ML20198E071
| ML20198E071 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 11/05/1985 |
| From: | NRC COMMISSION (OCM) |
| To: | |
| References | |
| REF-10CFR9.7 NUDOCS 8511130144 | |
| Download: ML20198E071 (111) | |
Text
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ORIGINAL UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the matter of:
COMMISSION MEETING Discussion of Exemption Requests - Environmental Qualification (Public Meeting)
Docket No.
Location: Washington, 3. C.
1 - 92 Date: Tuesdaf , November 5, 1935 Pages:
8511130144 e51105 PDR 10CFR PDR PT9.7
! ANN RILEY & ASSOCIATES Court Reporters l( 1625 I St., N.W.
Suite 921 l Washington, D.C. 20006 l (202) 293-3950 1
o 5' I D I SCLA I M EF 2
3 4
5 6 This is an unofficial transcript of a meeting of the 7 United States Nuclear Regulatory Commission held on ,b 3 11/5/85_
in the Commission's office at 1717 H Street.
9 N.W., Washington, D.C. The meeting was open to public 10 attendance and observation. This transcript has not been 11 reviewed, corrected, or edited, and it may contain 12 inaccuracies.
13 The transcript is intended solely for general 14 informational purposes. As provided by 10 CFR 9.103, it 6s 15 not part of the formal or informal record of decision of the i
16 matters discussed. Expressions of opinion in this transcEipt 17 do not necessarily reflect final determination or beliefs. No 18 pleading or other paper may be filed with the Commission in 19 any proceeding as the result of or addressed to any statement 20 or argument contained herein, except as the Cemmission may ;
21 authorire.
22 23 24 25
s i 1
1 UN1TED STATES OF AMERICA 2 NUCLEAR REGULATORY COMMISSION 3 wnn
- 4 DISCUSSION OF EXEMPTION REQUESTS -
5 ENVIRONMENTAL QUALIFICATION o ***
7 (PUBLIC MEETING'J s nun 9 Nuclear Regulatory Commission 10 Room 1130 -
11 1717 H Street, Northwest 12 Washington, D.C.
13 14 Tuesday, November 5, 1985 15 16 The Commission met in open session, pursuant to 17 notice, at 2:05 p.m., the Honorable NUNZIO J. PALLADINO, 18 Chairman of the Commission, presiding.
19 COMMISSIONERS PRiSENT:l
.?
i 20 NUNZIO J. PALLADINO, Chairman of the Commission 21 THOMAS M. ROBERTS, Member of the Commission 22 JAMES X. ASSELSTINE, Member of the Commission 23 FREDERICK M. BERNTHAL, Member of the Commission i
.4 LANDO W. ZECH, JR., Member of the Commission l
25 l
2 1 STAFF AND PRESENTERS SEATED AT COMMISSION TABLE:
2 S. CHILK 3 P. BOLLWERK 4 W. DIRCKS 5 C. GRIMES 6 H. THOMPSON 7 R. VOLMER 8 J. OPEKA 9 R. KACICH 10 N. REYNOLDS -
11 12 13 14 15 16 17 IB 19 20 21 22 23 24 25
3 1 P R O C EE D I N G S 2 CHAIRMAN PALLADINO: Good afternoon, ladies and ;
3 gentlemen.
4 The subject of today's meeting is schedular 5 extension request for environmental qualification.
6 Recently, we've had several meetings with the Statt, 7 as well as a meeting with the utilities representative to
- 8 discuss his request. At today*s meeting, we will discuss the 9 extension sought by Northeast Utilities for the Millstone Unit 10 1 nuclear plant. -
11 At today's meeting, the Statt will make a briet 12 presentation of the basis for their recommendation regarding 13 Millstone. The Stati recommended, in SECY 85-345, that the 14 subject requast be denied.
15 I understand that this paper has been made available 16 on the table in the back of the room.
17 Upon completion of the Stati's presentation, 18 representatives of Northeast Utilities will join us at the 19 table to present their arguments for the extension request 20 approval 21 No decision is planned for today's meeting.
22 However, towards the e r.d of the meeting, I will urge fellow 23 commissioners to vote as foon as possible on the SECY prper, 24 Do any of my tellow commissioners have any 25 additional opening remarks?
4 1 (A chorus of nos.)
2 CHAIRMAN PALLADINO: Then let me turn the meeting 3 over to Mr. Dircks.
4 MR. DIRCKS: I think Chris Gleason -- Grimes, I'm 5 sorry, could help us.
6 MR. GRIMES: Thank you, Mr. Dircks.
7 My name is Chris Grimes, I'm Chief of the Systematic 8 Evaluation Program Branch. As a tollow up to the meeting that 9 we had on October the 25th, at which time we had some 10 discussion on Northeast Utilities
- proposal relative to ISAP ,
1 11 and the explanation of the Statt*s rationale for developing 12 recommendations for approval or denial of the EO extension 13 request for ten other licensees.
14 I'm going to brsefly walk through the Statt paper 15 and explain the views we developed based on Northeast to Utilities
- September 30th, 1985 EQ extension request, as it 17 relates to Millstone Unit 1.
18 In that request, Northeast Utilities proposed to 19 resolve environmental qualification for 28 motor operators 20 originally supplied by Crane-Teledyne by qualifying eight 21 motor operators, request an exemption for six motor operators, t
22 and they propose to deter resolution for eleven motor 23 operators to ISAP.
24 In comparison with the other applications, we did I
I 25 note that the Crane-Teledyne situation appeared to be somewhat l
i 1 unique in that the licensee asserts that there are no other 2 plants in the country, that they know of, that have that 3 particular motor operator. And to the best of our knowledge, 4 right now, that seems to be the case.
5 They described, in their submittal, the procurement 6 ditticulties that they had to try and achieve qualification 7 for those motor operators and their etterts to obtain the B parts necessary to put replacement motor operators in. They 9 also explained that because of those ettorts, they will have 10 all of the materials necessary to achieve qualitication by _
11 replacing all of the motor operators during their current 12 refueling outage, which started on October the 26th. But they 13 still request that those eleven valves be deferred into ISAP, 14 because they believe that the safety improvement attorded by 15 the replacement operators does not justify the cost.
le The Statt's review, in this context, has been to try 17 and relate the Northeast request to the exceptional 18 circumstances that the Commission requested in 8$-15. And in 19 the context of the licensee's proposal, the Statt concludes 20 that an indefinite referral for resolution of this issue in 21 ISAP doesn't meet that intent, and on that basis, recommended 22 denial.
23 However, the Statt also notes that based on the 24 information that we have to date, we believe that there is 23 some merit in the licensee's argument that the safety
O 1 improvement is, at best, minimal and maybe non-existent when a 2 thorough review is completed. And therefore, we're proceeding 3 by accelerating that part of the ISAP review related to these 4 valves, to try and determine before November 30th whether or
$ not their arguments would constitute a basis for exemption.
O CHAIRMAN PALLADINO: Is this for the eleven or the 7 six?
8 MR. GRIMES: The eleven.
9 With respect to the six, we believe that the 10 licensee will be able to withdraw their exemption and would -
11 not have to quality the valves in accordance with their 12 approved EQ plan, because the modifications that they will 13 make should be sutticient to term a basis for not having to 14 quality the valves.
13 COMMISSIONER ASSELSTINE: But I take it for the 16 eleven, it they choose not to quality them, they have to have 17 an exemption?
18 MR. GRIMES: At this point, that appears to be the 19 case, because we cannot make the finding that the 20 configuration of the valve, as it exists, conforms to the 21 rules that we've established for concluding that qualitication 22 i s not required. That is, a tailure in any mode would'not 23 compromise the system function.
24 However, we have walked through the system arguments 25 in relation to the safety significance of not putting in the f9
/
7 1 operators and depending on the results of the failure modes 2 and ettects evaluation that we do, we would at least conclude 3 -- I think, at this point -- that it's unlikely that they 4 would tail in such a way as to inhibit the safety functions.
5 But we're in the midst of that now, and we're not in a 6 position today to say that we have a full case to support an 7 exemption trem the rule so that the Commission could conclude 8 in some way that EQ is resolved for this plant.
9 And that is why we recommended a denial 10 CHAIRMAN PALLADINO: I have a problem with that. GE -
1 I
11 apparently put these valves in because they tnought they 12 needed them, and made them safety grade, made them motor 13 operated. Now the implication is well, you don't really need 14 them. I'm sure that GE wouldn't have put something in there 15 that we didn't need and I'm having ditticulty in following the le argument that these are not needed for safety.
17 MR. GHIMES: The original system design included 18 provisions for isolation valves to isolate the system, in case 19 that system were to become an accident. In subsequent reviews 20 of the plant *s specific probabilistic analysis, the likelihood 21 of that accident and its consequences are becoming better 22 understood, so that we can judge the ettects of failure of 23 those valves.
24 Also, it's important to recognize that an integral l 25 piece of that evaluation is the circumstances under which they
8 1 would be exposed to the environment that would cause them to 2 tail For example, the arguments related to breaks inside 3 containment, relative to valves outside containment. That's a 4 part of that safety evaluation, as well. And that also is one 5 piece of -- one of the rules by which you can conclude that 6 safety related equipment need not be qualified to the harsh 7 environment.
8 CHAIRMAN PALLADINO: I'm not sure I followed all of 9 that, but let me assume that whatever you said says that 10 they*re not needed. .
11 I have another problem and that is that PNA was used 12 to show that you don *t need these components or that they 13 bring only a very marginal safety bene 11t. Well, I thought 14 PMAs had to do with systems. You can get any component, 15 especially when you have defense in-depth system, and show 16 that the tailure of that component' would only contribute a 17 small amount to risk. But we don't'do it that way.
18 Otherwise, every time somebody has a; problem with a component, 19 you just say well I'll show it doesn*t contribute greatly to 20 risk.
21 But our concept is a defense in-depth concept and 22 this PRAs are to be systems, not component oriented. And I 23 was wondering how you react to that kind of consideration when 24 they say that this only is a two-tenth percent increase or 25 decrease n risk.
9 1 MR. GRIMES: PRAs also provide measures of 1
2 importance for the components in the system, so that you can 3 judge what benefits you get it a component in that system lg s 4 becomes damaged or not functional. And that was the way that 5 we viewed it, with respect to what additional margin in safety 6 are we getting? What measure of defense in-depth are we 7 getting by replacing these meter operators, as compared to the 8 cost both in terms of the installation costs and the person 9 exposure to install these valves?
10 And right now we've judged that that is a very close _
11 comparison.
12 CHAIRMAN PALLADINO: Incidentally, the exposure, I 13 would expect, be the same whether they do it this outage or 14 some other outage?
, 15 MR. GRIMES: That is correct.
16 CHAIEMAN PALLADINO: So that doesn't send me as a 17 pertinent argument. But getting back to components, when you 18 make the analysis on the increment that this component adds or 19 detracts from risk, you*re making assumptions about all the 20 other things and I don't know how many other things in ISAP, 21 fire protection and all the other things that go on, whether 22 we're postulating those are in good shape.
23 I think the concept of PHA is to work on a systems
, 24 basis and see it the system meets the expectations. And this
, 25 assumes that the compenents are function in accordance with l
10 1 their supposed capability.
1 2 MR. DIRCKS: But I don't think you've arrived at a I I
3 final conclusion. I think that was the point.
4 CHAIRMAN PALLADINO: Well, I was gathering that you 5 almost were retracting the substance of your paper by saying o well, it looks like they may be right on this business of 7 safety increment. And I was wondering whether you were 6 looking at it just from the components standpoint or the 9 overall system and defense in-depth concept that I think 10 permeates all our regulations. -
11 MR. GRIMES: We were looking at it from the defense 12 in-depth point of view that we did in SEP. We were trying to 13 determine whether or not, by not upgrading the system to 14 current requirements we were, in fact, sacriticing an 15 important part of defense in-depth or margin in safety.
10 And what we*ve said in our paper is that exceptional 17 circumstances aren*t there for this plant, in terms of their 18 justification for an extension, primarily because there is no
! 19 end point defined for EQ.
- 20 On the other hand, we want the Commission to 21 understand that if the licensee were to have more time to 22 develop the arguments that they had hoped to present in ISAP i
23 with respect to not having to put the operators in, we think f 24 that there is a case that can be made there. But we don't 25 know how strong that case is. We don *t know what measure of
11 1 margin of safety we would be giving up.
j 2 COMMISSIONER BERNTHAL: Well, I think there is
, 3 another point to be made. If you don *t buy the principle and 4 subscribe to the idea that all other variables may be held 5 constant and the one variable or component added and removed 6 to determine how it attects the outcome, we're going to have a n
7 devil of a time trying to do cost benefit analysis under the 8 backtit rule, because that underlies t' h e whole principle of 9 cost benefit for a particular backtit, a
- 10 So I think you have to accept the principle. -
1 J
11 MR. GRIMES: The approach that we would take would i 12 be the procedures that are described for backtit rule, in !
- 13 terns of developing a cost benefit conclusion.
i 14 COMMISSIONER BERNTHAL: Well, what are you telling 15 us today? I thought your paper supported the concept that i
16 we should be not granting an exception on these eleven valve
- 17 motor operators. And I get the impression you're backing away 18 from that.
19 MR. DIRCKS: I think, based on what we know today, 20 the arguments today, we're seeing denied. But it the licensee 21 were given more opportunity to make his arguments, provide the 22 date, based on what we*ve seen today, he might prevail -- at l
(
.3 least from the Statt*s point of view -- on safety issues. But i
! 24 we don't have all that data in yet. We don *t have all the l
25 arguments made.
l l
l
12 ;
1 But from what we*ve seen, I gather, Chris, it*s a l 2 pretty substantial concept that we agree in principle with 3 many of the points he's made. But we ve got to have the data 4 to back it up.
5 CHAIRMAN PALLADINO: What data do you need*f They*ve 6 known since at least July, when Hugh Thompson wrote and 7 appended a tootnote on the back -- a list that was appended to B his letter -- that they were going to face this. Now what 9 prevented them from doing whatever they were going to do to j 10 prove their case between then and now. .
11 MR. GHIMES: In terms of where we stood in our 12 review, we received their plant specific probabilistic 13 assessment on July the luth. We started to review that for 14 the bulk of the 80 topics that were going to be addressed in la ISAP. In August, when the generic letter was issued regarding 16 EQ, we recognised that it they didn*t get an extension to 17 their schedule, that those topics would be forcibly resolved 18 outside of ISAP and we kept reviewing the probabilistic study 19 from the standpoint of the other 79.
20 On September 30th, when we received their submittal, l
21 we started to focus on the specific attributes, particularly 22 after the October 25th meeting, when we talked a little bit 23 about the ISAP concept and how it fit in to those exceptional i
24 case criteria that the Commission wanted for EQ. And we 25 reached the point where we decided that all we can do, in 1
=
13 1 terms of justitying one way or the other whether these 2 modifications should or should not be made, would be to review 3 them to see it an exemption is warranted. It it is, then 4 elearly they*re not necessary. It it isn't, then we go on the 5 basis of cost benefit, o CHAIRMAN PALLADINO: It what isn't?
7 MR. GRIMES: It there is a case to be made for an 8 exemption, then we would support the licensee's removing the 9 eleven valves so that EQ can be declared finished and call EQ 10 done for this plant. _
11 COMMISSIONER BERNTHAL: That's the right way to go, 12 it seems to me.
i 13 CHAINMAN PALLADINO: How long would it take you to 14 complete your analysis?
15 MR. GRIMES: We hope to be able to have all of the to components to be able to complete an evaluation by about the 17 13th. But that's beyond the decision time that the licensee 18 needs, in order to know whether or not -- in order to minimize 19 the extension of his outage, it he in tact has to put the i
- j. 20 valves in.
