) 23 The issues we're talking about again are the RHR 24 valve leakage with the two isolation valves being shut; the 25 spurious group one isolation; and again, the MSIV outboard Heritage Reporting Corporation (202) 628-4888
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() 1 valves being unable to be reopened.
2 (Slide) 3 BECO did make a decision down here at the bottom of 4 this slide, in July of 1986 to remain shut down for refueling 5 outage number seven. That decision was predicated on a number 6 of factors, both internal and external to the site. The 7 licensee was going through hearings at that time as a result 8 of Mark I issues and other safety issues which were being 9 brought up by officials in the area. Additionally, the NRC at 10 that point catw s out with a bulletin that required inspection 11 of the RHR pump ,sar rings as a result of the Peach Bottom 22 event. There were a number of enhancements which were 13 necessary to support plant restart which would carry them
() 14 beyond the original proposed schedule.
15 (Slide) 16 Following the decision to go into refueling outage 17 number seven, the NRC issued a supplement to the o'*iginal 18 confirmatory action letter. That supplement dated August 27th 19 broadened the issues to includo those assessment issues 20 containad in SALP and the diagnostic team inspection. They 21 contained additional technical issues which had come to light 22 since the plant shutdown, and they also required BECO to 23 perform a number of assessments, submit those assessments to 24 the NRC for review, as well as a plan to restart the plant.
25 (Slide)
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() 1 This is a continuation of the first slide which 2 indicates the issues which I have just covered for the August 3 27th confirmatory action letter.
4 (Slide) 5 The intention of this slide is to further clarify r
6 the technical issues which were then being looked at in 7 conjunction with the plant shutdown on the 12th. As I've 8 mentioned, there was spurious group one primary containment 9 isolations on April 4th and April 12th; failure of the 10 outboard MSIV's to opent and the recurring pressurizing events 11 in the residual heat removal system which of course is the 12 high pressure to low pressure interface.
13 (Slide)
() 14 The results of the IAT or the special event response
- 15 team which was sent to the site which reviewed the events in 16 conjunction with the first confirmatory action letter, 17 indicated that the BECO approaches to the issues were 18 carefully structured and appeared thorough.
19 The failure of the MSIV's was attributed to a loose 20 poppit valve in the plant, hardware system. That poppit valve 21 had not been torqued upon manufacture.
22 The recurring pressurization events and the residual 23 heat removal system, after taking the valves apart and testing 24 the valves it was determined that leakage rate was acceptable, 25 although the tightness of the check valve immediately up Heritage Reporting Corporation O (202) 628-4888 I
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1 l
143 1 stream of the RHR B pump ended up in the line being 2 pressurized. Since there was no pressure gauge and no routine 3 method, standard operating practice to vent that line, ,it was 4 considered an operational even and modifications were 5 subsequently installed in the system to provide for enhanced 6 detection and enhanced relieving of the pressure.
7 Are there any questions on that slide?
8 (No response) 1 9 (Sl ide) l 10 Again, I'd like to set the time frame. We're 11 talking now the period of time following the issuance of the i 12 second confirmatory action letter. We're now involved in late 13 1986 where the plant is continuing in refueling outage number 14 seven. They're also continuing to address the issues that are 15 contained in both confirmatory action letters.
16 The NRC at that point in time conducted a meeting 17 with the licensee, Boston Edison, to try to understand the 18 progress that was being made in the refueling outage ar.J the 19 progress that was being made in conjunction with the 20 confirmatory action letters.
21 (Slide) 22 This is Management Meeting 86-41. It's a report 23 that people who are familiar with the project have used very 24 much. Its purpose was to provide a perspective of the overall 25 issues at the site. It contains an attachment which lists
() Heritage Reporting Corporation (202) 628-4888
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() I those issues by SALP functional area, and depicts to the 2 licensee at that point in time, which is November 1986, the 3 issues that need to be resolved prior to plant restart. That 4 report was provided to the ACRS.
5 (Slide) 6 Our concerns at that point in time following that 7 meeting were the slow progress being made to address the 8 85-99 SALP areas. Additionally we were looking for a strong 9 evidence of progress prior to any reconsideration for restart.
19 (Slide) 11 I'm now carrying over into tho first part of 1987.
12 I'm dealing with the 1986 86-99 SALP report. This is the 13 details of the SALP report itself. The issues are fairly
() 14 self-explanatory. We indicated they had made significant 15 progress. Licensee program improvements were beginning to 16 have a positive effect. We did note some improvements. There 17 were organizational changes. However, there still existed 18 problems with stability in key staff and management positions, 19 staffing vacancies, both of these are historical issues. And i
20 slow developing improvements in some previously identified 1
21 long term problem areas, specifically I think we were looking 22 there at fire protection and radiological controls.
23 (Slide) 24 In conjunction with those regulatory issues there 25 were a number of other issues which have transpired since the Heritage Reporting Corporation l
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\
L'd 1 plant shutdown. Those issues include emergency preparedness; 2 outside issues as Dr. Kerr mentioned, there was a FEMA self-3 initiated review. That report has been provided to the ACRS 4 this morning. For reference, it noted deficiencies which 5 resulted in an inadequate state and status of emergency 6 preparedness. FEMA did withdraw their interim approval of the 7 emergency preparedness plan which is standard when they find 8 deficiencies which result in the plan being unacceptable. An 9 annual full participation exercise exemption was granted. We 10 have granted an additional exemption at this point in time.
11 (Slide) 12 Safety enhancement program was also mentioned 13 earlier. This is a voluntary program by the licensee to 14 address some of the issues which result from industry 15 initiatives in the Mark I program. BECO is implementing 16 several of these enhancements. They are being reviewed under 17 the 10 CFR 50.59 process. The NRC has performed overviews of 18 that which I'll get into in a moment.
I 19 Also there are two legal actions pending. Two 2.206 20 petitions have been submitted by the Commonwealth. They have l
21 been responded to in part. The first petition and the second 1
22 dealt with management, Mark I containment, and emergency 1
23 preparedness. The first petition was responded to with the 24 exception of management. The second petition was responded 25 with the exception of management and emergency preparedness. l
() Heritage Reporting Corporation (202) 628-4888
t 146 O 1 ^84teto# 11v, ex 11c = i=9 ceio av co ei== 4 2 throughout the shutdown period and there are a limited number j 3 of those that remain to be resolved prior to plant restart. ,.
4 MR. CARROLL: Could you amplify on the basis for the 5 exemption to the emergency exercise?
6 MR. COLLINS: Yes sir. The basis, out of context, j 7 but a simplified answer, the basis was that given that there 1 8 is a recognized status of emergency prM>aredness which does fi 9 not meet the NRC criteria, it would be more fruitful for the ;
10 NRC to determine that the plan is adequate to support the l l
11 drill prior to conducting the drill. That same basis was used !
12 in both exemptions. ;
13 (Slide) l 14 That concludes the presentation on the issues. I'd 15 now like to briefly overview ths licensee actions.
16 I do have a milestone chart which is contained in 17 slide 16. It's a very busy chart, but it's a tool I think j 18 that's appropriate for the ACRS to have available. It's used !
i 19 by the Restart Assessment Panel. It is a tracking method to [
20 indicate both NRC and licensee actions. It's a living
(
21 document, and it's historical as well as used for planning 22 purposes, and I'll briefly overview that. 1 23 (Slide) 24 What we're looking at here is a consolidated l 25 milestone schedule of actions leading up te and resulting from Heritage Reporting Corporation O (202) 628-4888
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i r 147
) 1 the shutdown of the Pilgrim station. To put into perspective 2 where we are, the IATI report was issued yesterday. The full i
l 3 ACRS committee meeting of course is today on the 8th. There [
4 is another revision to this milestone chart, but I do not have i 5 it made into a slide. Then we play out here into the actions 6 that remain into the future which I'll get into later on in (
k 7 the presentation.
8 (Slide) [
J :
9 The initiatives which Boston Edison has taken as a {
i 10 result of the shutdown are listed in a further slide, but f I I 11 generally they are the SEP, the restart assessment plan, the t i
- 12 maintenance improvement plan, the radiological enhancement {
j 13 plan, the self assessments, and the power ascension program.
i v 14 All of those plans have been submitted to the NRC. They have I
j 15 been reviewed by the NRC. The last review was complete ,
16 yesterday. That is a review of the power ascension program. I i 17 The next milestone within this chart is the restart i I
18 assessment report. That restart assessment report will j
19 contain the staff recommendation from the Restart Assessment .
< l I 20 Panel to the Regional Administrator. That report is scheduled !
I 21 to be out within the next two weeks to support a proposed 1
l 22 meeting date to discuss the report, to discuss the IATI, the [
f 23 integrated assessment team inspection, and to discuss the 1
l 24 2.206 issues in a public meeting in the area of the facility. f 1 1 25 (Slide) i
() Heritage Reporting Corporation (202) 628-4888 f
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() 1 This chart is a little easier to understand as far j 2 as the major activities. I won't detail them again but it 3 does serve as a reference for the activities that have taken 4 place in conjunction with the plant shutdown including the 5 SALPs, the confirmatory action letter, the FEMA self-initiated 6 review which is the EP issue, the 2.206 petitions, the self-7 assessments, and the other initiatives taken by BECO as a 8 result of the requirements in the confirmatory action letter.
9 (Slide) 10 For the purpose of the agenda I'd now like to l
11 discuss the assessment activities and the results of those 12 assessment activities.
13 As I mentioned previously, we did form a Restart
() 14 Assessment Panel that was an approach taken by Region I in 15 conjunction with the recognition of the staff effort that 16 would be necessary to review and assess activities in 17 conjunction with Pilgrim. We do have a Restart Assessment 18 Panel which was formed as a result of the approach taken by, 19 proposed to, and agreed upon by the NRC Regional Administrator 20 in Region I. The Restart Assessment Panel is composed of the 21 individuals listed.
22 The advantages of that, and it's a unique effort, is 23 to focus and integrate the NRC attention on the project, both 24 headquarters and Region I. It involves a high level uf NRC 25 management. He do have the ability to commit resources and Heritage Reporting Corporation Ox (202) 628-4888
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- 1 schedule milestones. The panel did meet on-site, met every 2 other week, and every other meeting was at the site to become 3 familiar with the issues and the hardware at the site.
4 (Slide) 5 The additional initiatives by that approach taken by 6 Region I in addition to the Restart Assessment Panel is 7 augmented inspection and review activities. I'll get into that 8 in a moment. The Restart Assessnent Panel. The diagnostic 9 team inspection which is the AITI inspection. And the 10 assessment report to the Regional Administrator.
11 This plan was laid out in advance of the 12 censideration for plant for restart. It is a concerted plan 13 to provide a pathway for assessment and evaluation, and the
( 14 plan is also now being used in conjunction with the Peach 15 Bottom plant assessment.
T 16 (Slide) l 17 As an indication briefly of the result of the l 18 augmonted inspection review activities, you can see the l 19 inspection effort which has gone into the facility throughout l 20 the period of time. Of course we're talking about the 21 shutdown in this area. But you can see here, this is a 15 22 month period. The amount of effort going into the site is 23 approximately three times normal. Single unit sites typically 24 receive approximately 2400 hours0.0278 days <br />0.667 hours <br />0.00397 weeks <br />9.132e-4 months <br /> of direct inspection effort. l 25 HR. WARD: I notice that, how many hours did you
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() 1 say?
2 MR. COLLINS: A typical single unit site in Region I 3 is approximately 2400 hours0.0278 days <br />0.667 hours <br />0.00397 weeks <br />9.132e-4 months <br /> on an annual basis.
4 MR. WARD: Back in '80 and '81, maybe that wasn't 5 the standard then, but ' 80 and ' 81 the inspection was quite a 6 bit less than 3000 hours0.0347 days <br />0.833 hours <br />0.00496 weeks <br />0.00114 months <br />.
7 HR. COLLINS: Yes sir. At that point in time the 8 resident inspector program was just being implemented. At 9 that point in time there was one resident at the site. We 10 supplemented the residents in January of 1987 to three 11 resident inspectors.
32 MR. WARD: I guess I didn't ask the question well.
13 What was the rate of the inspection intensity in '80 and '81?
() 14 Was it average for plants at that period of time?
15 MR. COLLINS: I don't have the figures going back 16 that far, but I would anticipate generally looking at how the 17 staff has increased and how the inspection program 18 requirements have increased, that that is a fairly typical 19 number. It may even be a little bit high for that point in 20 time, which basically involved inspectors travelling to the 21 site and no resident inspector.
22 (Slide) 23 Briefly, and I won't get into the backup slides 24 although they' re available to you in the handout, in 25 conjunction with the augmented inspection process we did O Heritage Reporting Corporation (202) 628-4888
151 1 conduct a number of meeting activities both in the area, in 2 Region I and in headquarters. We conducted 42 meetings since 3 the shutdown. twenty-eight of those meetings were conducted 4 in the last SALP period. Table 5 of the SALP report which is 5 provided to you as backup slides to 22 depict those meetings.
6 Generally the advantage of those, they're used to 7 understand the process and the progress at the facility. The 8 meetings include meetings with the public, meetings with the 9 officials, and of course meetings with the licensee Boston 10 Edison. They were used to explain the process and the status 11 to the public as well as to provide for public input.
12 Some of those meetings I guess I'd be safe to say 13 were fairly spirited in the area. There were a number of
() 14 individuals as well as parties local to the Pilgrim station 15 who are very interested and very involved in the restart 16 effort.
17 (Slide) 18 Additionally I mentioned the licensing effort as 19 part of the staff work. Approximately 20 licensing actions, 20 which is a fairly high number with a plant shutdown. The 21 major areas are included fire protection, many upgrades and 22 many actions in that arent containment safety enhancements; 23 organizational administrative changes due to the 24 reorganizations. These three areas are the specific actions 25 which remain outstanding at this time, and I'll cover those in O ie e ti e co e (202) 62s-4ses tie-
152 k- 1 the next slide. I guess they were outstanding as of two weeks 2 ago. I assume they're still outstanding.
3 (Slide) 4 You have the resolution to the 2.206 petitions 5 outstanding. Safety enhancement program reviews, we did I
6 receive a submittal dated August 18th which indicated that i 7 Boston Edison proposed as installation of the direct torus 8 vnnt valve. They're proposing installation and testing of the 9 valve as a containment barrier. Disarming the valve both .
10 electrically and with the nitrogen operating supply to provide 11 for a containment barrier.
12 We have tech spec licensing actions. Threm of those 13 remain outstanding. This is the fire protection wall rating /
14 degraded grid voltage considerations; and the organizational 15 change. Boston Edison tech specs allow reorganizations to be 16 taken in place and for the reorganization tech specs changed 17 to be filed following its implementation. It's fairly unique 18 among tech specs.
19 Bruce Boger, do you have a comment?
20 MF. BOGERt Right. The degraded grid voltage 21 license condition has been issued as of today, so there are 22 only really two remaining items.
23 MR. MICHELSON: What is the situation on the fire 24 wall rating?
I 25 MR. BOGER: Originally when the license condition
() Heritage Reporting Corporation (202) 628-4888
153 1 was established it looked like the wall would require a three 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> rating. Based on a review by the licensee of the 3 combustible materials in the area it was determined that a 4 wall of a lesser rating was acceptable. The staff reviewed 5 their submittal and agr,eed that a wall with less than a three 6 hour6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> rating was acceptable.
7 MR. MICHELSON: How much less are we talking about?
8 HR. FOGER: Two and a half hours.
9 MR. MICHELSON: Thank you.
10 (S1/de) 11 MR. COLLINS: In conjunction with the assessment 12 activities I've already mentioned, we have conducted a further
. 13 SALP --
14 DE. KERR Excuse me, Mr. Collins.
15 MR. BOGER: Let me clarity that. It is a two and a 16 half hour rating wall. It didn't reduce it by two and a half 17 hours1.967593e-4 days <br />0.00472 hours <br />2.810847e-5 weeks <br />6.4685e-6 months <br />. It's a two and a half hour --
18 }R. MICHELSON: That's the way I interpreted it.
19 MR. BOGER: Okay.
20 MR. COLLINS: In conjunction with the previously 21 mentioned ansessment activities we have conducted a more 22 recent SALP which was an NRC commitment prior to considering 23 any plant restart. The SALP period was 15 months, ended in 24 May, the middle of May.
25 The issues looked at were the organizational changes
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\> 1 were looked at as being positive. There were significantly 2 higher staffing allocations. There were aggressive areas in 3 most program areas of weakness. There was some delay in 4 implementation of improvements which I'll explain in a moment.
5 The conclusions are listed here, one to five.
6 Basically we acknowledged the e:. tensive efforts of 7 the 1.' nsae. They have been generally successful in 8 cs sng both the staffing, the organization, and the 9 hardware issues. The self-assessment process which was 10 proposad and implemented by Boston Edison is looked at as 11 being a positive attribute. Performance in some areas lag 12 behind others due to later implementation and that was 13 perceived to be true both in the maintenance, in the 14 radiological controls area. Both of those it was the staff's 15 decision were impacted by the extended outage.
16 Additionally we acknowledge" that a continued Boston 17 Edison commitment was needed to sustain the overall 18 performance trend in performance since *.here had been a 19 historical problem with maintaining improved performance.
20 DR. KERP.: By th< way, if there are those in the 21 audience who think they hear a loud vibration, see your 22 psychiatrist. .it's just your imagination.
23 (Laughter) 24 (Slide) 25 MR. COLLINS: Here briafly we had an earlier
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1 question by Mr. Michelson on the SALP areas. Here is the 2 complete chart which depicts the last SALP as well as the 3 previous here. We've taken the SALP history which was in the 4 latest SALP document itself and spread it out into pre-5 shutdown and post-shutdown.
6 These are the tronds. You'll notice that 7 surveillance, fire protection, and security all have improved 8 one category in our assessment, and radiological controla has 9 an improving trend at the time of assessment which was mid-10 May, and we have an update on that as a result of the 11 integrated assessment team inspection which I'll mention in a 12 moment.
13 I would like to acknowledge, though, that the next 14 SALP period we have committed to be a shortened cycle. A 15 shortened cycle will most likely encompass a period of 16 approximately eight months or so.
17 (Slide) 18 We're dealing now with the latest staff efforts to 19 assess licensee performance and that's the integrated i 20 assessment team inspection. We committed in the confirmatory I
l 21 action letter to perform a diagnostic team inspection after
?. 2 Boston Edison had submitted their plan for restart, after that 23 plan had been reviewed and approved by the NRC staff. Boston 24 Edison submitted a letter in late June acknowled;ing that 25 the ar actions were at a status where they felt they could
() Heritage Reporting Corporation (202) 628-4888
O 156 1 support an independent NRC assessment of their actions and its 2 results. We responded to that letter in July and conducted 3 the inspection throughout August.
4 (Slide) 5 Briefly here is some background information on the 6 IATI. It's purpose as well as the schedule, a very extensive 7 effort, involved over 1,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> of direct inspection effort 8 and the operating plant objective.
9 (Slide) 10 Briefly this is the team composition. I won't get 11 into details, but the majority of these people have been 12 residents or senior residents at one site or more than one 13 site before. We did have a representative from headquarters,
() 14 Loren Plisco, Frank Akstulewicz as well as Dan Mcdonald who is 15 here today. We did also have two observers from the 16 commonwealth of Massachusetts who were given the cyportunity 17 as a result of a protocol agreement with the C'mmonwealth to 18 participate in all aspects of the inspection. One of those 19 was Ms. Pamela Chan. She's a representative of the 20 Massachusr'.ts Energy Agency. She reports to the Executive 21 Department of ths. Commonwealth. And Mr. Steven Sholley who was a consultant to the Attorney General's office. He is a rapresentative of MHB Associates.
44 Those individuals were given the opportunity to 25 comment on the inspection plan, to partake in the week's
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() 1 inspection preparation on-site. They were there throughout 2 the inspection period end they were given tbn opportunity to 3 be available during the documentation. Ms. Chan as well as 4 another representative of MHB, Greg Minor, was at the exit of 5 the inspection.
6 (Slide) 7 The ex't was conducted the end of August. The IATI 8 report was issued on the 7th. The public meeting sequence 9 calls now for the public meeting to be the week of the 26th.
10 (Slide) 11 Herein the remaining few slides are the future 12 activities, future assessment activities which we intend.
i 13 Again, we' re using a subset of the milestone chart. Looking
(} 14 here at the 2.206 issues has been addressed; the management l 15 portion of the inspection of the AITA will be used in part to 16 respond to the 2.206 petition, both petitions which are 17 outstanding as far as the management iscues are concerned.
18 EOP issues I'll mention in a moment, the status of EOP issuvas 19 as far is restart. The SEP issues, I mentioned that we hsve a 20 recent submittal from the licensee on August 18th which ici 21 under staff review. The restart confirmatory action letter 22 will be updated prior to any proposed restart. The power 23 ascension program has been approved as a result of a letter 24 issued yesterday.
25 Coming up in the future, we have a series of public lieritage Reporting Corporation O (202) 628-4888
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Os 1 meetings in conjunction with the issuance of the Restart 1 2 Assessment Report which is now sc.4eduled for mid-September.
3 That will contain the recommendation to the Regional 4 Administrator. Subsequently we will assess the status of 5 emergency preparedness. Following satisfactory completion of 6 that we'will go on through the blorw diagrams as they depict, 7 ultimat<1y ending up in a commission briefing via the 8 Commission policy to review restart of plants in extended
. 9 shutdowns.
10 (Slide) 11 Now in the last agenda item which is conclusions, 12 this is an overview of the facts. Talking about shutdown on 4
13 the 12th due to the technical issues. Again, we have the 14 three technical issues, confirmed by a confirmatory action 1
15 letter. The confirmatory action letter was expanded in i
16 August. This is a subjective assessment of BECO's actions to 17 date as a result of the SALPs, the AITI.
- 18 It's important to note, and I neglected to do it 19 earlier, but the AITI report is a result of the inspection 20 hours which took place before then. In other words although 21 the AITI report will come to some conclusions as far 22 licensee's performance, those conclusions are not based solely 23 on the AITI. You can't take that in isolation.
24 The inspection efforts leading up to the AITI, of 25 which as I mentioned previously there are 9700 hours0.112 days <br />2.694 hours <br />0.016 weeks <br />0.00369 months <br /> in the
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() 1 SALP period, had a ter.dency to track and confirm BECO actions 2 throughout the process. The AITI by definition and by purpose 3 was looked upon to be a confirmatory inspection following 4 Boston Edison's independent assessment that the status of 5 their program supported restart.
6 (Slide) 7 It's important to note that the level of staff 8 activity as well as Commission and public Jnterest remains 9 very high in the facility.
10 (Slide) 11 Lastly, the restart criteria which have been 12 established by the Director of NRR, Tom Murley; his very 13 stable and effective management staff at Pilgrim; resolution
() 14 of major technical issues; demonstrated improvement in SALP 15 problem areas, maintenance program, and work valve clog 16 addressed; satisfactory resolution of certain EP issues.
17 The management and the staff at Pilgrim, we have 18 performed both technical reviews of qualification and of the 19 organization in conjunction with the AITI inspection, traching 20 the management transitions throughout the shutdown period as 21 well as a concerted effort during the AITI in conjunction with 22 the toch spec submittal for the reorganization. It's just 23 that that requirement has in fact been met.
24 Resolution of major technical issues, they have been 25 tracked and verified. We have a restart check list which is a Heritage Reporting Corporation O (202) 628-4888
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() 1 subject of evaluation, of course. That check list tracks 2 outstanding restart items which need to oe addressed by the 3 licensee prior to restart. At this time there are 4 approximately 24 items outstanding. About half of those are 5 administrative items. The remaining 12 to 13 items are a 6 result of the AITI inspection and follow through items from 7 technical concerns.
8 Demonstrated improvement in the SALP problem areas.
9 That was assessed during the 87-99 SALP. In addition we 10 performed an update of licensee pertormance in conjunction 11 with the integrated assessment team inspection. On a previous 12 slide we acknowledged that one of the purposes of the IATI 13 inspection was to ensure chat the performance trend and the
() 14 assumptions, or the conclusions of the SALP rather, could be 15 confirmed by an independent on-site inspection. The IATI 16 confirmed that, as indicated in the summary of the IATI report 17 which was issued yesterday.
18 Maintenance program and work backlog issues. We did 19 have a concerted team inspection in the maintenance area prior 20 to the integrated assessment team inspection. That inspection 21 resulted in a fairly extensive review and revision of the 22 maintenance program at Boston Edison. That maintenance 23 program was subsequently implemented and its effectiveness was 24 assessed during the integrated assessment team inspection.
25 That program was determined to be in a status that supports
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161 1 plant restart.
2 Emergency preparedness issues remain outstanding.
3 There is a recent letter from FEMA to the Commonwealth dated 4 August 22, 1988 which clarifies a number of the issues for the 5 Commonwealth as far as evacuation is concerned and the 6 criteria to be used for asseasment of emergency preparedness.
7 The Commonwealth acknowledges that progress is being made.
8 The Commonwealth and the 'ocal groups acknowledge that a 9 satisfactory plan does not currently exist. That's true. The 10 staff is now putting together an internal report which will 11 depict the status of emergency preparedness actions. The 12 Commonwealth has committed to also perform that assessment and 13 to submit that report to the NRC.
14 At the time when a decision is necessary, which is 15 following the resolution of the items which precede it, and 16 the completion of the public meetings, and the acceptance of 17 the recommendation by the Region Administrator and the 18 Director of NRR, a status of emergency preparedness will be 19 reviewed and the adequacy of that status will indicate whether 20 we proceed with the process, 21 There has been a statement made by the Director of 22 NRR that as a minimum there are six issues in the FEMA report 23 which are indicated as representing problems which resulted in 24 the inadequate status on state of emergency preparedness. The 25 Director of HRR has indicated that two of those issues which
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() 1 are the identification of schools and the bussing of those 2 school children as well as the movement of the mobility 3 impaired need to be addressed, and there should be some 4 limited demonstration in those areas. That statement was made 5 in conjunction with a field hearing conducted by Senator 6 Kennedy in the Ducksberry area.
7 That concludes my presentation. Are there any 8 questions?
9 DR. KERR: Thank you Mr. Collins. Are there 10 questions?
11 (No response) 12 DR. KERR: Mr. Collins, I have a couple of things 13 I'd like to ask you.
