ML20205C206
| ML20205C206 | |
| Person / Time | |
|---|---|
| Issue date: | 08/07/1986 |
| From: | Advisory Committee on Reactor Safeguards |
| To: | |
| References | |
| ACRS-T-1542, NUDOCS 8608120281 | |
| Download: ML20205C206 (89) | |
Text
ORlcl995 7_yqg UlN11ED STATES O
NUCLEAR REGULATORY COMMISSION IN THE MATTER OF:
DOCKET NO:
ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 316TH GENERAL MEETING l
l O
I LOCATION:
WASHINGTON, D.
C.
PAGES:
1 - 80
)
DATE:
THURSDAY, AUGUST 7, 1986 228NFlaE0,0PY U Jo Vo; Removeiram ACRSTice
{
ACE-FEDERAL REPORTERS, INC.
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UNITED STATES OF AMERICA 2
NUCLEAR REGULATORY COMMISSION 3
ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 4
^
5 1
6 Nuclear Regulatory Commission Room 1046 7
1717 H Street, N.W.
Washington, D.
C.
8 9
Thursday, August 7, 1986 10 The 316th General Meeting convened at 2:00 p.m.
11 ACRS MEMBERS PRESENT:
13 MR. DAVID A. WARD, Chairman 14 MR. JESSE C.
EBERSOLE 15 MR. HAROLD ETHERINGTON 16 DR. MAX W.
CARBON DR. WILLIAM KERR 17
^
~
l 18 DR.
J.
CARSON MARK 19 MR. CARLYLE MICHELSON 20 DR. DADE W.
MOELLER 21 DR. DAVID OKRENT 22 MR. GLENN A.
REED DR. FORREST J.
REMICK 24 DR. PAUL G.
SHEWMON O
25 DR. CHESTER P.
SIESS MR. CHARLES J. WYLIE ACE-FEDERAL REPORTERS, INC.
3)2-347 3700 Nationwide Coverage 800 336-66 4
i
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PUBLIC NOTICE BY THE l
UNITED STATES NUCLEAR REGULATORY COMMISSIONERS' ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 4
TNURSDAY, AUGUST 7, 1986 The contents of this stenographic transcript of the proceedings of the United States Nucle &_- Regulatory i
j Commission's Advisory Committee on Reactor Safeguards l
(ACRS), as reported herein, is an uncorrected record of the discussions recorded at the meeting held on the above date.
No member of the ACRS Staff and no participant at
()
this meeting accepts any responsibility for errors or inaccuracies of statement or data contained in this transcript.
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1 PROCEEDINGS (2 00 p.m.)
2 g
MR. WARD:
We will convene.
The next topic is 1
3 l
seismic qualification of equipment.
Mr. Wylie?
i 4
j MR. WYLIE:
All right.
Thank you.
As you said, 5
the subject of this is the final resolution of USI A-46, hseismicqualificationofequipment in operating plants.
6 7
Day before yesterday -- I lost it now -- but the l
8 3 Reliability Assurance Subcommittee met and heard j
9 presentations by the Staff and the seismic qualification 10 utility group and EPRI, regarding the activities directed j
11 toward the resolution of A-46.
Myself, Jesse Ebersole, 12 Mr. Michelson, Mr. Siess, Mr. Reed, were present.
SOUG 13 gave a summary of the total activities to date, a summary 7-V 14 of that on their activities toward resolution; a progress 15 report of the documentation of the seismic adequacy of the 16 l equipment for safe shutdown earthquake and the generic I
l 17 application plan; a report on the seismic experience that 18 they gathered to date.
9 d
i 19 il EPRI gave reports on equipment anchorage i
l 20 l guidelines that are being developed, and generic equipment, ll 21 f spectrum data, and relay evaluation procedures which are 22 ? being developed.
23 The Staff gave a report on their progress and 24 status of the resolution of A-46 and the Staff is t
25 :
approaching a final resolution.
They plan to meet with
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CRGR in September and issue resolution in a generic letter 2
in October.
3 There are a number of questions raised at the 4
meeting by members of the Subcommittee.
There's a lot of 5
documentation which the Subcommittee has not had available 6
to them and has not seen.
For example, the implementation 7
plan, the guidelines and some of the reports.
8 The ACRS was briefed, this committee was briefed 9
on resolution of USI A-6 in July of
'83, in May of
'84, I
10 l August of '85 and in January of this year.
11 I believe that all of our concerns are being 12 addressed, with the exception of the review of those i
13 l
guidelines, reports and procedures which we indicated in
,, l
(_'
l 14 our letters that we would be reviewing.
i 15 i We have available with us today, members of the 16 Staff and SOUG, and the Staff is prepared to make 17 recommendation on the implementation of USA I-46, and SOUG 18 is available to answer any questions which members may have i
d 19 j!
regarding their activities.
J l
20 Before I begin, do any of the other Subcommittee 21 members wish to make a statement?
I 22 MR. MICHELSON:
Well, I have a few items that I 23 think need to be clarified during the presentation.
It may 24 ;
be simpler if you just give them now -- if I just give them 25 !
now and then the appropriate speaker can emphasize them and (1) l s
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I then we'll see what S.he situation is.
2 There were several areas that I had a little bit 3 !
of concern, about which were, in a way, details.
One had 4
to do with how the FEMA analysis will be done, in the case i
i 5
of determining whether the minimum set of equipment is 6
appropriately protected against a seismic event.
I need a 7 i clarification as to whether FEMA will involve the fl simultaneous failure of all equipment which is deemed to 8
0 9
have a failure potential during the earthquake, or is it i
10 )
taking one element at a time and analyzing it one at a time.
lI think it's a straightforward clarification.
11 i
12 The next questions are slightly deeper and that 13 is, how do you handle system interaction effects where the
}
14 i
interactions are not direct phyvical, or not directly h
15 l! direct electrical intercouple interactions but one step 16 l
further, are more subtle.
l 17 !l For instance, what happens when a tank on one 18 side of a room which is not qualified and whose foundation 19 had not been checked out topples during the earthquake and 20 j
the water passes across the floor to the opposite side of 21 the room?
Is that included in the failure modes and effect 22 analysis that show that you have retained the minimum set i
23 of equipment required?
24 So, clarification of how far will those system 25 interactions actually be considered, and when you identify t
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the boundary when you no longer consider them, then what's fthejustificationforignoringtherest.
2 3
Another problem I have is that there are no pipe ihbreaksbeingconsideredofahighenergyvariety, 4
either i
5 inside or outside of containment, either seismic or not 6
I seismic.
7 k
The documentation remains silent on low energy 8
lines, but I understand that low energy lines aren't i
9 considered a break either, irrespective of size.
But I 10 would like a clarification and justification for why, for 11 instance, 1-inch water lines can't break during a seismic l
12 I
event.
i 13 i There are no seismically induced fires O
14 considered at all, even in terms of protecting the minimum 15 set of equipment required for safe shutdown.
I would like 16 a clarification of why we think that there will never be a l
l 17 i fire during such an event, at least in the areas where our f
18 j minimum equipment is located.
19 I have a number of reservations or. how relay 20 j chatter is being handled.
I think that the work has still 21 :
got a ways to go and, therefore, these may be cleared up 22 ) with time.
I think it is important, though, to emphasize l~ that 23 relays include more than the device we commonly think 24 of as relays.
It also includes instrument contacts, a 25 I number of other control electrical contacts.
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So, this, again should be emphasized when 2
considering failure of whatever.
3 The last and final comment is that I can see 4
where there is a number of items that have been left out by 5
assumption, or perhaps by the bounding of the problem to a 6
manageable size.
As a result, though, of leaving these 7
items out it certainly has skinnied down the margins that 8
we have.
Since we are not dealing with even single failure 9
criterion in this case.
We are dealing with a minimum set 10 of equipment which, if it were to fail it must somehow --
I 11 h it may be, and it's required, as I understand, to be at h
12 y least backed up by some alternative device.
But it isn't 13 real clear whether this alternative device has to be O
14 protected against whatever caused the failure of the first 15 l device.
n 16 j!
So, it is a very minimum set of equipment and it d
17 i really appears that one cannot consider failures to any l
18 l extent in that minimum set.
So I think the margins are 19 pretty skinny, and there are a lot of uncertainties in d[
20 earthquakes as to the magnitude and so forth.
It just 21 ]
leaves me a little bit uncomfortable.
i 22 l
MR. OKRENT:
I have a few general matters; some 23 t
may be overlapping the things that Carl just mentioned that i
24 i I thought again I would mention now and hope that they 25 i would be addressed, either answers or a formal presentation,
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I don't care.
I guess the broadest question is:
How do we i
2 know that if what is being proposed in, I assume, the draft 3
l Staff position,
-46, if that is accepted, how do we know or 4
do we care if the safety policy is going to be i
5 approximately met?
6 I
In other words, in the safety policy, there are 7
some words about -- there should be reasonable assurance fthat there is not a core melt for the life of the existing 8
9 plants.
There's also guidance to the Staff that, in fpreparingtheirimplementationplanthat 10 the Commission 1
11 itself will approve that a goal of 10 to the minus 6 per 12 l reactor year for a major release of radioactivity should be 13 l
examined, evaluated, presumably included, at least as a O
14 l minimum, for study if not for actual adoption.
So that's il one question.
15 1
16 I can't tell from what I've read, how to go from l
17 l what is in here to any kind of relationship to those i
18 particular aspects of the safety policy.
19 A second point relates a little bit to what 20 Michelson was saying.
I guess, on page 3 of NUREG-1211 it 21 q gives some assumptions.
One is the seismic event does not 22 cause a loss of coolant accident, steam line break accident, 23 high energy line break, and so forth.
24 j
If one considers, again, the safety policy, t
25 i which is not stated in words that, for the SSE this will l
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1 not occur, or that we will not have a core melt but that in 2
the life of the plant, given what may occur per reactor 3
year there should be a certain frequency of a major release, 4
J or there should be reasonable assurance of no core melt, i
5 how do you factor in earthquakes larger than the SSE, and 6
does the proposed approach to qualification include 7
earthquakes larger than the SSE?
And, if so, large enough 8
i by an amount such that at least you are approaching what 9
) the Commission has stated as either their safety policy or i
10 their possible guideline.
11 So, in effect, I'm trying to understand the flevelofshaking,orthenumberofSSEs, or however you 12 i
13 want to put it, for which the Staff thinks it has
(
14
! confidence or reasonable assurance or whatever it thinks it I
15 l needs, to be in approximate conformance with the safety
)
16 policy?
Or are you ignoring that?
Are you just saying we farelooking in terms of SSE?
17 18 If you are only looking in terms of SSE, I need f
to understand why, in view of the Commission 's recently 19 k
20 } adopted safety policy.
0 21 j And just one last point, again on page 3 it says:
i 22 Piping tanks and heat exchangers are not included, except l
23 l those tanks and heat exchangers tequited to achieve and 24 maintain safe shutdown.
Must be maintained -- et cetera.
25 Getting back to Michelson's point, it seems to i
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me other kinde ef tenks comid oet ene iete trouhte, even 1
2 though you didn't need their water for this purpose.
So I 3
don't at the moment understand the exclusion and I don't j
4 know if there are some other things of that sort that you 5
have excluded in the same way that happen not to be listed.
I 6
So, I guess the issue is:
Why is what you are proposing
}
7 adequate?
What is it you are measuring adequacy against?
1 8
And how should I judge that what you are doing is
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9 sufficiently comprehensive, even though I'm not asking that 10 you guarantee there is no scenario not forgotten.
Okay?
11 i
MR. WYLIE:
Mr. Reed?
5 12 MR. REED:
Mr. Michelson, and to some degree I
13 Dr. Okrent, have got me confused.
Because I thought that iO 14 we had gone through, years ago, the issue of flooding, j
15 internal flooding in plants, from tanks and all kinds of 16 things, and that was an issue that had been taken care of l
17 and I know there are plants with dikes in them to prevent 8
18 tanks, nonsafety tanks, when they rupture, from flooding i
19 out vital equipment and so on.
And I thought we had gone 1
20 i through, years ago, the issue of high energy line breaks 0
i 21-and what they would do, and I'm having a problem trying to 22 figure out why a tank draining, splitting, is any different l
23 if it was to do it from one way or from the seismic way?
1
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24 Or whether a high energy pipe splits and ruptures and whips 25 around from one way by its own internal energy versus
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l seismic energy?
I'm not so sure we aren't asking these 2
questions of the SQUG activity two or three times here.
i 3
MR. MICHELSON:
Could I answer that?
When the i
i 4
Giamboso letter was issued in '72 it was required that the 1
5 utilities go through and analyze their plants in terms of 6
taking pipe breaks, flooding mechanisms of various sorts, 7
one at a time -- just one -- and show that if you were to i
l 8
experience that one event that you could still shut down l
9 safely, even though you were now required to use single 10 failure criteria.