21 CHAIRMAN PALLADINO: You said you'd have everything 22 you need to make the analysis. Would the analysis be done?
23 MR. GRIMES: Yes, we've already started people 24 working on the evaluation of the cost versus benetits of 25 installing these motor operators.
l
14 1 COMMISSIONER ASSELSTINE; That strikes me as a 2 change from the situation that I had understood, as of the 3 time that the paper was submitted to us, because I thought --
4 yes, that*s right. You have two categories. You*ve got six, 5 where I thought they had submitted their technical information 6 to support their exemption request and the Statt was going to 7 be in a position to make a decision on that and finalize the 8 exemption determination by the middle of the month.
9 And the preliminary view of the Statt was there was 10 sutticient technical information to justify the issuance of an 11 exemption for the six.
12 Now I thought the situation on the eleven was such i
13 that they intended to do the same thing. That is, their 14 objective was to present enough information so that the Statt 15 could agree that an exemption was warranted for the eleven as 16 well as for the six. But they intended to do that as part of
! 17 the ISAF program and that it would be done well down the road.
18 literally months or perhaps years from now, so that we 19 wouldn't have a final judgment as to where this plant stood on 20 EO, at least as far as those eleven items, for some long 21 period of time to come.
i 22 Are you now saying that -- in tact, I talked to 23 Harold last week, and he said that they haven't submitted the 24 technical information to support that exemption 25 determination. Are you now saying --
- . _ ~ - . -3w,gw.- - . - -,
15 1 CHAIRMAN PALLADINO: For the eleven.
2 COMMISSIONER ASSELSTINE: For the eleven. Are you 3 now saying that they have done the technical work for the 4 eleven, that they*ve submitted that information to the Statt.
5 that the Statt believes that it has enough information t o-6 reach a judgment one way or the other, and it*s simply a 7 matter of processing the exemption request and making a l
l 8 determination.
1 9 MR. GRIMES: Let me clarity that the approach that 10 you described is correct. The licensee requested an exemption -
11 for six and they wanted to deter eleven to ISAP.
12 COMMISSIONER ZECH: Are they the same kind of i
13 valves, the six and the eleven?
14 MR. GRIMES: Yes, they're all similar valves, with 15 Crane-Teledyne m o t,o r operators.
10 COMMISSIONER ASSELSTINE: They're just in different 17 systems?
i 18 MR. GRIMES: That's correct.
t 19 And the Statt view was that the Commission would not 20 accept an indettnite deterral of EO. So we decided to 21 approach the review of the eleven as an exemption and i
i 22 determine whether or not there was a sutticient basis to 23 conclude that we would likelf grant an exemption based on the 24 safety significance.
i l 25 COMMISSIONER ASSELSTINE. And that judgment would be
t 10 1 based upon a safety determination, not on the tact that this 2 is included within ISAP?
3 MR. GRIMES: That's correct We would tollow the i
I 4 rules of 50-12 to determine the safety significance of lack of 5 qualification for these valves. We have enough to start. We 6 have the system diagrams and descriptions. We've got the j 7 probabilistic analysis and we have a general understanding of i
- 8 the plant operating procedures.
9 Before we're done, we're likely going to require 10 additional information to make sure that evaluation is .
11 complete. But certainly, there are enough people working on 12 this right now, that I can say confidently that we're working 13 toward a goal of having a complete story by November the 15th.
I 14 CHAIRMAN PALLADINO: Even on the eleven?
?
j 15 MR. GRIMES: Specifically on the eleven. We're 16 concentrating all of our ettorts right now on those eleven 17 valves.
i 18 MR. THOMFSON: But I think that w3uld be predicated 4
f 19 upon any questions that we raise during our review being able l 20 to be responded to very promptly by Northeast.
21 CHAIRMAN PALLADINO: But that is a ditterent story 1 22 from what is presented in the paper.
23 MR. GRIMES: The note 2, or 2A, on page S is what I j 24 was just describing, and that was what we were trying to I 25 inform the Commission when we presented this conclusion.
i
, , l 17 1 COMMISSIONER ASSELSTINE. All right.
2 MR. GRIMES: We recognize that the licensee has not 3 applied for an exemption for these eleven valves, but we're ;
4 not in a position right now to know whether or not that 5 procedural step would be of any use. We've got the 6 information in order to start judging safety significance for 7 these eleven valves, and all we can tell you today is we think 8 that there is some merit in that argument. But we haven't 9 plugged all the holes in terms of containment integrity, 10 reliability of the systems, tallures modes and ettects, -
11 ultimate consequences, variations in release categories, and 12 all of the other things that we need to walk through in order 13 to be able to say that we have some confidence in the measurk 14 of safety.
l l 15 COMMISSIONER ASSELSTINE; Is it fair to say that one le way out of this particular situation would be to the licensee i
17 to commit to saying we want an exemption for these eleven?
18 That's wnat we intended to pursue all the way along. We're 19 willing to accelerate that to the point where we're prepared 20 to request an exemption now, to provide the technical 21 information to support an exemption determination now, as long j 22 as the NRC Statt is prepared to process that expeditiously 23 with the objective of making a decision one way or the other
! 24 by the end of the month?
25 MR. GRIMES: That would be one of the options i
1
16 1 available.
5 2 COMMISSIONER ASSELSTINE: And 11 the Statt -- 11 the 3 licensee is right, that an exemption is warranted ter these 4 eleven items, it the Statt agrees, then they're in compliance.
5 MR. GRIMES: That was what we had hoped we would
, o achieve by this, but the down side to that is that it the 7 Statt is not convinced ultimately, that there is a basis for i d 6 an exemption, we're left with a cost benetit determination and i 9 then we'd have to make a judgment and at that point, it we 10 decide the valves need to be put in, he either extends his -
11 outage or we make some other schedule or arrangement. But it 12 would most likely be an extension of the outage.
l
] 13 CHA!HMAN PALLADINO: Chris, suppose it was 14 determined that you can't grant the exemptions on these 15 eleven. When would be the next opportunity to put them in, 11 10 it weren't in this outage?
17 MR. GRIMES: !! it weren't a torced outage, it would 16 be the spring '87 outage, I believe. 18 months trom now.
4 19 COMMISSIONER BERNTHAL: I don't think what they*ve 20 written here is inconsistent with what Chris is saying. I 21 think the emphasis got lost a little bit, though, because on 22 page 2.4 you mention the eleven in connection with the ISAP i
- 23 program and the point kind of got lost somewhere that you 24 weren't even sure that they needed to be included in the EQ l
25 program.
l l
1 19 l
1 MR. GRIMES: It was ditticult to try and keep this l 2 issue straight, because we originally talked about 28 motor 3 operated valves. Three of them went away by a procedure in 4 accordance with the plan. And now they*re proposing to fix 5 some of them and we think that the rationale for fixing them 6 is too reasonable. They have demonstrated through the 7 probabilistic analysis that they have a functional 8 significance in the system. i I
9 And then there are these eleven remaining that they l
10 do not think are justitied because they're roughly an order at -
l 1
11 magnitude lower in terms of safety benefits on a probabilistic 12 basis. But we've already recognized that we don't take 13 probabilistic numbers straight. We have to walk through those 14 evaluations and make sure we understand what they mean, in 15 terms of safety margin.
16 COMMISSIONER BERNTHAL: If you*re really down to 17 splitting the h et i r s , though, about cost benetit, it sounds 18 like a pretty marginal call. I would have thought that most 19 things in EQ were something that an engineer could take a look 20 at and say this clearly belongs in EQ.
21 MR. GH!MES: Well, I think that a good example is 22 the case where you have one valve inside containment and one 23 valve outside. The purpose of the valve is to isolate the 24 system in the event of a break in that system. It's not the 25 design basis accident, but it's certainly an accident that
1 I
20 1 should be designed against, 2 If you apply the single tailure criteria, along with 3 the lack of environmental qualitication, all I need to do is 4 tail one by EQ and the other randomly, and then I have an i
5 uncontrolled break for wnich I would like to have some e containment integrity.
7 And in the case of a probabilistic analysis, you
- 8 walk through and look at what is the likelihood that the valve L
9 outside containment, for a break inside containment, is the c
(
10 valve that's going to tail or that you wouldn't otherwise be .
11 able to mittgate it by using other systems, for example on the
! 12 LPCI loop selection valves.
1 J
13 The design basis for this plant is core spray, not 14 LPCI. This is the only plant in the country with a FWCI
$ 15 system instead of --
! 10 COMMISSIONER BERNTHAL: A what?
^
17 MR. GRIMES: F-W-C-I, for the benefit of the to transcriber. As opposed --
i 19 COMMISSIONER BEMNTHAL: And the Commission.
20 MM. OHIMES: -- as opposed to a high pressure core 21 spray system -- or a high pressure cooling injection system, 22 as most BWHs have.
23 So these are the unique aspects and in any other 24 safety issue, where we get 90 percent of it done and you're 25 looking at the last 10 percent, that's when you start to
r
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. l l
21 1 consider the plant specttic teatures. And that's where we i
2 stand in this evaluation.
4 3 CHAIRMAN PALLADINO' Chris, I still come back -- !
4 they've known at least since July that this was a problem.
i 5 And I know they were working on the whole spectrum of things, 4
i e but somewhere along the line -- prior to this last moment --
j l 7 couldn*t they have provided the information necessary for the t
i 8 Statt to make its analysis, so we don *t come down to the wire?
9 MM. GHIMES; In a July screening review, we i
t 10 identitled a note in the list of issues for Millstone Unit 1 ,
11 that recognised that the licensee was going to have to do l 12 something about 28 motor operator valves.
I 13 CHAIRMAN PALLADINO: Yes.
l 14 MH. ORIMES: In February, wnen we granted them an ,
l 15 extension untti November, we told them that they were going to
! r J
j 10 have to do something about these 28 motor operator valves.
17 But this is one of 80 issues that !*m trying to embrace before 18 the end of this year. And we have been reviewing the larger i
19 p i c t t.r e in order to try and get a handle on all of the issues. !
l 20 We got to this point in time and realised we*re i
21 going to have to tocus on this one issue in order to get to i
l 22 the other 79.
i 2 *J CHA!HMAN PALLADINO: But did they provide all the ,
24 information?
25 MM. GRIMES: They've provided all the information
. - _ __ - _ . .. -- _ _ _ _ _ - _ .- ~ , . - __ -.
l a
i .
22 i
1 that we need in order to proceed with our review, but not for 2 us to conclude the review with respect to an exemption for d
3 these valves. That's a decision that was not made until the 4 end of October.
5 CHAIRMAN PALLADINO: But still in July they had a 6 tootnote to their list of equipment that says "The licensee 7 plans to complete all the environmental qualitication of 1
8 electrical equipment according to 10 CFR 50.49 Schedule 1
9 requirements, except for the motor operators for the 28 safety 1
10 related MOVs. Before these motor operators can be installed. .
l 11 their etteot on the ongoing projects such as the seismic l
j 12 analysis need to be evaluated."
}
I 'J So we all knew, at least at that point, they were i
14 going to be ready on everything except these motor operators, 15 and I still have trouble figuring out why they didn't provide 16 the data and give us a chance to do the evaluation before this 17 late date.
I le '4R . ORIMES: The licensee has requested of the 19 Commission. an extension to resolve this issue in ISAP. They 20 did that an September 30th. That was the first time that we 21 saw the new JCOs for these valves. Up untti that point, we 22 had simply seen the systems addressed in the PHA, But nore
. 23 importantly, at that time the Statt, too, expected that this 1
I l 24 would be an issue of these valves are either going to be 25 addressed in ISAP or they're going to be addressed outside
j .
a i 23 i
1 ISAP.
i 2 CHAIRMAN PALLADINO: Well, in this letter you tell 3 them it's going to be outside ISAP.
4 MR. GRIMES: No, sir, !
5 CHAIRMAN PALLADINO: Well, let me read a paragraph a
o that leads me to believe that. This is a letter of July 31st, 7 1 think from Hugh Thompson, it I remember correctly. And I 8 had it typed in large type so I can read it. It's on pages a
9 tour and five of that letter.
4 j 10 "As a result ci the Statt screening review of topics .
1 11 to be addressed in ISAP, we note that there are a tow issues l
12 that may require exemptions or license amendments to deter 1
13 action until ISAP is complete. In accordanca with the i
14 required procedural practices, you should separately request i 15 the necessary aremptions or 1toonse amendments to deler these j lo faquirements. We will act on such requests promptly. Your l
j 17 requests for deterral or exemptions should clearly state the 1
te justification for continued planned operation and compensatory 2
i 19 plant design teatures which form the basis for which you have j 20 concluded that the issue involved may be deterred untti a more ,
1 21 ettective resolution implementation schedule can be developed i i
22 trem the integrated assessment "
i
! 23 The implication is that it was well known that this 24 was going to have to be treated and it was well known in, at i
i l
25 least July 31st.
l
I i .
24 1 MR. THOMPSON: Yes, sir. And I think that is 2 correct, that we recognized at that time that we did not have 3 the authorization with respect to the EQ to go beyond that i
4 which we'd already acted on. And therefore, we wanted to
$ clearly identity the responsibility rest with the utility to 5
O do that.
7 CHAIRMAN PALLADINO: Let me ask one question.
8 What's your recommendation at this moment? Is it the same as o
9 in here?
10 MR. THOMPSON: Well, I think the Statt indicated in 11 their presentation last time -- this probably was the most i
12 ditticult one, weighing the issues and gleaning the wisdom 13 t r o:a the Commission's guidance to the Statt, as to what sere i
14 the criteria that we wished -- that you wish that we apply.
15 We came down on the tact that this really was an 16 issue that was not totally beyond the control of the utility l 17 and that theretore the basis for an exemption -- an exteniton l 18 did not apply. However, we did believe that they had l
19 sutticient information and t re a t they had submitted to us, I
20 which we had under review, that might form the basis tor, in
~
i 21 tact, exempting this material -- these valves -- trem the 22 Commission's requirement to have them qualitted by November 2
23 30th, 1
24 So our recommendation to the Commission was, and 1 25 believe sill 1 is, that we don't believe the standards that the
2 *>
f 1 Commission had given us had been met for an exemption.
J 2 Now there are competing interest, and that is ISAP, 3 which was not -- I don't believe -- one of the issues that the 2
4 Comnission asked us to apply in making our judgment. It the
$ Commission wishes that, we don't see a safety problem at this I o time in granting an extension, though it does not resolve the 7 EQ problem for some period of time.
l 8 So there are competing issues here, and I think 9 that's one of the basis and one of the reasons we think it's 1
1 10 appropriate for you to hear trom the utility on this issue, ,
d i 11 because they have a viewpoint that I think is clearly one I,
12 that's important for you to hear.
13 CHAIHMAN PALLADINO: Have we made an agreement on i,
14 ISAP on this plant? I don't think we have, not it I recall
$ 15 what I read, f !
to MM. THOMPSON. With respect to these valves or with 4 ;
17 respect to --
18 CHAIRMAN PALLADINO. With the ISAP program.
- 19 Someplace it says which has not yet been approved. And I i
i 20 think it was in a Northeast Utilities letter, but !*11 have to 1
21 lind it.
22 MM. THOMPSON: Chris, do you want to --
1 23 COMMISSIONEN HOBERTS; I'm not sure it I understand ,.
i
- 24 what Hugh said. The Statt sees no threat to public health and i
! 2$ safety it the plant operatesV i
1
l 26 l
1 MR. THOMPSON, Let me just check that That*s my -
2 memory.
3 MR. GRIMES: That's correct T!. ore are approved 4 JCOs for this equipment. Those justifications for continued 5 operation go beyond just the standard, there's another system 6 or another component that can serve the function. o 7 CHAIRMAN PALLADINO: Isn't that true of all of i
B these? They all have JCOs.