() 14 In the letter from Mr. Barry who is the Secretary of 15 the Executive Office of Public Safety as I understand from his 16 letterhead, he mentions that the Boston Edison Company 17 installed a venting system at the Pilgrim station but that it 10 has not yet been reviewed by the NRC. Let me read from his 19 letter.
t 20 "In our view if there is evidence that containment 21 venting can play an important role in preventing a core melt 22 accident and the engineering work to make such a device 23 operational is largely completed at Pilgrim station, then 24 should not the licensee be required to complete the project 25 and should not the NRC staff review it before restart?"
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() 1 Would you be willing to comment on that question?
2 MR. COLLINS: Yes sir, I will address the staff 3 actions in that regard and then Mr. Bruce Boger can addres:
4 any Mark I issues which I believe the SEP initiatives and the 5 direct torus vent are in response to.
6 The staff has reviewed the SEP proposal by BECO in 7 conjunction with their 50.59 review process. That 50.59 8 review process, of course, allows for the licensee to make a 9 decision internally on whether proposed changes or 10 modifications to the plant that's described in the final 11 safety hazards analysis warrant an independent review by the 12 NRC, and the criteria is listed in 50.59.
13 We have taken the option to independently review the
() 14
~"
basis of those 50.59 results.
The initial proposal as forwarded to us by Boston 16 Edison acknowledged that a direct torus hard pipe vent, and 17 that's an eight inch hard pipe vent coming upstream of the 18 standby gas treatment system, was preferable to the existing 19 vent through the 11 inch low pressure gauge, standby gas 20 treatment duct work.
21 In conjunction with that proposal they acknowledge 22 that they were installing the hardware necessary to provide 23 for that direct torus vent with the exception of installing 24 the valve which would provide 'Jor operator control of that 25 system to vent.
Heritage Reporting Corporation (V~') (202) 628-4888
164 1 The staff reviewed that submittal in conjunction 2 with the barriers provided by the valve not being installed 3 being containment isolation valve barriers, and we have 4 reviewed that submittal.
5 Subsequent to that there is an August 18th letter 6 which I mentioned during the presentation which indicated that 7 Boston Edison now proposes the installation of that valve.
8 The installation of that valve would also be reviewed 9 internally. It's being proposed under the 50.59 review 10 process. The staff has that under review now.
11 A long windod answer. The direct answer is, we will 12 review the submittal as proposed under the 50.59 process. We, 13 and I'm speaking for the staff now, do acknowledge that there
() 14 are some studies which indicate that a hard piped vent has 15 advantages, however as both the staff and Boston Edison agree, 16 that at this time operation of that system is pending the 17 completion of the review of the EOP Rev. 4 procedures by both 18 the staff and the industry.
19 DR. KERR: Thank you.
20 MR. COLLINS: Mr. Boger, do you have anything to add 21 to that?
22 MR. BOGER: Just to recognize that the SEP 23 modifications were kind of at the leading edge of Mark I 24 containment improvements. The staff is not going to require 25 these modifications in advance of the generic resolution.
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1 DR. KERR: But will the staff permit them before?
2 MR. BOGER: It's being installed under the 3 provisions of 50.59. 10 CFR 50.59, and that's the licensee's 4 call on that issue. We're going to review the design and 5 installation to make sure it is appropriate for their use 6 under those considerations.
7 DR. KERR: So insofar as you can predict at this 8 point, it is likely that the system will be installed and can 9 be operated by the time restart occurs?
10 MR. BOGER: We will have completed our review of it.
11 You might want to address that to Boston Edison to see what 12 their schedule for installation would be.
13 MR. COLLINS: Sir, let me clarify that answer. I
() 14 believe the installation will be complete. The operation will 15 not be complete. In other words, the hardware will be 16 installed. The hardware will serve as a containment boundary 1 17 and will be tested to verify that it meets the requirements of 18 the containment boundary, but the actual operation of that 19 valve in conjunction with EOP Rev. 4 will not be either 20 proposed by BECO or approved by the staff, pending completion 21 of the review of the EOP Rev. 4, both by the staff and the 22 industry.
23 DR. KERR: So the hardware will be there, but they 24 catt' t use it.
25 MR. COLLINS: Correct. The electronics will be l
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(~)h t,_ 1 disabled for the solenoid valves. There will be no nitrogen 2 to operate the air systems.
3 DR. KERR: Is that because it simply is efficient to 4 do it that way rather than do a separate review for Boston 5 Edison? Or because, it strikes me that we have gone this far 6 with what must be an expectation that there is some advantage 7 to this. That being the case I am a little puzzled that we 8 are simply going to let the thing sit there for some period 9 not operational.
10 Can you help me a bit?
11 MR. COLLINS: I think that question is probably more 12 appropriately proposed to Boston Edison. They have not asked 13 us yet to --
() 14 DR. KERR: They may not have provided you with a 15 form of submittal, but Boston Edison proposed to install one 16 of these things at least a year ago it seems to me. There 17 have been numerous consultations since then haven't there?
18 Perhaps you don't have a formal proposal from them to ;
19 inaugurate EOP 4 or something, but unless I completely miss 20 the point, I thought they had suggested that they would like 21 to install this thing and have it operational.
22 MR. COLLINS: Their studies, I guess in summary, 23 their studies which form the basis of the SEP, and again I 24 don't want to speak for Boston Edison, this is my 25 understanding, indicate that there are advantages to that hard l
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- 1 pipe vent and there are situations under which its operation 2 will enhance the ability of the licensee to cope with that low 3 probability accident.
4 The staff studies are still continuing, although we 5 acknowledge that the installation of the hardware as provided 6 for by the 50.59 process which we will review, does not 7 introduce any additional hazard for that modification to be 8 installed.
9 DR. KERR: Okay. Maybe I should save my further 10 questions for them. I woula have assumed that they would not 11 have installed this thing unless they had some evidence that 12 it might improve things. But as I said, I'll wait.
13 MR. BOGER: I think there is one thing, that Rev 4 14 or the EPG's has been imminent for probably the last five or 15 six months.
16 DR. KERR: By the way it is true I think, is it not, 17 that there are BWR's thst have emergency operating procedures 18 that call for venting?
19 MR. COLLINS: Yes sir.
20 DR. KERR: There are BWR's . So presumably if Boston 21 Edison used whatever pathway those used, they could have this 22 thing operational. They just chose the wrong pathway, is that 23 it?
24 HR. COLLINS: No sir. Thoir existing procedures 25 allow venting.
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() 1 DR. KERR: But not through this system, is that 2 right? ,
3 MR. COLLINS: That's correct. The existing vent 4 path is through the standby gas treatment system which is a 5 low pressure system.
6 DR. KERR: And even though there seems to be 7 evidence that venting through this system would perhaps be 8 less risky, they could ven through the other system that might 9 be more risky. Is that it?
10 MR. COLLINS: I don't think it's a matter of degrees 11 of risk. I think it's a matter of advantage to the mitigation 12 of an accident and where you want the release to be. The hard 13 part provides for an elevated release.
() 14 DR. KERR: Presumably you want it to be in the place Is that 15 where it is going to cause less damage, Mr. Collins.
16 not --
17 MR. COLLINS: No sir. We are not disagreeing with 18 your premise. We are only saying we have not reached that 19 same conclusion pending --
20 DR. KERR You're not convinced that the hard pipe 21 system is better than the system which vents through the lower 22 pressure pipe, is that it?
23 MR. COLLINS: No sir, I did not say that.
24 DR. KERR: You just haven't made up your mind.
25 MR. COLLINS: I said the issue was still under staff Heritage Reporting Corporation O (202) 628-4888
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- 1 review pending review of how the operator will make those 2 judgments and under what conditions he's allowed to make those 3 judgments.
4 DR. KERR: I'm not sure I understand that statement, 5 but I'm afraid to go farther.
6 Next item.
7 MR. COLLINS: I think it's really clear that at some 8 point in time the staff has to make a decision on the 9 acceptability of the EOPs. Those EOPs provide for venting 10 operations of which the hard pipe will --
11 DR. KERR But I thought the staff had already made 12 a decision that it was okay to vent through the standby gas 13 treatment plant.
( 14 MR. COLLINS: That's correct, but there are 15 different pressures and different decision points involved.
16 MR. SOFER: Let me see if I can clarify just a 17 little bit. I'm Leonard Sofer with the Office of Research.
18 As you may know, the staff is working on a program 19 for Mark I containment improvements which has been alluded to.
20 One of the distinctive features of this program is a hardened 21 vent capability.
22 With regard to your questions, Dr. Kerr, there is no 23 doubt in the staff's mind that a hardened vent capability is 24 better and more effective than the present version of venting 25 which is basically through the standby gas treatment system.
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() 1 In a severe accident this would certainly rupture and would 2 contaminate areas of the reactor building making recovery and 3 damage control operations much less likely.
4 However, in briefing the commission on interim 5 status of the Mark I containnent improvements, there were 6 questions raised with regard to inadvertent venting and who 7 would give the order to vent, who would have the permiesion to 8 vent. The staff is still mulling over a number of these 9 questions.
30 So it is not a question of the technical merits of 11 doing so. It's more a question of some of the procedural 12 aspects I would say.
13 MR. CARROLL: Has Boston Edison provided you all the
() 14 information you need to make your, continue your 15 deliberations?
16 MR. SOFER: I can't answer with respect to Boston 17 Edison specifically. We're looking at some of the generic 18 aspects and trying to address those.
19 MR. CARROLL: Generically then, do you have a time 20 frame where you think this is going to be resolved?
21 MR. SOFER: We are planning to make a final 22 recommendation to the Commission by the end of this year.
23 MR. BOGER: Revision 4 of the EPG's is imminent like 24 in the next couple of weeks. The new revised schedule.
25 DR. KERR Thank you, Mr. Sofer. I wish I could say Heritage Reporting Corporation O (202) 628-4888
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() I that made things clearer, but at least it didn't make them any 2 less clear.
3 (Laughter) 4 DR. KERRt Mr. Collins, further, Mr. Barry has the 5 following comment. "It is our understanding," and I think 6 he's speaking now for the office of Public Safety, "that a 7 filtered event was installed at the Shoreham Long Island plant 8 which was planned to be a BWR facility." I thought it was a 9 BWR facility. "Presum=bly the design for such a system was 10 approved by the NRC. It would be helpful to understand the 11 rationale that led to NRC approval in one case, but a staff 12 recommendation against the idea for other BWR plants." .
13 MR. COLLINS: Yes sir, let me answer that by simply
() 14 saying two things. One, Shoreham is a BWR facility.
15 Secondly, that filter vent was neither proposed nor approved 16 by the staff and it is not installed. There has been some 17 reference to that in correspondence, but not under any formal 18 licensing submittal or any proposal to install.
1 19 MR. SOFER: I would just like to add that --
2 20 (Inaudible - away from mike) -- torus venting system that has 21 been proposed by Boston Edison would be through the
- 22 suppression pool and would constitute a filtered vented 23 arrangement. The staff concluded in its presentation to the 24 Commission earlier on the interim status that the filtration
, 25 would be significaat and we did not believe that an additional Heritage Reporting Corporation O (202) 628-4888
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k_) 1 filtration system was therefore necessary.
2 DR. KERR: Mr. Sofer, with all due respect, I think 3 that statement could be misleading. It certainly isn't 4 filtered beyond the vent from the torus. Normally when one 5 talks about filtered vented containment one is talking about 6 filtering beyond the vent point.
7 MR. SOFER: There are arrangements such as the 8 Europeans have where the containment affluent is not scrubbed 9 at all and then is passed through some kind of an external 10 filtering system. In Mark I containments, because of the 11 scrubbing through the suppression pool, there is in effect a 12 significant filtration. So I guess it's a question of 13 semantics. But there is in fact a good deal of filtration l () 14 there already.
( 15 DR. KERR: Of course. But I think normally when one j 16 talks about filtered vented containment, one is talking about 1
17 venting through a filter anc that I think is not the case La
(
l 18 this situation. I just wanted to avoid confusion, and I may 19 have added to it.
1 20 MR. SOFER: I appreciate that, but it should be 21 recognized that there is in fact quite a bit of filtration 22 that occurs if the affluent goes through the suppressien pool.
23 MR. CARROLL: And to make a chemical engineer happy, 24 you mean scrubbing when you say filtration.
25 MR. SOFER: Scrubbing, I'm sorry.
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() 1 MR. COLLINS: Yes sir, I'd like to clarify. I think 2 scrubbing is the correct term. Also, for the purposes I think 3 of the direct discussion, the proposal that I believe Mr.
4 Barry is referring to is a type of external filter which is 5 available in West Germany and Sweden and has been proposed in 6 a number of cases in Europe. That particular filter has not 7 been proposed, reviewed, or approved by the NRC.
8 DR. KERR: Are there further questions of Mr.
9 Collins?
10 (No response) 11 DR. KERR Thank you very nuch, Mr. Collins.
12 MR. COLLINS: Thank you.
13 DR. KERR Although the cjenda doesn't show a break
() 14 at just this point, I think it's a logical place for a ten 15 minute break. Let's reconvene at five after.
16 (Whereupon, a brief recess was taken) 17 (Continued on following page) i O Heritage Reporting Corporation (202) 628-4888
174 t/4 1 DR. KERR: This brings us to the presentation of i
I g- 2 Boston Edison representatives, Mr. Bird who is the Vice 3 President responsible for the nuclear program at this point, 4 as I understand, is going to open the presentation.
5 (Slides being shown.)
6 MR. BIRD: Good afternoon. I'm Ralph Bird, the 7 Senior Vice President of Nuclear. I joined Boston Edison on 8 the 1st of January, 1987 and after two months of an 9 intensive program on the Pilgrim Plant I assumed my 10 responsibilities at the end of February 1987.
11 31nce then I have spent most of my time at the 12 plant in order to be closer to the people and to their 13 problems. When I arrived at Boston Edison my immediate task 14 was to assess the strengths of the organization and 15 determine the areas that needed improvement.
O 16 The next step was to assign priorities and direct 17 our attention and our resources accordingly. We've 18 continually reassessed our situation, adjusting resources, 19 and refining *.he process which resulted in filing of the 20 self-assessment of our readiness for restart report.
21 We evaluated management practices at Pilgrim and 22 presented our conclusions to the NRC in a September 1987 23 public meeting.
l 24 We determined the plans and actions necessary for l 25 restart and issued our July 30th, 1987 restart plan.
I 1
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175 1 We conducted in-depth assessments of maintenance
'2 and radiological controls and implemented improvement action 3 plans covering both restart related and the longer term 4 actions.
5 We conducted investigations and critiques of 6 specific events at Pilgrim, and identified actions to 7 prevent recurrence of those events.
8 These assessments are the building blocks which 9 support our recent self> assessment report. We are resolved 10 to continue the self-assessment process at Pilgrim Station 11 to move this initiative down and across the entire nuclear 12 organization and to make it a part of every day operation of 13 the plant.
14 This afternoon Roy Anderson, who is the Plant Manager, and I will discuss the corrective actions taken
)15 16 since the plant was shut down and the status of our efforts 17 to achieve continuing rising standards of excellence.
18 Ed Howard, the Vice President of Nuclear 19 Engineering, and Ron Varley, the Manager of Emergency 20 Preparedness is here to answer any questions you may have in 21 their areas.
22 The long-term management organization has been 23 defined and almost all of the key positions have been 24 filled. All of the key managers at the section head level 25 and above are Boston Edison employees.
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176 1 The senior management team is a season team with 2 over 250 man years of successful nuclear power experience.
3 They are strong individuals who have high standards and they 4 work well together.
5 We have strengthened the organization by adding 6 people who are among the very best in the field. There are 7 new managers in emergency preparedness; security; 8 radiological protection; operations; plant support; special 9 projects; training; and quality assurance.
10 In addition we have maintained continuity of the 11 work force and management through the retention of most of 12 the long-term Boston Edison employees.
13 We have also upgraded the Nuclear Safety Review 14 and Audit Committee, which is the offsite Safety Review 15 Committee. We brought in Bill Wagner as Chairman, and we 16 have added other new outside members to this important group 17 who are widely recognized experts in their fields. They 18 include Henry Stone, Murray Miles, Leo Duffy, and Jack Grig/
19 and that groups is rounded out by Dr. William Corcoran who 20 is a longer term member of this committee.
- 21 The condition of the plant has improved 22 dramatically since the beginning of the outage in 1986 and I 23 the rate of improvement has accelerated through 1987 and 24 1988. I 25 The plant is refuel. And we have successfully Heritage Reporting Corporation (202) 628-4888
177 1 completed the hydrostatic test and the integrated leak rate 2 testa.
O 3 Major modification work has been completed, and we 4 are doing testing; surveillance; and some continuing 5 maintenance. Details of the extensive work done during this 6 period are in our restart plan and in our self-assessment of 7 readiness for restart report.
8 Certainly one of the most significant projects has 9 been the safety enhancement program which includes both 10 equipment modifications and procedure improvements. We have 11 dedicated significant resources to this program which 12 exceeds current NRC requirements and therefore is not a 13 prerequisite for restart.
14 Our program which emphasizes prevention of core 15 damage was a Boston Edison initiative in response to the 16 draft severe accident contaiament policy for boiling water 17 reactors, which the NRC staff presented to the industry in 18 June 198f. And we have kept the NRC staff informed of our 19 plans and the bases for those decisions.
20 To perhaps help clarify the situation on a direct 21 torus vent, as you know we have proposed the hard pipe 22 direct torus vent for Pilgrim. And we are proceeding now 23 with the hardware installation. The NRC has not yet 24 approved the operating guidelines for tne direct torus vent 25 for boiling water reactors on a generic basis, but we expect Heritage Reporting Corporation (202) 628-4888
1 178 1 the operating guidelines will be through the review soon.
s 2 When the NRC approves the generic operating 3 guidelines Boston Edison will be in a position to promptly 4 implement operation of the direct torus vent in accordance 5 with these new generic guidelines.
6 The safety enhancement program modifications are 7 now virtually complete. And the second diesel driven fire 8 pump is the one remaining issue wh.;h will be completed 9 after restart.
10 We did proceed to implement new emergency 11 operating procedures based on the Revision 4, BWR guidelines 12 because they are technically superior to the earlier 13 revisions. This major initiative has been a well 14 coordinated effort by the nuclear engineering, operations, 15 and training departments who use the new plant simulator 16 extensively in their work.
17 We are very proud of our accomplishments in this 18 program because we have significantly improved our 19 capability to effectively respond to any off normal events 20 in a safe reliable manner.
21 MR. MICHELSON: Excuse me. You show backup 22 nitrogen supply, is that for containment inerting?
23 MR. DIRD: Yes.
24 MR. MICHELSON: Not for backing up an air system?
25 MR. DIRD: Well, we already have nitrogen for the Heritage Reporting Corporation (202) 628-4888
j 179 ,
1 operation of some of the valves in containment.
Do you want to elaborate, Ed? l O23 MR. HOWARD: It is available to back up the 4 nitrogen supply to the safety relief valves as well.
5 MR. MICHELSON: And all the rest of the 6 containment isolation valves are motor operated or do you i 7 have some air operated containment isolation valve besides 8 steam?
9 MR. HOWARD: None other than the main steam j 10 isolation.
11 MR. MICHELSON: Thank you.
12 MR. BIRD: We did pay particular attention to 13 improving those minimally acceptable functional areas which 14 were rated SALP 3 in the period ending in January '87. Four 5
15 of those five areas moved into the two category for the These are assurance of !
16 period ending May 15th, '88.
17 quality; fire protection / security and safeguards and 18 surveillance. Radiological was rated as a category 3 but 19 improving. And there has been a great deal of progress in 20 this area since the end of that SALP report.
21 MR. MICHELSON: Could you tell me very briefly l 22 what your problem was with fire protection and rated it 3, 23 and how you upgraded it?
24 MR. BIRD: Well, that last SALP report closed out 25 about the time I arrived.
Heritage Reporting Corporation (202) 628-4888
180 1 MR. MICHELSON: Maybe somebody else could tell me.
2 MR. BIRD: It was largely because we had not 3 completed the appendix R work, which we subsequently did 4 during this outage.
5 Also another issue was a large backlog of minor, 6 individually minor repair items, but a large number of them 7 both in security and fire protection.
8 Ed, can you add anymore to that?
9 MR. HOWARD: I think the concern that we were 10 overly dependent on compensatory measures.
11 MR. BIRD: That's right, and that's because of 12 large backleg of maintenance primarily.
13 MR. MICHELSON: By compensatory measures you mean 14 manual fire watches and that sort of thing?
15 MR. HOWARD: Yes.
16 MR. MICHELSON: Thank you.
17 MR. BIRD: That was also a complaint in security.
18 And compensatory measures have been virtually eliminated in 19 both areas now.
20 Among the emprovements that we have made in 21 radiological controla virtually all accessible areas of the 22 pJant, 90 percent of the process buildings are now 23 radiological clean and they are accessible to anyone in 4
24 street clothes.
25 The health physics and radiological protection Heritage Reporting Corporatiois (202) 628-4888 i
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181 1 staff has been grea ly expanded. Additional numbero as well 2 as quality of people which has drastically reduced our 3 reliance on contractor personnel.
4 We track exposures carefully. We post results.
5 And we emphasize radiological safety throughout the work F 6 force, Many of these changes were not fully implemented 7 until late in the most recent self-evaluation period which 8 ended in May. But we now have clear evidence that they have 9 been effective and they continue to be effective.
10 Even as our SALP ratings improve we will continue 11 to make every effort to achieve rising standards of 12 excellence in every aspect of the operation. We will be 13 relentless in this effeset and we have the right people to 14 succeed.
15 Shortly attor we completed the self-assessment of 16 our readiness for restart the Institute of Nuclear Power 17 Operations performed a two week plan evaluation. The 18 results of the 'NPO evaluation confirm the self-assessment 19 of our readiness for restart which we submitted in May 1988.
20 And our restart report concluded that upon completion of the 21 actions identified in the self-assesar ,at J.d restart plan 2 that we would be ready for safe and rel165'c operation --
}
23 for safe and reliable restart and continued operation.
24 The INPO team examined station organization and 25 administration, operations, maintenance, technical support, Heritage Reporting Corporation (202) 628-4888
182 1 training and qualification, radiological protection, 2 chemistry, and operating experience.
'O 3 They also looked at management involvement and 4 commitment, material, and outside service, human resources, b and emergency preparedncas.
6 As I'm sure you know, INPO's mission is to assist j 7 member utilities in achieving the highest standards of 8 excellence in noclear pl&nt operation. They recommendations 9 are based on the boat industry practices, and therefore lead 10 to rising standards of performance.
- 11
- .n light of these standards ;e take special pride 1
12 in thei r identification of a number of beneficial practicer 13 and strengths in their last report.
14 MR. MICHELSON: Did INPO look at the operation of 15 your Safety P.eview Committee during their last report?
O 16 MR. BIRD: I don't think they did. However, the 17 NRC staff looked at it in considerable depth during the 18 jntegrated team inspe tion and they complimentad us on the 19 recent upgrade of the Nuclear Safety Review and Audit 20 Committee.
21 MR. MICHELSON: But INPO didn't touch on it is 22 time.
J3 MR. B7RD: I don't think they did.
24 .. MIC6 71011: Thank you.
25 1- "O L. . This is Sam Collins. I've had some
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183 1 discuss 0 ns with INPO on that topic and INPO does not gs 2 typically, in the types of review they performed at Boston
\"f 3 Edison, assess the independent review committees.
4 MR. MICHELSON: On some occasion, of course, but 5 perhaps not this occasion.
6 MR. COLLINS: Yes, sir, they did not in 7 conjunction with that review.
8 MR. MICHELSON: Thank you.
9 MP. . BIRD: Today we think that employees at 10 Pilgrim can be proud of where they work and what they do, 11 and one can see the improvements in the morale.
12 These next three slides are to illustrate our move 13 toward self-sufficiency. This slide shows the ramp down in 14 contractors at the site. The line across the bottom is the 15 gaard force which we have made a conscious decision to 16 continue as a centract force. But you can see that as we 17 ramp down we are essentially self-sufficient now with the 18 excepticr. if the guard force.
19 And of course in addition to becoming self-20 sufficient we have to be sure the staffing is adequate so 21 that we can get the work done with a reasonable amount of 22 overtime and we can plan and control the overtime.
23 This chart shows that we ars .;oing that. The 24 planned overtin.e has not been exceeded in any month this 25 year.
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184
-1 MR. MARD: Excuse me. On the previous chart then 2 the total shown includes the guard; is that it?
i 3 MR. PIRD: Correct. The line across the bottom 4 showa the guard force which has come down a number somewhat 5 over time. But you can see that the total number of 6 contractors will not go below that line.
7 And finally, for us to become self-sufficient we
., 8 need to displace the contractors with some additional Boston 9 Edison staffing, ar.d this shows the ramp up that has 10 occurred during this year and the planned number in the I
1 11 organization at the end of the year.
l 12 We are meeting our goals to compiute work, to 13 improve housekeeping, and preservation, to reduce the 14 contractors, to increase Boston Edison staffing, and to do 15 high quality work.
16 We are generally meetiag our schrdule and visitors 17 consistently comment favorably on plant condition, worker j
18 attitudes, and thu pervasive sense of pride in the
) 19 organization.
I 20 Despite the fact that on three occasions we have
]
! lowered the threshold for issuing radiological occurrence 21 1
l 22 reports which is the me"hod by which we document and fcllow l 23 up on corrective action for minor radiological problems.
24 The number of events has dropped since the beginning of the 25 year, and so has the severity of the individual items i
f 1
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t 185 1 reported.
2 We have also virtually eliminated the backlog of O 3 open items which shows that we are dealing with the issues 4 in a timely manner.
5 MR. WARD: Is this reduction due primarily to 6 better proceduras or to the fact that the plant areas are 7 cleaned up?
8 MR. BIRD: Both. But the most important change is t
, 9 one, again, of attitude. Radiological controls at a nuclear l 10 powerplant has to be a concern et' everyone who enters the j 11 process buildings. And unless it is, the radiological 12 section alone cannot achieve a high level of performance. }
13 So this represents much better cooperation between j
14 maintenance, operations, and radiological, and a much higher
! sensitivity to radiological problems, and an increased sense 1
( ) 15 16 of personal responsibility on the part of aach person that ,
17 enters the process btildings.