So where I had a train A and a train B l
11 RHR, and I found I had a tank in the same room as train A f
I
]
12 RHR, whose rupture would not out train B but did not knock i
i 13 out train A, I was all set.
That was an acceptable
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i 14 response.
15 Now when we come to this issue it's very 16 possible that I might want to pick train B as my minimum l
17 set, not train A.
I'm not required now to look at the tank l
18 over in the corner in that train B room.
So, if that tank l
l 4
19 were to fail like you postulated originally, it would now i
1 20 knock out train B, and train B is the only one I have i
21 protected from the earthquake.
1 j
22 It's a logic problem.
The next problem we ran
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i 23 into is Giamboso says take one at a time but the seismic 24 event is a common challenge to all equipment.
Any i
4 25 equipment which cannot withstand that event is potentially --
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1 may potentially fail.
So you've got to consider all the 2
potential failcres simultaneously, which you never had to 3
do in the pine break analysis.
So it's quite a bit i
4 different kind of analysis.
That's why I point out the 5
FEMA has to be with simultaneous challenge to all equipment 6
rather than random failure one at a time.
That's a big 7
difference in the analysia.
II 8
l MR. OKRENT:
In the systems interactions l
9 g proposed resolution on which the Committee wrote a letter, 10 one or two months ago, in the originally proposed 11 resolution, in fact, the Staff is recommending two focused I
12
[ areas of work that should be done.
Then they changed it to 13 l
sort of point out that this was important but they weren't O
k 14 l going to require it.
In fact, the Committee recommended i
15 they go back to the earlier position.
l One of these was seismically caused interactions 16 4
4 17 p of nonsafety systems on safety systems, spatially 18 originating.
Not the more subtle functional things, which g
6 19 9
they don't say ignore but they say it's a lot harder to get
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20 q a handle on.
i
- j The other, in fact, was flooding effects.
And 21 ll l
22 ]
the reason that they mention flooding effects is they have i
4 23 judged, quite accurately, I think, that the industry 24 l
response to that 1972 or whatever the date was, request 25 l that everyone do studies after the Quad City flooding 4
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event -- industry response, although approved, plant by 2
plant, by the NRC, has proven to be inadequate.
In fact, 3
there are a variety of plants -- some plants are in good 4
shape but there are some plants that are not in such good 5
shape.
Of course Oconee found a real bad problem when they 6
did a PRA.
But it was judged that flooding in general 7
needed another look.
8 Then just one other point, the people who do i
fragility estimates or capacity estimates for seismic 9 '
10 events, have identified certain kinds of tanks, in 11 particular tanks built for sometime period, as among the h more vulnerable to seismic events.
i 12 It just so happens that 13 f these -- why, I don't know -- weren't designed to be as O
14 l strong as the containment buildings or so forth, given an
)
15 earthquake.
16 So, to exempt tanks caught my eye because I read 17 1 what the NRC's own expert panel has written.
18 MR. MICHELSON:
One more thing on that to keep g
I 19 i in mind, the old analyses done for the pipe breaks outside 20 i of containment made one -- allowed one important assumption.
21 ] That is, if a device was involved in the effects of the li 22 break, all you had to do is, do not take credit for the 23 l functionality of the device.
But you do not analyze for 24 l unwanted actions from the device and so forth.
You just 25 i lose its function.
It was a very simple-minded, I
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1 straightforward analysis, i
2 MR. REED:
Well, if I take what you just said, 3
you are saying that an earthquake is different from a i
4 self-actuated pipe break or tank break or this, that or the 5
other, and you must consider simultaneous breaks all over 6
the place.
7 MR. OKRENT:
Those are his words.
8 MR. REED:
I don't see how in the final analysis 9
I can do anything other than expect you two people to vote 10 for a backup, alternate, dedicated decay heat removal
'l 11 I
system.
Thank you.
l 12 !
MR. OKRENT:
I'm an advocate of one.
It's not I
13 that I'll vote on someone else's motion.
O 14 MR. MICHELSON:
I didn't say you have to take l
15 breaks.
I said you have to consider them.
You have to 16 look at each and every device which will get you into I
i
'h difficulty during the earthquake and you have to look at 17 l
18 them occurring more than one at a time.
It's unrealistic 19 3
to believe only one thing will break even though it's shown l
jl 20 by analysis none of it will withstand the earthquake.
21 MR. REED:
If you put corrosion on top of 22 everything else --
l l
23 MR. MICHELSON:
On the other hand, it's
[unrealistictoassumeoverythingwillfail,either, 24 that's I
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25 not designed for an earthquake.
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MR. WYLIE:
Any other comments?
2 MR. EBERSOLE:
I have a few.
In all the plants 3
they visited I think few of them demanded of their 4
functional processes a continuity, even suggested of a 5
nuclear plant, which required continuity of heat removal.
6 Maybe some approach that, but I think few of them would 7
approach the need for continuity that a nuclear plant 8
requires.
So the fact the plant survives is not a 9
legitimate measure that a nuclear plant would survive.
10 Nuclear plants can have long, complex daisy l
11 chains of intersupportive features that are required to
( keep a single functional process going, all sorts of 12 l
13 auxiliaries and supports which are supports to support O
d l systems, 14 which is a characteristic, again, I don't think fmanyplantshave.
15 16 :
The third item was they did mention that within k
17 h their scope so far was not an answer to the corroding pipe k
18 k problem where one would experience a degradation of pipe 19 l strength in a localized context and the stress 20 concentration that would result.
We mentioned earlier 21 about internal rusting.
There was pipe at Watts Bar that j
22 q was leading to near penetration, in the local sense.
I 23 don't know whether those attacks of local penetration would 24 j degrade the pipe in the sense of total peripheral 25 degradation -- they may be just nodules -- but you may o
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recall they needed to line those pipes with concrete to 2
keep them from going out at a very fast rate.
3 The thing that bothers me most, though, is the 4
time span of human experience which they are dealing with, 5
which is just a microsecond in the context of this kind of p phenomenon.
We are looking at earthquakes which, the best 6
7 you can say -- well, not even 100 years has it affected 8
machinery of the kind we design today.
That's hardly a 9
statistical expcsure to seismic parameters -- what you'd 10 call comprehensive.
11 Pinally, on this tank business, I recall South J
12 Texas has already had its oil down to the diesels and the 1
13 potential of fire and this brings up whether you have
' O i
14 failures as such kind as that the complex or rather, the i
15 combination of that sort of invitation to have fire and the 16 loss of fire protection features may be an undesired i
17 l
combination for the health of the plant.
I 18 k MR. REED:
That was an overfill of the plant,
}
4 19 j not a rupture.
il 20 il MR. EBERSOLE:
If I look at tank failures again, 21 it's easy to say I might have some piping failures and tank 22 failures that would cause oil spills.
It's fundamentally 23 l poor design to have high oil tanks above hot equipment anyway.
24 !
The combination of this can look very funny, in an extreme 25 seismic event.
That's about all I can add since the i
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meeting.
2 MR. WYLIE:
Okay.
Are there any other comments j
l l
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3 by any other members?
i 1
4 Well, if not, let's proceed and we'll call on t
i l
5 the Staff to present their status of the resolution i
j 6
MR. CHANG:
My name is T.Y. Chang, I'm the test i
I 7
manager of USI A-46.
My purpose of being here today is to l
8 brief you about the status of USI A-46, and before I do i
9 that I, just to refresh your memories, I want to give you 4
l 10 some background.
11 Task A-46 was designated as an offset of the
)
12 issue in December 1980, out of the recognition that to
}
13 assure the seismic adequacy of equipment in those operating
!O 14 plants is a concern.
1 i
i j
15 (Slide.)
j 16 When the SSE level earthquake hits a plant like l
j 17 that, the concern is that we want to make sure that the l
18 plant can be brought to a safe shutdown.
I 19 The seismic qualification criteria of the j
20 equipment has been changing over the years,.so we recognize 21 there is a need to take a look, again, at those older 22 plants.
At the outset, there are five tasks identified f
23.
that have potential to address the concerns.
After the i
l 24 SOUG we concluded that the use of the seismic experience I
25 data approach is the most reasonable alternative to the I
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I current requirement.
It is also cost-effective.
Also 2
during the study of the seismic experience data approach, 3
we recognize there is a need to collect test data as well l
4
, to supplement the seismic experience data.
5 The feasibility of using the seismic experience 6
data approach to qualify equipment has been established by 7
a Lawrence Livermore study and also by the pilot program of 8
SOUG.
9 (Slide.)
10 The pilot program studied eight classes of 11 equipment from a number of plants; underwent the San 12 Fernando earthquake and Imperial Valley earthquake in '71 13 !
and
'79.
(
14 Since then, data from other earthquakes were l
15 l added to the data base; among them are the Coalinga, Morgan
'l i
[
16 h Hill, Chile and Mexico earthquakes.
1 17 In June of 1983 the SSRAP, senior seismic review i
18
! and advisory panel, was formed jointly by SOUG and by NRC.
19 g Their function is to act as an independent panel, to advise i
20 0 SOUG how to use the seismic experience data to qualify Il 21 ) equipment.
And also they act as a consultant for both SOUG l
22 !
and NRC.
23 l On the subject of test experience data 24 l collection, EPRI started in 1984 an effort to collect test 25 j
data from past experiences.
Those were the " shake table" (1) l l
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tests performed by the test labs on the qualification of 2
equipment for nuclear power plants.
j 3
The NRC Staff has participated in all the 1
4 meetings with SOUG and SSRAP, and has monitored very 5
closely their work.
The propcsed Staff resolution, A A,
6 is based on both the seismic experience and test experience 7
l approach.
8 (Slide.)
4 9 l The study of the seismic experience data pointed 10 l out that there are only three areas you should be really 11 concerned about.
Those three major concerns ares the 12 first is equipment anchorages.
The conclusion of the study 13 is under certain caveats and exclusions, and under the
(
14 seismic motion bonds, equipment in general is pretty rugged 15 as far as earthquake loadings are concerned, so long as you 16 have adequate anchorages.
17 l Another thing I learned from the seismic l
18 l experience is that relays -- the functionality of relays 19 were established after the earthquake.
However, during the f
earthquake, it cannot be established.
So the functionality 20
)
21 l
of relays becomes a concern, and the conclusion is that the 22 seismic experience, we will not be able to address this 23 !
concern and you'll have to look into the test data in order 24 ;
to address that concern.
25 The third concern is the outliers.
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1 the oddball equipment that's not covered by either the 2
seismic experience or the test data experience.
So, for j
3 that equipment you have to take a look and do something 4
about it.
5 l
(Slide.)
l 6
MR. OKRENT:
Excuse me, since you are planning l
I 7
to go to a proposed resolution and I guess you think you 8
have outlined the problems that need to be addressed, 9
perhaps you can tell me now, then, what is the answer to
)
10 the question I posed concerning the level of seismic safety 11 you are trying to achieve or think you are achieving by 12 your proposed resolution and how this compares with the l
l 13 safety goal policy, and so forth, and how you know?
l 14 MR. CHANG:
Based on the seismic experience data, 15 it showed the equipment is inherently very rugged.
There l
16 is a big seismic margin there.
17 MR. ANDERSON:
The answe'r to the question really 18 lies within the scope and purpose of USA I-46.
First of 19 all, A-46 was conceived to be an alternative to meeting 20 l
current requirements for seismic qualification of i
21 mechanical and electrical equipment at the design level.
22 There is no intent and we never have intended to compare it l
23 with a safety goal.
We don't think that we are required to.
j 24 We think at the SSE level we are talking about, for most 25 plants, most seismic PRAs show that the risk at that level O
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is very low.
But we've gotten beyond what we, in some 2
areas, what we require for current requirements for seismic 3
qualification and we have no intention of expanding the 4
scope to that detail, that much.
I don't want to imply we 5
are not concerned about these other problems or these other 6
areas, but they shouldn't be taken into a program where we 7
are simply trying to develop reasonable alternatives to 8
meeting that current criteria.
9 MR. OKRENT:
Was it your plan for the resolution i
10 I
of the defined problem that you recommend they initiate a 11 new, unresolved safety issue, namely, adequacy of equipment 12 and components to exhibit sufficient seismic margin to be l
13 responsive to the Commission's recently adepted safety 14 policy?
15 MR. ANDERSON:
There's one problem, our seismic 16 margins program, which addresses this but it doesn't 17 specifically address the safety goals.
I don't know of any
}
18 ;
plans that the Staff has now to extend an 0-46-type effort 1
19 I
to try to show thtt equipment does meet the safety goal 20 with regard to seismic capability.
l 21 !