9 MR. GRIMES: That's why I observed that these 10 Justifications for continued operation go beyond that. That _
l 11 is the basis by which we*ve judged that there is a chance that 12 they might have an exemption.
i
) 13 MR THOMPSON: I would say that certainly is the 14 case for all recommendations we submitted down to the i 13 Commission. We see no health and safety issue with continued i
16 operation. We have not submitted Fort St. Vrain down to you, 17 y e t'. ,
19 -
COMMISSIONER BERNTHAL: I .t'htnk that's probably not 19 the driving issue here. It's whether the Commission means 20 what it says when it sets a deadline.
c 21 What i s this business about timing, though? Somehow i 22 tnat ran by me. The 15th of November and what happens? Does 23 the world come to an end it we go past that*
24 MR. GRIMES: No, let me try and put a little
( 25 historical perspective to it, going back to the roterence to i
i
,,, y , -. . . - ,. ,.-,.-_ _.. ,_, ,
27 1 the July 31st screening review, 2 We started ISAP review for Millstone Unit 1 in June, 3 following the issuance of SECY 83-100, that described the 4 cut down, modified ISAP pilot program. By August the 31st --
3 July the 31st, excuse me, we had identitled 80 topics for 6 Millstone Unit 1, 70 topics for Haddam Neck and we were 7 underway with the review of Millstone I with the intent ot
. 8 completing it by the end of the year.
9 At that time, we were also learning about a new 10 probabilistic analysis that had been created for Millstone -
11 Unit 1 We were looking at a large number of issues. One of 12 them was the qualitication of 28 motor operator valves 13 originally supplied by Crane-Teledyne.
14 We reviewed the overall FRA to see whether or not wo 15 had any confidence in it, and we have contractors working 4
16 right now providing risk perspectives for about half of tha 80 17 topics for Millstone Unit 1. !*ve asked them to stop working 18 on the 40 and work on this one, in terms of looking for all of 19 the holes in the assumptions, all of the questionable areas 20 that would influence a judgment about what kind of margin of 21 safety are associated with these valve operators.
22 COMMISSIONEH HERNTHAL: Let*s see. Let*s get down f 23 the schedule. And you expect that to be done by when?
24 MH, GRIMES: About November the 15th.
i 25 COMMISSIONEH BEHNTHAL: And what*s the problem with l
? . .
28 1 that for the utility?
2 MR. GRIMES: The utility, it he's going to put the 3 valves in this outage, in order to constrain tne extension of 4 the outage, needs to make a decision this week -- because he*s
$ in the outage right now -- on whether or not he goes or he ,
6 doesn't go. It he goes, he*s got to cut pipes and pipe 7 supports and things and make provisions for the new valve 8 operators.
9 It he doesn*t, then it*s going to extend the outage 10 oven further. -
11 COMMISSIONER BERNTHAL: Unt11 when?
12 MR. GRIMES: The original estimate, I think, was two 13 to tour weeks additional, but it depends on where in the 14 outage you make that decision, because these are spatial 15 dependent modifications.
to COMMISSIONER BERNTHAL: And ii he goes ahead, then, 17 and goes back into operation, then we're looking at a date 18 quite tar down the line.
19 COMMISSIONER ASSELSTINE: And in tairness, I think 20 isn't what the licensee is doing here, as basically hedging 21 his bets. He t h i e jc s that an exemption is justilted for these 22 eleven motor operators. That's what he intends to pursue.
23 And you think you can make a decision on that by the end of 24 the month.
25 But what the licensee has basically asked for is it l
29 1 the -- Just in case the Stati comes out that these things
- 2 still have to be qualified, that an exemption is not j
3 warranted, then what the licensee wants to do is rather than I
i j 4 extend its outage -- or his outage -- this outage -- simply 5 put these ott until sometime in 198??
i 6 MR. GRIMES: But I think it's more than that. I 7 think that the licensee has asked the Commission to schedule 8 those modifications using the procedures that have been set up 9 to schedule all of the results of ISAP. That is --
i 10 COMMISSIONEM ASSELSTINE: Which means it might not .
11 even be March 1987, it might be well beyond that.
I 12 MR. GHIMES: That's quite conceivable, i
i 13 CHAIRMAN PALLADINO: That's what bothers me.
14 COMMISSIONER ASSELSTINE: So it's an open-ended --
[
15 that*s rignt. That's what bothers me, too. l i
l 16 MM. GMIMES: That is the fundamental basis for the l
17 Statt's recommendation, that they deny it because it's clear 18 to us that you want to call EQ tintshed.
19 COMMISSIONER ASSELSTINE: That's right.
20 COMMISSIONEM WEMNTHAL: Well, but you know the other i 21 side of the coin here is -- I realise that ISAP is not I
4 l 22 something that we have permitted to be advanced as a 23 legitimate argument. Nevertheless, the Commission urged i
- 24 utilit es to participate in ISAP and I believe the conditions l 25 -- or the understanding that went with that kind of
)
r 30 1 participation was that the items you expiteitly and 2 specifically exclude from ISAP are those things that were 3 essentially public health and safety. They would be outside 1
4 of ISAP and you'd tix them immediately.
5 So .somehow we're caught in our own dilemma, in a i
j o sense.
7 MR. DIHCKS: There*s always going to be something 8 that you don't want extended that might have to be extended. >
9 Something has to give in IBAP.
10 COMMISSIONER BERNTHAL: Yes, we put these things -
11 outside ISAP. But then by definition they should have been
! 12 tixed a long time ago anyway, and the question snould never 13 have arisen- They're within ISAP and therefore, in principal, q
14 they're not essential to public health and safety as we've j .
l 15 already said. And the question becomes then --
' to CHAIRMAN PALLADINO: Well, we're not sure whether I
17 they're 1:eportant -- how important they are to public health
{
18 and safety.
a 19 COMMISSIONEN HERNTHAL: Well, we were just told that J'O they're act -- that's not the issue here.
1 21 CHA!NMAN PALLADINO: Well, I just have trouble !
22 accepting that.
2 ') COMMISBIONEW BEMNTHAL: Commissionov Noberta just i 24 asked the question.
25 COMMIS810NEN HOWENTS: I just asked the question.
i
I 31 1 COMMISSIONER BERNTHAL: That's not the issue.
2 MR. GRIMES: There's a distinction that we always l
l 3 make about immediate threats to public health and safety.
i 4 Those are things that are clearly required in order to make 5 sure that the plant does not pose an undue hasard. As opposed 6 to areas where we develop justitications for continued 1
7 operation, where we sacrifice a Targin of safety for some 8 limited time until a corrective action can be developed.
9 In this case, EQ has been riding on Justifications i 10 tor continued operation that have dwindled down slowly but .
11 surely since 1977 or thereabouts. And this is one case -- the i
12 most ditticult case that we had to look at, where we said, the i'
13 justification for continued operation is so persuasive it 1
14 might constitute a basis for an exemption.
)
15 The licensee clearly stated in his September 30th 16 submittal that they are confident that the results ot ISAP 17 will agree, and conclude that no further modifications on 18 these valves are warranted. But they're not going to t
l 19 foreclose that decision, just in case in an integrated sense i
1 20 they find they want to improve system reliability by moditying
, 21 those valves for other reasons.
i 22 I may have read more into the language in that i
! 23 letter than ! -- than you'll tind. But clearly that was the I
24 message that we had, that we discussed to a limited extent on
! 25 the 2$th.
i
32 1 CHAIRMAN PALLADINO: Does this ISAP include a plan 2 for each outage well in advance, or as it just something that 3 develops during the next 18 months
- 4 MR. GRIMES: We envision that the integrated j $ schedules that would evolve trom ISAP would look a lot like 2
6 the integrated schedules that were developed for Duane Arnold, 7 Pilgrim, and other plants that are proposing integrated 8 implementation schedules.
9 CHAIRMAN PALLADINO: Well, do we have an integrated 10 implementation -- -
11 MR. GRIMES: We will not develop one for Millstone 12 Unit 1 until we complete the review that decides what 13 corrective actions should be done to resolve the 80 topics.
14 And then they will develop an integrated schedule to resolve j 15 this.
1 16 CHAIRMAN PALLADINO: Is there one without regard to j 17 these 80 topics?
18 MR. GRIMES: No, in our July 31st screening review, f 19 we noted those activities that the licensee had ongoing, 20 independent at ISAP, that would keep him busy until we could !
21 develop an integrated schedule.
i i 22 CHA!MMAN PALLADINO: See, somewhere I know I read
(
23 s o m et t h i n g to the extent that there was something not developed I '44 get on the ISAP with regard to this program, and you seem to i
25 confirm it So we don't have a real ISAP for this plant
33 1 MR. GRIMES: We haven't finished one yet. We had to 4
2 stop and do an EQ review.
3 CHAIRMAN PALLADINO: Well, that*s part of the ISAP.
4 MR. GRIMES: We have a similar cirenmstance that 5 will arise, I think on ATWS, because there's similar language 1
e in terms at developing plants and schedules for ATWS I
7 modifications. And about a halt of dozen to a dozen of the 8 topics in ISAP relate to ATWS.
9 CHAIRMAN PALLADINO: Well, let me ask you one other 10 question then I think I*11 be through. Would the amount et .
11 time that would be taken to make the modifications that have 12 to be made, it they have to be made, would that time be not 13 additive to a tuture outage? Or would it still take an 14 additional eight days to whatever else they're going to do?
15 MR. GRIMES: My expectation would be it would not be 16 a critical path for the '87 outage.
17 CHA!HMAN PALLADINO: But I presume they*d have to 18 not do something else in order to permit that. Because I 19 gather you*ve got to cut pipe hangers, pipes, put in valves.
20 MR. GRIMES: The moditications probably could be 21 scheduled well in advance once a decision is made that these 22 particular valve operators need to be installed. Up untti now 23 -- I don *t think the licensee even now has all of the 24 materials that -- they*11 arrive sometime during the outage.
25 But he hasn*t had an opportunity before this time to plan 1
, 34 1 ' ahead to install all the motor operators, even it they had
)
! 2 Socided that'they were all Justitied. i 3 COMMISSIONER BERNTHAL: It sounds to me like the 4 dicensee is in a no-lose situation though. It it simply goes e
5 --
, 6 CHAIRMAN PALLADINO: Either that or a no-win. ,
7 ~ COMMISSIONER BERNTHAL: Well, depending on your e point.ot view, I guess. But why wouldn*t they just go ahead 0 -- wheh*3 their outage scheduled to end.
1 10 MM. GRIMES: They're.in an outage that started on _
i /
J .,
11 October 26th and it's supposed to end Novemoer 30th.
12 COMMISSIONER BERNTHAL: November 30th.
)
13 CHAIRMAN PALLADINO; And they say this --
14 MM. GRIMES: Yes, November 30th.
l 15 ' COMMISSIONER BERNTHAL: And it would take them six 1 * ,
10 to eight weeks to do this?
{
17 CHAIRMAN PALLADINO. No.
16 MR. ORIMES: No. It they know tomorrow -- I think 19 they said November 6th -- it they know tomorrow that they have 20 to put the valves in, then it will be at least eight' days, it 21 things go as planned. Longer it things go wrong.
22 [ Commissioner Roberts leit the room.1 23 COMMISSIONBR BERNTHAL: So they could tintsh in this 24 outage in any< ease.
i r.
25 CHAIRMAIU! PALLADINO: Yes.
t i
l
. 1 i
35 l
That's correct.
COMMISSIONER ASSELSTINE:
1 Why don't they just do it?
COMMISSIONER BERNTHAL:
2 They*re right here.
CottMISSIONER ZECH:
3 Well, I*11 let the licensee explain 4
MR. GRIMES:
5 that to fou.
They're going to explain 6
COMMISSIONER ASSELSTINE:
that. That*s right.
7 4
But on the other hand, 11 8
COMMISSIONER BERNTHAL:
ahead and your decision is what your 9 they decide to go They may ,
10 decision is, they've not lost much, it seems to me.
11 have to shut down, but they're going to be shut down anyway 11 12 they don't go ahead.
Say that again, Fred. I missed CHAIRMAN PALLADINO:
13
- 4 If they have to extend the COMMISSIONER BERNTHAL
15 11 16 outage, they're going to lose the operating time anyway.
17 they gamble on the decision and the Statt's paper coming out It 18 and saying that they don't have to do it at all, they win.
they haven *t lost.
19 the Statt says they have to do it, to shut Well, yes, they'd hav CHAIRMAN PALLADINO:
20 down --
have a special shutdown, unless we let them go until 21 22 1997. #
Well, precisely. And tinish COMMISSIONER BERNTHAL:
23
-- well, 1 guess that 24 --
Well, it would be more CHAIRMAN PALLADINO:
25
30 1 COMMISSIONER BERNTHAL: -- it would be better to l l
2 dovetail it, of course, at this -- well, never mind. I don't 3 run power plants.
4 CCMMISSIONER ZECH: We*re just talking about 5 Millstone plant, Unit No. 1, I presume; is that right?
6 MR. GRIMES: That*s correct. Millstone Unit 2 7 compiies with the EQ rule. We discussed Haddam Neck on the B 25th.
9 [ Commissioner Roberts returned to the room.]
10 COMMISSIONER ZECH: Right. -
11 MR. GRIMES: Millstone 3 is working towards a 12 license.
13 COMMISSIONER BERNTHAL: Well, maybe we also ought to 14 get clear though what the objection would be simply to going 15 ahead. I*d be --
16 CHAIRMAN PALLADINO: 56 million, among other things.
17 COMMISSIONER BERNTHAL; You know, 11 the question is 18 rapiditurn-around, I'll make a decision by the end of the day.
19 COMMISSIONER ZECH: -I think we 6ught to hear from 20 the licensee and see what they have to say.
21 CHAIRMAN PALLADINO: Yes, very definitely.
22 COMMISSIONER ASSELSTINE: I had a couple more 23 questions of the Statt before we go to that though.
24 CHAIRMAN PALLAdINO: Go ahead.
25 COMMISSIONER ASSELSTINE: Chris, could you describe l
37 1 briefly the systems where the 11 valves are located, and the 2 safety function that the valves are intended to perform. And 3 what the benefit is of those valves as you understand it, both a
4 for design basis accidents and for accidents that go beyond
, 5 the design basis?
6 MR. GRIMES: I'll take my best shot.
7 COMMISSIONER ASSELSTINE: Okay.
8 MR. GRIMES: There are tour valves that are in the 9 low pressure coolant injection system on the containment spray 10 lines. They are the valves that you would open in order to -
11 take LPCI flow to the containment spray rings inside 12 containment. They do not serve a function in a design basis i
13 accident analysis. I believe that they serve a function with 14 respect to coping with steam bypass to the wet well. Or 15 knocking down steam in the dry well for very small breaks.
16 They're outside the containment. Therefore, the 17 licensee contends that the lack of radiation qualitication and 18 aging are not significant with respect to accidents that would i 19 happen inside the containment.
20 For accidents beyond the design basis, the 21 containment sprays could serve to scrub iodine. And depending 22 on how severe the core melt you want to make it, you'd have to 23 get at the extreme end of the core melt range to get radiation 24 through the containment of sutticient magnitude to exceed what 25 we consider mild environment radiation.
38 1 COMMISSIGNER ASSELSTINE: Okay.
2 MR. GRIMES; There are two valves in the isolation 3 condenser system. They're system isolation valves in the 4 event that there's a break in the isolation condenser system.
5 Under the circumstances of a break in that system, 6 it's hard for me to envision how you get to a core melt
? accident unless you tail a lot of other things. The potential B reduction in core melt frequency is like 2/10,000ths of a 9 percent. So it's more from the system reliability point of 10 view in terms of tallure of the valves. _
11 Clearly, 11 you have a tailure in that system and a 12 tailure of the unqualified valve you could have an unisolable I 13 break. But that doesn't necessarily go straight to core L?lt, )
14 depending on what the rest of the event sequences go through.