18 The one key component of cuccessful management is t i 19 a system for measuring progress. Wo have decided to track 20 certain key indicators which are important because the j 21 indicators contribute to safe and reliable operation of the L 22 plant. They are good guides to the overall operation. And 23 in some cases they focus on areas thst have been concerns at 24 Pilgrim over the past years.
25 Roy Anderson the Plant Manager will now discuss Heritage Reporting Corporation (202) 628-4888
()
l i
186 1 four of these areas which are important to achieving safe, 2 reliable, and continued operation. These are maintsnance; 3 plant decontamination; radiation exposure control; and 4 operations preparedness.
5 Roy.
6 MR. ANDERSON: Good afternoon. My name is Roy 7 Anderson and I'm the Flant Manager of the Pilgrim Station.
8 I came to Pilgrim in March of last year. Hay of last year I 9 joined Boston Edison; and December of last year as the 10 Outage Manager where my job was to finish the major 11 projects; and then in March I assumed the duties as plant 12 manager.
13 With regards to maintenance, the maintenance 14 backlog has been dealt with. We have the resources and the 15 programs in place to stay ahead of the work load. The power 16 block MRs we had set a goal of 500; we achieved that. We 17 dropped our goal to 400; we achieved that. And as of 18 yesterday we were hovering at 306 open power block MRs.
19 Since the completion of the last SALP period NRC 20 maintenance inspuction 88-17 we have made a number of 21 dramatic imptovements. We implemented a revised t, 't 22 process which includes planning check lists and we trained 23 545 personnel including myself, my boss, Ken Hyphil and Mr.
24 Bird on its use.
25 We lasued a greatly improved maintenance manual.
j Heritage Reporting Cocporation (102) 628-4888 I
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187 1 Ne implemented detail work travelers which dramatically ,
1 2 enhonce the autoability of our work packages. We expanded 3 the post-work test matrix. We proceduralized supervisory 4 review to ensure thorough and conciatent maintenance 5 closeout. We assigned operations and system engineering 6 personnel to have the lead in prioritizing work to be done 7 at the station.
8 We have added a deputy maintenance section manager 9 to the organization and filled the position with an 10 individual who has 30 years abroad nuclear experience.
11 We have expanded the maintenance organization by 12 transferring personnel from other areas and at the same time 13 improved our supervisor to craft ratio. All supervisory 14 positions in maintenance are now filled with Boston Edison 15 employees, all who have attended supervisory training before 16 assuming those responsibilities.
17 MR. WARD: When you say you have improved the 18 supervisor craft ratio, it's not always apparent which 19 direction that is quantitatively.
20 MR. ANDERSON: I'm sorry.
21 MR. WARD: What ratios have you gone to?
22 HR. ANDERSON: We were running, I believe, and I'm 23 talking hictoricel numbers, at about eight craft per 24 supervisor and we brought that number down to about four 25 craft per supervf.sor.
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188 1 It's very important depending on the job, if we're 2 out digging a hole in the yard one supervisor can handle 10 3 people. If I'm in the protective cabinets I may want a 4 supervisor there for the two fellows doing the work. So 5 when I say improved it's -- the ratio has gone down.
6 We've improved the organization's ability to 7 integrate radiological and operational considerations by 8 assigning health physics and senior reactor operator 9 qualified personnel to assist maintenance in the planning 10 process.
11 Our recent assessments to the new work control 12 process show both value of the process and its acceptance by 13 the work force. And that's very important that it's 14 accepted.
15 We firmly intend to maintain the physical position 16 of the Pilgrim Station such that it's a source of pride for 17 our employees and our neighbors, and that it helps to meet 18 the growing need for electricity in New England.
19 (Slides being shown.)
20 MR. ANDERSON: When this outage began only about 21 45 percent of the spaces in the process buildings were 22 accessible without protective clothing. Entrance jnto some 23 areas required self-contained breathing apparatus. We made 24 a commitment that before restart 90 percent, virtually all 25 the accessible areas on the plant, would decontaminated; we Maritage Reporting Corporation (202) 628-4888
, 189 1 are there now, 90 percent accessible in street clothes and 2 we intend to keep it that way.
3 We think that a cleaner plant promotes safety and 4 quality. Inspections are more frequent a;*d more thorough 5 when operators do not have to dress out in protective 6 clothing to enter areas.
7 Beyond these benefits, however, we are always 8 vitally interested in reducing total worker exposure.
9 Our policy is ALARA as low as reasonably 10 achievable, and we are pursuing it aggressively. We are 11 communicating its importance through training and making 12 sure that every employee knows that individuni exposure is 13 an individual responsibility.
14 We originally set our exposure goal for the INPO 15 guideline of about 600 rem per year. The industry averages 16 decreased, but we are on track to come in well below that j 17 mark. We have established this new and much tougher goal of 18 390 rem for the y9ar, which is 20 percent for the 1987 19 industry average. Based on our performance this far in 1988 20 we will meet this very aggressive goal.
21 And finally, I would like to discuss the readiness 22 of our operations department for restart. A full fidel.ity 23 simulator of the Pilgrim control room has been an integral 24 part of our program of operational readiness for restart and 25 its use has added gree'.ly to our confidet;e level.
I Heritage Reporting Cor;> oration (202) 628-4888 O
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l 190 1 Because Pilgrim had operated for years before the 2 simulator was installed a lot of operating data could be 3 incorporated into the design. A Pilgrim representative was 4 on the site at the vendor for the entire course of the 5 simulator construction. All licensed operating crews also 6 went to the vendor and helped to fine tune the finished 7 product.
8 The resulting software is more rigorously 9 constructed and it incorporates more plant specific 10 information than is usual. The visual accuracy of the 11 simulator is enhanced by a sound system to provide the exact 12 control room atmosphere. We have received excellent 13 feedback from our operators about the level of fidelity of 14 the control room.
15 Most unusual is the duplication of back panels O 16 which are working models and permit training for 17 surveillance. Pilgrim simulator has the unique ability to 18 train operators on jumpering out relays in context used in a 19 '.ive jumpering system.
20 Having a plant specific simulator in our training 21 center provides for better qualified operators who have more 22 plant specific information. The simulator allows for 23 operators to perform casually drills that validate emergency 24 operating procedures as well as the drills that validate 25 tal operating procedures.
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l 191 l 1 Every qualified watch dander has been trained on 2 the EOPs using the simulator.
3 Another significant benefit has been the 4 availability of the simuletor to augment analysis for root :
5 cause events such as the loss of offsite power in November 6 of 1987. Our plans for the simulator include running 7 emergency prepared drills from the simulator to allow total L 8 participation by the operators. We are starting the 9 connections that will make this possible next year. We will 10 be able to simulate the emergency plan information computer 11 and the safety parameter display system with 100 percent F 12 fidelity.
I 13 By the end of 1988 we expect to complete a state L 14 of the art touch sensitive graphic instructor facility.
15 This graphic display of changing plant conditions will 16 enable us to develop a much more powerful lesson planned 17 program performance evaluation system, because we will be 18 able to preprogram scenarios and acceptance criteria. The 19 system will provide a more objective evaluation of operator 20 performance.
21 Since last summer two successive classes of (
22 reactor operators and senior reactor operators have taken 23 their NRC exams with 100 percent pass rate. And with 24 exceptionally high averaging grades over 90 percent. [
25 once the new licensees have met their operating i Eeritage Reporting Corporation (202) 628-4888
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192 1 experience requirements at 20 percent reactor power we will 2 staff a six shift rotation to permit scheduling for future I)
3 operator classes. During our restart we hrve planned for a 4 four shift rotation. This permits an extra senior reactor 5 operator to be assigned to each shift and allows a most 6 efficient use of experienced operators. Our operators look 7 better, they are now in uniform and they sound better.
8 Training and formal communicaticas has been 9 effective and it's showing clearly beneficial results in 10 improved control in a higher level of professionalism. All 11 four crews have completed t raining on a revised emergency 12 cperating procedures. Our operators haie been observed as 13 part of our self-assessment by INPO and by the NRC as part 14 of the emergency operating procedure inspection. Ever 15 assessing team has conc!.uded that they are well trained and 16 prepared to operate the plant safely and reliably.
17 MR. WARD: Excuse me. Maybe I rissed it but back 18 in ' 8 6, the first part of that chart when you had only seven 19 or eight licensed operators.
20 MR. ANDERSON. These are reactor aperators, not 21 SROs. This chart shows reactor operators.
22 MR. CARROLL: But that's still pletty skinny.
23 MR. WARD: Yes.
24 MR. ANDERSON: Yes, sir.
25 MR. WARD: A lot of overtime back then, I guess.
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193 1 MR. ANDERSON: Only from history; yes, sir. We 2 don't intend to get in that position. We intend to operate I O 3 with a six shift rotation. That allows for the routine 4 training of personnel without overtime. [
1 5 The 49 current license holders, that's ROs and (
6 SROn, have a total of 624 ya,ars of nuclear experience of 7 which 462 is at a boiling water reactors. Over 452 man 8 years of that experience is at Pilgrim Station. These are 9 well qualified personnel with extensive industry, Navy, and
- 10 plant specific knowledge. They are professionals. They 11 carry their duties out in a responsible, conscientious, and 12 professional manner.
13 The 49 key managers in the nuclear organization 14 have more than 800 man years of nuclear experience. Over 465 of them have boiling water reactors and 385 at Pilgrim l
[ } 15 16 Station.
I i i 17 Here again, we have an extremely healthy mix of !
18 Pilgrim, industry, INPO, and Navy experience, both I
- 19 presuurized water reactor and boiling water reactor that few 20 plants in the country can equal. And here again we perform j 4 l i 21 to a strict professional ethic. I
! [
22 In summary, the quality, timeliness, Boston Edison ;
23 ownership, professionalism, and pride are evident in the way f 24 we are doing business. I'm proud to be a part of this team f 25 and so are my people. !
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194 1 With this present team and our recent track record i 2 I am very confident that we are ready for restart.
3 Mr. Bird.
4 DR. KERR: Are there questions?
5 (No response.)
6 DR. KERR Thank you, Mr. Anderson.
t/5 7 MR. BIRD: In opening our presentation I mentioned 8 the self-assessments we have done to determine our readiness 9 for restart. These were rigoroas assessments. They were 10 overseen by a management team which I personally chair. The 11 process involved interviews, document reviews, plant walk 12 downs, and observation of operators in action at the 13 siraulator, as well as operations in the control room, and 14 during plant maintenance.
15 The views of the NRC team which recentlf concluded 0 16 its readiness inspection gave us good marks for self-17 assessment and gensrally confirmed our high degree of 18 confidence and the effectiveness of the improvements that we t
19 have made.
20 In summary, we have come a long way. We have an 21 effectivs Lanagement team with in-depth experience and a 22 proven track record of success. Our maintenance backlog has 23 been reduced and is well under control.
24 The material condition of the plant has been 25 oubstantially upgraded. We have implemented a safety Heritage Reporting Corporation (202) 628-4888
195 1 enhancement program which is at that leading edge of 2 technology in dealing with severe accident issues and 3 exceeds existing regulatory requirements.
4 We have a well trained staff of licensed operators 5 and they have demonstrated their proficiency in using new 6 and carefully developed symptom oriented emergency operating 7 procedures.
8 We have demonstrated our ability to identify 9 problems ourselves, and more generally, to accurately self-10 assess our own performance.
11 These facts together with many other improvements 12 which have been made show that subject to closeout of just a 13 few items Pilgrim is ready for a safe and successful restart 14 in accordance with a carefully defined power ascension and 15 test program.
16 Finally, the entire restructuring and 17 revitalization of the nuclear program has the full support 18 of our top management and our board of directors. Theia 19 support and their provision of appropriate resources 20 represent their determination to sustain excellence in 21 operation of Pilgrim.
22 Thank you.
23 LA. KERR Mr. Bird, in that connection, I think, 24 on page 10 of the recently released IAT report under l 25 Operations Review Committee I find the following: "Prior to Heritage Reporting Corporation (202) 628-4888
196 1 restart in order to strengthen its operational focus the 2 OAC," which I think is the Onsite Review Committee.
'- 3 MR. BIRD: That's correct.
4 DR. KERR "Will begin to review plant incident 5 critiques, review licensee event reports before their 6 issuance to NRC, review failure and malfunction reports on a 7 regular basis, and provide for a snonthly presentation and 8 discussion of plant operation as a specific agenda item."
9 That puzzles me. In the first place I'm not sure 10 what is meant by strengthening it's operational focuo, maybe 11 you know.
12 MR. BIRD: I think I do.
13 DR. KERR And secondly, it almost appears that 14 the NRC staff thought this was a rather completely 15 inexperienced and untrained review committee. I mecn, these 16 things are so obvious that I'm puzzled that the NRC is 17 telling you to do this and , umably each time they're 18 running an inspection they will check to see if you are 19 doing this.
20 And I thought the purpose of a review committee 21 was to sort of have the freedom to look things over and 22 decide what was going on and make recommendations.
23 Maybe you can help me, perhaps you understand this 24 better than I do.
25 MR. BIRD: Probably a little bit better. We'll Heritage Reporting Corporation (202) 628-488b
197 1 give it a shot.
2 The Operations Review Committee is composed of the
- O 3 most experienced and knowledgeable people at the plants the 4 technical support manager; the chief operating engineer; 5 chief maintenance engineer; and so forth. It represents the 6 best corporate memory and the best operating knowledge that 7 e xi s t.a .
8 They were, however, somewhat overburdened with 9 procedure change reviews and that sort of thing. None of 10 these items mentions,d here were ignored per ce. However, in 11 looking back through the records it was not easy to tell 12 exactly the level of reviews the records were not audible in 13 some cases. The operations review, for example, was largely 14 done outside the formal committee meeting simply through 15 their day to day involvement in plant operations, j 16 maintenance, and so on.
f 17 So the idea here is to make the reviews more I 18 structured and more formalized and I should add that there i
19 was no allegation by the NRC staff that any of these areas 20 were being neglected because we have a very powerful l 21 management oversight and assessment team which was heavily
- 22 involved in self-assessments. So there were no surprises.
23 There were no problems which -- no significant problems were I
24 undiscovered, nor was there any indication that we didn't 25 know what was going on in these areas, i
l l
l Heritage Reporting Corporation (202) 628-4888 lO i
198 1 But it is a valid concern that we should reduce I 2 the amount of administrative work the way we review -- do O 3 the safety reviews and procedures requiring the ORC to pick 4 up so much o* the 'ourden.
5 We have a plan to develop a qualified reviewer 6 program for less than the administrative burden on the ORC 7 and allow refocus of their attention more into the operating i 8 areas.
9 DR. KERR Mr. Bird, I think you're a diplomat. I l t
10 certainly hope, however, that the committee will strengthen i 11 its operational focus as a result of this injunction. !
12 MR. BIRD: They will.
13 DR. KERR The ORC committee. l l
14 This says that you're also going to conclude I 15 something or other. Have you concluded? I mean, my agenda 16 says conclusion, I don't know whether -- l 17 MR. BIRD: I just gave it. !
l 18 ,
DR. KERRt Are there further questions? ,
I 19 MR. COLLINS: Sir, I have a clarification of a [
i 20 previous answer that I gave Mr. Carrc11 on the emergency 21 preparedness on the basis for the exemption.
22 MR. CARROLLt Yes.
23 MR. COLLINS: I'm paraphrasing here, but we went 24 out and had the letter read over the phone. The response by 25 the NRC to the request for an exemption to that exercise Heritage Reporting Corporktion (202) 628-4888
199 1 basically acknowledges a temporary time delay thet' 7
, 2 necessary due to ongoing efforts not completed before the
3 required date.
4 MR. CARROLL: This is a response to whom?
5 MR. COLLINS: To BECO. It acknowledges a good 6 faith effort by the licensee, that extensive efforts to 7 upgrade the offsite plans and ireplement the char.ges, and 8 conduct necessary training have been pursued. And that 9 these initiatives preclude a meaningful and effective full 10 participation exercise.
11 The health and safety of the public is better 12 served at this time by the conduct of a full participation 13 oxercise following completion of the improvement efforts.
14 MR. CARROLL: Thank you.
15 DR. KERRt Mr. Bird, in the letter from Mr. Barry 16 there is, and I believe you said that you and your staff had 17 a copy of this.
18 MR. DIRD: Yes, we got a copy --
19 DR. KERRt He raises a question about the possible 20 use of mitigation enhancements inside containment, and the 21 fact that for Boston Edison, Mr. Robert Henry of Falsky and 22 Associates did some experimental work which was interpreted 23 by Mr. Henry to indicate that one didn't need some of these 24 mitigation systems, which apparently was called into 25 question by some consultants that the state had.
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200 l 1 Do you heve any comments on that paragraph? You 2 or some of your staff?
3 MR. BIRD: I think Ed Howard can probably comment 4 because we considered these factors in deciding exactly what 5 modificatisns we would make as part of the safety 6 enhancement program. !
7 Ed. f 8 MR. HOWARD: One of the initiatives of a safety 9 enhancement program was to co-fund with Falsky and !
10 Associates a set of experimental tests to examine the 11 effectiveness of water in preventing liner melt through in 12 contact with core debris, 13 This particular subject has been discussed at come 1 14 length as a discussion among different anclyst about 15 differing analytical results. Dr. Henry had long O
l 16 recommended through his participation in the IDCOR program t i
17 that experimental work be performed in order to reduce the f e
18 perceived uncertainty about the analysis results.
19 Those test results were shared at a NRC work shop f I
20 sponsored by the research side of the NRC in February of f
t 21 this year. The results, we believe, do provide a 22 significant additional confidence in the strategies we are ;
i 23 using in the safety enhancement program trith regard to l f
24 containment performance. l 25 Results have not yet been fully reported.
f l
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201 1 Additional testing is ongoing now and is sponsored by the 2 Electric Power Research Institute. They are fundirg the
'~'
3 documentation of all the test results and the analysis of 4 those results and we wi.11 make them available to the 5 research community when they are completed.
6 DR. KERRt Thank you, sir.
7 Are there further comments, questions?
O (No response.)
9 DR. KERR Thank you. Excuse me. Mr. Carroll.
10 MR. CARROLL. I just want Ed to clarify, what the 11 issue here is the concrete curb?
12 HR. HOWARD: The initial comments by Commissioner 13 Barry were about -- I believe his words are, we understand 14 t'.at Boston Edison Company safety enhancement program omits 15 one of the accident mitigation enhancements under study by 16 the NRC staff, namely, core debris control. That was one of 17 the five elements in Mr. Dannero -- Dr. Dannero's original 18 proposed severa accident policy for boiling water reactors.
19 Actually what -- the words of that draft policy 20 were that we should evaluate travel paths for core debris 21 and determine whether there was anything to do about those.
22 Subsequent in our -- industry has presented 23 information to the staff since that proposal was made and I 24 believe the current views of the staff are that core debris 25 barriers are not a topic that is currently being looked at.
Heritage Reporting Corporation (202) 628-4888
202 1 In fact my .nense of reading the discussions and the 2 presentations that the staff has made to the Commissioners 3 on the general subject is that there is more emphasis in the 4 direction we have taken in the safety enhancement program of 5 looking at making the water supply to the containment more 6 reliable as a better strategy to manage core debris.
7 MR. CARROLL Thank you.
8 DR. KERR Further questions?
9 (No response.)
10 DR. KERR Well, again I want to thank both the 11 staff and the licensee for their presentations. And that 12 will end the formal part cf the meeting having to do with 13 Boston Edison.
14 I would however like some comments from you. In 15 the first place I think we probably do need to prepare a 16 letter coramenting on this.
17 We have a number of possible options. First, my 18 understanding of'the schedule is that the procedure from 19 here invol'ces the transmittal of a regional assessment or 20 staff assessment to the regional administrator, and a 21 transmittal of a recommendation from the regional 22 administrator to NRR, Mr. Murley, I presume. Then Mr.
23 Murley makes a recommendation to the Commission.
24 My information would indicate that that 25 recommendation will not be made before October 15th, October Heritage Reporting Corporation (202) 628-4888
i l
203 3 14th or 15th. So that an ACRS letter could be delayed until 2 the next meeting if we conclude somehow that we would like 3 to have whatever new information might be developed. !
4 It rooms to me from what I have seen that, unless 5 some spectacular new information is introduced that Mr.
6 Murley's recommendation is likely to be based on what we 7 have heard today, which I interpret to be a favorable )
8 assessment of the readiness to restart. f f
9 We also, of course, have the existence of -- well, i
10 the lack of existence of an emergency plan with which to 11 deal. We can deal wJth this in a number of wayst I'll i 12 simply indicate some optione. (
13 One is to say, if we wrote a letter at this 14 meeting that we have not reviewed the emergency plan; and t
15 hence, we have no comment on it. ;
' O 16 Another option would be to say that we think that i
- 17 within the NRC there are some mechanisms for dealing with
- 18 the restart which somehow can operate within the context of I 19 the lack of an approved plan, but somehow fit within NRC l 20 regulations. I understand that one less clearly.
21 A third option would be to say that we do not !
22 think the plant should restart until it has an approved 23 emergency plan. There are perhaps other options, but at I i
24 least there are these three, i f
l 25 HR. CARROLL: Just for the sake of clarit'y, Bill, f f
i I
4 l 3
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1 204 1 I think we have understood that the onsite aspects of the 2 emergency plan have been looked at by the staff and to some O 3 extent by ourselves and there doesn't seem to be a problem 4 there.
5 What we are dealing with is the offsite emergency 6 plan, 7 DR. KERR That's important, and I do appreciate 8 that clarification.
9 At this point I would welcome any comments from 10 you in my own efforts to draft a letter. First, ignoring 11 the emergency plan question, what is your 'riew about what 12 you perceive to be the readiness of this plan to restart, if 13 you are willing to comment?
14 MR. CARROLL: I guess I'm willing to comment. I 15 was very impressed with what I saw during our site visit and 16 meeting in Plymouth and also today and I certainly would 17 endorse the restart separate from the offsite emergency 18 planning issue.
19 DR. KERR Any other comments?
20 MR. WARD: Yes. I think from what I've read and 21 what I've heard and the comment from the subcommittee it 22 certainly seems that the operational status of the plant is 23 improved. And if there are problems, there's certainly 24 problems that exist at most plants in the country. And ws 25 aren't trying to achieve -- no one is going to achieve Heritage Reporting Corporation (202) 628-4888
205 1 perfection.
2 So I don't see anything wrong with the committee 3 taking the position to endorse the restart.
4 DR. KERRt Any caveats? I mean, anything that you 5 have seen or heard that we should call attention to?
6 MR. CARROLL: I guess I am reminded of something 7 in your opening remarks, Bill, and that is that most of the l 8 senior management is heavier on nuclear Navy experience than 9 on commercial experience. I don't find that a big problem, ;
10 but I would encourage them to stay close to what is going on 11 in the industry with other plants that have different kinds 12 of backgrounds.
13 Probably a good plant for them to work closely l 14 with might be Montecello because it's a very successful l 15 plant that's got a different sort of person management.
d O 16 DR. KERR: Any other comments?
[
- 17 What about the emergency planning issue, are you 18 willing to make any comments at this point? t 19 MR. WARD: Well, let's see, I was a little puzzled l 20 by your -- I guess it was your third option which said that f
.l 21 -- let's see, of necessity there must be a viable emergency 22 plan for the plant to restart, isn't that right?
23 DR. KERR I said an approved, and I used the word 24 advisably because I believe that the approval has to come 25 from FEMA, if I understand things correctly.
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1 And currently, FEMA -- well, as I indicated FEMA
, 2 did a self-initiated review and revoked a previous interim O 3 approval of an emergency plan that had existed, if I j
4 understand the situation correctly. So that there is 5 currently not an approved plan in existence.
. 6 MR. WARD: I mean we could say that, we don't 7 think it's a good idea to restart the plant if they don't i 8 have an approved plan, but that's hind of a truism, isn't 9 it?
10 DR. KERR No. I understand that at least there I 11 is a fooling abroad, among the staff that legally at least J
12 it would be possible to start this plant without an approved
]
13 plan. And this -- again, I may be misunderstanding, it's 14 quite posrible. But the argument was that this is not a 15 licensing issue, it's a regulatory issue because the plant l 16 has been in operation, it had an approved plan.
i i 17 I must confess I'm not quite certain I understand 18 the logic, but at least there was testimony by Mr. Murley to
! 19 Mr. Kennedy's subcommittee meeting that was held in Plymouth 20 in which Mr. Murley said, legally in prinulple it would be i
21 possible to start the plant or restart the plant without an 22 approved emergency plan.
23 Chet, I'm a little at sea, obviously, in these 24 questions.
25 MR. WARD: Ca n rir . Collins clarify that?
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207 1 MR. COLLINS: Yes, sir, within the limits of the 2 NRC rules and regulations, let me address what I understand 3 the situation to be.
4 FEMA conducted a self-initiated review, and in 5 their report dated August 6, 1987 they acknowledged that 6 there were six deficiencies whica needed to be addressed.
7 To put it conversely, so it's perhaps a little easier to 8 understand. Those issues needed to be addressed in order to 9 provide for an adequate status of emergency preparedness to 10 be maintained at the site. Put that conversely, there are 11 six deficiencies. Those deficiencies, since they do exist, 12 represent an inadequate status of emergency prepare dness.
13 They aid not indicate beyond that, that they were 14 deficiencies which needed to be corrected to maintain that 15 adequate level of emergency preparedness.
16 Now by definition when FEMA comes to a ccnclusion, 17 this is the Federal Emergency Management Agency, ccmes to a 18 conclusion that there is a deficiency which bears c.n the 19 adequacy of the emergency plan, they withdraw approval of 20 that plan in entirety. It does not by definition nean that 21 the entire plan is inadequate. It means that they have 22 withdrawn approval.
23 In this case the approval that existed was an 24 interim approval. In other words, the whole emergency 25 process had not been completed, the 350 reviews, the public Heritage Reporting Corporation !
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208 1 hearings, those types. In fact there's only one State that 2 I'm aware of that that has taken place in the East Coast and 3 that's Connecticut.
1 4 So to retrack, they conducted the self-initiated 5 review based on history of issues, both with the locals and 6 with the Commonwealth. That review was done in conjunction 4
7 with the Commonwealth self-initiated review which is 8 referred to as the Barry report. FEMA concluded that there 9 is six deficiencies. Those deficiencies resulted in an 10 inadequate status of emergency preparedness, and therefore 11 they withdrew the interim approval.
