ML20205E672
| ML20205E672 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 10/09/1985 |
| From: | NRC COMMISSION (OCM) |
| To: | |
| References | |
| REF-10CFR9.7 NUDOCS 8510170372 | |
| Download: ML20205E672 (114) | |
Text
. _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
f e- UNITED STATES OF AMERICA '
i NUCLEAR REGULATORY COFDIISSION -
In the matter of: ,
COMMISSION MEETING Meeting with Carolina Power and Light Company on Environmental Qualification Exemption Request for Brunswick Nuclear Station (Public Meeting) Docket No.
Locaticn: Washington, D. C.
Date: Wednesday, October 9, 1985 Pages: 1 - 89 ANN RILEY & ASSOCIATES
' Court Reporters 1625 I St., N.W.
Suite 921 Washington, D.C. 20006 8510170372 851009 (202) 293-3950 PDR 10CFR PT9.7 PDR
4
- 1 D I SC LA I M ER 2
3 4 .
5 6 This is an unoff6cial transcript of a meeting of the 7 United States Nuclear Regulatory Commission held on Wednesday, 8 October 9, 1985 in the Commission's office at 1717 H Street, 9 N.W., Washington, D.C. The meeting was open to public 10 attendance and observation. This transcript has not been 11 reviewed, corrected, or edited, and it may contain 12 inaccuracies.
3 13 The transcript is intended solely for general 14 infeemational purposes. As provided by 10 CFR 9.103, it is 15 not part of the formal or informal record of decision of the g
16 matters discussed. Expressions of epinion in this transcript 17 do not necessarily reflect final determination or beliefs. No 18 pleading or other paper may be filed with the Commission in 19 any proceeding as the result of or addressed to any statement 20 or argument contained herein, except as the Cemmission may 21 authori=e.
22 23 24 25
l UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 2
3 MEETING WITH CAROLINA POWER AND LIGHT COMPANY ON ENQIRONMENTAL OUALIFICATION EXEMPTION REQUEST FOR BRUNSWICK NUCLEAR STATION 5
6 PUBLIC MEETING 7
Room 1130 8 1717 H Street, N.W.
Washington, D.C.
9 Wednesday, October 9, 1985 10 The Commission met, pursuant to notice, at 11 2:04 p.m.
12 COMMISSIONERS PRESENT:
13 NUNZIO PALLADINO, Chairman of the Commission 14 THOMAS ROBERTS, Commissioner FREDERICK BERNTHAL, Commissioner 15 LANDO ZECH, Commissioner 16 STAFF AND PRESENTERS SEATED AT COMMISSION TABLE:
17 S. ZIMMERMAN A. CUTTER 18 S. SMITH E. UTLEY 19 P. HOWE H. PLAINE 20 AUDIENCE SPEAKERS:
21 L. GUCWA 22 H. DENTON P. SHERMANSKI 23 24 25 l
2 1 PROCEED I NGS 2 CHAIRMAN FALLADINO: Good afternoon, ladies and 3 gentlemen. Commissioner Bernthal has been detained but he 4 will be joining us shortly. Commissioner Asselstine is on 5 travel and won't be with us today.
6 Representatives from Carolina Power & Light are 7 with us today to discuss environmental qualification of 8 electrical equipment important to safety at the Brunswick 9 nuclear plant. Section 50.49 of the Code of Federal 10 regulations allows the director of the Office of Nuclear 11 Reacter Regulatien to grant enemptions for completion of 12 environmental qualification to a date no later than
, 13 November 30, 1985 i4 good cause is demonstrated.
14 Beycnd this date, the Commission itself may grant 15 extensions in exceptional. cases.
16 By generic letter in early August, licensees were 17 advised of the Commission's intention to grant entensions la only in rare circumstances and that enforcement action will 19 be taken against licensees that continue to operate their 20 plants with unqualified equipment beyond November 30, 1985 21 without approved entensions.
22 Justification for continued operation has to be 23 provided to the staff and extensions will have to be 24 approved by the Commission, and fines will be imposed.
25 However, the generic letter indicated that some mitigation 7
3
' 3 1 of any penalty may be considered.
2 By letters dated July 9 and September 10, 1985 3
Carolina Power & Light submitted a request to extend the 4 Brunswick Unit 2 date for full compliance to March 30, 5 1986. Therein, the licensee presented the circumstances 6
which they believe justifies the additional 120-day 7 extension.