13 CHAIRMAN PALLADINO: But core melt is not the only 16 thing we*re interested in.
17 MR. GRIMES: No, but I'm talking about a tailure of 18 that system that would then breach containment.
19 CHAIRMAN PALLADINO: Yes, I understand.
c 20 MR. GRIMES: And then another series of tailures 21 that would cause enough radionuclides to be released so that 22 that breach of containment would become significant.
23 COMMISSIONER ASSELSTINE: Are those ' salves in or 24 outside et containment?
23 MR. GRIMES: I think it's one each.
$9 1 CHAIRMAN PALLADINO: How big are they? l 2 MR. GRIMES: They proposed to fix one of them, in 3 order to improve the reliability of the isolation condenser.
4 And that was the normally closed valve. The two valves that 5 we're talking about are normally open, and would only close it 6 there's a break in that system.
7 CHAIRMAN PALLADINO: How big a line are these valves 8 in? The ones that might bypass containment.
9 MR. GRIMES: I'm afraid I don't recall, but I would 10 say -- -
11 CHAIRMAN PALLADINO: Big, little, medium.
12 MR. GRIMES: -- it's eight to 14 inches.
13 Well, that's not an ~
CHAIRMAN PALLADINO:
14 insignificant break in containment. And we do rely on 15 containment, aside from core molt. So, I'm a little -- well, 16 okay, go ahead.
17 MR. GRIMES: There are two valves in the reactor 18 water clean-up system, a similar situation to the isolation 19 condenser. They're system isolation valves in the event 20 there's a break in the reactor water clean-up system.
a 21 There's a higher --
3 22 COMMISSIONER ASSELSTINE: The same situation? That 23 is, if you had a break in the system and the valve tailed 24 you*d have an unisolatable leak?
25 MR. GRIMES: Yes, 11 you had a tailure in the system
40 1 in the right place that you have to rely on this valve that's 2 not qualified, and the valve is exposed to a harsh 3 environment.
4 COMMISSIONER ASSELSTINE: Okay.
5 MR. GRIMES: They're not mutually exclusive. Those 6 are spatial dependencies.
7 COMMISSIONER ASSELSTINE: Okay.
8 MR. G R I ".E S : There are the two recirculation pump
- 9 discharge valves in the recirculation loops. They're 10 classically referred to as the LPCi loop selection valves. _
11 And the fundamental basis there is that the design 12 basis for this plant is coarse spray for events that would 13 otherwise rely on Icw pressure coolant injection. And that 14 even if you have a tailure of these valves so that the low 15 pressure coolant injection flow to the recirculation loops 16 Just spilled out the break, they would rely on coarse spray to 17 keep the core cool 18 The last valve is in the line between the condensate 19 storage tank and the hot well As I mentioned before, this is 20 the only plant with a feedwater coolant injection system 21 instead of a high pressure coolant injection system. It takes 22 suction from the hot well 23 And this valve is not qualified for radiation, and 24 it sits near the reactor building equipment drain tank, which l
25 under normal qualitication circumstances you assume would be
1 l
45 1 high radiation area anc would tail the valve.
2 The proposed resolution is to put a shield in. And l l
3 it -- the licensee *s argument is, you can't get that tank hot 4 unless you have a tailure of the feedwater coolant injection 5 system that causes the fuel to failure -- tail And so they 6 don't feel that that shielding is necessary. Otherwise, you
? replace it with a qualified valve operator, which is the 8 alternative fix.
9 COMMISSIONER ASSELSTINE: Which they now have.
10 MR. GRIMES: Which they have but have not put in. -
11 COMMISSIONER ASSELSTINE: Right.
12 MR. GRIMES: I believe that that is the case.
13 COMMISSIONER ASSELSTINE: I understand the last 14 system, at least this feedwater coolant injection system may 15 be ditterent than other plants, but in the other areas at 16 least there are similar systems are there not in other 1
17 boilers, BWRs?
18 MR. GRIMES: Yes.
19 COMMISSIONER ASSELSTINE: What have the other BWR 20 licensees done in terms of qualifying the valves and 21 associated equipment like the motor operators for these types 22 of valves? Not the manufacturer but, you know, the type of l
23 equipment.
l
! 24 MR. GRIMES: Normally -- the isolation condenser is 25 also somewhat unique in boilers. There are only a few that l
l
i
- 42 1 have isolation condensers. I believe they're designed by the 2 balance of plant systems, as opposed to the vendor.
3 In terms of low pressure coolant injection and the 4 dry well sprays and the reactor water clean-up systems, I
$ imagine they're similar. And I -- quite trankly, I don't know e what all the rest of them have done. I would expect tnat they 7 would be qualified.
8 COMMISSIONER ASSELSTINE: Has anybody else asked for 9 exemptions?
10 MR. GRIMES: The likely -- -
11 COMMISSIONER ASSELSTINE: For this type of 12 equipment.
13 MR. GRIMES: Not that I know of However, I 14 understand on a generic basis that a number of the EQ programs 1$ have conditions by which you can exclude things from 16 qualification based on the arguments of not being exposed to 17 the harsh environment.
18 But in general I would expect that, they didn't have 19 the Crane-Teledyne operators so they were either able to 20 establish qualification or they replaced the valves.
21 MR. THOMPSON. Yes, that's what I understand from 22 discussion with the Statt. Typically they would replace the 23 valves with limit torque operators and then quality them.
24 COMMISSIONER ASSELSTINE: So --
25 MR. GRIMES: Or they may have originally purchased
, =
43 1 limit torques.
2 COMMISSIONER ASSELSTINE: Okay. So it appears that 3 the other licensees have qualified valve operators.
4 MR. GRIMES: That's correct.
$ COMMISSIONER ASSELSTINE: For similar equipment.
6 When was the original EQ deadline for this plant? Was it
? March or was it one of those plants that had the earlier EO 8 deadline earlier than March?
9 MH. GRIMES: It was an earlier EQ deadline because 10 we granted them an extension to March and then a second -
11 extension to November.
12 COMMISSIONER ASSELSTINE: When was the earlier 13 deadline, do you remember?
14 MR. GRIMES: The 1984 refueling outage, but I don't 15 have the date.
16 COMMISSIONER ASSELSTINE: Okay. So really their 17 original EQ deadline was in advance of March et '85.
18 MR. GRIMES: But in advance of that, the licensee 19 recognised and informed the Statt that they were having 20 trouble trying to get qualification for these particular --
21 actually, that it, depending on how you define items, this 22 could constitute one item. And they have kept us abreast of 23 their ettorts to try and achieve qualification for this one 24 item.
25 COMMISSIONER ASSELSTINE: Okay. And apart from this i
l
, =
44 1 most recent question about the ISAP relationship, have they 2 had a diligent program that's kept you informed and has 3 diligently pursued the qualification of both these stems and 4 other equipment at the plant?
6 MR. GRIMES: We have focused for some time just on 6 these 28 motor operated valves. And it's hard for me to 7 characterize diligent other than to describe the licensee *s 8 chronology of ettorts to try and get, first the original 9 manufacturer to quality them and then to get the replacement 10 parts to put other valve operators on. -
11 And depending on your view you could say that their 12 ettorts to try and decide which, it any, of these things need 13 to be qualified, whether that's an aspect et diligence or 14 whether it's not, I think depends on your point of view. But 15 they've certainly been trying to figure out a way to resolve J
16 this issue on a continuing basis, 17 COMMISSIONEN ASSELSTINE: I had one, perhaps broader 18 question. Chris, when you were talking earlier on about how 19 you were going about making the judgment of looking at the 20 need for qualifying this equipment. I got the sense that what 21 you were doing, in essence, was using cost benefit analysis to 22 decide whether compliance with the regulation was needed. Is 23 that right? Did I get a fair sense for what you were --
24 MR. GRIMES: Yes. The cost benefit analysis is 2$ certainly the first step. You need a measure or weight. And
45 1 then you have to test how good that measure or weight is.
2 I think I also mentioned that, in addition to just 3 looking at a straight thousand dollars per manrem averted or 4 some measure like that, we also have to look at what g 5 assumptions went into that analysis. Are we relying on the 6 operator to take some action to mitigate an event? Are we
? relying on certain instrumentation being available, or other 8 actions that may not be all that easy to perform?
9 So we test the cost benefit analysis with 10 engineering Judgment. And 11 we're satisfied that the cost -
11 benefit analysis is reasonably conservative then we would 12 citer that as the rationale for either fixing it or not fixing I '3 it 14 We're usually put in both positions.
15 COMMISSIONER A S S E L. S T I N E : I guass I*m a 1itt1e 16 troubled, and maybe I need to just dig into this a little more 17 apart from this meeting. But I can understand doing a 18 straight safety analysis in trying to decide whether 19 compliance with a regulation, a safety regulation is necessary 20 or not.
21 Quite trankly, as I remember the OGC memos, I think 22 it's impermissible to consider the cost side of things. I 23 don't think there*s a legal basis for considering costs in 24 deciding wnether to -- whether or not a licensee has to comply 25 with the Commission's regulation. I want to dig out some of
4e 1 those OGC memos.
2 MR. GRIMES: In most of the judgments that we're 3 asked to make about relative safety and margin of safety in a 4 plant -- 11 you're talking about the strength of a wall, or 5 the thinning of a piece of pipe, it*s relatively .
6 straightforward to develop a measure of, well, how much more 7 wall have I got left or how strong is that structure in 8 comparisons to codes and standards.
9 COMMISSIONER ASSELSTINE: Yes.
10 MR. GHIMES: When you're talking about system -
11 functions where a valve works or it doesn*t work, our rules 12 are tairly simplistic. Maybe oversimplistic. To say that 13 containment isolation is served by one valve insice and one 14 valve outside containment, in most PRAs they suggest that*s 15 too much. But in some engineering judgments that*s not 16 enough.
i 17 And so I think that we*re saying cost benefit from 18 the standpoint of giving you the structured engineering 19 judgment.
20 COMMISSIONER BERNTHAL: I think he means PRA, Jim.
21 And I think that he --
22 COMMISSIONER ASSELSTINE: Yes.
, 23 MR. THOMPSON: Right, I*ve -- I*11 maybe let Dick 24 Volmer speak a little bit since he's looked maybe at more of 25 these than I have. But typically cost is not a specific
s 47 1 tactor. There may be some uniqueness in accordance with what 2 they have made their presentation in. But, you know, the 3 exemptions that I've been involved with have not had any basis 4 in cost. You know, basically it's providing the acceptable 5 level of safety, understanding the particular systems 6 involved.
7 Chris and I'll discuss this in more detail later.
8 He*11 enlighten me as to why.
9 COMMISSIONER BERNTHAL: I think we've slipped into 10 using PHA and cost benefit analysis to -- -
11 MR. THOMPSON: Yes. And it -- you know, we -- we're 12 into this mode, this aspect so frequently and when we're 13 deciding, you know, the backtit aspects and any new 14 requirements that we clearly would do it$n accordance with 15 the Commission guidance at that time.
16 COMMISSIONER ASSELSTINE: I tell you what, after you 17 and Chris have chatted about this, why don't you send us a 18 note identifying any instances in which exemptions decisions 19 have been made based upon any considerations of costs.
20 MR. THOMPSON: Be glad to.
21 COMMISSIONER ASSELSTINE: Good.
22 MR. VOLMER: I think maybe too, we're confusing 23 exemption -- taking these valves under the jurisdiction of the 24 rule or the purview of the rule, as opposed to extension of 25 the rule. And -- which ta a ditterence.
s -
48 1 As far as the rule is concerned, it the thing talls j l
2 under the rule's umbrella under safety relatedness and the l 1
3 other areas of the rule, we have been looking at that as a i'
4 requirement to meet the harsh environment to which it could be
$ subjected.
6 COMMISSIONER ASSELSTINE: Right.
7 MR. VOLMER: Without other considerations. So we 8 haven't used the, 11 you will, the mechanistic how safety --
1 9 how important to safety it is has not been a past 10 consideration. .
I 11 COMMISSIONER BERNTHAL: I have one question.
l 12 CHAIRMAN PALLADINO: Yes, go ahead, Fred.
13 COMMISSIONER BERNTHAL: Let me throw Chris a curve 14 ball here since he seems to have had a lot of answers.
15 CHAIRMAN PALLADINO: We've been all throwing you 16 curve balls, Chris.
17 COMMISSIONER ASSELSTINE: He*s done pretty good so 18 tar.
19 CHAIRMAN PALLADINO: Yes, he's done very well 20 MR. GRIMES: The last of 11 plants has got to be the 21 test case, I'm sure.
22 [ Laughter.]
23 COMMISSIONER ASSELSTINE: That one's coming.
24 MR. THOMPSON: That's what I was going to say. Fort 25 St. Vrain's not here yet. ,
49 1 MR. GRIMES: I had planned on being out of town for Fort St. -
2 Vrain.
3 ILaughter.3 4 COMMISSIONER BERNTHAL: I realize that ISAP is not 3 supposed to be part of the consideration here. but I'd like 6 your opinion on, given the milemma that the Commission, in a 7 sense, has placed itself in because of the way it's defined 8 ISAP and the things that will lie within and without the 9 definition of ISAP, in your judgment is it fair in this case 10 to ignore the impact of ISAP on this particular situation? .
11 And as part of that question you may also want to e
12 answer whether in your judgment it has impacted the current 13 situation. New I realize that that's not something that you 14 can present to the Commission as part of your case, but I'm 15 asking you anyway, because I think this is a policy matter for 16 the Commission.
17 We, in a sense, set up ISAP and I'd just like your 18 opinion on that 19 P.R . GRIMES: Maybe I can delicately side-step that.
20 COMMISSIONER BERNTHAL: No, you can't, I won't let 21 you.
22 MR. GRIMES: I would like to observe that I think 73 it's unfortunate that we didn't get started taster in 1983 24 because this issue would be now resolved.
! 25 COMMISSIONER BERNTHAL: We the NRC?
l l
L
30 ,
1 MR. GRIMES: We the NRC and the licensee should have 2 passed that decision point, and the licensee would be 3 implementing whatever recommendations would have evolved trom 4 the first ISAP review.
I
$ I would like to also observe that I think it's 6 unfortunate that we are both a victim of timing. The 7 licensee's outage coincident with a Commission desire to 8 resolve the issue that could otherwise only be resolved in an i
9 outage that's 18 months away.
10 COMMISSIONER BERNTHAL: Right. -
11 MR. GRIMES: And so I think that -- I think it's l 12 untair for all concerned. I think that it we had taken the 13 bull by the tail and started ISAP in 1983 -- but then, that 14 wasn*t entirely the Commission's tauit either.
15 COMMISSIONER BERNTPAL: He evaded the question to beautifully.
' 17 Chaughter.]
18 MR. THOMPSON: He'd probably evade the cost benefit 19 stutt too.
20 [ Laughter.]
21 COMMISSIONER BERNTHAL: I guess I'm through.
i 22 CHAIRMAN PALLADINO: Let me tell you what I appear 23 to be hearing in part. That even those valves that ought to i
24 have equipment qualification, because they're -- it*s 25 determined they're in a certain environment -- this applicant l
$1 1 does not plan to do them, and is trying to explain them on the 2 basis of PRA.
3 In other words, we're saying PHA is now going to 4 decide whether or not we're going to comply with our
$ regulations. Is that the thrust I'm hearing?
o MR. GRIMES: No, the thrust of the licensee *s 7 request and of what the Stati calls an exemption review is to 8 make a balanced judgment on what safety benetits these valves 9 actually provide in order to establish what it is that you 10 would get from upgrading their qualitication to current _
11 standards.