12 The NRC has various tools available to deal with 13 that type of a situation. The use of those has not been 1
14 proposed yet, because the status of amergency preparedness 15 will depend on when a restart decision has to be made.
)
16 At this time the Commonwealth is preparing a 17 report which they will provide to the NRC on their 18 perception of the status of emergency preparedness as is the 19 NRC staff.
l j 20 Based on those results and a comparison, and
! 21 hopefully, a conclusion on the status of emergency 1
j 22 preparedness, the tools that are availaule are within the 23 rules, there is a 120 day clock which is referred to which 24 is used as an enforcement tool to ensure that deficiencies 25 are addressed which represent significant deficiencies in i
)
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209 1 emergency preparedness, but not significant enough to 2 preclude operation of a facility.
O 3 DR. SIESS: Are the six deficiencies that FEMA 1
4 found significant deficiencies in the sense that you just l 5 used the word?
6 MR. COLLINS: Well, I guess I would have --
7 DR. SIESS: Do you know what they are?
8 MR. COLLINS: Yes, sir.
9 DR. SIESS: Who decides whether they are 10 significant?
11 MR. COLLINS: FEMA decides if they're significant.
12 FEMA is the consultant for the NRC on the implementation of 13 emergency preparedness, the guidelines they use.
14 DR. SIESS: So far they have not told you whether 15 they are significant?
16 MR. COLLINS: No, sir. There are six deficiencies 17 which are determined to be significant enough to warrant a 18 decision of inadequacy on the basis of being able to have a 19 olan which will provide for an adequate level of emergency 20 preparedness, 21 DR. SIESS: That's back where we started and I 22 don't understand it any better now than I did before.
23 MR. COLLINS: I have provided the FEMA report to 24 the committee.
25 MR. WARD: Maybe another perspective, are these lleritage Reporting Corporation (202) 628-4888
210 1 deficiencies things that are -- that's in the control of the 2 licensee to act on or are they dependent on the other O 3 players, the local governments or whoever? '
4 MR. COLLINS: The Commonwealth is responsible for ;
5 the status of offsite emergency preparedness. However, that 2
6 effort is achieved in conjunction with the resources in the 7 efforts of Boston Edison.
8 MR. WARD: Well, specifically to fix these six 9 things who has to do something? Is there anything Boston
]
10 Edison has to do?
i 11 MR. COLLINS: Yes, sir.
l 12 MR. WARD: And they haven't done those things or
- 13 they don't see the necessity for them or they can't do it
- 14 unilaterally?
15 MR. COLLINS: I think we're dealing in various 16 periods of time. Presently the staff has acknowledged that
]
! 17 progress has been made towards resolving those issues as has I
18 the Commonwealth.
19 Mistorically I think the FEMA report itself goes 20 through a history of how those issues came to result. There 4
21 are, I think, issues which exist both within the 22 Commonwealth and issues that exist within Boston Edison's 3
23 corrective actions based on previous exercise deficiencies.
24 MR. LEWIS: Is it possible to say in a sentence
! 25 what one of these six deficiencies is, some calibration?
4 Heritage Reporting Corporation i (202) 628-4888
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211 1 MR. COLLillS : Yes, sir, I can give them to you 2 right here. They're in the summary of the FEMA report. I'm 3 on page one. FEMA identified six issues during the course 4 of the review: lack of evacuation plans for public and 5 private schools and day care centers, that's one.
6 Lack of reception center for people evacuating to 7 the north, two.
8 Three, lack of identifiable public shelters for 9 the beach population.
10 Four, inadequate planning for the evacuation of 11 special needs population.
12 Five, inadequate planning for the evacuation of 13 the transport dependent population.
14 And six, overall lack of progress in planning in 15 apparent diminution of emergency preparedness.
O 16 MR. LEWIS: Those are pretty sweeping 17 inadequacies. Mostly evacuation, though, of sheltering.
18 But of the five that are specific evacuation.
19 MR. WARD: When it says, for example, inadequate 20 shelter or something, does that mean -- I'm trying to figuie 21 out whether there's just some disagreement over the --
22 DR. KERR: Mr. Bird maybe could add something to 23 the discussion. Do you want to try, Mr. Bird?
24 MR. BIRD: We would like to. Ron Varley who is 25 the Emergency Preparedness Manager is here and he can, I Heritage Reporting Corporation (202) 628-4888
212 1 think, put some of these things in context.
2 To answer one of your early questions, does Boston 3 not agree that something needs to be done. We agree to the 4 point where we brought together the best conseltants in the 5 country, a team of about 50 people and we are spending 6 millions of dollars. We are doing everything that we can do 7 to upgrade the facilities, the plans, and the procedures.
8 We do not have the ultimate authority for review and 9 approval. But we are doing everything we can to help the 10 process along.
11 MR. LEWIS: I'm just such a slow learner.
12 MR. VARLEY: Yes, my name is Ron Varley, I'm the 13 Emergency Preparedness Manager at Pilgrim.
14 What I found when I joined Boston Edison in June ,
i 15 of 1987 was a lack of strong communication and working ,
} 16 relationships between the utility, the Commonwealth and the 17 towns.
18 We set bout correcting that problem through a j 19 number of avenues. Examples of the types of things we are r
- 20 doing in working with the communities and the Commonwealth, I
l 21 we have entered into letters of agreement with each of the 22 communities to fund on a fulltime basis for the operating 23 life of the station a civil defense staff position in each 24 of the communities that comprise our emergency planning zone 25 and the reception center communities.
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213 1 So that we got at -- the heart of one of the 2 issues is a degrading offsite emergency planning program.
3 Part of the reason the program degrades is if you don't have 4 the people there to maintain it.
5 We recognize that the communities traditionally do 6 not have the type of resources to maintain an emergency 7 planning program at the level required for nuclear 8 powerplant. So we have committed to supporting the 9 communities by providing them with the funding necessary to 10 provide someone there day to day to maintain a program once 11 it has been developed and put in place.
12 We have also entered into letters of agreement and 13 have essentially complated construction on emergency 14 operation centers in each of the communities that are 15 involved in emergency planning.
16 We have upgraded their buildings. We have 17 upgraded their communication systems. And provide them or 18 are in the process of providing them with all of the 19 necessary pieces of equipment that they need to fulfill 20 their obligations.
21 We've also been working very closely with the 22 Commonwealth and the towns in developing upgraded emergency 23 plans and emergency plan implements.ng procedures that go to 24 the heart of all of the FEMA self-initiated review issues 25 and oo well beyond them to the point where they will have a Heritage Reporting Corporation (202) 628-4888
214 1 very well integrated emergency planning program; something 2 that did not exist in the past.
7_
(_' 3 What I found when I got to Pilgrim was that the 4 offsite program was designed to rely a lot on ad hoc 5 measures. And in this day and age in the nuclear emergency 5 planning field that's not an acceptable way of doing 7 business. And we have worked very hard over the last year 8 and a half with the Commonwealth and the communities to 9 remove the reliance on ad hoc measures.
10 MR. CARROLL: But at one time, presumably, FEMA 11 accepted that as being okay to at least provide interim 12 approval; is that correct?
13 MR. VARLEY: That's true. And I think what we're 14 seeing e.s an industry as a whole is that, as the theme that
, 15 Mr. Bird has instituted at Pilgrim of rising standards of 16 excellence, I think in the industry there have also been 17 rising standards for emergency planning. And what was i 18 acceptable in 1980, 1981 and '82 has been further refined 19 through guidance memoranda that FEMA have generated over the 20 last several years that become much more specific and much
- 21 more demanding than in the past.
22 DR. KERR Did you get your question answered, Mr.
23 Lewis? Would you repeat it, if you want.
24 MR. LEWIS: I would be happy to repeat it. I'm 25 just trying to be very simplistic on any of these things Heritage Reporting Corporation (202) 628-4888
215 1 that it's possible to make it so complicated that a person 2 doesn't know what the subject is, I'm trying to avoid that.
3 On one of these six things on which FEMA has used 4 the term unsatisfactory. Pick any of them, pick the 5 evacuation of school, that was the second one or something.
6 Does the word unsatisfactory or inadequate, whichever they 7 use, does that mean that there is no plan or that they 8 regard the plan as not being formulated for all schools or 9 they find it a pretty crummy plan? What do they mean?
10 MR. COLLINSt I understand, let me try to be 11 succinct here, if I can.
12 MR. LEWIS: Sure, let's be succinct.
13 MR. COLLINS: They identify six issues.
14 MR. LEWIS: Right.
15 MR. COLLINS: One of those issues is lack of O 16 evacuation plans for public and private schools and day care 17 centers.
18 MR. LEWIS: That was the second one.
19 MR. COLLINS: Specifically there was a plan and 20 there was a procedure for schools and day care centers.
21 MR. LEWIS: And they found it inadequate?
22 MR. COLLINS: It had not been updated over the 23 period of time to include transitions in schools, new 24 schools.
25 MR, LEWIS: New schools hadn't been added to it.
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216 i 1 MR. COLLIN0: Correct. I i
2 MR, LIMIS: That's what is called inadequate.
3 MR. COLLINS Correct. That is an example. And 4 if I can have a couple more minutes here I'll try to clarify 5 it.
6 MR. LEWIS: Might I just interject. That sounds 7 to me like a defect.
- 8 MR. COLLINS
- Yes, sir. I am not meaning to give i
9 the impression that there was not a plan or not inadequate 10 plan. There were six issues -- they're called issues or 11 they're called discrepancies.
12 MR. LEWIS: Please go on.
13 MR. CARROLL: Just to follow through on this one, 14 what's happened, has that been remedied?
15 MR. VARLEY: To a large extent all of these issues O 16 have been addressed. There has been an extensive amount of 17 work put into the offsite program over the last year and a 18 half. And on this issue in particular one of the concerns 19 that FEMA had were that private schools and day care centers 20 had never been identified and wrapped into the program.
21 That issue now has been incorporated into the draft town 22 plans and procedures so that the lack of identification has 23 been resolved.
24 MR. LEWIS I don't understand how there can -- ,
25 you know, stick to one for a moment. It cannot be a matter Heritage Reporting Corporation (202) 628-4888
217 1 of extensive ef fort unless they' re --
2 DR. KERRt You can talk to him if you don't look k' 3 at him.
4 MR. LEWIS: I'm accustomed to looking at people I 5 talk to.
6 DR. KERR Borrow Dave's. ,
7 MR. LEWIS: I'll say everything twice. You know 8 what I'm asking. l 9 MR. VARLEY: And I don't think any of the issues 10 that FEMA raised were insurmountable issues. And I think >
11 FEMA summed it up succinctly in their final finding which 12 was issuo six that the program had been in the state of 13 decline, and that's a reflection of the fact that you need 14 to get in there and do a better job of maintaining the 15 program.
16 MR. LEWIS: Does decline mean your schools hadn't 17 been added.
18 MR. VARLEY: Yes, exactly.
19 MR. LEWIS: I think I understand the problem now.
20 I'm not worried about emergency --
21 DR. KERR Any other comments at this point?
22 MR. CARROLL: Would you like to say uore about how 23 some of the other ones, wnere they stand?
24 MR. VARLEY: Well, let's take another example, 25 there was the shelter issue. FEMA had a concern that there Heritage Reporting Corporation (202) 628-4888
218 1 was a lack of sheltering capability for the general public.
2 We have worked very closely with the towns to identify 3 sufficient sheltering capacity to be able to address that 4 type of concern. And as the towns are submitting their 5 upgraded draft emergency plans and procedures fcr ar 6 informal review, the NRC and FEMA are beginning to see the 7 fruits of that labor in terms of new documents that do 8 address the FEMA issues.
9 DR. SIESS: Do those areas of Massachusetts have 10 master plans for hurricanes?
11 MR. VARLEY: Yes.
12 DR. SIESS Do they keep those up to date?
13 MR. VARLEY: To the extent that the towns have the 14 type of resources to devote to that. Certainly not to the 15 level of planning that is required for a nuclear amergency 9 16 plan. I mean, that's one of t"- benefits --
17 DR. SIESS: Hurricanes happen a little more 18 frequsatly than nuclear emergencies.
19 MR. VARLEY: They certainly do.
20 DR. SIESSt I'n. wondering if they keep more up to 21 date on those because they are constantly reminded of them 22 every few years.
23 MR. VARLEY: I think ist goes back to the whole 24 premise that the program had a great reliance on ad hoc 25 response, and that's true for hurricanos in particular. The
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219 1 towns have a great deal of experience in dealing with 2 natural disasters and respond to those. But the nuclear O 3 industry looks for more formalized assurance that a response i i
4 to a nuclear incident is well prepared for. And certainly 5 the processes that we are giving the towns greatly enhance (
6 their capabilities to respond to natural disasters and they 7 recognize that and welcome that type of assistance.
8 MR. LF,WIS : I have no experience in a nuclear j 9 disaster, but I have lived through a hurricane in l I
10 Massachusetts and we did okay, enudles and Jim Beam as I !
11 recall. >
1 12 DR. KERR: Well, that's probably a good place to :
13 end the discussion. I appreciate your comments and I shall l 14 try to prepare a draft letter. I 15 Thank you again.
16 Mr. Collins, did you want to say something?
17 MR. COLLINS: I just have one clarification to be 18 sure that the panel knew that the Commission date was 19 October 14th.
20 DR, KERR The report to the Commission I 21 understand is --
12 HR. COLLINS: The Commission meeting date is the 23 14th.
24 DR. KERR The report will be made the date before i 25 probably. Thank you.
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220 1 (Whereupon, ta 4:15 p.m. the meeting was 2 adjourned.)
3 4
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1 CERTIFICATE n 2 U 3 This is to certify that the attached proceedings before the 4 United States Nuclear Regulatory Commission in the matter 5 of:
6 , Name 341st General Meeting of the ACRS 7
8 Docket Number:
Bethesda, Maryland 9 Place:
S ptember 8, 1988 10 Date:
11 were held as herein appears, and that this is the original 12 transcript thereof for the file of the United States Nuclear 13 Regulatory Commission taken stenographically by me and, 14 thereafter reduced to typewriting by me or under the 15 direction of the court reporting company, and that the 16 transcript is a true and accurate record of the foregoing 17 proceedings.
18 Is/ 6 On c a CJ/*
IRWIN L. $NNERRY 19 (Signature typed):
20 Official Reporter 21 Heritage Reporting Corporation 22 23 24 25 Heritage Reporting Corporation (202) 628-4888
1 CERTIFICATE 2
()
3 This is to certify thut the attached proceedings before the 4 United States Nuclear Regulatory Commission in the matter of:
5 Name 341ST GENERAL MEETING OF THE ACRS 6
7 Docket Nuinber: N/A 8 Flacet Bethesda, Maryland 9 Date: Septemner 8, 1988 1
- 10 were held as herein appears, and that this is the original 11 transcript thereof for the file of the United States Nuclear 12 Regulatory Commission taken stenographically by me and, 13 thereafter reduced to typewriting by me or under the direction 14 of the court reporting company, and that the transcript is a 15 true and accurate record of the foregoing proceedings ^.-
16 /S/ % W 17 (Signature typed): Joan Rose i
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18 Official Reporter !
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REPORT TO THE ADVISORY COMMITTEE Oil REACTOR SAFEGUARDS ON NOTICE OF PROPOSED RULEMAKlflG FOR MAlflTENANCE OF NUCLEAR POWER PLANTS SEPTEMBER 8, 1988 O
MON! DEY ADVANCED REACTORS S GENERIC ISSUES BRANCH DIYlSION OF REGULATORY APPLICATIONS OFFICE OF NUCLEAR REGULATORY RESEARCH j
OUTLINE OF ERIEFING Ov SCHEDULE CoticLUSI0 tis Af4D rec 0MMEtiDATIONS PURPOSE OF RULE FRAMEWORK OF RULE ColdTElils OF NPR ATTRIBUTES OF lhDUSTRY STANDARD i
I O- RECCt01Et:DAT10 tis FOR lt4DUSTRY STANDARD COMMEi4Ts SoliclTED
SUMMARY
OF REGULATORY At4ALYSIS l
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SCHEDUI.E FOR NPR l
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F!!iAL MEETING WITH ACRS ON SEPTEMBER 8, 1988. ACRS LETTER REQUESTED MEETlhG WITH CRGR ON SEPTEMBER 114, 1988 NPR DUE TO COMMISSION ON OCTOBER 3, 1988 i
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- 1 11/I/55 . lii/Ei . . 4/1 . 6/I ofl 9/1 11/1 1/Lisa . . </1 . . 1/1/i1 t ii,~ s i RULE IT >A A A A
?J R Public Final Pule Schedule for full Ir01.
Comt to Comission Ts11 17 1. Due terio6 REG. GUIDE L A 3 L Approach Li Guidance on What R.G. to Pubite Pgblish w/ KPR Package Ccestitutes an Endorse Cemnent R.G.
Acce, table 514. Ind. 5td. Period
=/ftnal pule or Provide Specific lNDUSTRY U"'d'"
Issue for STANDIRD Co ent h
Organize hk A A Coments f rcS Craft hPC Final Working NLC c6 Interim Standard Ct e nts Stand /rd Groups Crafts of St mcard e
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STAFF CONCl.USIONS AND RECOMMENDATIONS O
PRESCRIPTIVE RUI.EMAKING OPTIONS HAVE M!tllMUM FLEX 1BILITY AND MAY IMPEDE ltIDUSTRY INITIATIVES TO IMPROVE Malt 4TENANCE RULEMAKING SHOULD ENCOUCAGE RATHER 1HAN DIVERT CR H!NDER lilDUSTRY IfilTIATIVES DIRECTED TOWARD IMPROVING MAlf4TENANCE STAFF, THEREFORE, RECOMMENDS A RULE WHICH GIVES INCENTIVE FOR INDUSTRY TO DEVELOP A STAtiDARD FOR A MAINTEf1ANCE PROGRAM, WHICH NRC COULD ENDORSE IN A REGULATORY GUIDE I THE INDUSTRY STAhDARD SHOULD INCLUDE PROVIS!0 tis l FOR PERFORMANCE ASSESSMENT AND FEEDBACK OF RESULTS I
TO IMPROVE PROGRAM THE STAFF EXPECTS THE lhDUSTRY STAhDARD TO BE l
CCMPARABLE IN SCOPE AtiD DEPTH TO THE INP0 MAINTENAhCE GUIDEL!4LS i
O 4
I EALRP_0SE OF RULE O- IO IMPROVE LICENSEE MAINTENAf4CE PROGRAMS, WHERE WARRANTED, AND MAltiTAIN A SATISFACTORY LEVEL OF PERFORMAf4Cd:
i NUT BASED ON AN EXACT MEASURE OR THRESHOLD OF Malt 4TENANCE EFFECTIVENESJ. MAINTEf4 alice IS TOO BROAD AND TOO !!4TERRELATED WITH OTHER ASPECTS OF A PLAT 4T TO MEASURE QUANTITATIVELY OR EXACTLY 4
SETS A CCMPREHENSIVE STAl4DARD WHICH REFLECTS THOSE
/sTTRIBUTES OF A GOOD MAltiTENANCE PRC'"DAM DETERMINED BY PREVICUS EXPERIENCE AND JUDGEMEllT TO CONTRIBUTE TO AN EFFECTIVE MAINTENANCE PROGRAM !
i IS If4 TENDED TO ENSURE LICEtiSEES INCLUDE IN THEIR l MAlf4TENANCE PROGRAMS THOSE ATTRIBUTES IDENT!FIED IN THE POLICY STATEMElli l
1 l
- OVALITATIVE JUCGEMENT, BASED UPON lhSPECT10ft At4D ,
AUDIT OF LICENSEE'S MAINTENAliCE PROGRAM, USED AS THE (
f MEASURE OF ACCEPTABILITY NOT DIRECTFD SOLELY TOWARD TODAY'S POOR PERFORMERS.
PERFORMANCE CHANGES OVER T!ME AND RULE WILL HELP (
ENSURE CONSISTENT PERFORMANCE i
GIVES NRC A STRONGER BASIS TO REQUIRE UFGRADES IN O
LlCENSEE MAINTEriANCE PROGRAM $
t 5
FRAMEWORK 0F RECOMMENDED APPROACH TO MAINTENANCE RULE O
L)
FORM AhD CONTENT OF RULE:
GEtiERAL RULE REQUIRING EACH LICEf4SE TO HAVE Af4D IMPLEMEf4T A DOCUMENTED Malt 4TENAtiCE PROGRAM WHICH lhCLUDES PROVIS10ti FOR THE LICENSEE TO MONITOR ITS EFFECTIVEhESS Af4D MAKE IMPROVEM!!iTS WHERE WARRAfiTED GENERAL RULE WOULD REQUIRE Malt 4TEtlANCE PROGRAM TO lt4CLUDE THE SCOPE AND ACTIVITIES Ifi POLICY STATEMEt4T EACH LICENSEE WOULD BE RECUIRED TO HAVE HIS OWil M0tilTORING SYSTEM WFICH WOULD BE SUBJECT TO NRC REVIEW STAFF DOES f40T RECOMMEND REPORTitiG OF MPIS TO NRC AT THIS TIME COMPLIANCE VERIFIED BY NRC AUDIT AND liiSPECTION 1
l l
l O
1 .
f3 POSER BULE - REQUIREMENTS TO ENSURE THE EFFECTIVENESS OF MAINTENANCE O eR0 GRAMS FOR nuCtEAR e0weR eLANTS t
l REQUIREMENTS: EACH HOLDER OF OR EACH APPLICANT FOR A LICENSE TO TO OPERATE A NUCLEAR POWER PLANT SHALL (1) ESTABLISH, IMPLEMEf4T AND MAINTAlf4 AN EFFECTIVE Af4D DOCUMEf4TED MAINTENANCE PROGRAM, AND j (2) ASSESS THE EFFECTIVENESS OF THIS MA!NTENANCE PROGRAM AND, BASED UPON THIS ASSESSMENT, IMPROVE MAINTENANCE, WHERE APPROPRIATE.
IMPLEMENTATION: BY (INSERT A DATE 2 YEARS AFTER THE EFFECTIVE DATE OF THE AMEtiDMENTI EACH LICENSEE SHALL CERTIFY, BY LETTER TO THE DIRECTOR OF THE OFFICE OF NUCLEAR REACTOR REGULATION, THAT A COMPREHENSIVE DOCUMENTED MAINTENANCE PROGRAM IS BEING MAINTAINED AhD IMPLEMEt4TED, WHICH ADDRESSES ALL ELEMENTS OF A MAlliTENANCE PROGRAM AS DEFINED IN SECTich (B) 0F THIS AMENDMENT INCLUDING MEASURES TO MONITOR AND IMPROVE THE PROGRAM, WHERE APPROPRIATE.
IN ADDIT!Ofi, EACH LICEfiSEE SHALL SUBMIT BY (!hSERT A DATE 3 MONTHS AFTER THE EFFECTIVE DATE OF THE AMENDMENTl A TIMELY AND EXPEDITIOUS PLAN AND SCHEDULE (INCLUDlhG KEY MILESTONES) TO THE DIRECTOR OF THE OFFICE OF NUCLEAR REACTOR REGULATI0fl FOR MEETING t i
l THE REQUIREMENTS OF THIS AMENDMENT.
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ATTRIBUTES OF AN ACCEPTABLE lhDUSTRY STANDAFD (n
(_)
- SHOULD DEFlf4E THE SCOPE OF PLANT SYSTEMS, STRUCTURES Af4D COMP 0f4ENTS IfiCLUDED IN THE. MAlf4TEfiAf>.CE PROGRf M. IS If4TEilDED TO COVER 00P SYSTEMS, STRUCTURES AND COMP 0f4Ef4TS, WHERE FAILURE OF THESE COULD IMPACT PUBLIC HELATH AND SAFETY.
SHOULD PROVIDE CLEAR Al4D SPECIFIC PROGRAMMATIC RE0VIREMLf4TS THAT CAN BE PRACTICALLY IMPLEMENTED TO ACHIEVE HIGH RELIABILITY; SHOULD BE COMPREHENSIVE Ii ADDRESS! fig THE ACTIVIT!ES Afir FUNCT10!45 If4CLUDED lll THE PROPOSED RULE (THOSE IN THE MAlf4TENANCE POLICY STATEMEf4T PLUS PROVISIONS FOR SELF ASSESSMENT))
()
- SHOULD REFEREliCE STAf4DARES C1 GUIDELINES SUCH AS THOSE DEVELOPED BY ANS, ASME, IEEE, ASTM, INPO, OR EPRI WHERE PRACTICAL TO PROVIDE PROV!DE (A) SPECIFIC PROGRAMMATIC RECulREMENTS OR (B) GUIDANCE FOR MAINTENAfiCE OF SPECIFIC TYPES AF EQUIPMEtiTJ SHCULD If4CLUCE PROVISIONS TO ALLOW FLEXIBILITY FCR ADOPTION OF t'EW lhl40VATIVE TECHNOLOGIES AS THEY ARE VAllDATEDI AfiD l
SHOULD PROVIDE FOR SUFFICIENT DOCUMENTATION SO THAT PROGRAM EFFECTIVENESS Af4D CCMPLI ANCE WITH REQUIREMENTS OF THE STAf4DARD CAN BE EVALUATED.
)
i
BESpMf_NDATIONO FOR ITEMS TO BE CONSIDERED IN INDUSTRY STANDARD AS A RESULT OF REVIEW _OF MAINTENAt1CE
() APPROACHES __AND PRACTICES IN OTHER COUNTRIES AtlD liiDUSTRIES
!) SHOULD REQUIRC A SYSTEMAT!C EVALUATION ("SYSTEMS APPROACH")
0F THE FUNCT10f4S AND OBJECTIVES OF PLANT SYSTEMS, COMP 0f4ENTS AND STRUCTURES TO DETERMINE MAltiTENAtiCE ACTIVITIES AhD REQUIREMEf4TSI
!!) FOCUS Ch LokG TERM MAINTEt4ANCE OBJECT!VESI ESTABLISH A PROACTIVE MAltiTENANCE PROGRAM AS OPPOSED TO REACTIVE MAlliTEtlAfiCE, INCLUDING A RELIABILITY CENTEFED APPROACHI
!!!) PROVIDE GU' DANCE ON HOW TO SELECT APPROPRIATE PARAMETERC FOR M0N1'10 RING THE EFFECTIVEt4ESS OF A MAltiTENANCE PROGRAh!