MR. OKRENT:
I'm trying to understand this 22 separation in thought processos, if I can.
On the one hand, j
23 not only through safety policy but through the novoro 24 i accident policy statomont, the Commission has mado cortain 25 statomonts about either its goals or what it thinks is the i
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current status of safety and so forth.
I 2
Let's look at the severe accident policy 3
statement for a moment, where the Commission takes a rather I
4 optimistic point of view concerning the safety status of 5
existing plants.
Are those PRAs that include seismic 6
components that are purported to show that at about two to q
7 three times the SSE for a typical eastern plant, is where 8 l you start getting significant seismic contribution to risk l
9 j unless you've got a really bad boo-boo somewhere.
But 10 j
those numbers, especially if they happen to be somehow 11 associated with what is sometimes called an early release, t
12 would not be something, I would say, that was in harmony I
l with the statement that the Commission has adopted in the 13 14 severe accident policy statement.
i 15 If you tell me you are just looking up to the l
16 SSE -- and I don't know of any other program that, for l
l 17 these plants is going to look beyond the SSE -- I
.J7't t
18 know how the seismic margins program -- in fact, what I 1
19 h
know of it, it will not look at this.
j 11 f
20 MR. ANDERSON:
Yes, sir.
l 21 MR. OKRENT:
It will not look at this from what l
22 I know of it.
23 MR. ANDERSON:
It looks at it in maybe a limited 24 manner.
l 25 MR. OKRENT:
In such a limited manner that I l
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think it is inconsequential, so far as I can tell.
It is 2
designed to do something else.
3 So, if this program doesn't look at the I
4 capability of what I'll call the possible weaker links in i
1 5
these plants from a seismic point of view, I.think it will I
6 not be looked at, and there will be this gap that is
]
7 present; maybe an Achilles' heel in the Commission's
)
8 position on severe accidents, just as, apparently, BWR Mark 9
1 containments they decided may be an Achilles' heel.
l
~
j 10 MR. ANDERSON:
The Staff's seismic margins 11 program and also the EPRI seismic program look for plant j
12 vulnerabilities specifically and do look for that Achilles' l
13 heel.
We are going through a trial seismic margins review 14 at the Maine Yankee plant, where we are doing at a discrete 1
{
15 acceleration level, about 2.5 times above its detsign level, i
16 and one of the objectives of that study is to find out 17 where to look for the vulnerabilities, in strictly a q
18 vulnerability study.
19 Although it doesn't quantitatively say what the 20 risk is or whether it meets a quantitative safety goal, it
]
21 certainly does look at a seismic margin in a plant and j
22 seeks out plant vulnerabilities.
1 23 l MR. OKRENT:
That sounds like a good idea, a 1
24 good program.
But I don't think it is going to provide 25 i enough information for resolution of your particular
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1 unresolved safety issue above the SSE, from what you've 1
2 told me.
l 3
Well -- I have nothing more to add.
I 4
MR. MICHELSON:
Which part of your program will 5
propose to look at nonseismic anchorages, which cannot 6
directly physically interact with your minimum set of vital l
7 equipment?
Are you including that at all?
8 MR. ANDERSON:
The seismic margins program has 9
selected those safety functions and systems to look at, 10 based on a review of the seismic PRAs.
11 MR. MICHELSON:
Are they going to look at the 12' minimum set selected by this program?
13 MR. ANDERSON:
No, sir.
They are doing it more 14 on a fault tree type --
15 MR. MICHELSON:
They are going to go in and as 16 !
long as there's something else that will work, they are 17 okay.
But in this analysis -- and correct me if I'm
)
18 wrong -- if I understand you correctly you are going to 19 l identify a minimum set of equipment.
One train.
i 20 !
MR. ANDERSON:
You mine for the A-46?
21 MR. MICHELSON:
For this analysis.
Yes, for I
i 22 your resolution you have identified only one train of 23 l
equipment to protect.
24 {
My question is, what -- to what extent are you i
25 l going to look at the failure of nonseismically qualified I
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equipment whose failure can cause a loss of this minimum
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set and what kind of losses are you going to look for?
Are 3
you going to look for water running on the floor or just 4
going to look to see if the tank falls directly on the i
5 panel?
6 g MR. ANDERSON:
On this program we are looking at l
0
/
I; direct physical contact.
W 8
f MR. MICHELSON:
What's the justification for not l
9 l going beyond that?
l l
10 MR. ANDERSON:
The flooding review that 'as done i
I
)
11 in 1972 did include large tanks.
12 MR. MICHELSON:
You heard my dissertation.
How 13 do you respond to that?
l 14 MR. ANDERSON:
The flooding issue, including 4
l 15 seismic failure of flooding for those tanks that have some 16 distance from them and have some potential for flooding, we 17 intend to cover in the A-17 flooding review.
1 18 l
MR. MICHELSON:
I don't find it.
bl 19 MR. ANDERSON:
I know you haven't.
We are 20 ( still -- as you know, we have an active debate on what that 21 scope should be.
22 !!
MR. MICHELSON:
It logically belongs here 23 because only in this case have you said, I'm down to-one 1
24 1 train of equipment before I handle the situation.
You have j
25 said in here that I'm only going to protect one train of l
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1 equipment to begin with.
All other cases we think we start l
2 out with two trains and, therefore, you get a different 1
3 kind of analysis when you look at the failure of equipment.
4 Here you've got to make sure that the fellow who does that 1
5 analysis in A-17 realizes you are already down to one set l
6 of equipment.
7 You have the same problem with fires.
The fire 1
8 people are starting out with two trains available; fire is 9
in one train and the other train protected.
You are 10 starting out with only one train available to begin with, 11 by design.
[
[
12 l
MR. ANDERSON:
Well, the Staff has to and we 13 intend to make sure there's no gaps between the fire
)
14 L protections, system interaction and the other.
I'm very
[
15 reluctant to try to expand the scope of A-46 at thl time.
i i
16 MR. MICHELSON:
I just want to make sure the l
17 Committee understands the limitations that we're involved 18 i
in.
19 j MR. ANDERSON:
Yes, sir.
0 20 MR. OKRENT:
I assume the reluctance, in part, l
l 21
- ) is based on a fiat that you have to have this resolved by l
22 the end of the year or something?
4
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23 MR. ANDERSON:
I won't deny that there's some 1
24 schedule pressure on us.
But the real driving thing here l
25 j is we started out to develop an alternative to doing what i
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I what we call current criteria and we find ourselves getting v
2 off into tanks and heat exchangers and cable trays and 3
other areas that are beyond the scope; now we would like to, 3
4 if we can, limit this to somewhat the same scope and same 5
type of activity we would require in current criteria.
l 6
MR. MICHELSON:
You are quite right except, you l
7 know, you tell me equipment anchorages is a problem, you 8
put it down.
That's one of your concerns.
I have to ask, 9
well, it's a concern everywhere there's a piece of 10 equipment.
Now 1 have to ask:
Can I handle these other 11 failures, where equipment anchorages are going to fail?
l 12 Can I handle all of them?
I thought it would be a part of l
13 your study.
It's really illogical to me to think it's not
()
14 part of your examination since you have already identified 15 it as a weak point in your design.
16 MR. BOSNAK:
Bob Bosnak, chief engineering 17 issues branch.
We have been reviewing this subject for a 18 number of years.
I have only been associated since the 19 reorganization, but a number of people, including all the h
20 i utilities -- we have 33 utilities; we have three abroad --
t 21 and the caveats were agreed to with the Committee.
In l
l 22 k other words, you recognized what some of these caveats are, l
23 l
and these are the bases on which we all went forward.
)
24 Again, we are talking about older plants.
We are trying to
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l So, I think as far as we are concerned, we definitely want 2
to keep the scope of A-46 where it is because all the work 3
has been based on that premise.
We think it is certainly 4
adequate.
There are these problems that have been 5
identified, and I think if we can go forward on that basis, 6
recognizing that there are limitations to what was done --
7 but there's been an awful lot of work accomplished -- I 8
think it's going to be a benefit to utilities around the 9
world.
10 MR. MICHELSON:
I think the work that has been 1
11 accomplished is fine and I don't think we have been 12 critical of the work that's been accomplished.
What we are 13 critical of now is how are you going to use the results of
()
14 looking at all these other earthquakes in terms of doing 15 analyses of plants which haven't started yet?
This is when 16 you set your ground rules for doing analysis of the plant 17 experience you have observed.
This is nothing new.
Now 18 you have seen the experience elsewhere, now you have to 19 decide how it applies to a nuclear plant and you haven' t 20 done the analysis yet.
As I understand it, you are just 21 getting ready to do it.
22 MR. BOSNAK:
That's correct.
Implementation i
23 reviews, and we want to have the Committee involved on the 4
24 implementation reviews.
There will be some pilot plants 25 and --
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l MR. MICHELSON:
That's the spirit of the 2
comments.
My comments aren't pitched at whether or not you 3
were looking at the right sort of pumps out in the 4
earthquake examples; it's how are you. going to use the 5
results now?
6 MR. ANDERSON:
Well, in addition -- maybe I'll 7
speak for the SOUG group here, make the commitment for them.
g 8
When they do the title reviews, when they have the 9
uorkshops for the utilities prior to the implementation, I 10 think any of the Committee members would be welcome to 11 attend those and get a much better idea of how these 12 reviews are going to go and have an opportunity to put some 13 input in them.
Jim probably jumped up to say no.
()
14 MR. THOMAS:
James Thomas, Duke Power Company, j
15 representing SOUG.
I would like to just make a couple of 16 comments and I think clear up some misconceptions.
Our 17 program has not said that we think we have an anchorage 18 problem in our plants.
Our program says that in these 19 nonseismically designed plants that we looked at, that one j
20 of the areas that we concluded needs a close look is 21 anchors.
We have not said we have an anchorage problem.
22.
MR. ETHERINGTON:
Isn't it true that you have i
l j some plants with ultra high-strength bolts that do not l
23 24 provide adequate anchorage?
25 MR. THOMAS:
The only misconception I'm trying
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to clear up, we did not say we have an anchorage problem in V
2 our nuclear plants.
We said in this resolution of A-46, 3
anchorage is a key issue; we want to verify we don't have a 4
problem.
And the other is in regard to the way we are 5
looking at what is required to get us to a safe shutdown, 6
is that we are going to look at one path.
But if at any 7
time we determine that in that path we determine a pivotal 8
component, we make sure to look that if that component did I
9 l
have some type of random problem that we have got another 10 piece of equipment that is seismically adequate.
11 MR. ETHERINGTON:
It seems to me we know of the 12 problem and there's not a very good resolution of it, the 13 high-strength bolts that are used to hold down, 14 particularly the Westinghouse steam generator's pumps.
15 MR. ANDERSON:
Well, probably, Mr. Etherington, 16 probably there's a couple of answers to that.
First of all, 17 l we do have another generic issue that we are working in the 18 Staff right now on bolting materials which includes that 19 problem you are talking about.
20 MR. ETHERINGTON:
Okay.
Il 21 il MR. ANDERSON:
In addition to that, the a
22 guidelines that are, I think, almost completed; the 23 f development by the SQUG, does give the ground rules on how 24 you review anchorages and it does look at the types of 25 fasteners and types of bolts.
The inadequate bolts or Ou I,
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l suspect bolts would be screened out from that flow path.
2 MR. ETHERINGTON:
When would you expect the bolt 3
problem to be resolved?
4 MR. ANDERSON:
I'm not familiar with the 5
schedule on that program.
6 MR. BOSNAK:
That should be resolved within the 7
year 1987.
8 MR. SHEWMON:
There is a USI?
9 MR. BOSNAK:
No.
It's really a generic issue.
10 I believe it's either 23 or 29.
11 MR. ANDERSON:
Dick Johnson is the task manager 12 on that program.
I 13 l
MR. BOSNAK:
Yes.
And all of the issues have 14 been taken care of.
It's now a matter of writing the final 15 report.
In other words, the high-strength bolting problem 16 that Mr. Etherington mentioned we are aware of, and I think 17 in developing the guidelines for the anchorages, those are 18 going to be introduced.
All of that is in hand and is 19 being taken care of and being addressed.
20 MR. ETHERINGTON:
Is this being taken care of on i
21 the basis that it's okay or that some change will be j
22 required?
i 23 MR. BOSNAK:
No.
It's being taken care of.
24 With respect to the high-strength bolting, you are in an 25 area where you have -- where you are susceptible to having
()
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1 stress cracking.
V) 2 MR. SHEWMON:
I find nothing in the tabs or 3
handout, but some of you have a document you are looking at 1
that is perhaps a SOUG report; is that available?
5 MR. WYLIE:
This document here.