12 CCommassioner Bernthal lett the room.]
13 CHAIRMAN PALLADINO: But are we doing that for all 14 applicants? Or are all of them doing that for each 15 component? Or are they just picking the ones that they just 16 haven't gotten done yet?
17 I mean, this applicant -- I just teel it*s a strange 1
18 attitude to say, well, we're going to do PRA and that*s going 19 to determine whether or not we're ever going to do equipment 20 qualitication. My worry is that they intend not to ever do 21 the equipment qualitication, even where the radiation tield 22 would say you ought to quality the equipment, because they 23 say, well, you can allow it to tail 24 MR. GRIMES: We've got to maintain --
! 25 CHAIRMAN PALLADINO: And I think I'm hearing that.
i
{
i
l 52 1 MR. GRIMES: We*ve got to maintain our perspective.
2 The licensee has completed qualification for everything except 3 these 11 valve operators.
4 CHAIRMAN PALLADINO: I appreciate that.
I 5 MR. GRIMES: And that constitutes thousands at 6 pieces of equipment. I haven *t -- I*ve been able to keep a 7 distance from EQ up until now, and so I'm not that familiar 8 with what means other licensees have used in order to get 9 specific justifications for not having to quality certain 10 equipment. -
11 I know that they*ve been doing that. In the context 12 of developing EQ programs most of them have laid out criteria 13 that establish under what circumstances they don *t have to 14 quality equipment. But I think it's -- Appendix R is the 15 closer comparison.
16 There are a number of utilities that have tried to 17 achieve compliance with Appendix R, and they*ve identified 18 specific areas where they*ve requested exemptions. And on 19 those basis, we review it for its safety benefits.
20 CHAIRMAN PALLADINO: Yes, and we're trying to avoid 21 the Appendix R situation.
22 MR. VOLMER: Yes, let*s avoid that it we can. But 23 that was the reason for my comment, Mr. Chairman. That 1 24 think what he may be referring to is an exemption trom this 25 equipment being under the EQ rule, which I think under 50.12
53 I
1 you could say, this class of equipment does not have to come 2 under the rule because. And you could make a good safety case 3 under the provisions of 50.12 --
4 CHAIRMAN PALLADINO: Yes, because it's not going to 5 face --
6 MR. VOLMER: -- and then it would be out completely.
7 CHAIRMAN PALLADINO: Yes, but as you say, it's not 8 going to face any adverse environment.
9 MR. VOLMER: That's right.
10 CHAIRMAN PALLADINO: Then that might be a good _
11 reason.
12 MR. VOLMER: Up until now --
13 CHAIRMAN PALLADINO: But 11 you find that it is 14 going to face an adverse environment, you don't get away by 15 saying, well --
16 MR. VOLMER: That's right.
17 CHAIRMAN PALLADINO: -- so it has to face it. It it 18 tails it*s only going to do 2/10th of a percent a reduction in 19 risk.
20 MR. VOLMER: In responding to your question, since 21 I've been with it since the very beginning I'm not aware of 22 any other case that has arisen like this where somebody has 23 tried to make a case for excluding something trom the 50.49 24 because of minimal safety significance, given that this piece 25 of equipment meets the criteria as specified in the rule. We
$4 1 have been going according to the rule criteria.
2 CHAIRMAN PALLADINO: Yes, that*s what --
4 3 MR. VOLMER: But we*ve always recognized that for 4 good reason you might find say, this piece of equipment 5 doesn*t fall within the rule because --
6 CHAIRMAN PALLADINO: Sure.
7 MR. VOLMER: You could make an exemption case.
< 8 COMMISSIONER ASSELSTINE: That*s right. But here 9 clearly --
10 MR. VOLMER: As we have done. -
11 COMMISSIONER ASSELSTINE: -- the equipment falls 12 within the rule. It meets, as I understand --
13 CHAIRMAN PALLADINO: Some of it.
14 MR. VOLMER: At least does tall within the rule, 15 yes.
16 COMMISSIONER ASSELSTINE: That"s right. What 17 they*re arguing is, because of the low safety significance an 18 exemption ought to be granted. That it will not substantially 19 reduce the level of safety provided by the plant it this 20 equipment is not qualified, and therefore, an exemption should 21 be issued.
22 MR. VOLMER: And it you did a 50.12 you could get 23 into the type of arguments Chris was talking about in terms of 24 safety basis and low significance and all that.
24 If I could make one more comment in response to
o 55 1 Commissioner Asselstine*s diligence. We# ve not yet done an 2 inspection, EQ inspection for this facility. But I understand 3 it's scheduled for the near future.
4 COMMISSIONER ASSELSTINE: Right, okay.
5 CHAIRMAN PALLADINO: Okay, other questions?
6 All right, then maybe we ought to hear trom the 7 representatives of Millstone plant.
N 'i~4 CHAIRMAN PALLADINO: I gather we're going be --
9 we're going to have join us at the table at least Mr. John 10 Opeka, senior vice president. And Mr. Opeka, I presume you'll ,
11 introduce your colleagues.
12 MR. OPEXA: Yes, sir. Commissioner, on my right I 13 have Rick Kacich, who is the manager of tacility licensing 14 -- supervisor of facility licensing for operating plants at 15 Northeast Utilities. And Nick Reynolds on my left --
16 CHAIRMAN PALLADINO: Who?
17 MR. OPEKA: Nick Reynolds on my left. He's legal 18 counsel 19 Good afternoon. I am John Opeka, senior vice 20 president of nuclear engineering operations for Northeast 21 Nuclear Energy Company, the holder of the operating license i
22 for Millstone Unit 1 I appreciate the opportunity to discuss 23 with ycu this afternoon our request for extension of the 24 environmental qualification deadline for Millstone Unit 1 and 25 integration of the remaining qualitication items into the
, a 56 1 Integrated Safety Assessment Program.
2 I have prepared some remarks that I believe will 3 assist the Commission in reaching a decision regarding our 4 request. After presenting these remarks, members of my statt 5 and I wou.d be happy to resopnd to any questions you may have o on this issue.
7 Let me say first that we are here today because we 8 believe that this extension of the EQ deadline is the correct 9 thing to do. Our philosophy at Northeast is driven first and 10 toremost by safety considerations. Thus, it we thought that .
11 public health and safety would be enhanced to a meaningful 12 extent by fully meeting the EQ deadline now, we certainly 13 would not be before you today. Before we have concluded that 14 safety considerations permit extension of the EQ deadline as 15 we have requested -- but we have.
16 I believe the 14 sue before the Commission today is l'? straightforward. simply stated, the issue is whether the 18 Commission should require the modification ut 11 valve motor 19 operators at Millstone Unit 1 during the current outage which 20 began on October 20, 1985, or should the Commission authorize 21 integration of qualification of these motor operators into the 22 Integrated Safety Assessment Program.
23 Significantly, the relevant tacts impacting this i
l 24 issue are not in controversy.
l 25 [ Commissioner Bernthal returned to the. room.]
.= _ . _
l
. l l
57 1 MM. OPEXA: First, our request involves only one 2 item of equipment, a certain type of valve motor operator 3 which to the best of our knowledge was used in safety related 4 applications at only two plants in the nation -- Haddam Neck 5 and Millstone Unit No. 1 We have diligently pursued 6 qualification of this item. As a result of our ettorts, all t
7 parts necessary to resolve the qualification of this item will 8 be on site tnis month.
9 In its assessment of our qualitication activities 10 tor this valve motor operator, the Statt found that we had ,
11 been diligent in our ettorts to quality the equipment by the 12 Commission's established deadline. In short, all parties 13 agree that we have diligently pursued qualification etterts 14 associated with this item.
15 As a result of these ettorts we could do all the 10 necessary modifications in our current outage for Millstone 17 Unit 1. It would require a minimum of an eight-day extension 18 of the current outage at an added cost of over to million, as 19 well as an estimated additional 105 manrem of radiation 20 exposure. This would increase the estimated occupational 21 exposure for the outage by approximately 60 percent. However, 22- the work could be done.
23 But both we and the Statt have identified these 24 modifications as elements of the ISAP ettort. Accordingly, in l
25 parallel with our qualification ettorts on this item, we i
i 58 1 performed ISAP evaluations of these valve motor operator 2 modifications. The results of these evaluations for Millstone 3 Unit 1, which are contained in the Attachment 2 -- which 1"s in i 4 the back at your package -- to your briefing package, are
$ significant.
o 01 the 28 valve motor operators of this type at
? Millstone Unit 1, eight warranted modification, and will be 8 mov.itied in the current outage. Three were removed from the 9 list because it was found that they did not require 10 qualification. Minor modifications to six allowed us to -
11 request permanent exemptions, and 11 appeared to warrant no 12 turther actions.
13 For respect to the six for which permanent 14 exemptionsheere sought, recent discussions with the Statt have I
15 resulted in agreement that these six are no longer within the 10 scope of 10 CFR 50.49. In other words, based on our ISAP 17 evaluations which were keing performed in parallel with our 18 qualification ettorts, we c cani t t e d to take appropriate action 19 on all except 11 of the valve motor operators of this type at 20 the first available opportunity.
21 The ISAF evaluation results for these 11 valves are 22 contained in Attachment 3 -- which is part of your package.
23 In this attachment, I have listed the 11 valves with the 24 corresponding decrease in core melt frequency which would be 25 realized by making modifications to these valves.
=
$9 1 As can be seen, the largest decresase in core melt 2 trequency would occur it valves 1RR-2A and B were moditted.
3 The decrease in core melt frequency from modification of these 4 two valves would be 1.5 times 10 to the -o per year. The next t largest decrease would be 2.5 times 10 to the -7 per year, o followed by 2.0 times 10 to the minus per year. And for the 7 remaining six valves, we could achieve no decrease B whatsoever.
9 In sum, the modifications of the 11 valve motor 10 operators would result in only a .2 percent improvement in the -
1 11 frequency of core melt. Based on this ISAP evaluation, which 12 was formally submitted to the Statt for review on October 17, 13 1985, I could find little safety benefit in making these 14 modifications. Accordingly, we formally requested that 15 the Commission place the qualification of these 11 valve motor 10 operators in the ISAP for Statt evaluation.
17 To review brietly, in Attachment 4, I have listed l
18 what I believe are the relevant facts impacting our request.
19 One, Northeast Utilities has diligently pursued qualitication i 20 of this one remaining item of equipment associated with the 21 request.
J2 Two, the ISAP evaluation of this item has proceeded 23 in parallel with the qualification ettorts and has not delayed 24 any qualification planning or moditications.
25 Three, the NRC Statt has stated its acceptance of
60 1 the justifications for continued operation associated with 2 these 11 valve motor operators and based on its acceptance has 3 stated that deterral of the modifications will not adversely 4 impact public health and safety.
1 5 Four, the results of the ISAP evaluation reflect 6 that there is virtually no safety benefit to be achieved by 7 modifying the 11 valve motor operators in question. The Statt 8 is still reviewing this analysis.
- 9 Five, tinally, occupational exposure associated with 10 installation of these 11 valve motor operators is estimated to _
i 11 be approximately 163 manrem. This is estimated to increase 12 the total occupational radiation exposure for the outage by 13 approximately oc percent.
14 The final point I would like to discuss involves the 15 Integrated Safety Assessuent Program itself. The Commission 16 by unanimous action endorsed this program in its November 15, 17 1984 policy statement. In that policy statement, the 18 Commission gave Northeast Utilities every indication that ISAP 19 would be a broad-reaching, comprehensive and stable program.
20 For example, the Commission stated in its policy 21 statement that "the scope of ISAP is intended to be as i
i 22 comprehensive as practical." Topics to be considered are, i
- 23 among other things, "all pending licensing actions ter the l
l 24 plant, including multi-plant actions, TMI action plan 25 requirements and specific license actions."
61 1 Further, he Commission contemplated the suspension 2 of specific implementation schedule requirements for the 3 plants to be reviewed in order to " provide a stable 4 environment" for the ISAP ettorts. Finally, the Commission 5 stated that the only exception for exclusion - tor inclusion 6 in ISAP are " issues for which the NRC Statt explicitly 7 determines that prompt action is required to protect public 8 health and safety." Significantly, the broad scope envisioned 9 by this policy has received clear Congressional support.
10 Chairman Palladino, this is the first opportunity _
11 that the Commission has had to address ISAP implementation.
12 We believe that 11 there was ever a topic that warranted 13 inclusion in ISAP, it is this topic. All agree that there is t
14 no immediate safety concern with regard to these 13 moc111 cations.
16 Further, all agree that Northeast Ottlities has 17 diligently pursued qualification of this item. Finally, 18 there is a great potential that based on the results of our 19 ISAP evaluations, no further modifications are warranted with 20 regard to this item.
21 Our voluntary commitment to tne ISAP program was l 22 based on the Commission's commitments set torth in its policy l
l 23 statement to provide a stable environment to conduct the j
l 24 ISAP. We have proceeded with the ISAP in reliance on these 25 commitments and have expended substantial resources to 1 - -
,' r ~ /
Q2 1 idplement the program. ,
d
~
2 We believe that the modifications at issue here are 3 precisely the type of action which the Commission's policy 4 statement ordorsed for integration into the ISAP. We
$ understand that the Statt supports this position.
6 In conclusion, as I stated at the outset of my
? remarks, this is a straighttorward issue. It does not involve 8 immediate public health and safety considerations, or concerns 9 about a utility tailing to do its job. Indeed, Northeast 10 Utilities has -- Northeast has diligently implemented the -
11 Commission *s quali1ication regulations and, at the same time, 12 has expended substantial r e'a o u r c e s to implement tully the 13 Commission's mandate concerning ISAP. Frankly, I'm proud of 14 our actions in both areas.
,a v I view the Commission's decision as one of policy, Y. 15 b 16 providing guidance as to the Commission *=, viewpoint on ISAP.
6 9 _17 Thts is a program that we are committed to and intend to 18 continue to implement. It is ironic that because et our i
19 , aggressive implementation of the ISAP on this issue, which was 20 supported by the Statt, we are in our current position. It we 21 had not implemented ISAP on this issue, we would not know that 22 modification of these valves would result in little safety 23 benefit while costing so much in terms of occupational 24 exposures and resources.
25 But we did implement ISAP and, based ~on that
(- - -_
e 03 1 evaluation, we did the correct thing -- we came to the 2 Commission itselt'with our request. By our request, we are 3 askir.g the Commission to let Northeast and the Statt finish 4 the evaluation and review process on these 11 valve motor 5 operators.
6 One final note, as I stated in my October 29 letter 7 to the Commission, we need prompt Commission action on this 8 request or we will be forced to do the work'to avoid turther 9 delay in the outage. We have already had to proceed with 10 preliminary work such as the erection of scattolding. In our -
11 present posture, a Commission decision on or before Friday, 12 November 8, will be timely. It no Commission action is taken 13 by that date, we will treat it as an ettecive denial of our 14 request and we will be forced to proceed with the work to 15 avoid turther delay.
16 CHAIRMAN PALLADINO: You're making it easy for us, 17 huh? Excuse me.
18 MR. OPEKA: Chairman Palladino, that concludes my 19 prepared remarks. At this time I would be happy to respond to 20 any questions that you may have with regard to our request.
21 CHAIRMAN PALLADINO: Thank you, Mr. Opeka. Let me 22 start with a few questions. And it they seem to repeat some 23 of the questions I asked the Statt, please bear with me.
24 You seem to have all your PRAs based on core melt 25 probabilities. This focus on core melt begins to worry me
A 1
, 04 1 because it's a focus on an extreme situation which we're 2 trying to avoid. And there are many other things that can 3 caus'e releases that we also ought to avoid.