IV) INCLUDE MAltiTENAt4CE TECHil!CIAtt TRAINING / CERTIFICATION PRCGRAMS) v) PRCYlDE GUIDANCE ON PLAtitilliG, SCHEDULIN. AND USE OF OVERTIME TO REDUCE ERRORS DUE TO FATIGUEl v!) RECU!RE EtiGINEERING SUPPORT Iti EVALUAT10ti 0F FAILURE DATA)
Vll) ADDRESS ENVIRONMEt4T/MOTIVAT!Ott OF MAINTENANCE TECHtilCIAtiS (E.G.
Et<HAhCED THRU CROSS-TRAltilf4G, "CREW CHIEF" C0tiCEPT);
VI!!) DEFINE THE INTERFACE BETWEEtt MAltiTEt4ANCE AND OTHER ACTIVITIES (Ef4GlidEERit4G SUPPORT, OPERATIOf4S. CA, CC, CORPORATE OFFICES, SAFETY REVIEW); AND lx) REQUIRE !!iCORPORATION OF APPROPRIATE MAINTENAt4CE DERIVED FROM PLAfiT AGlhG STUDIES.
O 9
e COMMENTS REQUESTED FROM PuetIc ,
i IN ADDIT 10ft TO COMMENTS ON THE CONTEllT OF THE PROPOSED RULEMAXING, THE SPECIFIC INPUT ON THE FOLLOWING QUESTIONS IS REQUESTED: t
- 1) WILL INDUSTRY COMMIT TO THE DEVELOPMENT OF A l 11AINTENANCE STANDARD 7 l
l
- 2) WHAT LEVEL OF DETAIL SHOULD i i l'lCLUDED IN THE INDUSTRY /flRC {
STANDARD 7 l
- 3) IS Two YEARS A REASONABLE TIME TG DEVELOP Af4D IMPLEMENT AN If4DUSTRY STANDARD?
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d 4
SUMMARY
OF REGULATORY ANALYSIS' 4
(2)
- THE' ECONOMIC IMPACT OF THE PROPOSED REQUIREMENT ON LICENSEES
, SHOULD BE NEGLIGIBLE.
j INITIAL FINANCIAL INVESTMENTS WILL BE REQUIRED BY SOME LICENSEES TO ESTABLISH A SYSTEMATIC AND COMPREHENSIVE MAINTENANCE PROGRAM THE SAVINGS DUE TO DECREASED CORRECTIVE MAINTENANCE i
COSTS AND INCREASED PLANT AVAILABILITY SHOULD OUTWEIGH
- THE INVESTMENT COSTS.
I l (:)
i
NUREG-1212 m Vol.1 O
i Status of Maintenance in the ,
U. S. Nuclear Power Industry 1985 Volume 1: Findings and Conclusions
.S. Nuclear Regulatory ommission Office of Nuclear Reactor Regulation O
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% APPENDIX B CURRENT NRC REGULATION OF MAINTENANCE IN COMMERCIAL NUCLEAR POWER PLANTS 1.0 THE CODE OF FEDERAL REGULATIONS AND THE REGULATION OF MAINTENANCE IN COMMERCIAL NUCLEAR POWER PLANTS 1.1 Introduction The Atomic Energy Act, Energy Reorganization Act, and Title 10 of the Code of Federal Regulations, predominantly Part 50 (10 CFR 50), establish the le basis for the NRC's regulation of commercial nuclear power plants (NPPs) gal When a utility applies to the NRC for a construction permit (CP), 10 CFR 50 is the major legally binding document to which they must conform. However, variousotherNRCdocuments(Regulato{yGuides,NUREGs,etc.)andindustry standards, e.g., ANSI /ANS, IEEE, ASME , become binding as a result of their incorporation in the CP application (and amendments thereto), Final Safety ,
Analysis Report, and subsequent incorporation into the provisions of the operating license. 10 CFR 50 is the basic regulatory structure upon which the licensing process is built. Weakness in this structure affect the overall regulatory framework governing operation of licensed nuclear power plants.
An examination of 10 CFR 50 shows that it contains no major reference to maintenance. Maintenance is only mentioned once in the body of 10 CFR 50:
Contents of applications; technical information, parag aph (b)(6)(iv),
which refers to the Final Safety Analysis Report (FSAR), states that the applicant shall include "plans for conduct of normal operations, including maintenance, surveillance and periodic testing of structures ,
systems, and components" (10 CFR 50.34).
1.2 FAA Regulation of Maintenance In contrast, in the Code of Federal Regulations, Aeronautics and Space, Parts 1-199, dealing with the Federal Aviation Administration (FAA) regulations, maintenance occupies the entirety of Part 43 of Title 14, which consists of 17 sections and 5 appendices. A recent FAA fine of $9.5 million against a major airline for maintenance violations also shows the seriousness with which the enforcement of maintenance regulations is taken. The I
ANSI /ANS - American National Standards Institute /American Nuclear Society .
IEEE - Institute of Electrical and Electronic Engineers t ASME - American Society of Mechanical Engineers O B-1
[')commercialaviationindustrymaintenanceprogramrequirementsbegantoevolve after WW !! with reliability measurement as a criterion for an air carrier to gain relief from restrictive FAA overhaul requircments. The collection of data by the airlines subsequently led to the more precise specification of goals and objectives for aircraft reliability. Focus on preventive maintenance became a major element of the FAA approach to safety to ensure continued in-service reliability. The aviation industry's prescriptions for ;
maintenance activities were developed and promulgated by industry groups
- which produced maintenance manuals and maintenance p ograms. An industry steering group authored a policy and procedures handbook which became the e basis for FAA guidance in development of preventive maintenance programs for all certified transport aircraft. The basis for FAA regulation of maintenance evolved from designating prescriptive overhaul intervals to the current use of reliability methods and condition mcnitoring as the basis for ;
maintenance program development. A good summary of the evolution of the FAA ,
regulations can be found in EPRI report NP-3364, Commercial Aviation Experience of Value to the Nuclear Industry, January 1984.
The FAA has authority for the initial preventive maintenance program for each newly certified aircraft. The NRC does not specifically approve maintenance programs as part of facility licensing. Utility FSARs do not include a full maintenance program description. NRC instead discusses maintenance, surveillance, and testing of structures, systems, and components in accordance with component specifications and Technical Specifications.
In the aviation industry, maintenance requirements for critical items differ (e.g., required independent inspection of work) from maintenance for other aircraft components. NRC requirements for activities affecting systems J "important to safety" also differ from other activities, although maintenance requirements in either case are very general.
Effective preventive maintenance programs in the air transport industry ,
ensure operational reliability of aircraft and have been emphasized because of the direct relationship to economics as well as safety (EPRI NP-3354). .
While a utility's maintenance and surveillance activities for structures, systems, and components are required to be described in the Final Safety Analysis Report (FSAR) by 10 CFR 50.34, the NRC does not require a preventive maintenance program and does not prescribe requirements for specific maintenance program functions. In fact, no formal integrated maintenance program review and approval is conducted by the NRC for licensing.
The airline industry has an active reliability control program which relies on extensive collection, evaluation, and use of reliability and maintenance event data. Each airline is able to develop and operate a program to meet its individual needs and is monitored by the FAA. In contrast, comercial nuclear power plants may or may not develop and use reliability data, and no approval or control of maintenance related data is performed by the NRC. A voluntarv industry data reporting system exists (NPROS) but is not used by the NRC to determine maintenance needs. The NPRD system has now improved to the point where it may warrant further use by the NRC as a source of reliability data to meet agency needs (AE0D Annual Report, April 1986).
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1.3 NRC Regulation of NPP Maintenance The subject of NPP maintenance is not treated programmatically in NRC regulations nor is it defined nor described as it is in the airline industry.
O General performance objectives for maintenance are not provided. Clearly, equipment experience history data plays a major role in reliability and maintenance in the aviation industry. The central feature of maintenance program development, that is, information collection and feedback, is not well developed among the nuclear utilities. The aviation industry emphasizes use of reliability data starting with the design phase, following through to aircraft operation and continual monitoring by the FAA. The nucicar industry has evolved without the extensive use of reliability data as the basis of regulation of design and operating activities. Additional observations which can be made regarding the lack of NRC focus on NPP maintenance are as follows:
- Maintenance is not mentioned in requirements for the contents of the Preliminary Safety Analysis Report (PSAR).
- No mention is made of maintenance in the regulations on construction ;
permits.
- No mention is made of maintenance in regulations concerning technical ,
specifications (although "surveillance requirements" as one of the categories required to be covered in technical specifications is defined in the Code as preventive measures).
- In-service inspection requirements are covered under 10 CFR 50.55a, Codes and Standards, but no attempt is made to connect this constituent O
of preventive maintenance to the concept of a maintenance program.
No mention is made of maintenance in 10 CFR 50, Appenoix A, General Design Criteria, although maintaining system reliability within design limits is the purpos~b of maintenance. Inspection and Testing are -
' mentioned, but not as part of a comprehensive maintenance program. .
- The 1985 Commission Policy Statement on Training and Qualification I endorses the Institute of Nuclear Power Operations (INP0) accreditation of industry training programs, including training for electrical, mechanical, and 1&C technicians. The Policy Statement endorses the essential elements of perfonnance-based training but does not contain prescriptive guidance.
j 1.4 Conclusion in conclusion, NRC regulations do not provide a basis for a coherent approach to regulating NPP maintenance, and this is also clearly reflected in the way maintenance is treated in ancillary guidance (Regulatory Guides, NUREGs, etc.) promulgated by the NRC.
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2.0 NRC GUIDANCE ON MAINTENANCE OF COMMERCIAL NUCLEAR POWER PLANTS 2.1 Introduction .
This section describes guidance promulgated by the NRC staff to assist the applicants and licensees in interpreting and complying with 10 CFR 50. Such guidarce is not binding unless incorporated into the provisions of the ooerating license as previously discussed. It also describes the guidance on methods acceptable to the NRC staff for implementing maintenance regulations through "Regulatory Guides" whic,h endorse standards developed by professional sociaties, such as ANS, IEEE, and ASME. l 2.2 Guidance on Maintenance to Applicants Preparing Preliminary (PSAR) and Final Safety Analysis Reports (FSAR) 1 Basic guidance on the required contents of the PSAR and FSAR is contained in 10 CFR 50. However, applicants take their cues on what to include in these reports from the Standard Format and Content of Safety Analysis Reports for Nuclear Power Plants (Regulatory Guide 1.70) and '.he Standard Review Plan (SRP) (NUREG-0800, Rev. 0-4, July 1981). {,
None of the chapters in the SRP deal directly with maintenance. Chapters 13 l and 17 cont 61n the few references to maintenance in the SRP:
Section 13.1.1. This section states that a description of responsibilities for various areas should be included in a SAR review and the "development of plant maintenance programs" is one of the 11 areas mentioned. Nowhere is a description of the actual maintenance program required. This paragraph also states the FSAR should provide "educational and background experience" for
$aciveiao metateaeace O certaia cetesories or meaesemeat' supervisors Persoaae1 support.
Sections 13.1.2 - 13.1.3. These sections state that the applicant should "describe the structure, !vnctions, and responsibilities of the organization establir.hed to operate and mof ntain the plant." It goes on to state that -
education, training, and experience should be described for "management.
operating, technical, and maintenance positions."
This section of the SRP addresses "Training for Nonlicensed f Section 13.2.2.
Plant Statf." Maintenance is not addressed directly in this section; but '
Regulatory Guide 1.8 and ANS!/ANS-3.1 are referenced under acceptance criteria and these documents do address maintenance personnel, i i
Section 13.5.2. This section on "Operating and Maintenance Procedures" states that the PSAR should describe "preliminary schedules" for the preparation of operating and maintenance procedures and that the FSAR should provide descriptions "as to the nature and content of procedures," including
- instrument calibration / test, and maintenance and modification procedures.
l This section of Chapter 13 contains the only acceptance criteria that i specifically address maintenance. The first, 13.5.2-IIA, requires a "generally acceptable" target date for the completion of operating and ,
f maintenance procedures. The second, 13.5.1-!!C, references staff positions
! in Regulatory Guide 1.33 and ANS!/ANS-3.2.
B-4 4
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l Chapter 17. This chapter of the SRP deals with the ways that the applicable ,
requirements of Appendix B of 10 CFR 50 are satisfied, focusing only '
peripherally on the issue of maintenance. The most relevant reference is p found in SRP 17.1, dealing with acceptance criteria for "activities related V to corrective action" during design and construction. This section states that such activities are acceptable if.
- 1. Procedures are established and described indicating an effective correc'tive action program has been established. The QA organization reviews and documents concurrence with the procedures.
- 2. Corrective action is documented and initiated following the determination of a condition adverse to quality (such as a nonconformance, failure, malfunction, deficiency, deviation, and '
defective material and equipment) to preclude recurrence. The QA organization is involved in the documented concurrence of the adequacy of the corrective action.
- 3. Follow-up action is taken by the QA organization to verify proper implementation of corrective action and to close out the corrective action in a timely manner.
- 4. Significant conditions adverse to quality, the cause of the conditions, and the corrective action taken to preclude repetition are documented and reported to imediate management and upper levels i of management for review and assessment.
Conclusion. Only isolated references to maintenance are scattered throughout Chapters 13 and 17 of the SRP. Also, no definition is provided for corrective, preventive, or predictive maintenance. Furthermore, acceptance i O criteria in the SRP are grossly incomplete for judging the adequacy of a NPP's maintenance program.
Finally, a review of FSARs for near-term operating licenses (NT0Ls) reveals .
that these documents contain only minimal reference to maintenance and, as
- currently constituted, do not provide the NRC staff with information necessary to judge the adequacy of plant maintenance programs.
2.3 Guidance on Methods Acceptable to the NRC Staff for Implementing
! hintenance Regulations: Regulatory Guides Regulatory Guides (RGs) are not legally binding on utilities seeking licenses for commercial reactor operation unless they are incorporated in the utility's operating license application and that application is accepted by NRC. Regulatory Guides 1.33 and 1.8, which describe quality assurance and i personnel qualifications respectively, contain the most complete treatment of maintenance program requirements. They are reviewed in the next two sections of this report.
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1 Regulatory Guide 1.33, Quality Assurance Program Requirements. Criterion 1, Appendix A, 10 CFR 50, concerning General Design Criteria (GDC), requires that a quality assurance (QA) program be established and implemented in order to provide adequate assurance that NPP structures, systems, and components will satisfactorily perform their safety functions. Appendix B of 10 CFR 50 establishes QA requirements for the design, construction, and operation of ,
those structures, systems, and components that prevent or mitigate the ,
consequences of postulated accidents that could cause undue risk to the j health and safety of the public. Regulatory Guide 1.33 has been promulgated to describe acceptable methods for complying with the provisions of these appendices of the Code for the operational phase of NPPs.
The most recent official issue of Regulatory Guih 1.33 is dated February 1978 and endorses ANSI N18.7-1976/ANS-3.2, Administrative Controls and n Quality Assurance for the Operatioral Phase of Nuclear Power Plants. This ,
standard has since been tpoated and reissued as ANSI /ANS-3.2-1982. ;
Regulatory Guide 1.33 is also undergoing revision and several draft versions .
have been issued. The current proposed revision to RG 1.33 endorses '
ANSI /ANS-3.2-1982. I r ANSI /ANS-3.2-1982 has appended a list of "typical procedures" for pressurized l' water reactors (PWRs) and boiling water reactors (BWRs). This list was taken from the February 1978 issue of Regulatory Guide 1.33. Section A6 of the Appendix deals with maintenance procedures and A8 deals with calibration and ;'
test procedures. These, and an updated list of references, constitute the only substantive maintenance-related differences between ANSI /ANS-3.2-1982 '
and the NRC-endorsed ANSI N18.7-1976/ANS-3.2. ANSI /ANS-3.2-1982 contains one of the few treatments of NPP maintenance thus far considered for NRC O encorsement. Perhaps the most important reference to maintenance is contained in paragraph 5.2.7.1, "Maintenance Programs," which states:
A maintenance program shall be developed to maintain structures, '; ",
systems, and components important to safety at the quality required for '
them to perform their intended functions. ,
The paragraph also requires maintenance planning and scheduling, the development of maintenance procedures, malfunction evaluation and documentation, equipment deficiency reporting, and preventive maintenance (PM) of safety-related equipment and systems. Regarding the latter, the standard states: ,
l A preventive maintenance program including procedures as appropriate for '
structures, systems, and components important to safety shall be ,
established and maintained which prescribes the frequency and types of c maintenance to be performed.
. The standard further states that a preliminary preventive maintenance program should be developed before fuel loading begins. Paragraph 5.3.5, "Maintenance Procedures," describes the general content categories for i maintenance procedures, which include: 1) preparation for maintenance,
- 2) performance of maintenance, 3) post-maintenance check-out and return to ,
service, and 4) supporting maintenance documents. Policy on the use of B-6 i
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o maintenance procedures is addressea in paragraph 5.2.7, which states that written procedures and instructions will be available for maintenance or O modification of equipment "appropriate to the circumstances." Section 5.2.7 also states that skills normally possessed by qualified main'.enance personnel may not require detailed step-by-step written procedures.
Summary. ANSI /ANS-3.2-1982 provides the only compsndium of NPP maintenance requirements in the regulatory literature. 1he Regulatory Guide does not contain meisurable criteria by which to assess the adequacy of a maintenance program. Finally, the outdated version of Regulatory Guide 1.33 and the many subsequent versions of published ANSI QA standards adopted by the licensees create an inconsistent basis for regulation of operating reactors.
Regulatory Guide 1.8, Personnel Qualification and Training. Regulatory Guide 1.8 September 1975, reissued May 1977 endorsing ANSI N18.1-1971 prescribes that maintenance repainnen in NPPs have 3 years of experience in one or more crafts and a "high degree" of manual dexterity and ability, plus the "capability to learn." Technicians are required to have 2 years' working experience in their specialty and 1 year of related training. No specific training or requalification requirements were given for technicians or maintenance repairmen. ANSI /ANS has reissued the standard on Selection, Qualification, and Training for Personnel for Nuclear Power Plants - the i latest published version being ANSI /ANS-3.1-1981.
The 1961 version of ANSI /ANS-3.1 expands on the training requirements of the j pievious version of this standard:
) A training program shall be provided for job functions that could affect I the quality of structures, systems, and components important to safety.
l The program shall include applicable administrative controls, special i complex system and component instruction, and demonstrated performance J capability. The special training above the journeyman level of
! technician and maintenance personnel shall be based on a task analysis -
! of the individual's assigned functions (par. 5.3.4). .
The 1981 version of ANSI /ANS-3.1 is a more comprehensive and detailed l
j treatment of maintenance, training than are previous versions. Proposed
- Regulatory Guide 1.8, Revision 2, scheduled for publication in 1986, endorses i
ANSI /ANS-3.1-1981. Operating reactors and applicants currently subscribe to one of three different versions of the industry standard, resulting in less than consistent industry maintenance training requirements.
! Sununa ry. Current NRC guidance on training of maintenance personnel is in a l state of transition. Regulatory documents are outdated and endorse outdated standards. Industry maintenance training programs are in a state of change while accreditation is being implemented.
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e 3.0 IAE INSPECTION PROCEDURES ADDRESSING MAINTENANCE OF COMMERCIAL NUCLEAR POWER PLANTS A useful regulatory systens requires a feedback loop to assess regulatory compliance, the efficacy of regulatory initiatives, and the need for additional guidance or modifications to current guidance. The I&E arm of the
. NRC is the primary means for providing this feedback. I&E inspection procedures (IP) for hPP maintenance are contained primarily in I&E Manual j i Chapters 62700-62703. The IPs covering maintenance activities adhere t:
primarily to the quality assurance standard, ANSI N18.7-1976, that is current'y endorsed by the NRC. The IE Manual contains several IPs that e dddress the maintenance area. IP 62700 is a performance-based procedure that ;
requires the inspector to assess the licensee's implementation of the !
maintenance program. IP 62703 requires the performance of a monthly jj observation of maintenance on selected safety systems to ensure, on an i ,
on-going basis, that the licensee is adhering to his maintenance program. ' !
IPs 62704 and 62705 (18C and Electrical Maiatenance, respectively) require i i thorough observation of maintenance activities in each of these discipline !
j areas from a technical perspective, as well as a review of documentation [
l associated with the maintenance activities observed, t l
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l-REGULATORY ANALYSIS FOR RESOLUTION OF GENERIC ISSUE-99 "LOSS OF RHR CAPABILITY Ill PWRs" 2
PRESENTED TO THE O ACRS Futt Su8CorniTTEe SEPTEMBER 8, 19"';
i ALFRED SPANO, SENIOR TASK MAllAGER Divis10N OF SAFETY ISSUE RESOLUT!Oli 0FFICE OF fiUCLEAR REGULATORY RESEARCH O
?
O REGULATORY Ai;ALYSIS OF GEllERIC ISSUE-99 "LOSS OF RHR CAPABIL!TY tr PWRs" OVERVIEW 3ACKGROUtiD PRA FiliDillG3 RESOLUT!0il APPROACH PROPOSED REQUIREMEllTS C S8'EFIT RESULTS O
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DACKGROUND PROBLEM: FREQUEllT OCCURREllCES OF RHR SYSTEM FAILURES ,
i IN PWRS DUE TO:
j - AIR B!f1D!llG OF RHR PUMPS DUR!flG MID-LOOP OPERAT!0flS DUE TO EXCESSIVE LOWER!flG OF IIATER LEVEL IN RCS i
- LOSS OF RHR PUMP SUCT!0ft DUE TO AUTOCLO5URE INTERLOCK-RELATED SPURIOUS CLOSURE OF SUCT!0fl VALVES BOTH ARE COMMON CAUSE FAILURE MODES l
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RISK SIGi11FICAf1CE OF MID-LOOP LOSSES OF DHR REDUCED IllVEf4 TORY ALLOWS LESS TIME FOR RECOVERY PRIOR TO Boll!i1G/ CORE Uf4C0VERY.
RECOVER" 0F AIR-BOUl1D RHR PUMPS MAY BE DIFFICULT.
CDF 0F 3E-5/RY DUE TO MID-LOOP LOSSES OF DHR IS HIGH.
RCS Af1D C0llTAlf1MEf4T ARE TYPICALL/ OPEli DURIflG MID-LOOP OPERATI0llS.
O
4
(_/
PRA FillDINGS PRA STUDY (NUREG/CR-5015) BASED Oft ZI0li PLAllT MODEL MODIFIED FROM NSAC-84, WITH GEllERIC DATA Oft LOSSES OF RHR AllD GEf1ERIC COMPONENT FAILURE RATES CORE DAMAGE FREQUErlCY Ifl!TIATOR BASE CASE (N0 FIXES) _5 LOSS OF COOLING 4.3 E-5/RY* 82 O LOCA 0.4 E-5/RY 8 LOSP 0.5 E-5/RY 10 TOTAL = 5.2 E-5/RY 4
i "ABOUT 80% 10 DUE 70 MID-LOOP LOSSES, 8% DUE TO IllADVERTEllT SUCT!0ft VALVE CLOSURES, WITH RES!CUAL OF 127. DUE TO COMPONEllT FAILURES AllD MAlflTEllANCE UtlAVAILABILITIES.
4 O
() PRA UflCERTAltlTIES ,
PLANT-SPECIFIC EXPERIEllCE RELATED TO RHR SYSTEM LOSSES VARIES WIDELY !!! REGARD TO:
- AffilUAL TIME SPEllT ON RHR OPERATION
- NUMBER OF RHRS LOSS EVEtiTS
- CORRECTIVE MEASURES TAKEN BY PLANTS TO IMPROVE PREVENTION /MITIGAT!0fl 0F RHRS LOSSES O - SCHEDUL!flG OF PLANT SHUTDOWN REFUELING /f1AlflTENAllCE OPERATI0llS
- CONDUCT OF SHUTDOWil OPERATIUffs Old AVAILABILITY OF i
i PLANT SAFETY 8 SUPPORT SYSTEM ECUIPMEfiT FOR RESPONDING TO LOSSES OF RHR CAPABILITY
' HUMAf1 ERROR PROBABILITIES, REFLECT!!iG sells!TIVITY OF RECOVERY TO OPERATOR ACTIONS (E.G., COGfl!TIVE ERROR MODEL!flG)
O l
PRA UflCERTAlflTIES (CollT'D)
[
COST /BEllEFIT RESULTS REFLECT SOME TACIT C0flSERVATISMS, E.G.:
- IllCOMPLETE PRA MODEL!flG OF SPECTRUM OF RECOVERY ACTIONS POTEllTIALLY AVAILABLE TO OPERATOR;
- ASSUMPTION THAT CORE UtlC0VERY IS TANTAMOUllT TO CORE DAMAGE ;
CDF RESULTS TEND TO BE fl0ft-CONSERVATIVE Ill THAT AtlALYSIS OF
{
LOSS-OF-DHR ACCIDEliT SCENARIO DID fl0T INCLUDE CERTAlfi POSSIBLE O RAPID CORE-UllC0VERY SEQUEliCES (E G. , PRESSURIZATIOff LEAD!flG TO LOSS OF IflVErlTORY FROM COLD LEG VEllT LOCA-IflDUCED RHR LOSS DUR!flG MID-LOOP OPERAT!0flS)
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l b'N RESOLUTI0f1 APPROACH i
FOR DEFEllSE-Ill-DEPTH, IMPROVEf1EllT IS 11EEDED lli KEY PLAlli PROCEDURAL /IllSTRUMEl4TAL CAPABILITIES AIMED AT' I
i-PREVEllTitiG LOSSES OF RHR !
i t
PREVEllT!!JG CORE DAliAGE, GIVEf1 A LOSS-0F-RHR i CHALLEf4GE I ASSURIllG CollTAltlMEflT PROTECT!0ll Ifi THE EVEllT All I O EXTEl4DED LOSS OF SHUTDOWfi C00LillG RESULTS Ifl l
1 f
CORE DAMAGE i
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l .----___-.--_---_------------.--______--------_------------_------_--______--._-____j
IMPROVED RELIABILITY OF RHR OPERAT10!!