8 The staff has reviewed these submittals and has 9 provided recommendations regarding the CP&L extension 10 requests in SECY-85-321 dated October 4, 1985. By letter dated September 13, 1985, CP&L had previously requested a 11 12 meeting with the Commission.
13 During our last environmental qualification 14 meeting with the staff on September 17, 1985 the Co.nmi ssion 13 was advised that six plants had requested c:: tensions as of that date. Rather than address these six plants at one 16 17 time, the Commission has decided to meet with CP&L since is CP&L has indicated that the Commission's decision is needed 19 by October 15, 1985 in order to facilitate Brunswick Unit 20 2 outage planning.
21 The objective of today's meeting is to hear the CP&L basis for Brunswick extension requests first-hand. No 22 decisions are expected to be made today. However, I would 23 2: encourage Commissioners to vote just as soon as they 25 possibly can.
' 4 1 Do any of my fellow Commissioners have any 2 additional opening remarks at this time?
3 COMMISSIONER ZECH: No.
4 CHAIRMAN PALLADINO: All right. If not, then let 5 me turn the meeting over to Mr. Sherwood Smith, president 6 and chief e>:ecuti ve of f i cer of CPtL.
7 MR. SMITH: Thank you, Mr. Chairman. If I may 8 stand, please, to be close to the slides, I'd like to do 9 so.
10 CHAIRMAN PALLADINO: Would you introduce your II other colleagues?
12 MR. SMITH: Yes, sure.
. 13 CHAIRMAN PALLADINO: Thank you.
14 MR. SMITH: First, Mr. Chairman and members of the 15 Commission, we do wish to thank you for this opportunity.
16 We know that the Commission has a busy schedule. We think, 17 however, that this is an e::tremely important matter. It 18 will be the first of several similar requests to come I
19 before the Commission in connection with this subject. '
20 CHAIRMAN PALLADINO: There is a stand-up mlke 21 there. Oh, okay, good.
22 MR. SMITH: May I ast- if she can hear me without I
23 the mike?
24 CHAIRMAN PALLAD*.NO: I don't know if the people in 25 the audience can.
- 7
.- - . . .~ -- -- . - - _ . . . .- . . . . . - - . . - - ._ .=. = _
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1 COMMISSIONER BERNTHAL: I'm not sure the audience 7 2 can.
3 CHAIRMAN PALLADINO: The audience can't hear l
i 4 without it.
I 5 COMMISSIONER BERNTHAL: Maybe they can.
6 MR, SMITH: Thank you.
t i 7 Having asked to be heard, we certainly wish --
- i i 8 (Laughter) i 9 MR. SMITH: -- to take advantage of every l ;
10 opportunity to do so.
i 11 (Laughter) 12 MR. SMITH: Three of the very fundamental 4
13 questions that I think would come to the Commission's mind
'- today might be summari:ed as theses Has'this utility 14 l
15 undertaken a massive, effective, responsive commitment that f
i 16 has achieved substantial results already with respect to 1
17 the environmental qualification of equipment?
Is It's our purpose today to present facts that would 4
19 enable the Commission to answer unequivocally, "Yes."
f 20 Second, has the licensee come before the
! 21 Commission with a unit which is unique not only in this l 22 country but in the world and does have a more complex and 23 more difficult situation than exists at any other plant 24 licensed by this Commission or to our knowledge existent I
! 25 anywhere else in the world7 i i~
- 1 i
I t
t
i-
. 6 F We think that the facts should lead to the answer,
( 1 2 "Yes."
3 Third there should be, we believe, the question of 4 whether or not the inability to complete all of the
-5 environmental qualification work at this particular urit 6
has been occasioned in connection with a reasonable, hard-7 working, diligent program by the licensee and is its 8 inability to finish the work beyond its control?
9 While there will be other questions, and I wish 10 you would please interrupt me if you wish or ask me 11 questions at the end, we think those are three of the 12 fundamental threshold questions.
. 13 With me today is Mr. E. E. Utley who is our senior
-- 14 executive vice president; Mr. P. W. Howe, who is our vice 15 president in charge of our Brunswick nuclear project; Mr.
16 A. B. Cutter, who is our vice president for nuclear 17 engineering and licensing, and Mr. Sherwood Zimmerman who 18 is the head of our nuclear licensing section.