4 Have you looked at the PHA from other standpoints on 5 doses that you can avert or cannot avert?
6 MR. OPEKA: Well, on our criteria for ISAP we used 7 tive criteria, public safety, personal safety --
8 CHAIRMAN PALLADINO: No, I meant your PRAs, not on 9 your ISAP. I'll come to ISAP in a minutes.
10 MR. OPEXA: On PRAs we use core melt, but we also -- _
11 I thought we had a societal type risk also. But I'm not fully 12 sure of,that.
I '3 CHAIRMAN PALLADINO: You're suggesting to me we had 14 better look at our safety goals a little closely because we 15 seem to focus on such extreme circumstances that we may be 16 bypassing other circumstances that we'd very much like to 17 avoid as well 18 MR. OPEKA: Like I said, we have core melt in there 19 and we also have outside releases to the public, too.
20 '
CHAIRMAN PALLADINO: You didn't mention that. Was 21 that significar.tly changed by having these valves operate?
22 MR. OPEKA: I don *t know but I*d be very surprised 23 it it did.
24 CHAIRMAN PALLADINO: Well, could you provide that 25 information. Even it we may a decision I still would like to
1
=
l 65 1 have it.
2 MR. OPEKA. Yes, sir. '
3 CHAIRMAN PALLADINO: Now you say -- and I marked it 4 somewhere. "Pinally, there is a great potential that based on 5 the results of our ISAP evaluations no further modifications 6 are warranted with regard to this item." Here you seem to be 7 saying that even with ISAP, even we say let*s go ahead, let's 8 let them go with ISAP, you're going to use the probabilities 9 to say, well, it*s not worth doing.
10 COMMISSIONER ASSELSTINE: That*s right. ,
11 CHAIRMAN PALLADINO: You*re just not going to do the 12 equipment qualification, even 11 the environment says you 13 ought to do it.
14 MR. OPEKA: That's correct.
13 CHAIRMAN PALLADINO: Well, that I find great 16 ditticulty in.
17 MR. OPEKA: Well, let me explain the whole process
! 18 here. What we're doing in ISAP is that we're taking the 19 regulatory requirements and we're taking our own findings and 20 putting those items in one pot. Then we use FRA and use our 21 tive criteria to find out which ones provide the greatest risk 22 to the core melt.
23 CHAIRMAN PALLADINO: Well, core melt isn*t l
[ 24 necessarily the only thing we're trying to avoid. This is l
25 what -- breach of containment, aside from core melt gives me a 1 .
-. ,-n,-- . - -
66 1 problem.
2 MR. OPEKA: Well, what I'm saying is that we're not 3 saying that we're going to eliminate it, but what we want to 4 do is make sure that we spend our money on the items that 5 provide the greatest safety benefit.
6 And to give you an example, in our analysis we found 7 that the low pressure heat -- low pressure coolant heat B exchanges in our plant are the ones that we should be spending 9 our money on because it provides 60 percent of the risk to 10 core melt. We found that independent of regulations. We .
11 tound that because of the ISAP program and we put that at the 12 top of our list to get action to get resolved.
13 And what I'm saying is --
14 CHAIRMAN P A L L A D I N O ,: W e 1.1,, my focus --
15 MR. OPEKA: -- we're spending 50 million on what wo 16 think is a non-safety issue which we should be taking that 17 money and spending it on significant safety issues, 18 independent of the regulations.
19 COMMISSIONER ASSELSTINE: Joe, if I could add in.
20 You know, I have exactly the same reaction you do. And I 21 guess this may not be the right place to do it, but maybe what 22 we need to do is take a look at the ISAP concept and how it's 23 being implemented, because it sounds to me that there's a very 24 narrow tocus here, just on the core melt probabilities. And 25 I'm not sure that that's what I or we had in mind when we
67 1 embarked on this effort.
2 It sounds like the focus is narrower than the more 3 broad-ranging focus that we had in mind.
4 CHAIRMAN PALLADINO: Well, see -- I'm sorry. I 5 keeping we fine people because they didn't close the doors all 6 the way. Well, this says, you don't care, in an equivalent 7 situation.
8 MR. OPEKA: We don't -- it's not that we don't care.
9 CHAIRMAN PALLADINO: I don *t mean to put words in 10 your mouth, but the implication comes that way. .
11 MR. OPEKA: Well, one thing too is that we can't do 12 this independently. Statt has to review it and agree with our 13 recommendations and modity them so we come up with a mutual 14 agreement.
15 But what's important though is that the whole 16 program allows us to spend the money where we get the greatest l
17 benefit. And that's the whole benefit of this ISAP program, t
18 CHAIRMAN PALLADINO: But in the end it says though, 19 you're going to use the PHA to decide that you don *t have to 20 even do anything on equipment qualification. And even though l
i 21 these things have to function in an atmosphere that is adverse l
22 to them.
23 COMMISSIONER BERNTHAL: Well, Joe, I think in 24 tairness they've done a lot on equipment qualification.
25 CHAIRMAN PALLADINO: Oh, I'm sure.
1 1
68 1 COMMISSIONER BERNTHAL: But I think what -- this is 2 an after-the-fact appraisal which I think is honestly ottered 3 that I've heard before quite trankly. And I've heard it in 4 toreign countries. That, it I handed you today $32 million --
$ to pick a random number -- would you do this and would this be 6 the most safety effective thing that you could do. And the 7 answer sometimes in foreign countries and sometimes in this 8 country has been clearly no. This is not how I would spend my 9 532 million to achieve the greatest safety.
10 CHAIRMAN PALLADINO: well, we've already made a _
11 determination as a commission that the equipment should be 4
12 qualified to work in a --
13 COMMISSIONER BERNTHAL: I agree. I'm not 14 disagreeing with that.
15 COMMISSIONER ROBERTS: But let me read from the 16 policy statement on the ISAP program. "To provide a stable 17 environment to conduct ISAP the Commission has authorized the
' 18 Statt to suspend specific existing implementation schedule 19 requirements for the plants to be reviewed."
20 CHAIRMAN PALLADINO: Yes, but they haven't suspended 21 this one. This is what I was getting at.
22 Well, let me ask you two more questions and then 23 I'll turn it over. One, you say it would add 105 manrem to de 24 it now. Would it add any less to do it later?
25 MR. OPEXA: No, it would be the same amount.
l 69 '
l 1 CHAIRMAN PALLADINO: All right And now another i
2 question. I do recognize the dilemma you're in, and we're in 3 the same dilemma, that the Statt is analyzing the situation 4 and they might find good reason why these 11 don't have to 5 pass equipment qualitication. But they won't be done until e the end of the month.
7 Now it the -- and this is purely hypothetical -- 11 8 it were to be decided -- well, okay, it it turns out you don't 9 have to do the equipment qualification then you're in 10 compliance. But it it turns out later we say, well, by golly, .
j 11 there are some of these that have to have equipment 12 qualification then you'd have to do it on a torced outage.
13 How much -- how many days would a torced outage to --
14 MR. OPEKA: Well, forced outage -- it depends on the 15 valve. But it we take the most limiting one, which is the 16 isolation condenser valve, that requires ott-loading the core 1
17 completely. And 11 -- we just don't want to get put in that 18 situation.
19 There*s another option though. The other option is 20 allowing the Statt to do their work and 11 there findings 21 indicate some of these valves should be replaced, to replace 22 them at the next refueling outage. We'd be very receptive to 23 do that.
24 CHAIRMAN PALLADINO: You mean you would agree to do 25 that?
7U 1 MR. OPEAA: Yes, sir, at the next outage.
2 CHAIRMAN PALLADINO: Yes, which would believe is 3 '87.
i 4 COMMISSIONER ASSELSTINE: Is March '87.
5 MR. OPEKA: Scheduled -- yes, spring of '87.
t 6 CHAIRMAN PALLADINO: Well, I was trying to get, you
(
7 would gamble saving 56 million versus having to spend X 8 million dollars, and I was trying to find out what X was.
9 MR. OPEXA: See, the situation we're in right now is i t that we're in the process -- we're in a refueling outage. We -
11 have to unload the core this outage for different reasons. We 12 have to unload the core in order to make repairs to at least
- 13 one of these valves. We need to know the decision Saturday.
14 In fact, we spent about 5100,000 already preparatory work to 15 minimize the impact if the decision is negative.
16 It we know by -- it we either not get a decision or 17 get a no dacision on Friday we*re going to make the 18 modifications. And that will extend our outage by about eight 19 days. It we get a yes decision then we'd be very willing to 20 let.the Stati do its work. And it their findings are that we j
21 have to replace 11 valves next outage, we'll replace them.
22 COMMISSIONER BERNTHAL: It we had told you eight 23 days ago would there have been no extension of the outage? Or 24 does that not necessarily follow?
25 MR. OPEKA: No, the eight days ago -- the eight days j
. __ _ _ _ . . . _ _ . .__ _ __- - . _ _ __ - __. _. . . _ , .- - , . , . . ~ . . _ _ , , . . , , , _ _ . . .
71 l
1 that tied to these 11 valves. ]
2 COMMISSIONER BERNTHAL: To other things, yes.
3 MR. OPEKA: These 11 valves. I mean, the eight days 4 -- in other words, 11 you told me eight days ago that we had
$ to do them it still would extend the outage eight days.
6 COMMISSIONER BERNTHAL: Okay, all right. I have to 7 make one comment. I want to make an observation here which 8 may or may not be relevant. But based on your numbers, 11 I 9 do my arithmetic right here that it costs 163 manrem to make 10 this modification. I don *t know how many manrems you _
11 associate with a core melt accident -- and I would preter 12 actually to use the term core disruptive accident, which is a 13 TMI style accident.
J 14 According to my calculations, pretty ease 15 calculation, you*d have to have a million persons getting 100 16 R to break even in this circumstance, it the probabilities are 17 what they suggest they are. And I don *t think any core 18 disruptive or core melt accident postulates that kind of 19 exposure.
20 So 11 you simply forget about cost benefit here, 21 look at manrems expended to make the conversion versus manrem 22 probability in a core melt accident, you don't make it.
23 CHAIEMAN PALLADINO: I don't follow you. Suppose 24 you reduce it to zero?
25 COMMISSIONER BERNTHAL: What I am saying is that it
72 1 ain't worth the ottort in manrem to make the modification 2 based on the probability estimate.
3 CHAIRMAN PALLADINO: What manrem?
4 COMMISSIONER BERNTHAL: 165 manrem.
5 CHAIRMAN PALLADINO: What it that were zero, or what 6 it it were twice this much? You still --
7 COMMISSIONER BERNTHAL: Well, it it were many times 8 that much you'd have a different number. What I'm saying is 9 __
10 CHAIRMAN PALLADINO: But this is not the consequence _
11 of an accident. This is how much they're going to have to --
12 the workers are going to face.
13 COMMISSIONER BERNTHAL: No, I understand, Joe. But 14 you're exposing the workers to a certain amount. And you're 15 doing that to avoid a core melt ancident which has a 16 probability -- they tell us -- of 2 times 10 to the -6. Well, 17 that implies that you're associating an expected overall 18 exposure with core melt that's totally out of proportion to 19 the exposure you would make here.
20 You can ignore that it you like, but I think the 21 numbers --
22 CHAIRMAN PALLADINO: Well, then I think we've got a 23 different philosophy of regulation because that says, well, i
24 when you have a potential for a penetration to be breached, 25 even though there was no accident that you forgive it.
l
m 73 1 Here we have --
11 the Statt determines that some of 2 these valves operate in an adverse environment and you say, 3 well, I'm not going to fix them so they can operate, I think 4 you change the whole philosophy of regulation.
5 COMMISSIONER BERNTHAL: Well, the philosophy behind 6 our backtit regulation is going to be, we say, cost benefit.
7 But we assign a cost to human exposure.
8 CHAIRMAN PALLADINO: We also said --
9 COMMISSIONER BERNTHAL: And that's precisely how 10 we're going to do it. ,
I i 11 CHAIRMAN PALLADINO: No --
12 COMMISSIONER BERNTHAL; Now I don't want to make a 13 big issue of this, I just otter it for your amusement, that it 14 really doesn't --
15 CHAIRMAN PALLADINO: We also said we want diversity, 10 defense in-depth. There were a number of things there that I 17 think we still have to consider. ,
18 COMMISSIONER BERNTHAL: Let me put it a ditterent 19 way. It we were today applying the backtit standard here we 20 wouldn't even come close to recommending this.
21 CHAIRMAN PALLADINO: Well, I --
22 COMMISSIONER BERNTHAL: Because on this basis we 23 couldn't come close.
24 CHAIRMAN PALLADINO: Well, I'm not sure that that's 25 the answer. I don *t agree with that.
1 70 1 COMMISSIONER BERNTHAL: Well, it*s -- what*s wrong 2 with the numbers. It*s empirical 3 COMMISSIONER ROBERTS: Retresh my memory. How many 4 plants or utilities are in the ISAP?
5 MR. OPEKA: There*s only two plants. That*s Haddam 6 Neck and Millstone 1 One utility that is. Two plants.
7 COMMISSIONER ROBERTS: One utility.
8 MR. OPEKA: That*s correct.
9 COMMISSIONER ROBERTS: And refresh my memory again i
10 and give me the evolution of the program. .
11 [ Chairman Palladino lett the room.]
12 MR. OPEKA: Well, the evolution of the program is 13 that what we would do is take all the regulatory requirements, 14 and take modifications required by regulation, and take all 15 the modifications that we feel that are non-regulatory 16 that the utility finds, and evaluate those with the Statt to 17 determine which ones should be done first, and establish a 18 schedule for the subsequent refueling outages.
19 And what that assures us -- or gives us added 20 assurance is that we're spending our money where we get the 21 most from it, as far as safety -- overall safety of the plant 22 is concerned.
! 23 COMMISSIONER ROBERTS: How long nas the program been l
24 in ettect)
! 25 MR. OPEKA: Well, it hasn*t. It*s still being -- on l
l l
- / 5 1 Millstone 1 we have about 80 items and we finished our 2 evaluation about -- 81 and we tinished our evaluation, I l 3 believe on 80, and sent those to the Statt 4 The Stati right now is reviewing those. Ana I I
! $ believe the schedule now is that by April of next year the 6 Statt and ourselves should have a schedule for the next outage 7 on what jobs should be done.
8 And then for Haddam Neck I believe it's later on in 9 the year. It*s around September. But it*s a living type 10 schedule. .
11 COMMISSIONER ROBERTS: Yes, I understand.
j 12 MM. OPEKA: Which is a real worth to the program. 1 13 the example I gave on this low pressure heat exchanger 4
14 modification, that is a major problem which we found, which 15 was not part of any regulations which we want to fix because 16 we teel that has the most significant ettect on the overall 17 safety of our plant.
18 That modification will probably cost s5 million, i
19 That's hardware only, not replacement power costs. But what 20 we want to do is do it right, and work with the Statt and get 21 the best product.
22 COMMISSIONER ROBERTS: That*a all I have.
i
< 23 MR. OPEKA: On just an -- I wish the Chairman was 24 here -- but to give you an example of one, you don *t need a 25 PMA to find out some of the insignificance of these
70 1 modifications.
2 For example, we have a -- one of the valves is a low 3 pressure coolant injection spray valve. This valve is located 4 outside of containment and provides -- and when it opens 5 provides spray inside the containment to reduce the pressure e inside containment.
7 That has to be qualified for high radiation. In 8 order to get a high radiation situation you have to have core 9 melt. In order to get core melt you have to lose your low 10 pressure coolant injection system. !! you lose your low _
l 11 pressure coolant injection system, then the valve that we're I
12 talking about has no meaning because that*s the pump that 13 pumps water through the valve.