6 MR. SHEWMON:
That's just for him --
7 MR. WYLIE:
That's him.
Okay.
We have some at 8
the Subcommittee.
9 (Discussion off the record.)
10 MR. WYLIE:
Are you finished, Jim?
11 MR. THOMAS:
I clarified two points, the j
12 anchorage and the way we are looking at systems.
The only 13 other thing I would like to clarify is one earlier comment
()
14 about the limitations of the time we have to look at j
15 earthquakes.
I have to concur we only have gone back 15 or i
16 20 years.
That's the best we have available.
From 17 everything we've learned there that we think has any 18 implications on what could be a generic problem at our 19 plants, we are considering fully.
1 20 MR. WYLIE:
Glenn?
21 MR. REED:
I take some comfort about what 9
22 S Mr. Thomas just said, if he had a single component in that 23 one train that's been pointed out is the only one being 24 l
chased, that he would look at the other train.
I think 25 that's fine because it is quite possible -- I assume that O
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l you are looking at that -- that that one train might have l'
2 been out of service for maintenance or other aspects, and 3
allowed by tech specs.
So, certainly you should follow the other train if you do get a single component problem.
4 I
5 MR. MICHELSON:
I would like a clarification.
1 i
6 When you talk about an " alternate component," do you mean i
7 an alternate train or do you mean another inverter sitting k
l 8
right besides the one that's there?
9 MR. THOMAS:
Something that can do the same I
e 10 function.
i i
11 MR. MICHELSON:
The other inverter can do the I
l 12 same function and yet get flooded out by the same event, 13 yet it will satisfy the problem they are using.
If they
(
j 14 find the inverter has a problem they'll set another one in i
15 next to it.
1 16 MR. ANDERSON:
But if it has the same problem it j
j 17 won't do any good either.
I
{
18 MR. MICHELSON:
But they sit it there for 19 f another entirely unrelated event.
Remember both of you 20 gentlemen said you don't look at the tank in the corner 4
21 l when it falls and spills the water on the floor, so if it l
22 happened to be another backup it wouldn't necessarily be 23 another train, necessarily, it might be just another i
24 inverter, both of which might be flooded by the event.
l 25 MR. ANDERSON:
If you postulate that event, I (i) a ACE-FEDERAL REPORTERS, INC.
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I couldn't disagree with that.
2 MR. MICHELSON:
It's unreasonable to me not to.
3 I'm not saying anchorages fail, but they have to be looked 4
at.
But your program is not going to look at them unless 5
there's a direct physical interaction and that's where I 6
draw the line.
7 MR. ANDERSON:
In A-46, that's correct.
8 MR. MICHELSON:
I think it's too narrow a view.
9 MR. THOMAS:
There's a lot of other programs 10 that looked at similar issues.
One is Appendix R.
We've 11 had to look at such things as systems causing, in one area, 12 all equipment in that area not to be functional and.we have l
13 got to show that there's something else functional.
And 14 you are getting into the exact same systems.
There's a lot 15 of credit that can be taken for work done for other issues 16 that are getting into the same point that you are making.
17 MR. EBERSOLE:
Can I ask a question?- It's sort 18 of critically necessary after you look at what you can find 19 in this equipment standards examinations you are forced to 20 extrapolate your sample in time and in location, way back l
21 i
in time to some number of years ago, that gives you a i
22 i reasonable span of time to say:
Earthquakes won't be any 23 worse than this within this time span.
And I might have 24 the unfortunate experience of being in the wrong place when 25 one of these severe events occurred which might have O
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1 occurred 1000 years ago or something.
I'm bothered by the 2
absence of the span of time and the span of location that i
3 you have considered.
It seems that some extrapolative 4
technique is necessary to do the right thing.
I'm saying 5
they have only looked at, as he says, a time span of 50 6
years in which there's machinery.
That's a microsecond in h
7 k geologic time.
i la 8
MR. ANDERSON:
Mr. Ebersole, I think I 9
l understand what you are saying.
I would like to point out 10 that we'd be taking the same scope, same level of 11 earthquake and same basis for that earthquake as they do 12 currently in looking at equipment qualification for new 13 plants.
But let me finish.
Understand that -- I
("_T s/
14
, understand your point.
But we are accepting under A-46 the f
15 l current seismic design basis of that plant.
I il There are other programs.
The eastern 16 l
17 l seismicity programs, that I think we talked about yesterday, l
18 I
to look at whether or not larger earthquakes are credible.
q 19 If at some time they decide that they need to 20 increase the seismic design basis, then obviously you are 21 going to have to look to see how it affects the total plant, t
22 including the equipment.
But I think it would be i
23 }
counterproductive to try to extrapolate in this program to 24 try to consider larger earthquakes.
25 MR. EBERSOLE:
At least you are not going to do r1 As I
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l it as part of the support program?
]
2 MR. ANDERSON:
As part of A-46.
3 MR. EBERSOLE:
You might stand back and say well, i
4 that's a small sample in both time and location.
5 MR. ANDERSON:
You mean for the data base 6
earthquakes we used.
3 7
MR. EBERSOLE:
I'll arbitrarily go back to the 8
pyramids or something, if not further, and say, aha, now we 9
can work from then.
1 10 MR. ANDERSON:
That's an interesting question, 11 but with respect to the seismic design bases and the plants
)
t 12 we are looking at now, these earthquakes are quite large 13 for this purpose.
(
14 MR. EBERSOLE:
Your defense is that you are 15 seeing earthquakes, in reality, as bad as those that are 16 being theoretically calculated?
17 MR. ANDERSON:
Yes.
Worse than the ones j
18 prescribed as the current seismic design basis for these i
19 plants.
1 i
20 MR. EBERSOLE:
Through the analytical process j
4 1
1 21 you are looking at earthquakes'as bad as if-not worse th'an i
22 those.
That's ce.rtainly a good' comparative basis but not a 23 very good absolute basis.
]
24 MR. ANDERSON:
That's our intent, the 25 comparative basis.
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MR. THOMAS:
I would like to make one more quick 2
point in regard to the margin question.
We do have margin 3
in what we are doing.
I think one of the things that we've 4
learned is that the effects of the earthquakes in such 5
things as building response, what we are seeing, real J
6 earthquakes don't cause buildings to respond as bad as we 7
were predicting.
There's margins there.
I 8
We are incorporating margins in our senior 9
seismic advisory review panel caveats and exclusions.
They j
10 are definitely seeing that you have margins.
In our 11 girders work we have margins, in our anchorage work we have 12 margins.
We are incorporating quite a bit of margins in 13 this resolution.
j 14 MR. OKRENT:
What is not clear at all to me is j
15 how to know for which components you have a basis for the l
16 statement you've made and for putting a semi-quantitative i
17 evaluation on the margins and for which components all you 11 i
18 have is data, rough or good, that takes you approximately 19 to the SSE.
I have no way of knowing.
20 I still don't understand the exclusion of the 21 tanks, as one example.
I just don't understand it.
{
22 MR. BOSNAK:
Dr. Okrent, I think you probably j
23 have no way of knowing what the margin, specific margin is, 24 l even on plants -- today's plants.
25 In other words, unless the item was tested to O
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fragility, to its endpoint, you wouldn't have a 2
quantitative idea of what the margin is.
You have some 3
idea qualitatively, but this program is fundamenta]ly in 4
keeping with the same philosophy.
l 5
MR. OKRENT:
No.
Let me say that rightly or 6
wrongly, Mr. Kennedy, on behalf of most everybody, is 7
estimating fragilities for whole classes of components 8
including things that are, for nuclear purposes, tested to 9
perhaps a modest range, but for military purposes, if l
10 there's data, were tested to much higher ranges and so 11 forth.
12 So, when you look in the seismic PRAs, you do --
13 you don't automatically say, well, if the only thing they 14 did was qualify this at a test at 10 percent-above the 15 response spectrum, that's all we can give them credit for --
16 no.
We would be calculating unacceptable results, if 17 that's what the seismic PRA people did.
In fact, it may be 18 that 90 percent of the components that you have in these 1
1 19 !
old plants are as good as the plants that are newer, or 20 whatever plants it is Mr. Kennedy estimated fragilities for.
21 MR. KERR:
Mr. Okrent, I don't understand your 1
22 point about Kennedy.
Are you saying Kennedy's results are 23 as accurate as tests or very accurate or that they exist?
24 MR. OKRENT:
I'm saying people, and in 25 particular Mr. Kennedy, try to estimate fragilities for a i
i o t
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1 wide range of components.
In some cases by analysis, in 2
l some cases they have found other tests than those done for 3
the nuclear industry, done for the Army or by blast or so 4
forth -- to help them estimate margins for components --
5 that you can't analyze it where the nuclear tests only went 6
i up to a certain point.
7 You mentioned outliers somewhere.
What I can't 8 h tell is if there's anyway, in what you are doing, where you 9
can identify the dif ference between equipment for which 1
10 there is some basis for evaluation in addition to what went 11 f
through specific earthquakes, because not all this 12 equipment was in big earthquakes -- whether somewhere in 13 there you have a program for identifying, well, where do we 14 have equipment?
Because it was one of a kind for this 15 plant, because the vendor no longer -
you know what I mean.
16 MR. THOMAS:
We have a pretty strict program i
17 l such that we can evaluate those and determine which ones 18 !
those are.
Further, EPRI, in pulling together hundreds of 19 l cases for us, have shown that in actual tests the equipment I
20 j has far more ruggedness than what we are claiming from the i
21 experience data, from actual tests.
I 22 i And we are relying very heavily on our f
23 third party review, the SSRAP, that what we are saying that l
24,
we are going to use to identify these outliers, that they 1
25 concur if you look at it in that manner you will know it is f
O l
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l an outlier.
2 MR. OKRENT:
I don't want to belabor the point.
4 3
There are things one can ask but --
a 4
4 MR. WARD:
Mr. Wylie, you just have a few more J
5 minutes.
6 MR. WYLIE:
Go ahead, Mr. Chang.
7 MR. WARD:
Do you need more time?
What's your 8
estimate?
i 9
MR. WYLIE:
I don't know how much time you --
I 10 MR. CHANG:
I'll be finished in just five 11 minutes or so.
1 12 MR. WYLIE:
Okay.
j 13 MR. CHANG:
So the proposed resolution of A-46 14 is for the operating plants, two things have to be done.
i 15 First is to perform a walkthrough inspection.
Under that i
l 16 you have to verify the anchorages and review the seismic 1
17 system interaction by looking at the physical interaction --
i 18 yes?
4 19 MR. SHEWMON:
How do you verify an anchorage?
l 20 MR. CHANG:
The SOUG group, and in EPRI, they J
j 21 are developing the so-called anchorage review guidelines.
22 We presented that to the Subcommittee on-Tuesday so they 23 have specific rules.
4 24 MR. SHEWMON:
Can you tell me how they verify 25 one?
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g l
MR. WYLIE:
Ask somebody from SQUG.
2 MR. CHANG:
I can describe it briefly.
They 3
look at the different types of anchorages, such as, say, if 4
it's an expansion anchor bolt, they look at the anchor bolt 1
5 [ and whether or not it's a shell or in-shell type and they
)
I 6 l estimate the strength of the bolt from the manufacturer's f
information and they put on some kind of a safety factor on 7
1 8
that then they look at different types of equipment.
For 9 i example, if you look at the motor control center, the motor i
10 hi control center, you can estimate the upper bound, what is Il
]theheaviest type and what the center of gravity is and the 11 l9 12 location of the bolts --
0 13 g
MR. SHEWMON:
They go back and assume it was 14 made right and if it was made right and performs that way, ii 15 j then it's okay?
f 16 MR. CHANG:
But they suggest an alternative to 4
17 inspect the anchor bolt also, depending on what safety
\\
18 factor you use.
If you use a bigger safety factor, then i
l 19 the inspection procedures will be less complicated.
1 20 MR. SHEWMON:
Okay.
You have answered the i
21 r question.
22 MR. CHANG:
If you have more complicated, 1
23 ]
in-depth inspection, you can use a less complicated 1
l 24 l
inspection.
{
l 25 [
MR. MICHELSON:
How do you decide what your 1
(2) l i
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1 minimum equipment is you want to protect?
Before the 2
walkdown or afterwards?
3 MR. CHANG:
Before the walkdown.
I 4
MR. ANDERSON:
On a plant-specific basis prior 5
to the walkdown.
That's right.
6 MR. MICHELSON:
So the only thing you walk down I
7 is that minimum set of equipment you decided to use; is 8
that right?
9 MR. ANDERSON:
Plus any alternatives that you i
i 10 happen to have any anything that physically --
i j
11 MR. MICHELSON:
And any backup that you have J
12 that you have identified has to be protected.
l I
13 l
MR. ANDERSON:
Correct.