()
EtiSURE ADEQUATE ACCIDENT PREVE!lT ErlSURE RESP 0flSE CAPABILITY AND ACI-RELATED CollTAlflMEllT PREVEllT MID-LOOP LOSSES LOSSES OF PROTECT 10fl 0F RHR RHR CAPABILITY (Fix A) (Flx B) (Fix C)
REQUIRE: REQUIRE: REQUIRE:
(1) PROMPT OPERATOR AVAILA- APPROPRIATE ASSUAANCE OF BILITY OF PLAtlT STATUS ELIMillATION OF TIMELY CLOSURE lilFORMATIOil AUTOCLOSURE OF CONTAlllMElli
- RCS/RHRS INDICAT!0rlS/ FEATURE OF PEliETRAT! Olds ALARMS SUCT10fl VALVE FOR MID-LOOP
- RELIABLE WATER LEVEL lilTERLOCKS OPERATIOl4S MEASUREMEllT CAPAB!L!TY
' OPERATOR AIDS (2) ALTERilATIVE PROCEDURES FOR RECOVERY OF SHUTDOWil COUL illG (3) ADMiti!STRATIVE CollTROLO (l4) IECHfl! CAL SPECIFICAT!CN CHANGE (5) InAltittlG On LOSS CF SHUTDOWN CCCLING O
() VARIATION IN COST /DENEFITS VS, SITE POPULATI0il i
CDF-CEC'JCUON. CDST/EFJLEELI2 SITE POP $/ PERSON-REM '
FIX P_T TY 8,=S R=10%
HIGH(=888/SQ MI) 22* 22' A GENERIC (=340/S0 MI) 52' 52' LOW (=100/SQ MI) 120* 120' HIGH 98-200 150-240 B GENE 2!C 240-470 350-590 LOW 520-1000 780-1300
'NOT INCLUDIiiG AVERTED ONSITE COSTS CONTAINMEtiT CLOSURE COST / BENEFITS !
CDF-REDUCTION SITE POP $/PERS0fi-REM FIX Ifi PLACE DENSITY R=5% R-10% l HIGH 710 430 N0fiE GENERIC 1800 1100 LOW 3800 2300 111GH 7500 4500 A GENERIC 19000 11000 LOW 42000 25000 HIGH 9400 5600
> AaB GEf1ERIC 23000 14000 LOW 47000 28000 i i
4 O
l*
l CONCLUSION, RESULTS OF REGULATORY ANALYSIS OF GI-99 SUPPORT THE FOLLOW!llG RECOMMEflDATI0f4S:
REQUIRE IMPLEMEllTATION OF CDF-REDUCTI0ff Flx A RECOMMEf4D, BUT (10T REQUIRE, APPP.0PRIATE REMOVAL OF AUTOCLOSURE FEATURE FROM RHR SUCTIOil VALVE IliTERLOCKS' I
f O
- REQUIRE IMPLEMEllTATI0fl 0F ColiTAlllMEtiT CLOSURE REQUIREMEllT PEllD!flG APPROPRIATE IMPLEMEflTAT10fl <
OF CDF-REDUCTIOrt Flx A I
- ASSUMES EACH PLAf4T AflAL\S!S SUPPORT! fig REMOVAL OF ACI WILL !
DEM0liSTRATE f4ET SAFETY IMPROVEMEfiT l I
(
(2) l i
l-
.1 9 O O O LOSS OF l
DECAY l{ FAT REM 0t'AL ACRS PRESErlTATION l
1 l SEPTEMBER 8, 1988 I
i i
r .
ISSUE WE ARE SERIOUSLY CONCERNED THAT PWR OPERATION DURING DECAY H EAT REM OVAL SYSTEM COOLING IS A SIGNIFICANT CONTRIBUTOR TO THE LIKELlHOOD OF A RELEASE DUE TO A CORE DAMAGE ACCIDENT
~ -
i . .
O O O l
l l
l DEFINITIONS
- 1. PEDUCED RCS INVENTORY - A RV WATER LEVEL LOWER THAf' TilREE FEET RELOW Tile REACTOR VESSEL FLANGE
- 2. MID-LOOP CONDITION - AN RCS WATER LEVEL BELOW THE TOP OF THE HOT LEG FLOW APEA AT THE JUNCTIOP WITH Tile PEACTOR VESSEL
- 3. CLOSED CONTAI EENT - A CONTAINMENT CONDITION THAT PROVIDES AT LEAST OfiE INTEGRAL PARP.IER TO Tile RELEASE OF RADI0 ACTIVE MATERIAL 1
O O O EXPERIENCE IFCIDFFTS CONTINtIE TO IlliTI ATE AT AN llNACCEPTABI.Y HIFl! PATE. TWO PEPORTED IN fiAY f FD ONE Ifl JI!LY. NUMERolls PI'BL! CATIONS AND
.vEETINGS HAVE NOT LED TO S0LitTION
g g _
v s PHENOMENA PHENOMENA IDENTIFIED WHICH POTENTIALLY LEAD TO SEVERE CORE DAMAGE IN SHORTER TIME THAN PREVIOUSLY BELIEVED. OTHER "WEW" PHENOMENA AFFECT THE REACTOR COOLANT SYSTEM (RCS) DECAY HEAT REMOVAL (DHR) SYSTEM, INSTRUMENTATION AND OTHER EQUIPM ENT.
O O e GENERIC L~t . I I ER 87- 12
- c. NO RESPONSES FULLY SATISFACTORY.
SOME LICENSEES UNSATISFACTORY IN EVERY ONE OF 12 CATEGORIES EVALUATED. SERIOUS LACK OF UNDERSTANDING AND INADEQUATE PREPARATION FOR OPERATION IDENTIFIED.
SOME LICENSEES NOT TAKING CORRECTIVE ACTION OF ANY KIND.
e e e GENERIC LEI I ER 87-12 (cont)
- b. INDIVIDUAL LICENSEES HAVE SHOWN EXCELLENT INSIGHT INTO SELECTED AREAS SUCH AS RCS D RAI N I N G, CONTAINMENT CLOSURE, INSTRU M ENTATIO N , DHR SYSTEM O P ERATIO N , OTHERS. IN FORMATION IS NOT EFFECTIVELY SHARED.
1
1 l O O O l
PEDl'CED PCS INVEt!TOPY OPEPATION
]. LOSS OF DliR A FPE0llENT OCCIJRRENCE
- 7. ONE Tl!IPD HAVE OCCIIRPFD Dl! pit'G RED!!CED Ifn'EF' TORY OFCPATION
OCCl!RS WilEN INVENTORY IS PEDl!CED l
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T E
L C S I P P 1' E 0 F P E G G
S E R H E T N W
E O C
N R D I W E S P D E
D M O
l i E E T A N V I R E W G S
_ I 0 I H S P C N P S
_ A O S T S P F S S I 0 R S S S l i G E D U Y S O R E C L K R G V S A P P O I I N 0 R E D A W L P C A E D E E !
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N S S 0 f A l l' I A S 0 O T C E S 1 I
- I F N S 'G t
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D D
_ T O I I I A N P T T T G S E S S T I E E E E l i
S P M P W f O
- i
- I ll' : A : ;
O O o A CENERIC LETTER WILL BE ISSilFD Tl!AT PEC07 MENDS A NIFPFP OF ACTIONS AND PECUESTS PWR LICEf* SEES TO IflFORM llS OF TIIEIR ACTIONS CONCERNING THE PECOMMEP'DATIONS
o o . ;
, APPROACH
- 1. SOME REDUCTION IN CORE DAMAGE LIKELlHOOD -
"EXPEDITIOUS ACTIONS" ACCOM PLISH IM M EDIATE, EFFECTIVE REDUCTION IN LIKELlHOOD OF RELEASE IF CORE DAMAGE ACCIDENT OCCURS
- 2. SIMULTANEOUSLY INITIATE ACTIONS WHICH TAKE A LONGER TIME TO DEVELOP "PROGRAMMED ENHANCEMENTS"
O O O EXPEDITIOUS ACTIONS
- 1. DISCUSS DIABLO CANYON IMPLICATIONS AND CONDUCT TRAINING WITH STAFF
- 2. REASONABLY ASSURE CONTAINMENT CLOSURE
- 3. PROVIDE TWO RCS TEMPERATURES
- 4. PROVIDE INDEPENDENT RCS LEVEL
- 5. DO NOT PERTURB RCS
- 6. PROVIDE BACKUP EQUIPMENT
- 7. INAPPROPRIATE USE OF NOZZLE DAMS
- 8. INAPPROPRIATE USE OF STOP VALVES PROGRAMMED ENHANCEMENTS
- 1. INSTRUMENTATION AND ALARMS (TEM PERATURE, LEVEL, DHP SYSTEM PERFORMANCE)
- 2. PROCEDURES FOR NORMAL AND EMERGENCY
- 3. EQUIPMENT FOR NORMAL AND MITIGATION ACTIONS
- 4. ANALYSES
- 5. TECHNICAL SPECIFICATIONS
- 6. REFINE RCS PERTURBATION AVOIDANCE
T N E E E VF S E F N A E e NT C O S I
L Y S D R N E A N N F O CO I R
T A S OA E L R L N
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. . B E O AP I
S T I
D O N A T OC T S H N S L N i
ST I E S P A L U W VE C E L MP I S
- I -
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O O o ASSIIPE CONTAINMENT CLOSUPE
- 1. DEVELOP PROCEDifRES TO REASONABLY ASSUPE C0flTAINMENT CLOSUPE PRIOR TO THE TIME A CORE DAMAGF ACCIDEf!T CAN OCCUR FOLLOWING LOSS OF DECAY !! EAT REMOVAL
- 2. IMPLEMENT PROCEDilPES W AND CE: PRIOP TO PEDifCIFG RV LEVEL LOVER TilAP TilREE FEET PFLOW THE REACTOR VESSEL FLANGE Pr.H: PRIOR TO REDUCING RCS LEVEL LOWER TilAt' F0llR INCHES BELOW Tile TOP OF Tile HDT LEG AT THE REACTOR VESSEL
- 3. IF CONTAlflMENT CANNOT BE CLOSED PRIOP TO P.EACillLG CORE DAMAR 5. TilEN PENETRATIONS CAI! SING CLOSURE FAlliiRE SP0llLD NOT BE OPEf'ED
O O O PPOVIPE RCS TEMPERATURE
- 1. PROVIDE TWO TEr.PERATIIRES REPRESENTATIVE OF CORE FXIT WPENEVER RCS WATEP LEVEL AT OR BELOW LEVEL OF TOP OF fl0T LEGS AT THE P.EACTOR VESSEL
- 2. EITIIEP. PE AELE TO MONITOP IN CONTROL ROOM 0_R FP.0M LOCriTION OUTSIDF 0F CONTAINMENT BUILDIt'G WITil CONTIt!U0l!S COMMUtlICATION CAPABILITY TO OPEPATOR l
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PPOVIDE TF0 INDEPENDENT C0f!TINI!Pl!S WATER LEVEL IPDICATI0f!S
- 1. APPLICARLE TO PLATITS THAT DO NOT 11 AVE TWO INDEPENDEFT LEVEL ifDICATIONS IF Tl!E COTTPOL POOM
- 2. PROVIDE ESSENTIALLY CONTINil0 tis CO W!PICATIDF OF WATER LEVEL INFCRMATI0ff WiiEFEVER RCS LEVEL IS AT OR EELOW TIIE LEVEL OF THE TOP OF THE IlOT LEGS AT Tile REACT 0P VESSEL
7 'x
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'%_,l DO NOT PERTURB RCS DO NOT ALLOW PERTURBATION OF THE RCS AND/OR SYSTEMS USED TO MAINTA!N THE RCS I IN A STABLE AND CONTROLLED CONDITION WHILE DRAINING RCS OR AT REDUCED RCS INVENTORY.
3
O O O l l
l ASSilRE PACKIIP COOLING E0l!1Pt7.HT PRIOR TO PEDUCING LEVEL LOWEP THAN TilREE FEET PELOW THE P.EACTOR VESSEL FLANGE
- 1. IN ADDITI0fl TO ?J0PFAL DHR SYSTEM PROVIPE AT LEAST OP'E HIGH PPFSSURE INJECTI0r' SYSTEM A?1D ONE OTHEP '
SYSTEM
- 2. EFFECTIVE PATER ADDITIOP' PATE OF EACH MEANS TO EE SIIFFICIEP'T TO MAINTAIN COPE If8 A COVERED C0t'DITI0r' l
1
e O e CONTROL HOT AND COLD LEG CLOSURE ESSENTIALLY DO NOT SIMULTANEOUSLY BLOCK ALL HOT LEGS UNLESS A VENT PATH IS PROVIDED TO THE REACTOR VESSEL UPPER PLEN U M THAT IS LARGE ENOUGH TO PREVENT RCS PR ESSU RIZATION.
1 ff
~
C. PROGRAMMED ENHANCEMENTS l
- 1. INSTRU M ENTATION
- a. RCS LEVEL
- b. RCS TEMPERATURE
- c. DHR SYSTEM MONITORING
- d. ABNORMAL CONDITION IN DICATIONS 27 _
l
- 1. INSTRU M ENTATIO N --
GENERAL l
RELIABLE INDICATIONS TO BE PROVIDED IN THE CONTROL ROOM UNDER NORMAL AND ACCIDENT CONDITIONS WHENEVER 1RRADIATED FUELIS IN REACTOR VESSEL.
RELIABLE MEANS THE ITEM CAN BE REASONABLY EXPECTED TO PERFORM ITS INTENDED FU N CTIO N. CONTROL GRADE WILL GEN ERALLY MEET THIS R EQUIREM ENT. UNDER SOME CIRCUMSTANCES, A LESSER QUALITY IS S U FFICIENT.
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- 1. INSTRUM ENTATION -
cont
IND! CATIONS IN THE CONTROL ROOM.
- b. RCS TEMPERATURE CONTINUOUSLY DISPLAY TWO TEMPERATURE INDICATIONS WHENEVER REACTOR VESSEL HEAD IS LOCATED ON TOP OF THE REACTOR VESSEL.
L
l l
- 1. INSTRUM ENTATION -
cont
- c. DHR MONITORING PROVIDE THE CAPABILITf OF MONITORING DHR SYSTEM PERFORMANCE WHENEVER A DHR SYSTEM IS IN USE FOR COOLING THE RCS.
- d. ABNORMAL CONDITION IN DICATIONS PROVIDE VISUAL AND AUDIBLE INDICATIONS OF ABNORMAL CONDITIONS IN TEMPERATURE, LEVEL. AND DHR SYSTEM PERFORMANCE.
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- 4. ANALYSES
- o. PROVIDE BASIS FOR PROCEDURES, INSTRU M ENTATION , EQUIPMENT OPERATION, AND CO NTAI N M ENT.
- b. ENCOMPASS THERMODYNAMIC AND CON FIGU RATION CONDITIONS WHICH CAN BE REASONABLY ENCOUNTERED.
, c. EMPHAS!ZE DEVELOPMENT OF COMPLETE UNDERSTANDING OF NSSS BEHAVIOR DU PslN G NONPOWER OPERATING REGIONS OF INTEREST.
- 5. TECHNICAL SPECIFICATIONS IDENTIFY TECHNICAL SPECIFICATIONS IMPACTED BY ABOVE RECOMMENDED ACTIONS AND SUBMIT APPROPRIATE CHANGES.
O O O
- 6. PCS PEPTifPEATIONS P.EEXAMit:E EXPEDITIOUS ACTI0flS OF Tills TOPIC AND REFir'E AS NECFSSAP.Y TO REASCP'AELY l'IP'TMIZE Tile LIKElll800D OF LOSS OF DilR
O O O I
( CE?'ERIC LETTEP l
- 1. ADDPESSES LOPERED INVENT 0FY OPEPATION DIRECTLY
- 2. ADDFEFSES OTIIEP, SilUTDOWN COOLING OPEPATION IPDIRECTLY SINCE A BASIS FPOM W111CH TO ENTER LOWERED IfD'EFTORY OPEPATION IS ADDPFSSED
O O O
- 3. IIAS PEEN REVTEYED WITil THE COP 711TTEE TO PEVIEW GEFEPIC REQUIREFEarTS (CPGP) ON Al! GUST 24 Ti1EY PEQUESTED:
- t. . filNOR CLARIFICATIDFS REGARDING APPLICABILITY P. . A COST /PEFEFIT ANALYSIS SPECIFIC TO TIIE REC 0FFFDED ACTIONS TIIESE IIAVF PEEN COPPLETED AND ARE PEli4G PEVIEWED.
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SLIDE 1 O
Uti!TED STATES NUCLEAR REGULATORY COMISSION ADVISORY COMITTEE ON REACTOR SAFEGUARDS TECHil! CAL MEETING - SEPTEMBER 8, 1988 REVIDI 0F PROPOSED RES, TART OF THE P!LGR!ti NUCLEAR POWER STAT 10tl O
SAMUEL J COLLINS i DEPUTYDIRECTOR, '
DIV: S10N OF REACTOR PROJECTS REG:0ft i FTS 346-5126 I
l SLIDE 2 (
!!. NRC STAFF PRESENTATIONS i
, O l 1
AGENDA t
l II. NRC STAFF PRESENTATIONS 1:45 P.M. !
.l O A. INTRODUCTION 0 B.
ISSUES l
a J C. LICENSEE ACTIONS f
) D. ASSESSMENT ACTIVITIES AND RESULTS i i'
E. CONCLUSION 2:45 P.M. !
O .
i i
. t i
I J
)
!O
__-I
II.A INTRODUCTION SLIDE 3 O
INTRODUCTION OF NRC STAFF kkk0k'PkbNb'kGON O
Jg.g.WIGGINS, CHIEF,REACTORPROJECTS 0 LAWRENCE T. DOERFLEIN, PROJECT ENGINEER, RPS 3B 0 CLAY C. WARREll, SENIOR RESIDENT INSPECTOR, PILGRIM 0 JEFFERY J. LYASH, PROJECT ENGINEER, RPS 3C O
O BRUCE A. B0GER ASSISTANT D REC"0R FOR REGION 1 REACTORS,OFFICEOFNUCLEARREACTORREGULATION 0 RICHARD H. WESSMAN, PROJECT DIRECTOR, NRR 0 DANIEL G. MCDONALD, LICENSING PROJECT MANACR, NRR O
II.B. ISSUES SLIDE 4 HISTORICAL PERSPECTIVE
({}
PURPOSE: o TO PROVIDE EACKGROUND AND HISTORY OF ISSUES AT PILGRIM NUCLEAR POWER STATION IN ORDER TO A
ELA_(1 PERSPECTIVE ON NUCLEAR REGULATORY COMISSION (NRC) AND BOSTON EDISnN COMPANY (BECO) ACTIONS IN REGARDS TO EEA_ RT ACTIVITIES.
GONTEXT: o A REVIEW OF PAST ISSUE _S_ TO PROVIDE Hl5TORICAL BACKGROUND.
o ISSUES PRESENTED HAVE BEEN TH! SUBJECT OF '
EE(Q CORRECTIVE ACTIONS AND NRC $TAFF VERIFICATION ACT!VITIES.
o JSIMI RESPONSE BY BECO AND VERIFICATION BY NRC WILL BE ADDRESSED IN SUBSEQUENT PRESENTATIONS.
(])
4 l I 1
)
O l .
l
($)
II.s. ISSUES sLIot s BACKGROUN_D INFORMATIC'1 Od .
h PILGRIM NU E EAR PONER PLANT Utility: Boston Edison Location: 4 Mi SE of Plymouth, Massachusetts County: Plymouth County,' Massachusetts Docket No.: 50-293 CP 1ssued: 8/26/68 Operating License issued: 9/15/72 Initial Criticality: 6/16/72 (Based on a 20% power Itcense issued 6/9/72)
E)tc. Ener. 1st Gener: 7/19/72 Cem ercial Operation: 12/1/72 Reactor Type: BWR 3/4 Containment GE MKI Power Level: 670 MWe; 1998 MWt Architect / Engineer: Bechtel -
NSSS VenCor: General Electric Constructor: Bechtel Turbine Supplier: General Electri Condenser Cooling Method: Once Thru Condeaser Cooling Vater: Cape Cod Bay Licensing Project Manager: Daniel G. Mcdonald (Telephon : 492-1436) .
NRC Responsible Region: Region 1, King of Prussia, Pennsylvania William T. Russell, Regional Administrator
(]- James M. Allan, Deputy Regional Adm W strator Div. of Reactor Projec u: Viliiam F. Kars, Div Director (Tel: 8-346-3225)
(Region I) Samuel J. Collins, Deputy Director (Tel 8-346-5126)
James T. Viggins, Branch Chief (Tel: ' 8-346-5224)
A. Randy Blough, Section Chief (Tel: 8-346-5146) 1.awrence T. Doecilein, Project Engineer (Tel: 8-346-5132)
Senior Resident I M eector; Clay C. Warren (Tel: 8-617-747-0565)
Resident Inspectors: Jef f rey J. Lyssh (Tel: 617-747-0$65)
Tae K. Kim (Tel: 8-617-747-0565)
O
a SLIDE G II.B. ISSUES I
.O nitESTONE CsART 1/80 - 12/87 SALP CYCLE 2 SALP CYCLE 3 SALP CYCLE 1 9/81-6/82 1/80-12/80 9/80-8/81 REPORT 4/81 REPORT 12/81 REPORT 11/82 ,
i 12/83-12/84 ORDER TO SALP CYCLE 6 INSP 85-30 SALPCYClE4l'SALPCYCLE5 7/83-9/84 OUTAGE FOR MODIFY 10/84-10/85 SAFETY SYSTi 7/82-6/83 LICENSEE REPORT 5/86 FUNCTIONAL REPORT 1/84 REPORT 6/85 PlPE REPLACEMENT RADIO- INSPECTION LOGICAL 10/22-11/22, 1
674 HOURS
! h$hfk8 i 11/29/84
- INSP 86-06 PLANT CAL INSP 85-17
! DIAGNOSTIC SsVTDOWN 86-10 AUGMENTED SPECIAL SPECIAL INSP 4/11/86 4/12/86 SAFETY TEAM INSP 4/12 - 4/25/86 2/18-3/7/86 l
O 962 s0uRS _
57u 80uas ..
CAL M-1$~ MANA6EMENT IIId~SS. EE6l
- - ~$ECO SHUTDOWN ON EMERGENI CONTINUAT!0N FOR iEMENT MEETING 86-41 i
RFO-7
- SUf..//86 8/1 11/24/86 PREDAREDNE' 12/8e 7/86 2.206 RPT 12/31/86 ~
FETITION i
7/86 l ._
l .. y _.
"EAM
! ISSUES ,11/16-20/87 8/87 l
- 380 s0URS T
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L
e SLlDE 7
!! B. .I.SSUES SALP RESULTS PRIOR TO april 1986 SHUTDOWN l c:) . ASSESSMENT PERIOD CYCLE 2 CYCLE 3 CYCLE 4 CYCLE 5 CYCLE 6 i
[YCLE 1 1/80- 9/80- 9/81- 7/82- 7/83- 10/84-8/81 6/82 6/83 9/84 10/85 FUNCTIONAL AREAS 12/80 3 3 2 2 3 OPERATIONS 2 RADIOLOGICAL 21 31 CONTROLS 3 2 2 2 2 2 2 1 1 2 SURVEILLANCE MAINTENANCE 2 3 2 2 11 2 EMERGENCY PLAliNING 3 1 1 1 3D 3 FIRE 2 -
PROTECTION 2 2 3 1 2 2 2 2 2 2 SECURITY ENGINEERING AND TECHNICAL
(]) SUPPORT LICENSING - - 2 1 11 1 TRAINING - - - -
EFFECTIVENESS ASSURANCE OF - - - -
QUALITY /0A 3 3 OUTAGE 1 3 2 2 - 1 MANAGEMENT O
SLIDE 8 II.B. IS.TES PROGRAM ISSUES LEADING TO APRIL 1986 SHUTDOWN o HISTORY OF POOR PERFORMANCE o IMPROVEMENT PROGRAMS INHIBITED BY:
(1) INCOMPLETE STAFFING, IN PARTICULAR, OPERATORS AND KEY MID-LEVEL SUPERVISORY PERSONNEL, (2) A PREVAILING VIEW IN THE ORGANIZATION THAT THE IMPROVEMENTS IMDE TO DATE HAVE CORRECTED THE PROBLEMS, (3) RELUCTANCE, BY MANAGEMENT, TO ACKNOWLEDGE SOME PROBLEMS IDENTIFIED BY THE NRC, AND (4) DEPENDENCE ON THIRD PARTIES TO IDENTIFY PROBLEMS RATHER THAN IMPLEMENTING AN EFFECTIVE PROGRAM FOR SELF-IDENTIFICATION OF WEAKNESSES.
REFERENCES:
- 1. SPECIAL SAFETY TEAM INSPECTION 50-293/86-06, REPORT 4/2/86 i 2. SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE (SALP) 50-293/85-99, REPORT 5/23/86
- 3. MANAGEMENT MEETING REPORT 50-293/86-41, REPORT 12/31/86 O
BACKUP SLIDE 8A i i .B. JSSUES
() TECHNICAL ISSUES LEADING TO APRIL 1986 SHUTDOWN OPERATING 15 20 25 30 DAYS 1 5 10 NOV 85
- 30 DEC 85
- 31
- ************************** 28 JAN 86 FEB 86
- 28
- **** 11 MAR 80
- ******* 6 :
AIR 86 O
i P
]
BEFERENCE:
SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE (SALP) 50-29.3/86-9 REPORT 6/17/87 4
O
II.B. ISSUES BACKUP SLIDE 83 TECHNICAL ISSUES LEADING TO 1986 SHUTDO'm (Cot!TI!!UED)
O UNPLANNED AUT0w.ATIC SCRA*.S AND SHUT 00WS (11/01/85 - 02/31/27)
PILGR]M NUCLEAR POWER STATION Power Date Level Description Cause 01/03/86 1004 Main turbine generator Equipment failure -
bearing vibration random required a controlled plant shutdown for repairs 01/06/86 Restart 01/06/86 10*4 Reactor scram on ves- Operator error and sel low level during inadequate main-restart. Caused by tenance - es ossive operator inattentive- leakage past feed-ness while manually water regulation controlling level and valves leaking feedwater -
regulation valves .