14 COMMISSIONER ASSELSTINE: There's no water to pump.
15 MR. OPEKA: That's the type of scenario. That's le r i g *.t . I mean, that's why we come out with it's sero worth.
17 Why am I spending money on that? You don't need a PHA for I
18 that.
19 COMMISSIONER ASSELSTINE: But are there other --
20 COMMISSIONER ROBERTS: In the example that you just 21 gave you certainly do not.
22 [ Chairman Palladino returned to the r o o m . ')
23 COMMISSIONER ASSELSTINE: Let me ask you though, are 24 there other situations in which short of a core melt you have 25 problems and where you would want to have that valve operate, l
l l
77 1 and in tact you're counting on that valve to operate?
2 MR. OPEXA: In short of core melt, in probably a 3 lower radiation area.
4 COMMISSIONER ASSELSTINE: Then you don't have the 1
5 radiation.
6 MR. OPEKA: That's right.
? COMMISSIONER ASSELSTINE: So that it doesn*t have to 8 be qualified.
9 MR, OPEKA: Exactly.
10 COMMISSIONER ASSELSTINE: Okay, to the harsh ,
11 envir ent.
12 COMMISSIONER BERNTHAL: Since I've ottered one 13 number that the chairman doesn't agree with, let me otter 14 another number that presents the other side of the argument 15 though. The point is 11 you use the same argument for -- how to many items are there involved in all of these itxes, the 17 environmental qualification -- or the total number of pieces 19 you had to --
19 MR. OPEXA: Well, we had -- in Millstone 1 we had 20 about 700 pieces.
21 COMMISSIONER BERNTHAL: Okay. So let's say on the 22 order of 1,000. If you used a similar argument for every 2 'J single piece, of course, you'd never do anything. So that's 4
24 the other side of the coin.
25 CHAIRMAN PALLADINO: That's what --
l
e >
78 l 1 COMMISSIONER BERNTHAL: But I still maintain --
2 CHAIRMAN PALLADINO: That's what I was thinking.
3 COMMISSIONER BERNTHAL: Whore we are today, the 4
4 number that I gave you is correct.
5 MR. OPEKA: Let me add a comment on that. We have a i
6 number of valves that we're making modifications on, because 7 we found that they are -- that they are of significance as far 6 as -- that we shoulo make the modifications. It's only 11
, 9 here that we're talking about that we feel that we shouldn't 10 spend the money on. _
11 COMMISSIONER BERNTHAL: No, I understand.
12 COMMISSIONER ROBERTS: That's occurring during this 2 13 current outage.
14 MR. OPEKA: That's right, correct.
i 13 COMMISSIONER ZECH: You know, in all tairness to the i i
16 licensee, I think, as I recall just recently we had a 17 discussion on the safety goal here and at that discussion it 18 was interesting to me that we gave a tremendous emphasis to 19 core melt, 20 CHAIRMAN PALLADINO: That's wny I said maybe we 21 better reexamine it 22 COMMISSIONER ZECH: Well, I think it may be 23 something to think about, because what we're really talking
]
24 about is the public health and safety and releases. And so I 25 think their emphasis on core melt is not too far oli trom our 1
_____.________._m._..
s 79 1 own emphasis on core melt. And perhaps we should both take 2 another look at that.
3 !*d just like to mention that -- of course, the ISAP 4 program I think is rather unique. It is a relatively new 5 program that I think some.of my colleagues some months ago 6 when we were reviewing the budget were in strong support of 7 And I have come to recognise the value of the ISAP program.
.4 8 I think it*s -- perhaps we might even say still in i
I 9 the experimental stage, but it certainly does seem to have 10 considerable merit as far as I'm concerned. It*s unfortunate, -
l l
11 I think, that it comes together with this program. But I 12 think maybe it isn*t unfortunate. Maybe it's tortunate, 13 because it does point out some of the direction that ISAP, as a
14 Mr. Opeka has pointed out, has led them. And perhaps there's 15 a lot of good that can come from that program.
16 It seems to me that the Statt has given us, what I 17 at least consider a rather -- not at least a strong I 18 recommendation to deny this request. And they seem to -- at i 19 least my implication was that they teel this is a rather close 20 call, and that there has been merit by the utility *s ettorts 21 to work within the ISAF program, and also to work within the i 22 equipment qualitication program.
23 I think it*s something tnat is rather unique, and I 24 think we have to put it in that category. As far as !*m 25 concerned, the biggest consideration is, are we talking about
i r
i 80 1 valves that are going to be at significant impact on the 2 safety of operation of the plant and on public health. And I 3 think ultimately that's kind of how we're going to have to 4 base our judgment in this regard.
3 CHAIRMAN PALLADINO: I wonder it I could make a 6 point and maybe get a question in it also. It's my r
? understanding that this plant is essentially a sister plant to 8 Nine Mile Point. And at that plant, Niagara Mohawk tound 9 problems with this emergency condenser system to significant 10 extent so that they're doing quite an extensive system-wide .
11 upgrade of the emergency condenser system, because of this 1
2 ,
12 importance and because et ditticulties that they either 13 postulate or do face.
14 This is what worries me about analyses where in one 15 case one plant says, oh, it's not worth doing and another one 16 does a lot more. And so that's what gives me the unease -- in 1
17 part, some of the uneasiness in saying, oh, well, we've 18 dismissed the importance of this on the probabilistic risk 19 assessment.
20 But then I come down on my other concern that, I 21 gather -- and don *t let me put words in your mouth -- but I i
i 22 gather there's a question of wnether you ever intended to do 23 the equipment qualifications on those valves which the Statt 24 feels is exposed to an adverse situation. Oh, I guess you 25 changed that, You said, you'd be willing to do it in 1987.
81 1 MR. OPEkA; Plus, you have to understand --
2 COMMISSIONER ASSELSTINE: That's a tallback though.
3 CHAIRMAN PALLADINO: That's a tallback.
4 MR. OPEKA. You have to understand, we spent 5 5700,000 on these valves already. And what we're trying to 6 avoid is another 6 million because of the ISAP results. And 7 it we didn't have ISAP we wouldn't be here. We'd be 8 installing them.
9 But I can't ignore the fact that I'm going to be 10 spending so million on what I -- the preliminary findings _
11 indicate provide no safety significance. That's my problem.
12 CHAIRMAN PALLADINO: But also in a sister plant 13 they're finding great safety significance in this emergency 14 condenser system and they're doing extensive upgrade in lieu 15 of some of the valve modifications.
16 MR. OPEKA; Well, in part of -- one of the valves 17 that we're modifying this outage is an isolation condenser le valve. IC3 was the valve that has to operate in order to put 19 the system into operation. We're doing that because of 20 reliability reasons and because of problems we had in the 21 past. So we're not ignoring that.
22 COMMISSIONER BERNTHAL: I want to make a comment 23 about core melt because I think that somehow that issue is l
24 being distorted a little bit beyond where it should be. When 25 we did meet and talk about safety goal, I think the issue also
, a 82 1 arose in the context of discussing core melt that, at least in 2 the United Kingdom -- and elsewhere, I think -- people are 3 beginning to speak rather of core disruptive accidents. And 4 in my judgment that*s a more appropriate thing to do. In 5 other words, a Three Mile Island type accident.
6 [ Commissioner Roberts left the room.3
? COMMISSIONER BERNTHAL: People are going to argue 8 for a long time, I suppose -- or at least -- well, maybe not 9 so long -- but have argued for a long time already as to 10 whether that qualities as core melt or not. There clearly was .
11 core damage, extreme core disruption.
12 And as long as the integrity of the core is 13 maintained, you're really talking about an entirely different 14 scenario of accident then once core into,. ity is breached.
15 When core integrity is breached, then the possibility of major 16 exposures to human beings goes up very quickly.
17 So I agree that we should get away from talking 18 about core melt perhaps. But it's clear to me that we need to 19 continue to focus on the idea of a core disruptive accident, 20 because that's going to have to be the benchuark for a major 21 accident scenario it we're going to get anywhere at all, it 22 seems to me in the safety goal business.
23 So I just want to make that comment that core 24 disruptive is perhaps the right word. And in that sense then, 25 I think we are focusing on the right thing. The core
e 83 1 disruptive accident is where we have to make our judgment and ,
I 2 analysis on safety goal and other things. ,
3 COMMISSIONER ZECH: Or even something else that 4 would release radiation to the -- trom the plant, whether it's
$ disrupted or not.
6 COMMISSIONER EERNTHAL: Well, by and large, that has 7 to be core disruptive though. You have to have core damage --
8 and I'm -- I just can't think 01 an accident scenario where 9 you could have major releases unless you have core damage. As 10 long as core integrity is preserved, that simply isn't in the ,
11 cards.
12 [ Commissioner Roberts returned to the room.]
13 COMMISSIONER ASSELSTINE: That raises another 14 question in my mind, John. You talked about these various 13 valves in the system. You mentioned this LPCI example while 16 the chairman was out.
17 Let me ask you, is there no sittation in which you 18 could have a core damage event that would lead to a radiation 4
14 lield in the area where these valves are, ind in which you 20 would want those valves available to help y su arrest core 21 damage and return the reactor to a stable condition?
22 Are you saying that there isn't any situation in 23 which that would be the case?
24 MR. OPEKA: I don't know of any, but I don't have my 25 expert person on th.t. But that's one of the thing that he
84 1 has to make sure is the case.
2 CHAIRMAN PALLADINO: Isn't much of the manrem that 3 you're calculating coming from this natural circulation 4 emergency condenser loop? And doesn't that form part of the 5 basis for radiation ettects on some of these --
6 MR. OPEKA: You mean on the numbers? No.
7 CHAIRMAN PALLADINO: No, I was saying, there is a 8 source --
there is a source of radiation that I presume is 9 coming trom circulation through this condenser. It*s a 10 natural circulation system.
11 MR. OPEKA: That's correct.
12 CHAIRMAN PALLADINO: Now it that's going to attect 13 the workers then it must also attect valves. That*s what I i
!4 was thinking.
15 MR. OPEKA: No. That*s not -- the major source of 16 our radiation, this 165 are not associated with the isolation 17 and ccndensors. It's a s s o c i s,t e d with the recirculation 18 valves, the low pressure coolant injection valve and the clean 19 up valves. That makes up about 80 percent of it.
20 So this valve that we're replacing IC3 is outside of 21 containment, and it*s not a high radiation area. I can walk 22 right under it, and it's not a major source. It's about five 23 millirem per hour maybe. So that's not our problem.
24 CHAIRMAN PALLADINO: Okay, I must be thinking of --
well, I was thinking of at least one valve might be exposed to
I ,
85 1 such radiation. I was trying to expound on Jim's question.
2 COMMISSIONER ASSELSTINE: Could you give me a little 3 breakdown of the so million? ;
j 4 MR. OPEKA: Yes, the le million -- for every day 5 that we*re shut down we have to spend o$U million -- 1050,000 6 for replacement power.
7 COMMISSIONER ASSELSTINE: It*s supplied?
J 8 MR. OPEKA: That*s right, Well, you have to burn 9 oil for it, so that nuclear --
10 COMMISSIONER ASSELSTINE: So you have oil capacity ,
I 11 that you use to --
12 MR. OPEKA: Right, But that*s the cost to us. So 13 that comes out to be about -- over 55 mtllion. The other 51 14 million is for labor to actually install the valves.
15 COMMISSIONER ASSELSTINE: Okay. Because you*ve I
i 16 already paid for the valves, You*ve got the valves.
I
] 17 MR. OPEKA: That*s right. So this is ditterential 18 costs, additional costs.
19 CHAIRMAN PALLADINO; How much would the labor be?
i 20 MR. OPEKA: About 11 million.
I 21 CHAIHMAN PALLADINO: But that would also apply 22 later, wouldn*t it?
23 MR. OPEKA: That*s correct.
24 CHAIRMAN PALLADINO: Any time you do it 25 MR. OPEKA: But again, what !*m saying is that it wo 1
, ,,,_.r_,_. . . . , , , _ _ .
i i
l St 1 both agree -- it we all agree that we shouldn*t install these, 2 then we wouldn't incur that cost And we'd use that money for 3 something more signittoant. That's the point I'm trying to 4 make. ,
4 5 But we're not trying to deter -- you know, we're not l
6 trying to violate the law or anything. What we're trying to 4
i 7 do is we have some information that indicates that wo 1
a 8 shouldn't be doing this. We need somebody to vertly it. We r
9 need the NRC to verity it and then go with the results.
! 10 COMMISSIONEH ASSEL.STINE: You mentioned in your .
i
! 11 statement that you had three valves that were removed trom the 1 i
12 list because you tound that they didn't require 13 qualitication. What's the difference between the situation of 14 those three valves and these other 117 15 MR. OPEXA: What's the -- what we have to do is that t
q 10 we take a room and we assume a certain radiation dose in that 17 room for all valves in that room. And it the valve is in that 19 room we indicate -- and it the dose is high enough, we 19 indicate that that valve then has to be qualified to that 20 environment.
i 21 Before we make a final determination we actually go 22 to each valve and find out whetber the radiation in that room 4
j 2 '3 -- in that area of the valve is high enough to require i
24 qualificatica. In these particular three cases we found that 25 it wasn't i
4
87 1 COMMISSIONEN ASSELSTINE: Okay. But for the 11 you 2 can't make that judgment?
3 MM. OPEKA: No, we can't, 4 COMMISSIONEN ASSELSTINE; The radiation tield would 3 be high enough?
6 MM. OPEXA: It there's a core melt situation, we'd 7 have to quality the valves. But I went through that scenario 8 to indicate that it*s highly unlikely for that to happen.
9 COMMISSIONEE ASSELSTINE: But only it it*s a core 10 melt? You don *t see any accident situations in which you have ,
11 something short of tull core melt where -- like core damage 12 that --
13 MR. OPEKA: As far as I know, yes, sir.
14 COMMISSIONEM ASSELSTINE: Okay.
13 COMMISSIONEN HERNTHAL: Can ! Just clarity the 16 point? When you talk about core melt, you*re not talking 17 about core damage. In other words, you*re talking about a 18 lower probability event that*s core disruptive; is that right?
19 MM. OPEKA; Well, I don *t really ditterentiate 20 riither one.
21 COMMISSIONER BEMNTHAL: You do not.
22 MM. OPEKA; Coro damage would be core melt. And our 23 safety goal is based on -- well, 10 to the -4 for our plant.
24 That's what our company goal is.
23 COMMISSIONEW BEHNTHAL: Which is, according to your
e BB 1 calculations, that's the core damage threshold.
r i 2 MR. OPEKA; Right. I don't discern between, 3 distinguish between the two.
4 COMMISSIONER BERNTHAL: Yes, I think there is --
5 some people do. And the ditterence can be as much as -- well, T
6 approach a tactor of 10 in some people's --
7 MR. OPEXA: Well, our policy's based on -- I believe f B the guidance that we*ve received from the NRC, that using the i
4 9 10 to the -4. And it we don't get 10 to the -4 overall then 10 we take action. ,
11 COMMISSIONER BERNTHAL: Right, i
1 12 COMMISSIONER ASSELSTINE: One final point. It*s i
i 13 more comment than a question. John, when you were describing 14 the ISAP to Commissioner Roberts earlier, I had a little i 15 trouble with that because it sounded like what you were i
16 describing is basically the living schedule approach. That 17 is, well, you wanted to put your list et items on the table, 18 the Statt's list of items on the table, rank them in terms of 19 priority and then come up with a schedule.
20 I had envisioned the ISAP program as going beyond 21 that. Basically saying, let*s put the composite ot all of the, 22 issues -- certainly elements that you want to do from a 23 reliability standpoint -- but let's put a composite of all of 24 the safety issues on the table. And take a look at what can 23 be done that optimises safety, i
i l
89 1 And that may in fact result in you doing some things 2 that you might not otherwise do. And then seeking reliet trom 3 others that you might otherwise be obligated to do to receive 4 -- to come up with some, a solution that would provide the 5 best overall mix.
o MR. OPEXA: That's what -- it I didn't say that, 7 that's what I meant.