And an extensive review 14 of relays, contractor switches --
15 MR. MICHELSON:
I just wanted to make sure.
16 MR. CHANG:
Bill, do you have something to add?
j 17 MR. SCHMIDT:
My name is Bill Schmidt.
I serve 18 as technical coordinator for the SQUG group.
+
i 19 We have established a set of acceptance criteria
)
i 20 for anchorages of all types and these acceptance criteria l
f 21 l
include a methodology for evaluating various kinds of the j
I H
22 capacity of the anchorages, and they also include physical j
23 checks to verify that anchorages have been installed h
4 24 properly.
These will be done in field walkdowns.
i 25 MR. CHANG:
The third element of the walkthrough 4fO 1
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inspection is to identify and address deficiencies and 2
outliers.
3 The second thing that has to be done is look at 4
the functional capability of the equipment.
By that we 5
really are talking about relays and contactors.
For new 6
plants the A-46 doesn't require -- the implementation l
7 requirements will be included in the generic letter to be 8
issued under the provision of 10 CFR 50.54(f).
9 MR. MICHELSON:
Will you clarify another small
(
10 point for me?
You, I think, are not looking at tanks, 11 pipes and so forth; is that correct?
12 MR. CHANG:
Tanks'and heat exchangers, only up 13 to the extent they are required for hot shutdown.
14 MR. MICHELSON:
How about pipes?
f 15 MR. CHANG:
Only the anchorages, not the tanks 16 themselves.
17 MR. MICHELSON:
Do you check for physical 18 interaction of other bodies on the pipes themselves?
4 19 MR. ANDERSON:
The only system interactions we 20 look at of that type is at connections to the equipment and 21 the far connections for sufficient flexibility.
22 MR. MICHELSON:
You don't look at something else 23 l falling on a 1-inch pipe, for instance?
i
}
24 MR. ANDERSON:
Not under.this program.- For the 25 l air lines and for the essential services, including cable O
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l trays, which is within the scope the site system i
2 interaction applies.
But not for. major pipes --
1 1
3 MR. MICHELSON:
It doesn't apply to the pipes, 4
only at the connection, different connection to valves or 5
something?
6 MR. ANDERSON:
At the connection, if they 7
haven't put adequate flexibility.
8 MR. MICHELSON:
Is there some reason you don't 9
believe you have any physical interaction potentials l
l 10 anywhere else?
It's an assumption and you aren't even 11 going to look for it, apparently.
l 12 MR. ANDERSON:
Here again, that's a far I
13 extrapolation beyond what we do currently for plants under
()
14 this issue.
We are not saying that isn't an issue.
We are 15 saying it isn't an A-46 issue.
16 MR. MICHELSON:
Don't tell me then that you are 17 looking for all interactions, because I guess you are not.
18 MR. ANDERSON:
We are looking for the limited I
19 set of interactions that we define.
1 20 MR. MICHELSON:
And pipe is not defined as an b
]
21 l essential part of the equipment that you identified as the I
22 j minimum set.
That's a strange rationale but --
l 23 l MR. ANDERSON:
It may be strange, but it's a lot 24 more than they do currently for equipment qualification.
25 MR. MICHELSON:
That's a different issue.
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1 MR. BOSNAK:
But you are talking about category 2
2 over 1, if that's what you are getting at.
3 MR. MICHELSON:
That's what I was getting at, 4
but I was asking, if you identify an essential system, the 5
minimum set, the piping and the minimum set that must 6
remain intact, do you look for possible impact on the pipe?
7 That was my question.
8 MR. BOSNAK:
The answer to that has to'be yes.
9 MR. MICHELSON:
I thought I just heard no.
10 Let's make sure we understand.
11 MR. BOSNAK:
If it's required and it is a 12 possible systems interaction, it's one of the things, 13 spatially, you have to look for.
}
14 MR. MICHELSON:
So you look at the system 15 I required, say, for your safe shutdown and look for any 16 things that could impact that system or any components, 17 including pipes, duct work that might be needed or whatever, 18 in that system, is that correct, and whose loss would cause 19 a loss of the function of the system?
20 MR. CHANG:
Yes.
That is correct.
21 MR. MICHELSON:
Is that correct?
22 MR. ANDERSON:
I understand.
23 MR. MICHELSON:
That's a little different.
That 24 leaves me with a lot less pain.
25 MR. ANDERSON:
I guess I didn't understand your O
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1 question.
Sorry.
(>)
2 MR. CHANG:
The status of A-46.
3 (Slide.)
4 We have met with CRGR last year, and afterwards 5
the package they -- they recommend to issue the package for 6
public comment.
The package was issued in September of 7
last year and we have, since then, received all the 8
comments back and we have resolved all the comments.
They 9
are incorporated in the final proposed resolution package 10 l
and the package has been concurred to by all the NRR l
11 h divisions.
We are planning to meet with CRGR in September, I
12 and hopefully the final issuance of resolution and generic f
i 13 letter will be in October.
(')'
\\
(
14 That concludes the presentation.
I 15 {
MR. WYLIE:
Okay.
Are there any other questions?
16 I
MR. BOSNAK:
I would like to have one more, in 17 response to Dr. Okrent's question about the safety goals.
i 18 We believe that A-46 is fully in keeping with the i
19 k Commission's new safety goals.
I 20 l MR. OKRENT:
What does that mean?
i 21 I MR. BOSNAK:
Well, if I can, I can read to you i
22 l
the two safety goals:
" Individual members of the public 23 should be provided a level of protection for the i
24 consequences of nuclear power plant operation such that 25.
individuals bear no significant additional risk to life and i
j (1) l l
i I
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l health."
2 Plants that will be implemented under A-46, we 3
feel, will be as -- in other words, they will be equivalent o
4 to plants that aren't under A-46.
In other words, the new 5
plants.
And so therefore, the public has no significant 6
additional risk to life and health.
7 The second safety goal:
"The risk to life and 8
health of a nuclear power plant operation shall be 9
comparable to or less than the risk of generating 10 electricity by viable competing technologies and should not I
11 be a significant addition to other societal risk."
12 In other words, what we are saying here, if 13 there is any small increment of risk, it is very small if
(
14 you are trying to measure the difference between the risk 15 of a plant qualified under A-46 to one that's qualified 16 under today's technology.
And we believe that those things 17 are immeasurable.
18 MR. OKRENT:
Just to make the point clear, we 19 had a meeting yesterday, and Mr. Leon Rider on behalf of 20 the Staff gave his estimate that the safe shutdown 21 earthquake for most eastern plants probably fell in the 22 1 range of occurrence interval of 1000 to 10,000 years.
I 4
23 believe that the Commission is talking about a core melt l
t 24 frequency smaller than that number, no matter which of the 25 safety goals you are looking at.
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l So I think that means there needs to be margin 2
beyond the safe shutdown earthquake.
Indeed, you may have 3
margin in these things.
I'm quite sure in some of them you 4
do, from what I have read.
What I ca'n't tell is that you 4
5 have a basis for knowing that you have in it all that you
{
6 need, and I can't tell that there are not interactions that 7
are troublesome.
4 8
MR. KERR:
How much margin do you think is 9
needed?
d 10 MR. OKRENT:
More than I think they can show l
11 usually -- the SOUG program.
I think the SOUG program is a i
12 good idea.
I favored it, but I don't want to be claiming 1
l 13 more for it than it is able to accomplish.
I ()
14 MR. KERR:
You think that with the existing 15 seismic design, the core melt frequency will be bigger than 16 10 to the minus 4 per year because of seismic events; is 17 that your point?
i 18 MR. OKRENT:
Will you say that again?
19 MR. KERR:
You used 10 to the minus 3 or 10 to 20 the minus 4 as a number we heard yesterday, and as I 21 remember, it was closer to 10 to the minus 4 than to the
]
22 minus 3.
That was a safe shutdown earthquake.
Presumably j
23 these plants designed for earthquake will withstand a safe 24 shutdown earthquake and will still be able to shut down and 25 have people removed okay.
a
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1
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I ()
1 I.think you are saying you don't really believe 2
that the core melt frequency due to earthquakes is as low 3
as 10 to the minus 4, but it's bigger than that.
Is that j
4 the point you are making?
I'm not quite sure why you i
5 brought in the numbers yesterday unless you are had j
6 something like that in mind.
I j
7 MR. OKRENT:
Because it was suggested that this i
f 8
program assured meeting the safety goals.
9 MR. KERR:
They don't have a core melt number at 10 present.
i 11 MR. OKRENT:
They haven't but they have some 12 words that say " reasonable assurance of core melt in the 13 life of the existing plants."
We talked about that
(
14 yesterday.
15 MR. REMIC K:
I have been sitting here biting my 16 lip all day.
I just can't go beyond this point, I guess.
17 MR. KERR:
Which one?
j 18 MR. REMICK:
Five or six points today.
It's l
19 more than that, I counted five this afternoon.
I heard 20 reference to this bit of "no core melt."
That is not the 21 Commission's safety goal.
The Commission's safety goal, 22 fortunately, has a two page summary which very clearly says 1
23 what the safety goal is.
It's two qualitative goals, just 24 stated behind me, and the two quantitative objectives which 25 I won't repeat, you know what they are.
The tenth percent.
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l Back in the section " qualitative safety goals,"
l 2
the Commission does make the statement which is referred to, 3
talking about " severe core damage accidents can erode 4
public confidence in the safety of nuclear power and can 5
lead to further unpredictability and safety for the future."
6 They say "In order to avoid these consequences the 7
Commission intends to continue to pursue a regulatory 8
program that has as its objective providing reasonable 9
assurance while giving appropriate consideration to the i
t 10 uncertainties involved, that a severe core damage accident l
11 will not occur at a U.S.
nuclear plant."
12 I know we are interpreting that as the 13 Commission saying there will never be a major core melt.
I
(
14 sure can't.
I read it I don't know how many times today 4
j 15 and I sure do not read into that that it says there will be i
16 no core melt.
j 17 In the summary, which very clearly states what 1
1 18 the policy is, the Commission does make this statement:
19 "The Commission wants to make clear that no death I
20 attributable to nuclear power plant operation will ever be
- i 21 l acceptable."
I don't hear anybody saying that the j
22 Commission is saying there will never be a death, but 3
23 that's even more pointed, I think, than the other.
I think j
l 24 it's a red herring, this bit that the Commission's new i
25 safety goal says there will be no core melt over.
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l MR. SIESS:
It's in the policy statement.
2 Didn't you just read it?
3 MR. SHEWMON:
Not in the policy statement; it's 4
in the background.
5 MR. REMICK:
It's in a discussion and statement 6 k on trying to provide stability to the regulatory process 7
and it's about as weasel-worded as anybody can write.
It 8
doesn't say the Commission is saying there will never be a 9
core melt.
i 10 MR. SIESS:
Is there anything that tells you I
F 11 :! where the policy statement ends?
I 12 l MR. REMICK:
They have a two-page summary.
It 13 J says the two qualitative goals and two quantitative
()
14 objectives.
That's the safety goal.
The rest is verbiage --
l verbiage, I said, with a "v."
15 16 I,
MR. SIESS:
I don't know how to read a policy i
17 l
statement unless somebody tells me where to stop reading it.
18 MR. REED:
It's not a policy statement, but 19 everybody is referring to it as the Commission is saying 20 there will never be a core melt and that's not it.
l 21 i
MR. SIESS:
It just says they hope there won't 22 be one.
i 23 l
MR. OKRENT:
I'll not use the word "never" --
i 24 i MR. WAPD:
Read that part again.
We have all 25 read it 100 times.
Read it again.
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l MR. REMICK:
"In order to avoid these adverse 2
consequences" -- they are talking about erosion of public "the Commission intends to continue 3
confidence, okay?
{
4 to pursue a regulatory program" -- because, if you want to l
5 talk about conditions -
"that has as its objective I
6 providing reasonable assurance, while giving appropriate j
7 consideration to the uncertainties involved, that a severe i
]
8 core damage accident will not occur at a U.S. nuclear power 4
1 9
plant."
]
10 MR. SIESS:
We can refer to it as a Commission i
11 objective rather than safety goal?
2 12 MR. REMICK:
It's an objective. running a 13 regulatory program, that's an objective.
Yes.
But it 14 doesn't say that that's the safety goal.
j 15 MR. SIESS:
I read something.from some answers
~
i j
16 to questions that were submitted to Congress by the 17 Commission.
j 18 MR. KERR:
Mr. Chairman, I think this discussion l
19 is so fascinating that we should reserve it for some time 20 in the future.
1 2
21 MR. REMICK:
I agree.
J 22 MR. MICHELSON:
We'll never get through the I
l 23 other.
t j
24 MR. REMICK:
That's why I bit my lip.