(LER 86-001)
O ww86 20= wit 8 18e ve4t ie a half scram configura-tec8eiciae error and design tion for maintenance deficiency-changeout of a hypersensitive l
reactor high prassure pressure switches
- switch, slight bums l on the second pressure l
switch caused a false hig".eactor pressVre l scram (LER 86-002)
! 01/29/86 10 3 A recurrence :f main Eculpe.ent failure - t turbine generato? random i bearing vibratien '
l problems result u ir,a forced power reduction to 20 percent power ,
REFERINCE:
SALP REPORT 86-99 . 5 O
II.B. ISSUES BACKUP SLIDE 8C TECHNICAL ISSUES LEADING TO 1986 SHUTDOWN (CONTINUED)
O Power Date ke,.vd Description cause 03/07/86 100% Weld leak in the 4" Equipment failura head spray piping required a controlled shutdown to facilitate repairs. (LER86-005) 03/12/86 Restart 03/15/86 80% Increasing unidenti- Eauipment failure -
f'.ed drywell leakage random required reactor shutdown. The licen-
- see founc and repaired a weld leak on reactor water level instru-mentation line.
(LER 86-006) 03/31/86 Re; et .
04/04/86 100% A controlled reactor Ecuipment shutdown due to the failure -
O detection of small oil leak in the turbine random hydraulic control system. (IR 86-07) ,
04/04'86 5% During a controlled Eauipment failure - l reactor shutdown, spurious actuation tutomatic Closure of the M31Vs of the Main Steam l solation Valves s (M51V) initiated '
a reactor scrat.
(LER 86-008) 04/04/86 0% Following the reactor Operator error scram described above.
. a second scram signal was received due to
- the scram discharge volume (SDV) high level signal 3 (LER 86 008) 04/09/86 Restart O
II.B. ISSUES BACKUP SLIDE ED l
TECHNICAL ISSUES LEADING TO 1986 SIIUTDOWN (CONTINUED)
Power Date Level Description .
Cause 04/11/86 93% Indicated leakage from Equip ent failure -
the reactor water random recirculation system through the 'B' loop Residual Heal Removal (RHR) System injection valves forced a shut-down for maintenance 04/11/86 lot During a controlled Equipment failure -
reactor shutdown, spurious actuation automatic closure of the M51Vs of the M51Vs initiated a reactor scram (LER 86-006/IR 86-07) 04/12/86 0'. A Confirmatory Action Letter 86-10 was issued -
regarding the April 4 and April 12 MSIV iso-0 1ations and the RHR injection valve leakage.
The Confirmatory Action Letter was subsequently
, estended to cover correction of signifi-cant program..atic deficiencies. In July 1986, the licarsee l decided to continst the shutdown into 1987 and l conduct refueling, instali certain Mari !
centainment enhance-ments, and complete 10 CFR 50 Appendix R fire protection modifications.
, o Restart of the unit in i
pending NRC authori-24 tion in accordance
- g with Confirmatory Action Letter 86 10.
O f
SLIDE 9
!!.B. ISSUES APRIL 1986 SHUTDOWN
(])
CONFIRMATORY ACTION LETTER (CAL) 86-10 o APRIL 11, 1986 PLANT SHUTDOWN REQUIRED Bf TECHNICAL SPECIFICATIONS o WHILE SHUTTING DOWN AN UNPLANNED SCRAM OCCURRED DUE TO THE SPURIOUS PRIMARY CONTAINMENT GROUP 1 ISOLATION, THE OUTBOARD MAIN STEAM ISOLATION VALVES (MSIVs) COULD NOT BE OPENED o
NRC ISSUED CONFIRMATORY ACTION LETTER 86-10 ON APRIL 12, 1986 AS A RESULT OF TiiESE RECURRING EVENTS TO MAINTAIN THE PLANT IN A SHUTDOWN CONDITION UNTIL THE NRC COULD REVIEW IN DETAll THE CAUSES OF THESE EVENTS AND THE LICENSEE'S C00RECTIVE ACTIONS o CAL 86-10, 4/12/86 REQUIRED:
+ MAINTAIN PLANT CONDITIONS TO PROVIDE FOR NRC REVIEW 0F THE EVENT
(])
t PROVIDE A WRITTEN REPORT TO THE NRC PRIOR TO RESTART EVALUATING:
A. INTERSYSTEM LEAKAGE OF RESIDUAL HEAT REMOVAL SYSTEM B. SPURIOUS PRIMARY CONTAINMENT ISOLATION SIGNALS C. FAILURE OF OUTBOARD MSIVs TO REOPEN o BECO DECISION 7/86 TO REMAIN SHUTDOWN FOR RFO-7 o CAL 86-10, 3/27/86 SUPPLEMENTED TO INCLUDE OTHER HARDWARE AND SALP-RELATED PERFOPJ%NCE ISSUES:
t RESOLUTION OF SPECIFIC TECHNICAL ISSUES O
1 II.B. ISSUES SLIDE 9 (CONT'D)
+ FORMAL ASSESSMENT OF THE READINESS FOR RESTART OPERATION
+ FORMAL RESTART PROGRAM AND SCHEDULE !
i t ASSESSMENT AND RESTART PLAN TO BE SUBMITTED FOR NRC REVIEW AND APPROVAL f
6 i
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1 II.B. ISSUES SLIDE 10 APRIL 1986 SHUTDOWN
. CAL 86-10 l i
NRC INSPECTION 86-17 j o AUGMENTED SPECIAL SAFETY TEAM INSPECTION ,
o 4/12 - 4/25/86 IN RESPONSE TO 4/11 PLANT SHUTDOWN ,
o 3 OPERATIONAL PROBLEMS:
(1) THE SPURIOUS GROUP-ONE PRIMARY CONTAINMENT ISOLATION ON 4/4 AND 4/12/86 (2) THE FAILURE OF THE MAIN STEAM ISOLATION VALVES (MS!Vs)
TO OPEN AFTER THE ISOLATIONS (3) RECURRING PRESSURIZATION EVENTS IN THE RESIDUAL HEAT O REMOVAL (RHR) SYSTEM o BECO APPROACHES TO PROBLEM SOLVING WERE CAREFULLY STRUCTURED AND APPEARED THOROUGH I
O
.-..---.--_,n,- ,_.._,,,n,-,
!!.B. JSSUES SLIDE 11
() MANAGEMENT MEETING 86-41 o CONDUCTED 11/24/86 TO DISCUSS BECO PLANS FOR PROGRAM IMPROVEMENTS AT PILGRIM AND THE STATUS OF OUTAGE ACTIVITIES o TECHNICAL AND PROGRAM ISSUES TO BE REVIEWED PRIOR T0 i STARTUP WERE LISTED AS ATTACHMENT 1 TO MEETING REPORT o NRC LOOKING 10R STRONG EVIDENCE OF PROGRESS AT PILGRIM PRIOR TO RESTART ,
i o NRC INTENDS TO CONDUCT A SYSTEMATIC ASSESSMENT OF i LICENSEE PERFORMANCE (SALP) REVIEW PRIOR TO REACHING A POSITION REGARDING THE RESTART OF THE PILGRIM FACILITY
($)
t I
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II.B. ISSUES gg SALP FINDINGS 86-99 o ASSESSMENT PERIOD 11/1/85 - 1/31/87 o SALP D0ARD REPORT ISSUED 4/8/87 o SALP MANAGEMENT MEETING 5/7/87 o SALP REPORT 50-293/86-99 6/17/87 o ISSUES: ,
+
BEC0 MADE SIGNIFICANT STAFFING AND HARDWARE COMMITMENTS TO IMPROVE PERFORMANCE t PROGRAM IMPROVEMENT BEGINNING TO HAVE A POSITIVE EFFECT
+
ASSESSMENT OF PERFORMANCE NOTED SOME IMPROVEMENTS t ORGANIZATION CHANGES TO CLARIFY RESPONSIBILITY AND ACCOUNTABILITY STABILITY IN STAFFING KEY MANAGEMENT POSITIONS STAFFING VACANCIES SLOW DEVELOPING IMPROVEMENTS IN SOME PREviOUSLY IDENTIFIED LONG-TERM PROBLEM AREAS ,
o NRC ACTIONS:
o CONTINUE AUGMENTED INSPECTION PROGRAM o MONITOR CAL 86-10 ACTIVITIES k
O
II.B. ISSUES SLIDE _;[5 1
OTHER ISSUES O
o EMERGENCY PREPAREDNESS (1) ONSITE - NO SIGNIFICANT DEFICIENCIES OR PROGRAM WEAKNESSES (2) 0FFSITE - DEFICIENCIES IDENTIFIED BY COMMONWEALTH REPORT AND FEMA SELF-INITIATED REVIEW
- SIX FEMA DEFICIENCIES REQUIRE PLAN CHANGES AND SOME DEMONSTRATION
- ANNUAL FULL PARTICIPATION EXERCISE EXEMPTION GRANTED o SAFETY ENHANCEMENT PROGRAM (SEP)
(1) VOLUNTARY PROGRAM NOT A PREREQUISITE FOR PLANT RESTART (2) BECO IMPLEMENTING SEVERAL SELF-INITIATED ENHANCEMENTS TO THE PILGRIM MARK ! CONTAINMENT (3) IMPLEMENTED UNDER 10 CFR 50.59 (4) NRC HAS REVIEWED SAFETY EVALUATIONS o LEGAL AND LICENSING ACTIONS -
(1) TWO 2.206 PETITIONS HAVE BEEN SUBMITTED REQUESTING THAT BECO SHOW CAUSE WHY PILGRIM SHOULD NOT REMAIN SHUTDOWN UNTIL CERTAIN ISSUES HAVE BEEN RESOLVED. PETITIONS REQUEST FULL ADJUDICATORY HEARINGS TO ADDRESS ISSUES RELATED TO MANAGEMENT, MARK 1 CONTAINMENT AND EMERGENCY PREPAREDNESS (2) ALL LICENSING ACTIONS HAVE BEEN REVIEWED, THREE REMAINING ACTIONS WILL BE COMPLETED PRIOR TO RESTART f
^
II.C. LICENSEE ACTIONS SLIDE 14 O
AGENDA
- 11. NRC STAFF PRESENTATIONS 1:45 P.M.
A. INTRODUCTION B. ISSUES 0 C. LICENSEE ACTIONS D. ASSESSMENT ACTIVITIES AND RESULTS E. CONCLUSION 2:45 P.M.
O i
O :
[
l II.C. LICENSEE ACTIONS , SLIDE 15 O l MILESTONE CHART l l
0 PROVIDES AN OVERVIEW 0F BECO ACTIONS 0 PROVIDES FOR TRACKING, PLANNING AND DOCUMENTATION j OF NRC RESTART ASSESSMENT ACTIVITIES !
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0I# #5
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[ ut 80-10
""l h NRC SEP Ltr Restart
!] gr S%E SALP WFO-7 SALP 85-99 Ican 10 Ali Start t s HlI"9 86-99 Assess, from Plan
]((
Inso. Pit Scr -
RS-41 Plan RFCn Rev_ 0 %,
P s. . . . 8. . . ,R, . 8 - . - ->-.m. . .A,,,...)_.. .. JL -A _ .J 2 * .3 10/1/84- 2/16/86- 4/12/86 7/86 8/27/86 11/24/86 11/1/85- 7/8/87 7/8/87 7/30/87 Mr 12/31/85 3/1/86 1/31/87 3.,.o; 0 "C IEMA ! SEP Lir EP Ltr DECO flRR Mtg Pwr Asc Restart Site
"'*II 9"-
Self to to EP Re- with Prg Plan Work AIT ment Int Rev BECo BEco spouse BECo . Submit Rev. I i Stop .
F m- . 8- .. ,m.A u A . . -.m _L.. mA ... ,,mA ' , _, oJL, 3
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8/5/87 8/21/87 9/17/87 9/17/87 9/24/87 10/15/87 10/26/87 11/8/87 11/12/87 12/87 1
3 x
^
~
Pubile Mtg Start BECo BECo SEP NitC KWNeT lie (s/Ndt NitC~PuSTlc BRile1T ~ -
start Plan Resolution Mtg Re- Re. ~
Assessment I
,_estcrt Pilgri" on Restart Pre-Self Ltr to NRC Comunents to R/S Plan start Plan IMPO Report N n sk Plan Assessment Except DIV BECo Comunents Comunents Review Submitted $
,. : J > - = a .. - . . r -
3/18/88 x.>
5/6/88 5/11/88 t.. . . .
.x-I/4/88 1/21/88 2/18/88 2/22/88 2/22/88 5/9-20/88 5/26/88 MTB Self- '
~
NRC Rev o - 8Eco/ Staff ' 8[Co De A "
BECo 5 elf- Tenior **' " -
Assess /INPO NT g SAtP - C e e adt- g y- ACRS Rpt Resu Ms Prepara- at
^'5',5fa Mgent 7
" lATI Mt 9
Pubile Mtg ness IAll * $gg,
.'P' , QL3 _ _w . . !5/1{lE8 ~ ~ ' h _. _ a -
1
~mt _. -.~ *--- - - 5.Y C _ 1 a 5/26/88- 6/2/88 6/9/88 6/25/88 Bd 7/5/88 7/15/88 7/19-21/88 8/8-24/84 8/25/88 - 8/26/88 6/24/88 Rpt 7/26/88
~~ ~~
3^Il 2.206 MHC/ CAL NRC Comp NRC Restart Restart ACRS hec Rei E UP-- -- Restart IAT! NRC 2.206 Power Assessment Assessmer Rep rt olution issues ISS"' Issue Pubile Pubilc IU11 issue SE*l"5 Ascension Report Panel y SEP iss Addressi d Status Meeting Meeting P.lML Rey Recom RA
'*"g -18,_. .;; -
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I - .-+-- ; . ~~ !- - - 1 r 3
{7gj [ ] l l[ [ _J--l l jly/g_9/13/88llw/o 9/19/88l l l l_. -d _-l l >
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ED0Tals! NRC~Dver-
- m RK Recimi~~ V/NRR #
to Recomumenda. slon Brief- ^ ~--
sight Pit r C
Ilrector/ EP tion to ing Public Ccwen Restart Restart /PWR lNRC [6 Mo. ,, y g lisues EDO Meeting Assent Decisfo' Ascension SALP Qm gnRR l Release 3._ _. p ...._;_1 L_1,._;. .. .g _. . ; _. . . . q_. . g gge f I L_ I I ._I l_. .._I L _..I I .. __. .. I l_i_II l1 1 a c,
'II.C LICENSEE ACTIONS SLIDE 17 O
tiAJOR ACTIVITIES
~
o SALP 85-99 o DIAGNOSTIC TEAM INSPECTION .
o CAL 86-10, 4/86 o CAL 86-10, 8/86 o SALP 86-99 j -
o NRC PILGRIM ASSESSMENT PLAN, 7/87 o SAFETY ENHANCEMENT PLAN (SEP), 7/87 o PILGRIM RESTART PLAN, REV. O, SUBMITTED 7/87
{
) o FEMA SELF INITIATED REVIEW 0F EMERGENCY PREPAREDNESS (EP), 8/87 O PILGRIM P WER ASCENSION PROGRAM, SUBMITTED 10/07 o PILGRIM RESTART PLAN, REV. 1, SUBMITTED 10/87 o INPO REVIEW, 5/88 i o P!LGRIM SELF-ASSESSMENT REPORT, 5/88 l
o BECO/NRC STAFF COMMISSION BRIEFING, 6/88 l o BECO REQUEST FOR IATI, 7/88 o SALP 87-99, 7/88 l
j o ACRS C0ftlTTEE BRIEFING, 7/88
! o IAT!, 8/88 i*
o SALP MANAGEMENT MEETING, 8/88 o ACRS SUBCOMMITTEE BRIEFING, 8/88
- o P!LGRIM POWER ASCENSION PROGRAM REVISION, 8/88 o ACRS COMMITTEE BRIEFING, 9/88
, O i
4
\
!!.D. ASSESSMENT ACTIVITIES AND RESULTS SLIDE 18 O
AGENDA II. NRC STAFF PRESENTATIONS 1:45 P.H.
A. INTRODUCTION B. ISSUES C. LICENSEE ACTIONS D. ASSESSMENT ACTIVITIES AND AESULTS E. CONCLUSION 2:45 P.M.
O O
- 1. .
II.D ASSESSMEllT ACTIVITIES AND RESULTS .SilDE 19 RESTART ASSESSMENT PANEL '
o SPECIAL RESTART ASSESSMENT PANEL FORMED BY 7/S/87 MEMORAf4DUM TO NRC REGION I REGIONAL ADMINISTRATOR >
o PANEL CHARTER IS TO COORDINATE THE PLANNING AND EXECUTION OF NRC ACTIVITIES AND TO ASSESS THE RESULTS OF THESE ;
ACTIVITIES o RESTART ASSESSMENT PANEL MEMBERSHIP:
{
o DEPUTY DIRECTOR, DIVISION OF REACTOR PROJECTS, REGION I - CHAIRMAN o ASSOCIATE DIRECTOR, REGION I REACTORS, NRR, CO-CHAIRMAN
($) o CHIEF, REACTOR PROJECTS BRANCH 3, DRP o PROJECT DIRECTOR, NRR o PROJECTS SECTIONS CHIEF, DRP o LICENSING PROJECT MANAGER, NRR o CHIEF, ENGiliEERING BRANCH, DIVISION OF REACTOR SAFETY, REGION I o CHIEF, RADIOLOGICAL PROTECTION, EMERGENCY PREPAREDNESS ,
AND SAFEGUARDS, DIVISION OF RADIATION SAFETY AND SAFEGUARDS, REGION I '
o PANEL MEETING BI-WEEKLY, EVERY OTHER MEETING AT PILGRIM SITE O
ll,D, ASSESSMENT ACTIVITIES AND RESULTS
, SLIDE 20 AUGMENTED INSPECTION AND REVIEW ACTIVITIES o 7/8/87 MEMORANDUM FROM DIRECTOR, DIVISION OF REACTOR PROJECTS TO Ti1E REGIONAL ADMINISTRATOR, REGION I i
o MANAGEMENT OF NRC ACTIVITIES REGARDING PILGRIM RESTART:
(1) UN!QUE PLAN NEEDED FOR MANAGING NRC ACTIVITIES (2) NRC MUST COMPLETE REVIEWS TO PROVIDE AN INDEPENDENT JUDGEMENT OF PLANTS READINESS FOR OPERATION (3) MUST PROVIDE FOCUS AND GUIDANCE TO NRC PROCESS o ACTIONS:
(1) $$ MENTED INSPECTION PROGRAM TO IDENTIFY NEEDED IMPROVEMENT AND NEEDED NRC STAFF ACTIVITIES (2) SPECIAL PILGRIM ,RISTART ASSESSMENT PAJEL - SENIOR STAFF fiENDEPS (3) DIAGNOSTIC TEAM IfiSPECTION (IATI - INTEGRATED ASSESSMENT TEAM INSPECTION)
(4) ASSESSMENT REPORT TO REGIONAL ADMINISTRATO,R (RAR -
RESTART ASSESSMENT REPORT)
O
II,D, ASSESSMENT ACTIVITIES AND RESULTS SLIDE 21 AUGMENTED INSPECTION AND REVIEW ACTIVITIES O
INSPECTIONS SALP PERIOD INSPECTION HOURS ANNUAL 110VRS 1/80-12/80 1950 1950 9/80-8/81 2328 2328 9/81-6/82 3735 , 4482 7/82-6/83 3234 3234 1
7/83-9/84 4960 3968 10/84-10/85 3792 3500 t 11/85-1/87 6762 5409 2/87-5/88 9698 7758
'DURING THE LAST (2/87-5/88) SALP ASSESSMENT PERIOD, NINE NRC TEAM INSPECTIONS WERE CONDUCTED:
O 1. APPENDIX R FIRE PROTECTION PROGRAM REVIEW
- 2. PLANT MODIFICATION PROGRAM REVIEW
- 3. PLANT EFFLUENT AND ENVIRONMENTAL MONITORING PROGRAM REVIEW
- 5. ANNUAL EMERGEllCY PLAN EXERCISE OBSERVATION
- 6. ONSITE ELECTRICAL DISTRIBUTION ADEQUACY REVIEW
- 7. EMERGEliCY OPERATING PROCEDUREG REVIEW
- 8. MAINTENANCE PROGRAM REVIEW 9, IN-PLANT RADIOLOGICAL C0'iTROLS REVIEW ~
O
l l
. II.D. ASSESSMENT ACTIVITIES AND RESULTS SLIDE 22 !
O AUGMENTED INSPECTION AND REVIEW ACTIVITIES '
MEETING ACTIVITIES I o 42 MEETINGS CONDUCTED SINCE 4/86 SHUTDOWN
(
o 28 MEETINGS CONDUCTED SINCE 2/87 i l
o TABLE 5 0F SALP REPORT 87-99 (SLIDE 8, 9, 10) '
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II.D. ASSESSMENT ACTIVITIES AND RESULTS BACKUP SLIDE 22A s
TABLE 5 -
)
MANAGEMENT MEETING AND PLANT TOUR
SUMMARY
DATE Sp0N50R TOPIC 02/02/87 NRC Management meeting at Plymouth, MA to discuss the status of licensee improvement programs
(!R 87-08) 02/03/87 Massachusetts NRC Region ! Administrator and other Region I i
' Secretary of managers met in Bostoni MA with several Energy Commonwealth administrators to discuss NRC activities regarding Pilgrim 03/09/87 Massachusetts NRC Region ! Administrator and other members of
{ Legislature the staff appeared in Boston, MA before the Massachusetts Joint Committee on the Investigation and Study of the Pilgrim Station at Plymouth (IR 87-16) 03/10/87 NRC NRC Chairman Zech* toured Pilgrim accompanied by the Regional Administrator and attenced a licensee presentation (IR 87-16)
(]) 04/27/87
- Massachusetts NRC hegion I Administrator and other members of Legislature the staf f appeared in Boston before the Mass-chusetts Joint Committee on the Investigation and*5tudy of the Pilgrim Station in P!ynouth (IR87-18) 05/01/87 NRC Management meeting at NRC Region I to discuss a surveillar.co program violation and program weaknesses (IR 87-23) 05/07/87 NRC 1987 5 ALP sanagement meeting at Plymouth, MA 05/22/87 NRC HRC Commissioner Carr toured the plant and attended a licensee presentation 05/27/87 Plymouth Four NRC Region ! management representatives Board of participated in a public meeting in Selec tmen Plymouth, MA 06/24/87 NRC NRC Conmissioner Asselstine toured the plant and attended a licensee presentatica O
11,D, ASSESSMENT ACTIVITIES AND RESULTS BACKUP SLxec 22B Table 5 2
(] OATE SPONSOR TOPIC '
06/29/87- NRC Managtment meeting at NRC Region I to discuss the outage status, program improvements and licensee preparations for restart (IR 87-28) 07/23/87 Commonwealth of Mass, The NRC Section Chief, licensing Project Manager and Resident Inspectors for Pilgrim met onsite with representatives of the Commonwealth to iscuss the NRC inspection process (IR 87-27) 09/09/87 NRC orcement conference at NRC Region I to
.. cuss several security violations (IR 87-30) 09/24/87 NT NRC Director of the Office of Nuclear Gesctor Regulation, the Region ! Administrator and ett er senior NRC managers met with the 11censee in Gethesda, M3 to discuss licensee activities s ad restart readiness (NRR meeting transcript) 09/30/87 NRs Enforcement conference at NRC Aegion I to discuss several security violations (IR 87-10) 10/05/87 NRC NRC Commissioner Bernthal toured the plant and attended a licensee presentation O
30,08/87 Com,oe eaith of Mass. NRC Re,ien i idatei,trator aed other sent r NRe eanagers met 4t Region 1 with reprosentatIves of the CMaonwealth of Mass, and two private ci tizens to tensver questions regarding t te NRC inspection p'ocess (II 87-45) 10/29/87 Dunbury of Seloci, Scard men Four NRC Region I and NRR management representstises participated in a pub 11: meeting '
sponsored by the Ouxbury Board of Selectmen, Ouxbury Extrgency Response Plan Cormittee and the 09xbury Citizus' Committee on Nuclear Matt,at s In Dwabury, M 12/08/87 NRC
, NRC Region ! Adainistrator toured the plant and met briefly with licensee management to discuss tour observations (!R 47-57)
O e
O
11,D.
ASSESSMENT ACTIVITIES AND RESULTS BACKUP SLIDE 22C Table 5 3 O Otte s,0~s0R Toarc 01/07/88 United States NRC Director of the Office of Nuclear Reactor senator Regulation and the Region ! Administrator Kennedy appeared before the senate Labor and Human Resources Committee regarding Pilgrim. The public hearing was held in Plymouth, Ma, 02/18/88 NRC HRC Region I and NRR managers conducted a public meeting in Plymouth, M to solicit public comments on the licensee's Restart Plan 02/24/88 NRC Management meeting at NRC Region I to discuss the licensee's self assessment process to be l used for determining restart readiness (IR 88-10) 03/10/88 NRC The NRC Director of the Office of NRR and the i
i Region ! Administrator toured the plant and int.erviewed licensee staff regarding the design basis for the direct torus vent modification (IR 88-07) '
04'09/68 NRC Management meeting at NRC Region I to discuss O t.he licenset's proposed power ascension test areer >> (seesias xiaus > 85-42) '
04/22/39 NRC NRC Commit $1oner Carr toured the plant and
' att,enced a 114ensee presentation (IR 88-12) 05/06/88 NRC NRC Comnissioner Rogers toured the plant and att. ended a licensee presentation (!R 85-19)
C5/11/88 NRC NRC Region I and NRR annagers conducted a public meeting in Plymouth, M to provide responses to coeunents and concerns on tha licensee's Restart Plan raised during the 2/18/48 public meeting (Meeting transcrip()
4 O
II.D. ASSESSMENT ACTIVITIES AND RESULTS SLIDE 23 l
O :
Liq 1NSING ACTIONS RELATING TO PILGRIM RESTART !
- APPROXIMATELY 20 LICENSING ACTIONS COMPLETED IN PAST 11 YEARS .