B COMMISSIONEM ASSELSTINE: Okay, all right. But that 9 seems to me is a step beyond just the living schedule approach 10 where you put the reliability items and the safety items and ,
11 --
12 MR. OPEXA: Well, I guess the living schedule part 13 is that, it for some reason we put together a schedule for the 14 next outage today and then six months down the line the NRC or 15 we come up and say, hey, we got a problem here and we've got 16 to replace this component, Then we'd go back to the schedule 17 and say, can we remove one and put this one in.
19 COMMISSIONER ASSELSTINE: Okay, 19 MN. OPEXA: That's what I was talking about.
20 COMMISSIONER ASSELSTINE: Good, it sounds Itke we're 21 on the same --
22 COMMISSIONER ROWERTS: Can I paraphrase something 23 that was referred to earlier in the day -- your former boss
- 24 punchline on his letter to the Wall Street Journal -- read the 25 policy statement,
^ ~ . . . -
. r f ,D_
, e .x e t /
~
90 1 CHAIRMAN PALLADINO: Other questions?
2 COMMISSIONER ZECH: No, I don't want to prolong 3 this,' Mr. Chairman, but I'm a little ouncerned that we may --
4 mention was made that we -- on core distuption. ,
In order to 4 have any releasas. And I think that there are.other ways we
/
6 could have releases. I don't want to elaborate the
- 7 discussion, but there are other ways and we havef*.o look -- be 8 mindful'oi those, too. i
, F 9 CHAIRMAN PALLADINO: Yes, that*s why 1*m a little 10 con $erned by iocusing entirely on core molt. B u t' likewise, I ,
11 don't want to see anything unnecessarili done. And so, going
's '
12 to have to take some time -- I don't mean days -- but many 13 hours, at least because --
s 14 COMMISSIONER BERNTHAL: Well, I think -- excuse me.
15 Go ahead.
16 CHAIRMAN PALLADINO: B u't , I do want to urge all 17 commissioners to try to vote -- what is tomorrow?
18 MR, OPEXA: Wednesday.
19 i COMMISSIONER ASSELSTINE: The oth.
20 CHAIRMAN PALLADINO: Well, 12 you can vote tomorrow 21 that*s better. But certainly by Thursday noon we should try 22 lo vote so we have some basis for indicating an answer to the 23 Millstone people.
24 MR. OPEXA:- That would be very beneficial I 25 appreciate it. /-
r / l
/ #
94
'/^
.%, -. , , , . ..,---.,--~J
]
1
. e 91 1 COMMISSIONER BERNTHAL: I*11 certainly have a 2 decision on this, probably today yet.
3 CHAIRMAN PALLADINO: And it*s not an easy one.
4 COMMISSIONER BERNTHAL: I just wanted to say, 5 clearly you can have radiation releases without damaging the 6 core.
7 COMMISSIONER ZECH: Hight, that*s my only point.
8 COMMISSIONER BERNTHAL: But you can't have major i
9 releases where public health and safety becomes truly at risk 10 unless you're releasing that tission inventory, it seems to _
11 me.
12 COMMISSIONER ZECH: Well, I don *t think we want to 13 release anything.
14 COMMISSIONER BERNTHAL: Well, I agree. I agree.
15 And you're absolutely right. 11 you release primary coolant i
16 --
and there are lots oi other things where you can have minor 17 releases.
18 COMMISSIONER ZECH: Yes, that*s what -- correct.
! 19 COMMISSIONER BERNTHAL: But it*s iinally when that 20 core gets damaged that you begin to get in trouble. Big 21 trouble, as opposed to little trouble.
22 COMMISSIONER ZECH: Well, we don *t want big or 23 little.
i 24 CHAIRMAN PALLADINO: I*d like to see defense 25 in-depth to prevent getting there. But that doesn*t say how
_ .=. _ .- - _. .--. . .-. .
J e
- i 92 l t
1 I'm going conclude on this case.
2 Any other comments? Well, thank you very much. We 3 appreciate you're coming by. We understand it's not an easy i
4 case, but we'll do our best to do justice to it. ,
5 MR. OPEKA: Thank you very much. !
6 CHAIRMAN PALLADINO: We'll stand adjourned.
? CWhereupon, at 3:58 p.m., the commission meeting was i
8 adjourned.3 9
10 ,
11 12 13 14 15 16 17 ,-
18 19 4 20 21 22 23 24 l
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1 CERTIFICATE OF OFFICIAL REPORTER 2
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5 This is to certify that the attached proceedings 6 before the United States Nuclear Regulatory Comnission in the 7 mat ter of COD 1ISSION ::EETING 8
9 Name of Proceeding: Discussion of Exemption Requests - -
Environmental Qualification (Public Meeting:
to 11 Occket No.
12 Alace: Washington, D. C.
18 Date: Tuesday, November 5, 1985 14 15 were held as herein appears and that this is the original 16 transcr6pt thereof for the file of the United States Nuclear 17 Regulatory Ccemission.
13 (Signature) l (Typed Name of Reporter,) QPamela Briggia -
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23 Ann Riley *s Associates, Ltd.
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I COMMISSION BRIEFING REGARDING mil %- .o . e
. UNIT 1 REQUEST FOR EXTENSION OF +4s ENVIRONMENTAL QUALIFICATION DEE . NG by .
- John F. Ope' (November 5, .?
Good Afternoon. I am John Opeka, Senior Vice President of Nuclear Engineering and Operations for Northeast Nuclear Electric Company, the holder of the operating license for Millstone Unit
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- 1. I appreciate the opportunity to discuss with you this afternoon our request for extension of the environmental ,
qualification deadline for Millstone Unit 1 and integration of the reh'aining qualification items into the Integrated Safety Assessment Program. I have prepared some remarks that I believe will assist the Commission in reaching a decision regarding our request. After presenting these remarks, members of my staff and I would be happy to respond to any questions you may have on this issue.
Let me say first that we are here today because we believe that this extension of the EQ deadline is the correct thing to do. Our philosophy at Northeast is driven first and foremost by safety considerations. Thus, if we thought that public health 1
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I and safety would be enhanced to a meaningful extent by fully meeting the EQ deadline now, we certainly would not be before you today. But we have concluded that safety considerations permit exte sion of the EQ deadline as we have requested.
I believe the issue before the commission today is i
straightforward. Simply stated, the issue is whether the Commission should require the modif. cation of eleven valve motor operators at Millstone Unit 1 during the current outage which began on October 26, 1985, or should the Commission authorize integration of qualification of these motor operators into the l Integra,ted Safety Assessment Program.
Significantly, the relevant facts impacting this issue are not in controversy. First, our request involves only one item of equipment, a certain type of valve motor operator which to the best of our knowledge was used in safety related applications at .
only two plants in the nation - Haddam Neck and Millstone Unit No. 1. We have diligently pursued qualification of this item.
As a result of our efforts, all parts necessary to resolve ,
qualification of this item will be on site this month. In its assessment of our qualification activities for this valve motor operator, the Staff found that we had been diligent in our
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l efforts to qualify the equipment by the Commission's established deadline. In short, all parties agree that we have diligently pursued qualification efforts associated with this item.
As a result of these efforta we could do all the necessary mcdifications in our current outage for Millstone Unit 1. It j
would require a minimum of an eight day extension of the current 4
outage at an added cost of over 6 million dollars, as well as an estimated additional 165 man-rem of radiation expesure. This would increase the estimate occupational exposure for the outage 4
by approximately 66%. However, the work could be done.
Both we and the Staff have identified these modifications as elements of the ISAP effort. Accordingly, in parallel with our j
qualification efforts on this item, we performed ISAP evaluations of these valve motor operator modifications. The results of these evaluations for Millstone Unit 1, which are contained in Attachment 2 to your briefing package, are significant. Of the twenty eight valve motor operators of-this type at Millstone Unit 1, eight warranted modification (and will be modified in the current outage), three were removed from the list because it was ,
found that they did not require qualification, minor modifications to six allowed us to request permanent exemptions,
and eleven appeared to warrant no further actions. With respect to the six for which permanent exemptions were sought, recent discussions with the Staff have resulted in agreement that these six are no longer within the scope of 10 CFR 550.49. In other words, based on our ISAP evaluations which were being performed in parallel with our qualification efforts, we committed to take appropriate action on all except eleven of the valve motor operators of this type at the first available opportunity.
The ISAP evaluation results for these eleven valves are contained in Attachment 3. In this attachment, I have listed the eleven valves with the corresponding decrease in core melt frequency which would be realized by making modifications to these valves. As can be seen, the largest decrease in core melt frequency would occur if valves 1RR-2A and B were modified. The decrease in core melt frequency from modification of these two
-6 valves would be 1.5 x 10 / year. The next largest decrease would
-7 / year, followed by 2.0 x 10-9/ year, and for the be 2.5 x 10 remaining six valves, we could achieve no decrease whatsoever.
In sum, the modification of the eleven valve motor operators would result in only a .2% improvement in the frequency of core melt. Based on this ISAP evaluation, which was formally submitted to the Staff'for review on October 17, 1985, I could
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4 find little safety benefit in making these modifications.
s Accordingly,' we formally requested that the Commission place the qualification of these eleven valve motor operators into the ISAP for , Staff evaluation.
To review briefly, in Attachment 4, I have listed what I 1
believe are the relevant facts impacting our request:
D (1) Northeast Utilities has diligently [
4 pursued qualification of this one 1 i remaining item of equipment associated l
l with the request.
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(2) The ISAP evaluation of this item has 4-proceeded in parallel with the l qualification efforts and-has not delayed 4
l any qualification planning or modifications.
(3)- The NRC Staff h&s stated its acceptance of the justifications for continued 7,
operation associated with-these eleven valve motor operators and based on its l
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acceptance has stated that deferral of modifications will not adversely impact public health and safety.
(4) The results of the ISAP evaluation reflect that there is virtually no safety benefit to be achieved by modifying the ,
.i eleven valve motor operators in question.
4 The Staff is still reviewing this 4
analysis.
l (5) Finally, occupational exposure associated with installation of these eleven valve motor operators is estimated to be approximately 165 man-rem. This is estimated to increase the total occupational radiation exposure for the outage by approximately 66%.
The final point I would like to discuss involves the Integrated Safety Assessment Program itself. The Commission by unanimous action endorsed this program in its November 15, 1984 Folicy Statement. In that Policy Statement, the Commission gave ,
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Northeast Utilities every indication that ISAP would be a broad reaching, comprehensive and stable program. For example, the Commission stated in its Policy Statement that "the scope of ISAP is intended to be as comprehensive as practical." Topics to be considered are, among or.her things, "all pending licensing actions for the plant, including multi-plant actions, TMI action plan requirements and specific licensing actions." Further, the Commission contemplated the suspension of specific implementation schedule requirements for the plants to be reviewed in order to
" provide a stable environment" for the ISAP efforts. Finally, the Commission stated that the only exception for inclusion in ISAP are " issues for which the NRC Staff explicitly determines that prompt action is required to protect public health and 4
safety." Significantly, the broad scope envisioned by this policy has received clear congressional support.
Chairman Palladino, this is the first opportunity that the 1,
i Commission has had to address ISAP implementation. We believe that if there was ever a topic that warranted inclusion in ISAP, it is this topic. All agree that there is no immediate safety concern with regard to these modifications. Further, all agree that Northeast Utilities has diligently pursued qualification of this item. Finally, there is a great potential that based on the
t results of our ISAP evaluations, no further modifications are warranted with regard to this item.
1 Our voluntary commitment to the ISAP program was based on the Commission's commitments set forth in its Policy Statement to 9
provide a stable environment to conduct the ISAP. We have proceeded with the ISAP in reliance on these commitments and have ,
expended substantial rescurces to implement the program. We believe that the modifications at issue here are precisely the type of action which the Commission's Policy Statement endorsed for integration into the ISAP. We understand that the Staff supports this position.
In conclusion, as I stated at the outset of my remarks, this is a straightforward issue. It does not involve immediate public health and safety considerations, or concerns about a utility failing to do its job. Indeed, Northeast has diligently implemented the Commission's qualification regulations and, at the same time, has expended substantial resources to implement fully the Commission's mandate concerning ISAP. Frankly, I'm proud of our actions in both areas.
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I view the Commission's decision as one of policy, providing guidance as to the Commission's viewpoint on ISAP. This is a program that we are committed to and intend to continue to impl.ement. It is ironic that because of our aggressive implementation of the ISAP on this issue, which was supported by the Staff, we are in our current position. If we had not i plemented ISAP on this issue, we would not know that modification of these valves would result in little safety benefit while costing so much in terms of occupational exposures and resources. But we did implement ISAP and, based on that evaluation, we did the correct thing - we came to the Commission itself with our request. By our request, we are asking the Commission to let Northeast and the Staff finish the evaluation and review process on these eleven valve motor operators.
i One final note, as I stated in my October 29 letter to the Commission, we need prompt Commission action on this request or we will be forced to do the work to avoid further delay in the
- outage. We have already had to proceed with preliminary work such as the erection of scaffolding. In our present posture, a I Commission decision on or before Friday, November 8, will be timely. If no Commission action is taken by that date, we will i
treat it as an effective denial of our request and we will be forced to proceed with the work to avoid further delay.
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Chairman Palladino, that concludes my prepared remarks. At this time I would be happy to respond to any questions that you
' may have with regard to our request.
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. ATTACHMENT 1 i
ISSUE Whether the Commission should require the modification i of eleven valve motor operators at Millstone Unit 1 during the current outage which began on October 26, 4 1985 or should the Commission authorize integration of
. qualification of these motor operators into the Integrated Safety Assessment Program.
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ATTACHMENT 2 ISAP EVALUATION RESULTS FOR VALVE MOTOR OPERATORS Millstone Unit 1 (28 valve motor operators):
8 warrant modifications
- 3 determined to not require qualification 6 needed minor modification to remove from scope of Section 50.49 11 appeared to warrant no further action (these 11 are the subject of NNECO's extension request) e
ATTACHMENT 3 "
i ISAP EVALUATION OF MODIFICATIONS OF ELEVEN VALVE MOTOR OPERATORS i Decrease in Core Valve Melt Frecuencv ,
1-RR-2A, B 1.5 x 10-6/yr.
! 1-CU-3 2.5 x 10-7/yr.
1-IC-2 2.0 x 10-9/yr.
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- 1-IC-4 0.0 1
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1-CU-2 ,, 0.0 1-MW-96A 0.0 1-LP-15A,8 1-LP-16A,8 LQ TOTAL: 1.75 x 10-6/yr (0.2%)
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ATTACHMENT 4 L
IMPORTANT FACTS i a Northeast Utilities (NU) has diligently
! pursued qualification.
o The ISAP evaluation has proceeded in parallel with qualification efforts and has not delayed any qualification modifications.
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0 The NRC Staff found acceptable the
,, Justifications for continued operation associated with these eleven valve motor
, operators; deferral of modifications will not
!- adversely impact public health and safety.
The NU ISAP evaluation reflects that there is o
virtually no safety benefit to be achieved from modifying the eleven valve motor operators in question. The Staff is still reviewing our evaluation.
a s
o Occupational exposure (approximately 165 man-rems) associated with installation of these 4
eleven valve motor operators is estimated to increase the outage man-rem exposure by approximately 66%.
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ATTACHMENT 5 i
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I CONCLUSION l
o The Commission should grant the extension and i include qualification of these valves in ISAP.
q a Need Commission decision by November 8 to minimize further impact on the current outage.
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