)l 25 MR. WARD:
Charlie, we are finished?
i
! ()
i i
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l MR. WYLIE:
Finished with the presentation.
I'm j
2 not sure what we do with it.
3 MR. BOSNAK:
Could we add one other thing?
4 MR. WARD:
Okay.
But don't bring up something
)
5 again like the safety goal.
i 6
MR. BOSNAK:
The Staff is looking for a letter l
7 of continued endorsement of A-46.
We are about to enter 8
the implementation phase.
We want to-keep the Committee 9
totally involved in the guidance documents, should they j
10 become available, and all the other'information as it is J
i j
11 becoming available, and we want you to participate, but we l
12 are looking for a letter of continued endorsement.
j 13 MR. MICHELSON:
Could we get a couple of 14 clarifications?
I brought it up at the beginning of the 15 meeting but nobody over said.
One of of the questions isz j
16 Is it the assumption, now, that no pipes in the plant break,
i j
17 irrespective of size or pressure rating?
Is that correct?
j 18 Is that an allowable assumption for the analysis?
~
19 MR. ANDERSON:
The assumption is no major piping i
20 that would either affect the piping system or function of j
21 the equipment.
We are limiting that to the piping that is i
j 22 involved in performing the functions or. involved in the
)
j 23 integrity of the primary coolant system boundary.
I j
24 MR. MICHFr, SON:
I can rupture a water line that 1
1 25 is not required for the functioning?
i 4
! ()
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MR. ANDERSON:
That's not required for the V
2 functioning -- we are not considering or not attempting to 3
inspect those other pipes.
It's not within the scope of 4
A-46, 5
MR. MICHELSON:
But you are allowing in the 6
analysis the assumption that they won't break anyway even 7
though you don't look at them; is that correct?
8 MR. ANDERSON:
We are not assuming anything a
9 l either way.
I think we feel that they are not going to 10 break, we are not going to have major breaks, but it's not 11 within the scope.
12 MR. BOSNAK:
hhat you are reading is that the 13 J seismic event does not cause these lines to break and r's I
(_)
14 that's what it says.
Exactly right.
15 MR. MICHELSON:
Irrespective of energy level and 16 irrespective of size.
i 17 MR. BOSNAK:
These plants we are required to i
18 look at pipe breaks, you know.
19 MR. MICHELSON:
I just want a clarification.
20 Even if it's a 1-inch line or half-inch line or whatever, 21 it won't break --
22 l MR. BOSNAK:
That's correct.
I 23 l MR. MICHELSON:
-- as a result of a seismic l
24 event.
MR. BOSNAK:
If you have a pipe break 25 it doesn't occur simultaneously with the seismic event.
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MR. MICHELSON:
Another question now, it isn't (O.
2 clear, but what's your assumption concerning seismically 3
induced fire?
Can there be a seismically induced fire?
i 4
MR. KERR:
Not unless you rub two sticks 1
5 together during the seismic event.
6 MR. MICHELSON:
Other seismic events have had 1
7 fires so you can't use the experience --
8 MR. BOSNAK:
Fire in the seismic event is not 9
considered in A-46.
10 MR. MICHELSON:
I just wanted to make sure.
11 MR. ANDERSON:
One other statement, if I may, 12 with regard to the potential endorsement of this program by 13 the ACRS, I think -- I hope that you would endorse the 14 program within its scope.
If you want to point out that 15 there are a number of areas that you have concerns about 16 that you understand are outside the scope, that's fine.
17 But we really are looking for an endorsement or whatever 13 comments you might make within the scope of A-46 as we 19 think we defined it.
20 MR. WARD:
All right.
Thank you very much, 21 Mr. Anderson, Mr. Bosnak.
I r
22 Let's turn to the next topic on the agenda, then, 23 Dr. Kerr, the NRC regulatory process.
At least that's what 24 it is called here.
25 MR. KERR:
This is the green cover that doesn't
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have holes punched in it.
I will not insult your 2
intelligence by reading the material to you.
I think it's 3
self-explanatory.
I have made a recommendation and I'm f
4 willing to try to respond to questions.
t
(
5 MR. MOELLER:
I thought Gary Quickscriber's memo 6
was well done.
l 7
MR. KERR:
I did, too.
8 MR. MOELLER:
The only question I had, I was 9
reading the chairman of the NRC's memo of August 6th, to 10 see where this effort falls, you know which bullet it falls 11 under, and generally it falls under, I guess, several of 12 the bullets.
But it's interesting that no single bullet 13 really would cover this.
I think several could cover it.
14 MR. KERR:
You recognize that Gary and I l
l 15 recommend two rather different things.
1 16 MR. REMICK:
Could you remind us, Bill, what 17 precipitated this?
I'm at a loss to know how this came up.
l 18 What's the background on it?
I 19 MR. WARD:
I think you are being a little too f
20 cryptic here.
Could you summarize?
l l
l 21 l MR. KERR:
We were discussing at the last
{
22 meeting advanced plants or something like this and we 23 failed to discuss regulatory problems and it was concluded 24 that we really ought to say something about the way in 25 which regulation was carried out, and I was asked to draft O
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something.
I drafted about two paragraphs and there was a LJ 2
long discussion that said those two paragraphs -- well, the 3
two paragraphs said the Commission ought to appoint a group i
4 to study the regulatory question.
5 Subsequent to the meeting, Gary pointed out, as 6
did Ray, that we had written a number of comments, a large 7
number of committees had commented that there had been 8
suggestions for a lot of changes and that if we were going 9
to write a letter requesting another study, at least we 10 ought to let people know that we knew some of these things 11 had occurred, which is a good suggestion.
12 My own thinking, I decided that since all these 13 recommendations had occurred and nothing had resulted --
p()
14 I
not enough had resulted therefrom, that rather than telling 15 l the Commission what it ought to be doing, maybe we ought to l
16 be doing a bit of work ourselves.
That, therefore, led to 17 my suggestion that a letter of the type that I am i
18 l recommending would be appropriate.
E 19 !
MR. SIESS:
The subject is regulatory process?
i 20 !
MR. KERR:
Yes, sir.
21 MR. SIESS:
Why does it say we are going to do a i
22 better job?
{
23 MR. KERR:
It doesn't say we are going to do a 24 better job.
It says we are going to do something before we 25 !
tell the Commission, namely, study the situation a bit.
1 l
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l MR. SIESS:
How many of you read the letter from 2
Zach about duties of the ACRS?
3 MR. KERR:
I have.
j 4
MR. SIESS:
There's a couple of places;where he 5
thinks we should advise the Commission on the Staff's j
6 performance.
7 MR. WARD:
Well, let me clarify a couple of 8
things.
I think you are generalizing a little too much.
9 First let me say something.
The letter from Zach I think 10 is in response -- first of all, it's directed to the other 11 commissioners.
This isn't the charge to the ACRS yet.
It 12 is toward the development of more guidance to the ACRS, I
13 which we have asked him for.
14 When you say the last bullet there advises on i
15 staff activities to implement two specific things, if you 16 read it:
"The safety goal and severe accident policy."
l i
17 MR. SIESS:
What about on the second page, the 18 bottom -- no, the bottom bullet on the first page.
1 1
19 MR. WARD:
Yes.
But they are rather specific.
20 I don't disagree --
21 MR. SIESS:
What Bill is proposing and what we 22 are proposing is not inconsistent with that, if that's a 23 virtue.
j i
I l
24 MR. WARD:
What's the purpose of Gary's letter 1
i 25 that's different from what you said?
t
()
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l MR. KERR:
Gary's letter would ask the NRC to 2
undertake a study.
My letter would say:
We are going to 3
study this issue and eventually make some recommendations 4
for changes rather than asking the Commission to set up a 5
study group.
6 MR. WARD:
Okay.
And you are giving the 7
Commission some advanced warning of this or just sort of 8
documenting in advance?
9 MR. KERR:
We are going to do it.
If you have 10 some suggestions we would like to get them.
We would hope 11 to discuss this with you early on where input may be 12 appropriate.
It seems to me if we are going to do 13 something we ought to do a bit of preparatory work before
()
14 we tell the Comn.ission what to do.
15 MR. SIESS:
I looked at the 10 items in Gary's 16 letter and I bet you, just offhand, a number of the things 17 [ are already documented, sent to him --
18 MR. WARD:
Which' document are you talking about?
19 MR. KERR:
Please recognize the idea of setting 20 up a study group was not my idea.
I simply undertook to a
21 compose what turned out to be a two-paragraph letter in f
response to a committee request.
22 I
23 ;
MR. WYLIE:
Could I ask a question?
What do you-1 l
24 i think of it?
25 MR. KERR:
Well, I guess, I think before we tell l
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l the Commission what to do we ought to give a little more 2
thought to what it is we want them to do and why, than I 3
think we did.
So if we are going to do something, if we 4
are going to give advice to the Commission, it ought.to be 5
a little bit better founded than I think --
t 6
MR. WYLIE:
Do you suggest we study the problem 7
and come to some understanding of what we really want to 8
say before we say so?
9 MR. KERR:
I would think so.
10 MR. SIESS:
I don't think we sent them a laundry 11 list.
Gary's list is a laundry list in the sense that it's 12 a lot different --
13 MR. KERR:
Gary's list is quite appropriate, I 14 think, if we are going to do what we said we were going to 15 do, because it at least gets on record the fact that we 16 recognize that studies have been made and here are the ones 17 that we have recognized.
18 MR. SIESS:
I'm talking about the list of 10 j
19 items on the second page.
]
20 MR. KERR:
Okay.
That, I guess, I --
j 21 MR. SIESS:
A lot of.it would be hooked up with 22 the long-range planning.
I l
23 MR. REED:
I favor Dr. Kerr's approach rather 24 l than Gary's.
After all, we already have a copy of some of l
25.
the things that might be laid on us and I don't think~it-(2)
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l would be appropriate for us to say to the commissioners, 2
hey, a bunch of things that you ought to be doing.
3 After all, we are here to give them advice and 4
it seems to me to serve notice in advance -- and I like the t
5 10 issues -
" Serve notice:
These are the kind of issues i
6 that we are going to be looking at" is a fine way to go.
I 7
would add something to item 3 on the management issue, but 8
that's editing.
9 MR. MOELLER:
Another approach would be, and I 10 hear what is being said, would be to take Gary's memo and, l
11 instead of saying on the second page that the NRC should 12 set up a oroup, to say that we are setting up a group and 13 we would like to have a designated section within the NRC
()
14 to interact with, or designated group there to interact 15 with as we move along.
16 i
MR. WARD:
Charlie?
I f
17 MR. WYLIE:
A lot of these same questions are 18 questions that have been considered and addressed during 19 the long-range planning study that Mike Carpenter was 20 involved in --
21 MR. SIESS:
This thing is loaded.
22 MR. KERR:
It sure is.
I i
23 l MR. WYLIE:
I think the recommendation coming I
l 24 !
out of long-range planning is loaded to some extent.
q j
25 MR. MICHELSON:
Not this much.
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l MR. SIESS:
To make the statement that the 2
existing regulations and requirements and Staff's 3
enforcement does not ensure adequately high quality power 4
plant performance --
5 MR. WYLIE:
I wouldn't make that statement i
6 R before a further consideration and discussion by this 7
committee, because I don't believe that.
8 MR. SIESS:
I'm prepared to discuss it.
But the 9
point is, it's going to take elaborate study --
i h
10 MR. KERR:
I have sat here and listened to all l
11 the things wrong with Davis-Besse and all the things wrong 12 with TVA.
If that's not an inappropriate level of 13 performance, I don't know what is.
14 MR. SIESS:
But you are blaming it on the b
15 l
regulations and Staff.
l 16 MR. KERR:
No, no, wait a minute.
I do not i
17 l blame it.
I say their system hasn't produced.
I don't say 18 that they should have.
I simply say it hasn't.
l 19 ij MR. SIESS:
I am not disagreeing with you.
I
]
20 MR. WARD:
A key example was the Davis-Besse 21 situation where we have been told for a year or two years i
22 that Davis-Besse met the regulations, but Davis-Besse was 23 unsafe and the Staff new it and there didn't seem to be any j
l j
24 effort to resolve that ambiguity.
25 MR. SIESS:
I agree.
l i
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l MR. WARD:
I think that's what triggered the 2
concern.
3 MR. SIESS:
I'll give you another issue.
The 4
4 regulations don't guarantee safety.
They don't even i
5 guarantee you'll meet the safety goal any more.
I don't 6
think the OA ensures quality, and yet the OA is part of the 1
7 regulations that is costing a tremendous amount of money.
8 There are a number of things like that, I say, to make a 9
case.