- MAJOR AREAS INCLUDE
- FIRE PROTECT 10H
- CONTAINMENT l
- SAFETY ENCHANCEMENTS
- ORGANIZATIONAL AND ADMlHISTPATIVE CHANGES
- LICENSING ACTIONS TO COMPLETE BEFORE RESTART DECISION
- FIRE BARRIERS WITH RATINGS LESS THAN 3 HOURS l
- DEGRADED VOLTAG6 IRIP SETPOINT f O
I
- STATION ORGANIZA110N CHANGES i i
f k
4 ;
I !
i !
1 t
, t i !
I l
l O r i
!! D. ASSESSMENT ACTIVITIES AND RESULTS SLIDE 24 O
P LICENSING ACTIVITIES REMAINING o RESOLUTION OF 2.206 PETITIONS o SAFETY ENHANCEMENT PROGRAM (SEP) REVIEWS i !
- o TECHNICAL SPECIFICATION LICENSING ACTIONS - 3 ITEMS 3
REMAIN OUTSTANDING FOR RESTART:
)
L (1) FIRE PROTECTICN APPENDlX A FIRE WALL RATING CLARIFICATION <
l (2) DEGRADED GRib VOLTAGE (3) ORGANIZA110N' CHANGE l
t t
i j '
i i i !
i l
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O l
II.D. ASSESSMENT ACTIVITIES AND RESULTS S 1DE 25 J
SALP 87-99 o ASSESSMENT PERIOD: 2/1/87-5/15/88 o SALP BOARD: 7/5-6/88 o BOARD REPORT ISSUED: 7/27/88 ,
9 MANAGEMENT MEETING: 8/25/88 o ISSUES:
1
+ '
PERSONNEL A!.D ORGANIZATIONAL CRANGES CONTINUED THROUGHOUT THE PERIOD, FUNCTIONAL REPORT CH/ (NS WORKING WELL
+
SIGNIFICANTLY HIGHER. STAFFING ALLUCATIONS
+
AGGRESSIVE ACTIONS IN MOST PROGRAM AREAS OF WEAKNESS SCME DELAY IN IMPLEMENTATION OF IMPROVEMENTS o CONCLUSIONS:
O (1)
- EXTENSIVE BECO EFFORTS TO IMPROVE CORPORATE AND SITE MANAGEMENT ORGANIZATION STRUCTURE
'2)
. EFFORTS GENERALLS SUCCESSFUL IN CORRECTING STAFFli1G, ORGANIZATION AND MATERIAL DEFICIENCIES (3) SELF-ASSESSMENT PROCESS SUCCESSFUL IN TARGETING MANAGEMENT ATTENTION (4) PERFORMANCE IN SOME AREAS LAGS BEHIND DUE TO LATER !
IMPLEMENTATION OF PROGRAM AhD ORGANIZATIONAL IMPRGVEMENTS ;
7 DUE TO HIGHER PRIORITY OUTAGE WORK ,
(5) A CONTINUED BECO COMMITMENT IS NEEDED TO SUSTAIN THE OVERALL IMPROVING TREND IN PERFORMANCE
. O !
W, . - - - - - -
II.D. ASSESSMENT ACTIVITIES AND RESULTS SLICE 26 SALP REPORJ Pilgrim SALP , istory Assessment Period , Post Shutdowr.
1/80- 9/80- 9/81- 7/82- 7/83- 10/84- 11/85- 2/87 Funettonal Area 12/80 8/81 6/82 6/83 9/84 10/85 1/87 5/88 Operations 2 3 3 2 2 i
3 2 2 Radiological Controls 3 2 2 2 30 31 3 32 Surveillance 2 2 2 1 1 2 3 2 Maintenance 2 3 2 2 11 2 2 2 Emergency Planning 3 1 1 1 30 3 2 2 'T.
Fire Protection 2 2' 3 1 2 -
3 2 Security 2 2 2 2 .
2 2 3I 2 Engineering and Technical Support .
1 1 i
Licensing - -
2 1 1 2. 1 2 2 Training '
Effectiveness - - - - - -
21 2 Assurance of l Quality /0A 3 3 - - - -
3 2 i
j Outage Management 3 2 2 -
1 1 1 -
- e g r
i l
l
)
O
. _ . ..._..._...____._m_
ll.D,
. ASSESSMENT ACTIVITIES AND RESULTS. SLIDE 27
() INTEGRATED ASSESSMENT TEAM INSPECTION (IATI) o COMMITTED TO "CONDUCT A REGION I DIAGNOSTIC TEA AFTER BECO SUBMITTED ITS READINESS INSPECTION R THE PILGRIM RESTART ASSESSMENT PANEL HAS INDE THAT LICENSEE PROGRAM AREAS ARE REASONABLY READY THIS INSPECTION."III o
.6/25/88 BECO LETTER 88-099 REQUESTED THE NRC TO INTEGRATED ASSESSMENT TEAM INSPECTION (IATI) ON ON COMPLETION OF THE BECO RESTART READINESS SELF-(RRSA) AND IDENTIFICATION AND SCHEDULING OF REMA T9 BE DONE BEFORE RESTART, i
o 7/11/88 IAT1.
NRC LETTER CONFIRMED REVIEW OF RRSA AND SC O
REFERENCES:
! (1)
MANAGEMENT OF NRC ACTIVITIES REGARDING PILGRIM RESTART, MEMORANDUM 7/8/87
)
I
ll D,
. ASSESSMENT ACTIVITIES AND RESULTS SLIDE 28 O '^" 'c "" ""E o lATI PURPOSE:
"TO INDEPENDENTLY REVIEW AND ASSESS THE READINESS OF YOUR MANAGEMENT CONTROLS, PROGRAMS AND. PERSONNEL TO SUPPORT SAFE RESTART OF THE FACILITY."II) o 1ATl SCHEDULE" . '
ONSITE PREPARATION 7/19-21/88 INSPECTION 8/8-19/8C DOCUMENTATION 8/20-24/88 INSPECTION EXIT MEETING 8/24/88 0
IATI OPERATING PLAN OBJECTIVE:
l "THE NRC HAS PERFORMED NUMEROUS INSPECTIONS TO DETERMINE THE STATUS AND ADEQUACY OF THE IMPROVEME THE OBJECTIVE OF THE IATI IS TO REVIEW THE ADEQUACY Q OF ANY ISSUES NOT PREVIOUSLY INSPECTED OR WHICH REQUIRED FOLLOWUP INSPECTION, TO DETERMINE IF 1"PROVEMENTS NADE ARE EFFECTIVE AND APPEAR LONG LASTING, AND TO DETERMINE IF BECO IS PREPARED TO SUPPORT THE RESTART AND SAFE OPERATION OF PILGRIM."
REFERENCES:
(1) NRC LETTER TO BECO, 7/11/86
\
O l
II.D. ASSESSMENT ACTIVITIES AND RESULTS BACKUP SLIoE 28A IATI (CONTINUED)
O ATTACHMENT A ORGAN!ZATION l 5ENIOR I l MANAGER l l l l S. Collins l I I I
I I
I IN i i TECH i I LEADER I I ASST l 1 l l l l R. Blough l l C. Warren l 1 l l l l
I I I D IN A55T l l l l M.J. 01Donato I i l I i
O ,
i i
l 1
I
. I l l l 1 1 I I l SHI P INSPECTORS I I SPECIAl.!ST INSoS I I 1 l l l L. Rossbach l l T. Dragoun l B. Raymone l l l G. Smith l l L. Plisco l l 0. Mcdonald I l F. Akstviewicz l l J. Lyash l l 1 l L. Doerflein l l l M. Evans l l l I O
. m
1,D _ ASSESSMENT ACTIVITIES AND RESULTS BACKUP SLIDE 28B { IAdEI (CONTINUED) l () ATTACHMENT B Pilorim IATI Rester Senior Manager: Sam Collins Team Leader: Randy Blough Technical Assistant: Clay Warren Administrative Assistant: Mary Jo 01Donato Shift Inspectors: Larry Rossbach Loren Pitsco Bill Raymond Frank Akstulewic2 Specialist Inspectors: HP: Tom Dragown Security: , Greg Smith Maintenance: Jeff Lyash (Bill Raymond) Surveillance: Larry Doerfietn (Frank Akstulewicz) Training /Mana2ement: Dan Mcdonald Michele Evans
- () Additional Area Assignments
Fire Protection: Larry Rossback QA/QC: Loren P11sco Seview Committees: Loren P11sco (Frank Akstblewic2) Inspection Report Coordinator: T. J. Kim i j k O
t
\
II.D. ASSES $ MENT ACTIVITIES AND RESULTS - SLIDE 29 O ' i IATl CONCLUSIONS d i i F I o EXI.T liEETING CONDUCTED - 8/24/88
- o h
IATI REPORT SCHEDULE - 9/7/88 1 l I i i o PUBLIC MEETING SCHEDULE - WEEK OF 9/26/88 t l ! i ! l O , - l l ! 4 4 l' l f l t
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II.D. ASSESSMENT A U VITIES AND RESULTS SLIDE 30 O , FUTURE ACTIVITIES IATI SALP EX1T ACRS lATI MGT SUBCOMMITEE MEETING REPORT MEETING I I s 8/24/88 8/23/88 8/26/88 ' 9/2/88 ACRS RESO UTION FULL R0P 2,20G RESTART / CAL OF S P LSSUES i COM MTG l# SUE ISSUE ISSU S ADDRESSED I I SYATUS STATUS I I i 9/7/88 _) S10N B IC C' gM MEETING MEE ING START MENT j l I I I
, s W/0 9/19/88 W/0 9/19/88 9/30/88 '
O RESTART ASSESSMENT ! PANEL EMERGENCY RECOMMENDATION PREPAREDNESS TO REGIONAL ISSUE REGIONAL ADMINISTRATOR ADMINISTRATOR STATUS RECOMMENDATION TO DIRECTOR, NRR l m i D/NRR COMMISSION RECOMMENDATION ' COMMISSION RCSTART I BRIEFING ASSENT TO EDO PUBLIC MTG DECISION I f s I COMMISSION CORRECTIVE _ DISSENT ACTIONS POWER NRC NRC - gN Oh RELEASE ASSESSMENT /SALP i
/ L O
I
!!.E. CONCLUSIONS SLIDE 31 l i
O i AGENDA ; i II. NRC STAFF PRESENTATIONS 1:45 P.M. i 1 A. INTRODUCTION ! l B. ISSUES f 1 : C. LICENSEE ACTIONS j D. ASSESSMENT ACTIVITIES AND RESULTS c j 0 E. CONC!.USION 2:45 P.M. - I ! 3 i t I [ 1 i t i t [ t l i i O i t
II.E. CONCLUSION SLIDE 32 ([) CONCLUSION o PILGRIM SHUTDOWN april 12, 1986 DUE TO TECHNICAL ISSUES (MSIVS, CONTAINMENT ISOLATION AND INTERSYSTEM LEAKAGE TO RHR SYSTEM) o ' SHUTDOWN CONFIRMED BY CAL 86-10 0F 4/12/86 o ISSUES AND NRC CONCERNS EXPANDED BY SUPPLEMEN CAL 86-10, 8/27/86, WHICH REQUIRED A FORMAL ASSESSMENT BY BECO OF THEIR READi?iESS FOR RESTART AND A RESTART PROGRAM WITH A SCHEDULE BE SUBMITTED NRC 4 o BECO HAS DEVOTED SUBSTANTIAL RESOURCES TOWARD RESOLUTION OF THE ISSUES AND THE NRC HAS REVIEW () ACTIONS REGARDING MANAGEMENT AND ORGANIZATIONAL CHANGES, NEW PROGRAMS AND IN-PLANT IMPROVEMENTS - o THE LEVEL OF NRC STAFF ACTIVITY ON PILGRIM IS VER HIGH AND WILL REMAIN HIGH IN CONJUNCTION WITH R; ASSESSMENT ACTIVITIES ' o THE LEVEL OF COMMISSION INTEREST AS WELL AS PU; INTEREST IN THE FACILITY IS HIGH I O y , - - - -+
II.E, CONCLUSION 9 SLIDE 33
~
CONCLUSION (CONTINUED) 4 RESTART CRITERIA L STABLE AND EFFECTIVE MANAGEMENT AND STAFF AT PILGRIM i RESOLUTION OF MAJOR TECHNICAL ISSUES DEMONSTRATED IMPROVEMENT IN SALP PROBLEM AREAS MAINTENANCE PROGRAM AND WORK BACKLOG ISSUES ADDRESSED NRC SATISFIED THAT CERTAIN EMERGENCY PLAN (]) IMPROVEMENTS HAVE BEEN MADE l 4 9 1 i i 1 I . ()
~
i 4 REPORT OF PILGRIM SULCOMMITTEE MEETING The ad hoc subcommittee on Pilgri m restart met in Plymouth, Mass : on August 26. The subcommittee toured the plant and the training ! center on A u g u's'. 25. 4 i I remind you that the Pilgrim Plant, a 670 Mwe PWR with a tik I l I containment, operated by the Doston Edison Co., and located a few I miles south of Plymouth, Mass., went into operation in 1972. In April of 1906, nhortly aftcr a number of equipment failures had occurred, and after an incident whi h resulted in over pressurication of the RHR system, the plant was thut down by l Boston Edinon Co. for testing and maintenance. Previous to j shutdown the SALP ratings for the operating organi: ation hei sagged to a low point, and after occurrenct of the last incident, ,
! and the shutdown, the NRC issued a Confirmatory Action Letter l
} (CAL), which confirmed that Boston Edinon must obtain NRC l l approval before restart. The letter listed a number of actions l l to be talen before restart could occur, and called for approval j by the NRC before restart began. Later, as the efforts toward restart developed, another CAL was issued which provided , additional requirements that must be met before restart. l Since the 1906 uhutdown there has been a replacement of more than l ) half of the upper and middle l ev el management responsible for ! operation of the plant, e l ar ge fraction of the backlog of 1 maintennoce that had accumulated befcre the shutdown has been i j accomplinhed, an accumulation of contamination in the plant, some , of which resulted from continuing operation with failed fuel, has [ ] been removed to che point that 90*. of the plant area la now said [ j to be accessible without special clothing or equipment, security } 1 and fire protectiati have been improved markedly. a simulator has !
+
l been purchased and incorporated into their training programs, all of their traininu programs have been accredited by INPO, they 1 have formulated and put in place a symptom bated set of emergency i procedures which go significantly beyond design basis accidentn. f I and they have formulated and installed, voluntarily, a Gafety t f Enhancenent Pr ogr am (SEP) which includes both equipment and f l training not currently re qui r e- i bv regulations. ! I I I A major concern of the NRC staff at the time of the issuance of the CALs wan what was seen as inadequate management. The two top . people now r oupon si bl e for p l arit operation, one a Vice president, j ar= new since the shutdown. Eoth have Navy nuclear bac6groundu, ! and both, cince retiring from the navy, have been annociated with h ] c omwrc i al nuclear power as consultants. T h v. have atsembled a !
- team whic5 although it retains a few of the people who wert with .
a plant cperation when it nhutdown, in in oryanization and [ j operation coapletely new. cnd tu the mMang af thene two top l l people. M,ny of the now t en members hase n a v ,- nucleat l l e<perience, some military and nome civilian, a few have
- commercial nuclear e periente. If the new team har a weM nes s, j it might be a paucity of J1 rect e c per t ence in operation of a {
j commercial nuclear power plant. 1 i \_ ; 1 1 i , i _ _ _ - . _ _ . _ _ _ _ _ __ __ ____i
e - a During our tour o* the plant I was impressed with the cleanlinuss and orderlir.ess of the place, and with the way in which the ( ) current activities were being performed. I did not visit the plant before it was shutdown, but reports from the NRC staff indicate a major positive transformation. Since they did not have a simulator before the shutdown, the one they have obtained is new and is one of the more advanced utmulators anywhere. It's capability is thought to go considerably beyond the traditional design basis accidents. It is now an integral part of operator training and retraining. As part of their SEP program they have added an additional syst em for pump trip to mitigate against an ATWS. This system opens the breakers that supply power to the recirc pumps. (It complements a system which breaks the circuit that feeds the generator exciter) They also will use enriched boron in the Standby Liquid Control System, thereby increasing the neutron poisoning effect by a factor of ... over tLee 'ht uses unenriched boron. ( - L. g 4 K4 Partly because ce the history of loss of offsite power at the Pilgrim site, 'ad partly, I suppose, in anticipation of the blackout rule, they have installed a third diesel generator, which can be connected to either of the two safety buses. Although not safety grade, it is kept on warm utendby. The installation is not, however designed to provide protection for unicmt: exposura, nor is there protection against tornados The fire protection is not what one would O and hurricanes. find in a safetv grade system. Nevertheless it undoubtedly provides added protection. They have also arrenged for a system which can be used to bring water from the fire fighting system into the reactor heat removal synten in an cmergency. The required pumping power for this system is supplied by a separate dedicated diesel. In order to protect against se,me postulated accident sequences which would produce over pressure of the torus before significant core damage occurs, they have added piping and valves which would permit unfiltered venting of the torus to the stack. This system is not yet operational, since it han not yet been approved by the NRC staff. If and when approval is obtained, they will make the system operational, and will install the anuociated procedures into their operator training. The plant does not have an approved emergency plan. Before shutdown it had a plan which had received interim approval. However, eince the shutdown occurred, FEMA, fol1ow1ng a "solf initiated" review, has revoked the earlier toterim approval. Docton Edison hau made significant funding and other support available to the surrounding towns and other government entities innide the ten mile EPZ to assist them in developing an O acceptable plan. However, an approved plan does not now exist. nor is there a reliable estimate of when one may be
?
approved. This in clearly a sticky wicket, ana is a situation which appears to be a cource of major concern among the local populace. Boston Edison has recently completed a Self Assensment of l Readiness to Restart, and has concluded that the plant and its staffing are at a point at which restart should be approved. I i We received what I would irterpret as favorable reports from the i
- NRC staff based on an exter sivo program of review performed under l the auspices of Region I s t. a f f , and including a recent SALP l report which showed major improvement compared to the period when the plant was shut down, and a report of an Integrated Assessment l Team, the results of which were given to us orally and whic.h are i now available in written form. We do not yet have the !
recommendation of the director of NRR which will go to the [ Commission before it makes a decision on the requested restart. y You will recall that the Commission has asked that we provide f commento to them before they are scheduled to make a decision on 3
.?9 art.
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h e*3 O O . EOSTON EDISON COMPANY PILGRIM NUCLEAR POWER STATION PRESENTATION TO THE: UNITED STATES NUCLEAR REGULATORY COMMISSION ADVISORY COMMITTEE ON REACTOR SAFEGUARDS SEPTEMBER 8,1988 RALPII G. BIRD, SENIOR VICE PRESIDENT, NUCLEAR ROY A. ANDERSON, PLANT MANAGER
~
O NUCLEAR ORGA:0ZAT!ON CHART O , SENIOR t VICE PRESIDENT i NUCLEAR 1 DIRECTOR NSRAC SPECIAL PROJECTS 4 BUSINESS OUALITY VICE PLANNING & EMERGENCY SPECIAL ASST TO PRESIDENT PNPS ASSURANCE BUDGET PREPAREDNESS THE $R. VICE PRF i. NUCLEAR STATION DEPARIMEtJT CONTROL DEPARTMENT NUCLEAR FOR NERNG N TOR MANAGER DEPARTMENT MANAGER HUMAN RESOURCES MANAGER OnC fJUCLEAR NUCLEAR MAflAGEMENT EtJGINEERNG SERVICES DEPARTMENT DEPARTMENT MMJAGER . MANAGER PLANNING & NUCLEAR PLANT OUTAGE TRANNG SUPPORT PLANT DEPARTA'ENT DEPARTMENT DEPARTMENT MANAGER MANAGER MANAGER MANAGER
- r,w--m- .-,-- -..-----m- -.----em n---- -,------------,-,~------,-y- , - - .w . - . - - - - - - - - - - - -- .- _ , , , - - - - . - - - -, - - . --- - - - . - - - , , , -
i o o o .
~
i i ! CURRENT PLANT STATUS i PLANT REFUELED
- REACTOR REASSEMBLED HYDROSTATIC TEST COMPLETE ILRT COMPLETE MAJOR MODIFICATION WORK COMPLETE i~
PLANT CLEAN AND DECONTAMINATED
!- o o o . 1 4 l l 1 i SAFETY ENHANCEMENT PROGRAM ! EQUIPMENT MODIFICATIONS AND PROCEDURE ' IMPROVEMENTS EMPHASIZE PREVENTION OF CORE DAMAGE i REVISE EOPs TO REV 4 BWR GUIDELINES l i )
- I
o o o - SAFETY ENHANCEMENT PROGRAM l l THIRD BACKUP DIESEL GENERATOR SWITCHYARD IMPROVEMENTS STANDBY LIQUID CONTROL SYSTEM IMPROVEMENTS CONTAINMENT SPRAY SYSTEM MODIFICATIONS REACTOR CONTROL SYSTEM IMPROVEMENTS BACKUP NITROGEN SUPPLY FEEDWATER -RHR TIE- IN DIESEL FIRE PUMP l DIRECT TORUS VENT I i
C 3.=2 FACILITOPERFORMANCE FUtJCTIOfJAL AREA CATEGORY CATEGORY RECEfJT TREND LAST PERIOD
- THIS PERIOD "
- 1. Plant Operations 2 2
- 2. Radic:ogical Controls 3 3 Improving
- 3. PAaintenance and FAodifications 2 2
- 4. Survei!!ance 3 2
- 5. Fire Protection 3 2 C. Emergoncy Preparedness 2 2 Improving
- 7. Security and Safeguards 3 2
- 8. En0 neering i and Technical Support 1 1
- 9. Licensing Activities 2 2
- 10. Training and Oualifications 2 2 Effectiveness
- 11. Assurance Of Quailty 3 2
- 12. Outage FAanagement and 1 FAodifications Activities
- iJoverrtaer 1,1985 to Jaruary 31,1987 " February 1,1987 to May 15,1988 FJot evaluated as a separate functional area; f andngs relative to outage activities are integrated into "Engineering and Tectincal Support , Maintenance and Moddicatons" and other functional areas as appropriate. ip,8248h
O O O _ PILGRIM STATION NON-BOSTON EDISON RAMP DOWN 0 7 2000- 5 $ } , , 3 , 2 7 ^ 1500- 7 2 g g 1000- . 4 4 44 34 5 3 22 2 2 2 2 W 7 9 70 8 9 8 26 4 4 4 26 0 L' . e
- I - -
Sep- Oct- Nov- Dec- Jan- Feb- Mar- Apr- May- Jun- Jul- AuG- Sep- Oct- Nov- Dec-87 87 87 87 88 88 88 88 88 88 88 88 88 88 88 88 22 FCRST ACTLS -*- GUARD FRCST "- ACTLS 1pi8248a
O . PILGRIM STATION NUORG OVERTIME cc e 7000 - M 6000 l 9 8 A 4 7 3 o N 5000- , 3 g 9 4000 2 0 $ $ Jan-88 Feb-88 Mar-88 Apr-88 May-88 Jun-88 Jul-88 Aug-88 Sep-88 Oct-88 Nov-88 Dec-88 NOTE:JUNTHRU DEC 72 FRCST 8 ACTUALS REFLECTS BUDGET REFORECAST j 1piS248b l
i O O 0; . PILGRIM STATION NUORG STAFFING 1000-- , 8 8
- 5 M 900-- , ,
7 2 2 s A 7 7 7 7 9 9 0 2
, 7 7 7 g 0 0 N ' 6 S *
- 800- 4 50 : : : : : : : : : : : :
Jan-88 Feb-88 fAar-88 Apr-88 fAay-88 Jun-88 Jul-88 Aug-88 Sep-88 Oct-88 Nov-88 Dec-88 NOTE: MONTHLY AVERAGES l 1pi8248c \ 1
l l 1 0 o o - l 100-- 90- ! 8 - RADIOLOGICAL 30 1 OCCURRENCE 50- REPORTS (RORs} 40-- 30-0- + + + + t"+E
- i 2/12 3/3 3/24 4/13 5/3 5/24 6/13 7/5 7/25 8/17 0 number issued E tota! open -
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i: L'29 6/f t 2/98 7/38 S/2. 9/88 SS/2 98/2% 89/93 3274 02/25 8/IS 2/5 2/26 3/22 4'3 B S/2 %/23 6/83 7/5 2/25 s/IP 1987 1988 1 pia 258a
Centrollad'~Arca Ccntaminaticn Status . Araco by Cc&minatien Levcl ~ Qv i'C as of 09/03/88 - '
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- comte.as.4 An p ee amans to the h ye.) t -
7,) ,g, PILGRIM NUCLEA OWER STATION . IP I W FF 0 m f#3 @ N C I I W C I[L[L T M C I D N @ 0 0 @TT3 03 $ ( STATUS AS OF AUGUST 23,1988 ) ALARA TRACKING 400 - - A 350_ j 300_ 250_
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=- ,,
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te r q e6 4 .13 b .
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6 m j$ I v Jan F ! y Jun Aug Sep Oct Nov Dec Jan Feb Mar Apr May Jun Jul 9 1986 1987 1988 4 1TR822Ph
LICENSED PERSONNEL - YEARS TOTAL EXPERIENCE ~ 200 - 180 - W O - Z 160 W K W 140 D. M W _ g 120 COLD LICENSE = NEED 20 DAYS ON g : WATCH >20% RCTP +5 REACTIVIIY CHANGES 4 100 - ! : > 10% CHANGES RCTP W I 80 - 4 F : . - ) 60 -
] 2 40 - -
20 - R l m : f.h5 N- - _ l if COE NU C. NOS NPRO
- NPRO WATCH (COLD LICENSE)
ENG. EXPERIENCE- . N; EXPERIENCE TOTAL YEARS
^
^
NUCLEAR NAVY h--------- -- BECo/OTHER EXPERIENCE Itr8198d
O O O . PILGRIM NUCLEAR POWER STATION 49 KEY MANAGEMENT POSITIONS j 802+ , YEARS 800 m 0 - Z W ,. x , m ., O. 600 CT',' y
;[ 467+
m s9f ~ YEARS g ~ q m. ' " 386 + W 400 YEARS
- f o
4 . 24 . i_ s, . O ~- 200 7 ^9 hae' 80+ YEARS r NUCLEAR BWR PILGRIM CURRE?fi POSmON s I tr8198a
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