10 MR. KERR:
We could decide to do this without i
11 sending anybody a memo and maybe if we decide to do it 12 that's the way to do it.
13 MR. WYLIE:
I would suggest that we undertake a
(
14 study to decide what we want to do.
i 15 MR. SIESS:
If you sent this first paragraph up 16 and the Commission came back and said "we don't agree, 17 don't bother" --
18 MR. KERR:
That might be the happiest solution 19 to the whole problem.
20 MR. SIESS:
Well, if we are independent we go 21 ahead and do it anyway.
That's another issue.
4 22 MR. WARD:
Charlie?
f 23 MR. WYLIE:
I would like to comment on the TVA I
24 comment.
You have to remember that it was the Staff that 1
25 kept pushing TVA.
Finally, when you get right down to it, O
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l they are the ones that told them if they didn't shut'down 2
they were going to shut them down, so I say the process was 3
working at TVA.
They finally came down to the fact --
4 MR. SIESS:
But the process to make a good plant i
j 5
wasn't working.
6~
MR. WYLIE:
The Staff doesn't do that.
The fact 7
that people are leaving TVA with experience levels because 8
of other reasons is not the Staff's problem.
9 MR. MICHELSON:
But the Staff was well aware of i
10 what was happening at TVA --
11 MR. WYLIE:
And they kept telling them.
12 MR. MICHELSON:
They kept telling them in a very 13 soft manner.
(
14 MR. WYLIE:
My opinion is they got pretty damn 15 rough with them and told them if they don't do it 16 MR. WARD:
Gentlemen, you decided you wanted a 3
17 record of this sort of thing and we can't if three people 18 are talking at the same time.
)
19 MR. MICHELSON:
That's good, i
20 MR. EBERSOLE:
What ~ about the Davis-Besse case 21 or the Salem case or Browns Ferry or TMI-2?
I 22 i MR. WYLIE:
Browns Ferry fire was a poor i
23 judgment by TVA to use that kind of cable.
When you get i
24 down to it nobody in the industry used that kind of cable.
I 25 MR. EBERSOLE:
This gets down to the fact that l
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l by and large there's a spread in the industry confidence 2
and zeal to do the right thing.
It's like the old Indian i
i 3
tribes --
4 MR. WARD:
If it's important to use the right i
5 kind of cable should there be a regulation to provide 4
6 assurance that it's used?
j l
7 MR. WYLIE:
At that particular time of a
8 development, you've got to remember that was a good while 9
ago.
That was way back.
At that particular time there was 10 no requirements on cable at all.
11 MR. EBERSOLE:
They could use polyethylene.
12 MR. WARD:
Is there today?
13 MR. WYLIE:
Oh, yes.
Certainly are today.
It 14 wouldn't have happened today.
15 MR. WARD:
Is this --
16 h
MR. WYLIE:
The cable being useo today, it would i
j 17 not happen.
18 l
MR. SIESS:
I'm not beating on the Staff.
The I
l 19 l
Staff is doing its job.
It is enforcing the regulations at 2
{
4 i
20 the same time it is writing new ones.
I think to go out l
21 and say a plant should be responsible for safety, they I
22 shouldn't just stop with what the NRC tells them to do.
J 23 But if you are sitting out there in a plant and you get 200 24 questions on every license amendment you submit, and all 1
'1 1
25 the detail the Staff wants to see your calculations, wants i,
- ()
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l to review them and do this, you are soon going to get the 2
idea that, gosh, those guys know everything.
If I do 3
everything they tell me to do, the plant is going to be 4
safe.
And besides, I haven't got time to do anything else.
5 Now, the regulations are there and they are 6
being enforced, but I'm not sure they are producing good 7
plants or safe plants.
8 MR. KERR:
That may be preclSely the reason they 0
9 aren't.
Maybe they are overregulated.
ql 10 i
MR. MICHELSON:
In areas where they aren't 11 regulated you have to see how they behaved.
Generally when 12 you look into those areas you find that if the NRC doesn't 13 require, the utility doesn't co much.
So the experience is
()
14 bad on the side where it's nor. regulated, too.
15 i
MR. KERR:
I think that's true of some utilities.
l 16 I don't think it's true of all of them.
17 MR. MICHELSON:
I wouldn't want to generalize to 18 l
all.
You have to look at both sides of that one, though.
19 MR. SIESS:
If you look at that, if you do what i
20 l the NRC tells you, it's right, and if it doesn't work out right 21 f it's their fault.
H l
f 22 MR. MICHELSON:
That's the way it works.
1 23
.r MR. SIESS:
But I think it's a hot potato.
i I
24 MR. WARD:
If you notice, in Prailey's cover i
25 l letter for this copy of the other letters the commissioners l
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l got for guidance to the ACRS, Frailey said that the list i
2 does not include the facets of the regulatory process that i
3 impact on safety, for example.
And at least Zach's
{
4 assistant expressed interest in learning about other things 5
we think are important and my implication is that the ACRS-6 should be working on that.
7 I don't think it would be a bad idea if, as Zach i
j 8
is seeking guidance from the other commissioners for an 9
ACRS agenda, that we could also comment on it.
This i
10 particular thing, the point that Bill expressed in his f
11 draft, perhaps could be generalized, perhaps given as an j
12 example of the sort of thing that we think it's important i
13 for us to address, if you believe'that.
()
14 MR. SIESS:
I expressed the concerns that a 15 number of times there's not a clear-cut relationship 16 between regulation and safety because there's a clear-cut
]
17 assumption that if regulations are satisfied, it is safe.
I j
18
( I have had the same concerns about OA and safety.
19 If somebody is going to invest'igate whether 20 there's a relationship between safety and regulation and if 1
)
j 21 so which regulations do and'which don't, I'm not sure this
,i j
22 committee is the one to do it because I think we probably 1
]
23 contributed as much to the regulation complications as we i
r 24 i have to anything else.
Maybe it needs some outside group I
25 that hasn't been involved in it too much.
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MR. WARD:
Well, Chet, when you say there's no
(_)
2 relationship between regulation and safety, I guess you are 1
3 being half flip and the 4
MR. SIESS:
I can think of regulations --
5 MR. WARD:
Certainly the purpose of the i
6 regulations is nuclear safety.
They may do that 7
imperfectly.
In fact they may be very imperfect.
I think 8
that's what Bill's letter is trying to address.
Charlie?
1 9 0 MR. WYLIE:
You know, at least in several of the j
0 10 l
cases there's really big problems like Davis-Besse and the i
11 TVA problem, it stems from top management of the company.
j 12 Both of them do.
That's a hard one for the Staff to attack.
13 I wouldn't say it's something the regulations shouldn't l
14 attack, that NRC shouldn't attack.
But it's a hard one to 15 say that that one is a condemnation of the Staff, because 16 it's not.
17 MR. EBERSOLE:
Using the human factors analysis 18 starts at a level where you push buttons and turn knobs.
k 19 MR. SIESS:
Do you think it improves safety?
20 MR. WARD:
Do I think it improves safety?
l 4
21 4
MR. SIESS:
Do you think all the extra pipe i
22 l restraints improved safety?
)
i 23 !
MR. WARD:
No.
I'm granting you that there's an 24 !
imperfect correlation between safety and regulation.
I 25 l MR. SIESS:
I didn't say all regulation.
Some i
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I regulations do, some don't.
l 2
MR. KERR:
Let me bring up something else that i
3 certainly if it exists is not the fault of the Staff.
4 Under the Atomic Energy Act as amended, the 4
5 Atomic Commission had the responsibility for promoting and l
6 regulating nuclear power.
I'm told by interpreters of the l
7 Act that separated the NRC out, that the NRC has no i
8 responsibility for promoting.
I personally don't believe 9
that because I don't see how you can regulate something j
10 that doesn't exist.
But it seems to me that the system 11 might work better if the NRC either had explicitly or 1
12 implicitly some responsibility for developing safe nuclear 13 power.
If it is national policy to have nuclear power, and J
O 14 if it e ooino to ee eefe, thee it seems to me ene cen't i
15 separate reliable from safe.
I think there is an i
16 artificial separation which sometimes perhaps may make l
17 things less safe than they otherwise would be.
And I think i
18 it leads to the adversarial relationship that exists, which i
19 I personally consider very counterproductive toward both 20 safety and reliability.
i 21 MR. WYLIE:
I think that's a good point and 22 that's one this committee probably should consider, as to i
f 23 how you could go about reducing that adversarial situation.
24 MR. EBERSOLE:
Didn't that require an attitude j
25 and level of competence in the utilities that doesn't exist, jl0 t
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1 at least in the worst utilities?
And there is a spectrum j
2 of good to bad utilities.
i j
3 MR. WYLIE:
There are probably ways, though, I
4 that you could create a relationship that would reduce that.
i 5
MR. EBERSOLE:
You use the carrot and the stick?
l 6
MR. KERR:
Jesse, right now as I look at the 7
spectrum of fines that this organization assesses against l
l 8
organizations, they fine the good and the bad about equally.
9 This is supposed to be something that guidance.
j 10 MR. EBERSOLE:
Aren't the fines drawn out of the 11 ratepayers' pockets, Charlie?
12 MR. WYLIE:
I don't know where they come from.
j
)
13 MR. SHEWMON:
Not always.
It's up to the PUC.
14 MR. WARD:
Some PUCs don't permit that.
l 15 MR. MOELLER:
It seems to me this subject and-I 16 the long-range goal and long-range plan are heavily 17 l
intertwined.
It may be that we can accomplish what we aro
{
18 seeking to do here if and when we go over the long-range l
19 plan and decide on something before we go forward'to the 20 Commission.
l 21 l MR. WYLIE:
I would support that, that we at f
j 22 l least look at it before we write this letter.
l j
23 l MR. MOELLER:
Look at it.
Right.
Right.
I l
l 24 i think it is intertwined and we can save ourselves some time.
I j
25 MR. WARD:
I guess it's intertwined to some l
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l extent.
But also, I guess, Bill, the letter says we are 2
going to undertake something, an in-depth study of the 3
issue.
But I haven't heard any plan for the Committee how 4
it should undertake this.
5 j MR. MOELLER:
We have done that in a big way in 6
the long-range plan.
7 MR. WARD:
No, no, the long-range plan isn't 8
something for this committee to do.
We are just commenting 9
on what the Agency should have in the long-range plan.
10 MR. MOELLER:
Right --
11 MR. WARD:
But Bill is promising in this draft 12 that this Committee will do something on this topic.
I i
13 f would like to understand what it is.
()
14 MR. KERR:
I will present a detailed plan but I 15 didn't want to do it until the Committee decided whether 16 they wanted to take it.
I 17 [
MR. WARD:
But I want to see -- I want to see 18 the NUREG.
19 (Laughter.)
20 We had this discussion this morning.
21 MR. KERR:
The Committee wanted to do something l
22 and I'm suggesting it ought to do a little more homework l
23 I before it tells the Commission what to do.
The homework l
depends a little bit on what the Committee wants to do 24 l
l because, as I said before, this thing was not my idea.
If 25 I
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l I'm going to put something down on paper I need input from j
2 the table who wanted to tell the Commission what to do.
}
3 MR. WARD:
Okay.
i 4
MR. REMICK:
I have a general concern about what 5
is proposed.
It is for this reason I support the idea.
I l
6 think there should be a comprehensive look at the
)
7 regulatory process.
That is a tremendous job and this i
l 8
Committee could do it, I think, or could do most parts of i
9 it, but only if that was the only thing we are doing.
I 10 look at the things we are.doing with all of our l
11 subcommittees, all the things we are starting to get 12 involved in, and I really have to question, how good a job I
13 would we do?
I think this needs to be done, but to do it,
(
14 I can see, it is almost a full-time job or at least a t
15 full-time job for this Committee, and I'm not sure we would i
l 16 do the job that needs to be done with our limited i
17 availability.
And that concerns me.
i 18 I agree, I think the whole process should be
]
19 looked at.
I think there are opportunities for improvement.
20 Maybe there is overregulation.
21 j
MR. KERR:
My own counter to that, and not that
{
22 it's a strong one, is that I don't know anything more l
=
23 important than the thing we are doing.
l 24 MR. REMICK:
Then-let's get rid of 90 percent of 25 the other things we are doing.
Because that and waste l
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alone would be a major contribution to the Committee 2
because vc are spread so thin I don't think we do anything 3
well.
4 MR. WARD:
I want to comment, I agree with you, 5
I don't think the Committee is capable of undertaking, even 6
if we devoted full time to it, the sort of review that's 7
needed, comprehensive review that's needed.
But I don't 8
think it's our role to do that.
What I suggest might be an 9
alternate is for us to do enough of a study of the 10 situation to develop a recommended program for the Agency l
11 to take on.
I mean, I think that's more the sort of role 12 we could reasonably take.
And it strikes me that probably 13 is not, you know, an overwhelming task for us if we believe 14 it is a high priority one.
15 Well, let me find out:
Does the Committee --
16 let me ask for sort of an indication of whether the 17 Committee thinks that this is an issue that we should begin 18 to spend some Committee time on, at least to the extent of I
19 developing some recommendations for, let's say, an Agency 20 program.
That's one way to look at it.
If we think it is, 21 should we tell the commissioners and describe what we are 22 doing in advance and give them some sort of schedule and a 23 general indication of what we are gcing to do?
24 MR. WYLIE:
That's two points.
Do you want a i
l 25 vote on each?
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l MR. WARD:
Let's vote on the first one.
2 Should -- I'm not very good at posing motions.
Should the 3
Committee take on the task of reviewing the regulatory 4
process with the aim of providing some recommendations for 5
a more comprehensive program to the commissioners?
Let's 1
)
6 have a soft vote.
i 7
MR. WYLIE:
Wait a minute.
Are you saying we
)
l 8
would make recommendations to the commissioners for them to i
9 undertake a study or initiate somebody else doing that?
10 MR. WARD:
I'd presume we'd do enough work to 1
11 kind of sharpen up our focus.
12 MR. WYLIE:
Say:
"This is what I think'you i
13 ought to look at."
14 MR. WARD:
Yes.
Glenn?
j.
15 MR. REED:
I think I support the motion, but
'l j
16 what I would visualize is that we would discuss each one of 17 these 10 issues, and maybe there are more, and we would
'l 18 decide that they are very important, that something needs 19 to be done, that we do not understand what should be done 1
1 20 at this point in time or how important they are, that we i
21 might even draw in a consultant just to sharpen our focus, 22 as you said.
And then we would come out on each one on the 23 items and say:
There has to be some look taken here on a 24 more comprehensive basis.
Yes, that I would support.
1 25 MR. WARD:
I don't know that these are the 10.
1 i
C:)
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l These look like real good points that Gary has listed, but j
2 we might decide on slightly a different set or different 3
approach.
Yes?
i 4
MR. SIESS:
How much resources are we going to 5
devote to this?
We don't have any resources --
6 MR. WARD:
Zero so far.
We haven't decided to 7
do it.
4 8
MR. SIESS:
How many contingent Subcommittee 9
meetings have we got?
10 MR. MICHELSON:
How empty are your pockets?
j 11 MR. WARD:
Based on what the Committee decided 12 several months ago, we've got a sort of priority list for l
13 our activities.
If you decide at this meeting that you
}
14 want to take on this task and we talk'about the rough scope 15 of it and then your friendly management committee can look 4
16 at that and inform the Committee of what we think should be 17 dropped off from the bottom of the list.
18 MR. REMICK:
Friendly planning committee; right?
19 MR. WARD:
Right.
Friendly planning committee.
l
?
20 Right.
I 21 Could we have a soft vote on whether we should
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22 l
undertake this sort of task and then talk about-what it j
23 might be?
How many people think we should?
Seven.
How I
24 many are opposed?
Okay.
It's unanimous.
1 l
25 MR. MICHELSON:
No.
No.
1
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l MR. WARD:
If you don't have an opinion --
i 2
MR. SHEWMON:
It was seven to zip, let's put it 3
that way.
4 MR. WARD:
Do we have what we want to do well t
5 enough in mind so that we should send a letter to the 6
commissioners, informing them of our intent at this meeting?
7 MR. KERR:
We have a Procedures and Policies 8
Subcommittee.
Why don't we ask them to formulate something.
9 Regulatory policies --
10 MR. WARD:
The chairman of that isn't here.
l 11 MR. KERR:
Well, that's a great reason.
It's 12 certainly in that realm.
13 MR. MOELLER:
I think that's premature until we 14 read the long-range plan statement.
15 MR. WARD:
I think that will give us added focus 16 on it.
But how many -- does anybody have any sense of what --
4 17 anything they would like to say,, what they think the i
j 18 priority for this sort of task should be?
In order to 19 reach the sort of goal we are -- within a quarter-or half a j
]
20 year, we would have a set of recommendations for the 21 Commission in this area?
How many subcommittee meetings do l
j 23 you think we'd need, for example?
Put it in.those terms?
I 23 MR. MICHELSON:
Three or four.
i 24 MR. WYLIE:
Four.
i 25 MR. EBERSOLE:
It's sure a tough thing to get a
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2 MR. WARD:
I know it is.
1 3
MR. EBERSOLE:
There's some that would say we l
4 don't need any more -- TVA doesn't need any.
The reason 5
they don't need them is because they lost the whole picture j
6 of expanding the economy.of the country.
I 7
MR. WARD:
Are we talking about the same thing?
8 MR. EBERSOLE:
Yes.
Same thing.
This is the 9
degree to recover the option, as I see it.
There's lots of 10 folks who say we are never going to be able to pick up and 11 build --
12 MR. WARD:
He's giving a pep talk for the 13 urgency of the thing.
()
14 MR. SIESS:
How many-Subcommittee meetings have
)
15 you had on long-range plan, Max?
?
16 MR. CARBON:
I guess six.
17 MR. SIESS:
No less.
No fewer.
l 18 MR. WARD:
Than what?
Six?
.i 19 MR. CARBON:
Six, I think.
20 MR. REED:
No one has mentioned the state of the 21 nuclear power subcommittee, of which Dr. Kerr was the l
22 chairman of --
23 i
MR. KERR:
You are just trying to remind me of 24 all my failures.
25 MR. REED:
.I'm not so sure if this is not-just i
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1 indicative of the persistence of Dr. Kerr to try to 2
revitalize and get through in a different way, by questions 4
)
1 3
rather than by statements, these very important issues that 4
came forward in the state of nuclear power subcommittee.
I f
5 applaud this technique.
I think it's good.
But I'm not so 6
sure that Dr. Kerr should turn it over to another 7
subcommittee because he's done such a good job in 8
reintroducing this.
j 9
MR. SIESS:
I think it has about as much chance i
10 of success.
1
]
11 MR. KERR At other efforts.
Yes.
I say Glenn 12 is just trying to remind me of my failures.
i 13 MR. WARD:
Bill was asked to do both of these
()
14 things --
1 1
15 MR. REED:
If this keeps resurfacing and 16 resurfacing, there must be a hell of a lot of smoke behind 17 it along with this fire.
Quite frankly, I think these are 18 the kind of things that we should be giving advice to the f
19 Commissioners on.
t j
20 MR. WARD:
Okay.
Let me say I gather what the
}
21 Committee wants to do is go ahead, try to develop.some sort I
22 of program of this sort.
We regard it as a fairly high J
23 priority activity.
It ought to be assigned to Louis'
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24 Subcommittee.
I'll talk to Louis about it and I won't t
i 25 recommend a letter.
Does anybody have any input to give to
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me beyond what you've already given?
If you have, please 2
give it to me.
3 Any other comment?
4 MR. WYLIE:
I would suggest setting up an ad hoc 5
subcommittee.
6 MR. MICHELSON:
The problem is Louis doesn't 7
have subcommittee meetings very often.
If you are talking 8
about six you are not realistic.
l 9
MR. WARD:
Let me talk to him.
l 10 MR. MICHELSON:
It doesn't do you any good to j
i 11 give him a subcommittee because he doesn't ever want to 12 read.
13 MR. CARBON:
He doesn't attend them anyway.
14 MR. WARD:
Let's take a break and come back in l
15 15 minutes for Dr. Carbon, please.
I 16 (Recess.)
(
17 MR. WARD:
The next topic is a discussion of the
[
]
I 18 long-range plan.
Dr. Carbon.
l 19 MR. CARBON:
At Harper's Ferry about 1-3/4 years 20 ago the Committee decided to get involved in long-range 21 planning.
I'm not sure but the discussion was along the s
22 lines of the ACRS itself preparing long-range planning.
In 23 l any event, a subcommittee of Louis Moeller, Remick, Carbon i
24 and Siess were appointed.
Chuck Siess dropped out, Chuck 25 has been a part-time participant.
Ital has rarely i
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participated.
The subcommittee enhanced its efforts by 2
inviting a dozen respected people, highly respected people, 3
to give us advice and judgment on several questions such as 4
Should the NRC have a long-range plan, what role should the 5
ACRS play in development, what should long-range planning 6
cover, how should it be developed and so on.
7 The results of the discussions were as follows.
8 All of the dozen people plus the Subcommittee members 9
themselves felt that the NRC should have a long-range plan.
70 The full Committee wrote to the Commissioners last August, 11 saying so.
It should be noted that either simu.1taneously 12 with our Harper's Ferry meeting or soon therwafter, the 13 Commissioners also concluded that they needed a long-range 14 plan and they directed OPE and ACRS to work together to l
15 develop one.
It was their thought, suggestion, requiat, 16 that the ACRS provide input to OPE.
l l
17 l In their view I think they thought of OPE i
18 {
developing the plan patterned pretty closely after the PPG
{
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19 # approach.
l l
20 l
This direction from the Commissioners of OPE and 1
e 21 ACRS to work together soon fell apart for coveral reasons, l one of which was the Commissioners wanted OPE to keep all 22
(
23 l
its reports and planning confidential and ACRS had the of l
24 problem that we couldn't consider their material in j
f 25 confidential sessions, so there came a parting of the ways.
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So, to make a long story short, I believe that 2
Commissioner Zach is not a strong proponent of long-range 1
3 planning.
There is a PPG document, OPE no longer exists, 4
and long-range planning is receiving little Commission 5
attention at present.
6 I wrote that about a half hour ago and came back
,I 7
in the room and got Ray Frailey's things for PG planning, 1
8 so let me stop at this point and have Ray give you a brief 1
9 report, brief summary on what is in his report here.
Ray?
l 10 (Whereupon, the mooting proceeded in closed 11 session.)
12 13 14 1
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CERTIFICATE OF OFFICIAL REPORTER O
l This is to certify that the attached proceedings before the UNITED STATES NUCLEAR REGULATORY COMMISSION in the matter of:
NAME OF PROCEEDING:
ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 316TH GENERAL MEETING r
l DOCKET NO.:
PLACE:
WAS!!INGTON, D.
C.
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DATE:
TilURSDAY, AUGUST 7, 1986 were held as herein appears, and that this is the original transcript thereof for the file of the United States Nuclear Regulatory Commission.
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JOEL,BREITNER Official Reporter ACE-FEDERAL REPORTERS, INC.
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O USI A - 46 ACRS PRESENTATION
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AUGUST 7, 1986 O
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l i
O BACKGROUND l
o TASK A 146 DESIGNATED AS USI IN DECEMBER 1980 i
o 5 TASKS IDENTIFIED, USE OF SEISMIC EXPERIENCE DATA PROVED TO BE THE MOST REASONABLE ALTERNATIVE l
o COLLECTION OF TEST EXPERIENCE DATA BY EPRI TO SUPPLEMENT SEISMIC EXPERIENCE DATA O
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SEISMIC QUALIFICATION OF EQUIPMENT USING EXPERIENCE DATA STAFFESTABLISHEDFEASIBILITYOFUSINGSEISMICEXPEhlENCE o
DATA (LLNL STUDY) o SOUG CONDUCTED PILOT PROGRAM TO COLLECT AND EVALUATE SEISMIC EXPERIENCE DATA (SEPTEMBER 82) o ADDITIONAL SEISMIC EXPERIENCE DATA COLLECTED FOR C0ALINGA, MORGAN HILL, CHILE, MEXICO EARTHQUAKES o
SSRAP FORMED JUNE 1983, JOINTLY SELECTED BY SOUG AND NRC o
EPRI INITIATED TEST kXPERIENCE DATA COLLECTION IN 1984 o
NRC STAFF PARTICIPATED IN DATA EVALUATION AND CLOSELY MONITORED SQUG/EPRI/SSRAP EFFORTS o
PROPOSED STAFF POSITION BASED ON USE OF SEISMIC EXPERIENCE O'
AND TEST EXPERIENCE O
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THREE MAJOR CONCERNS t
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- 1. EQUIPMENT ANCHORAGES l
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- VERIFY FUNCTIONAL CAPABILITY OF EQUIPMENT (RELAYS) o NEW LICENSEES O
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IMPLEMENT BY GENERIC LETTER i
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RESOLUTION OF COMMENTS INCORPORATED IN PROPOSED RESOLUTION PACKAGE, AND CONCURRED BY NRR DIVISIONS o
PLANNED TO MEET WITH CRGR IN SEPTEMBER 1986 FINAL ISSUANCE OF RE'OLUTION AND GENERIC LETTER IN OCTOBER 1986 S
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