19 I should say also at the outset that the very 20 highest priority that we have at Carolina Power & Light 21 Company is the safe operation of our three nuclear units 22 now in operation, and our next priority is the successful 23 completion, in a quality way, of our fourth unit under construction and its safe operation. That receives a 24 25 primary call on our resources, our top management is very 1
4 1
l . 7 I much involved in our nuclear program, our senior officers i
2 are, and I personally devote a great deal of my own time to r
l 3 it.
4 As the Commission is aware, we are requesting an 5
extension of 120 days to complete the environmental 6 qualification of equipment at one of our two nuclear units at Brunswick. The work on the other unit, Unit 1, is now
! 7 t
I 8 complete.
9 I'll describe generally what our program has been.
10 COMMISSIONER ROBERTS: Excuse me, if I may
- 11 interrupt. l 12 MR. SMITH
- Yes. ,
l j COMMISSIONER ROBERTS: Is that in dispute, or has 13 14 the staff told you that Unit 1 is in compliance?
O MR. SMITH: The staff has very recently conducted 15 to an audit. Their audit confirms the qualification of the a
17 work as being complete, with a few minor discrepancies f 13 which are being addressed, and there is no question but
[ 19 before Unit I comes back into service as it soon will be 20 able to -- in mid November -- that all of those ;
e i 21 di screpancies will be cleared up that I would feel safe in i
j 22 saying the staff would confirm my statement, Commissioner 8
' Roberts.
23 r
1 24 COMMISSIONER ROBERTS: Excuse me. Go ahead.
i a
25 MR. SMITH: In the spring of last year, we i
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+ 9 1
notified the staff that it would be necessary to request 2 this extension. We have not been dilatory. We have sought 3 to keep the staff very much informed about our situation, 4 and we knew -- for reasons beyond our control -- that it 5 would be imoossible to fir.ish the work on Unit 2 by the 6 November 30 deadline. ,
7 I might say that in connection with all of our 8 operations at the Brunswick plant now we take a great deal 9 of pride. Our plant manager there received the American 10 Nuclear Society Award of Excellence this year, Mr. Charles 11 Diet , for excellence in nucleer operations.
12 Our recent SALP reports -- not only on Brunswick but our other two sites -- have been very good. We
. , 13
' ' 14 received all is and 2s. In fact, in the latest 15 comprehensive series of which I am aware, we are the only 16 multi-unit nuclear utility in the entire Southeast with 17 multiple sites that received all is and Os. We have a 18 massive commitment to excellence. ,
19 We are not there, and I don't think anybody in the 20 industry is there yet. But we are going to be the envy of 21 the world in our nuclear program if we are going to 22 continue to operate it, and we must do this in order to 23 have public support.
24 We come to you today with no excuses. Excuses are 25 not things that we accept. We don't say that looking back 4
9 I
1 with hindsight that we would have done anything, or could 2 have done anything, different than it has been done.
3 Of course, we have had the benefit of the staff's 4 recent recommendation, and the staff's recent 5
recommendation which reviews in summary -- as 80 such 6 recommendations must be limited to -- the facts of the 7 Brunswick unit. There are certain major facts with which 8
there is complete agreement between ourselves and the 9 staff.
10 To the extent there is disagreement between 11 ourselves and the staff recommendation, it lies in the area 12 of a more full and more comprehensive statement, and we 13 appreciate the chance to do that today.
14 We do not feel that the staff comments to the 15 effect that the Brunswick plant perhaps may be similar to 16 another unit mentioned in the staff's recommendation, tho 17 Hatch unit, is correct. Brunswick is not a twin of Hatch, 18 there are a great many differences. They are being treated 19 in a familiar way. I would say they are distant cousins.
l l 20 We are prepared to deal with that in substantial 21 detail today, if that should be a question for the 22 Commission.
23 We have a more comple:: task and we have addressed 24 it, and our addressing it goes back to 1982, even before 25 the final Commission rule which was adopted early in 1983.
10 r~ ' We submit that this matter, which has been before 1
l_
2 the Commission for discussion for perhaps eight years --
3 and some would say, "Well, that's long enough for it all to 4 have been complete" -- unless one is aware of the facts 5 behind the statement of the Commission itself in 1984, I 6 think in fall when t ie Conimission extended the deadline and 7 knows the complexity of what is going on, it's impossible I
i 8 to understand why it is reasonable now for almost all of e
J 9 the units -- qualification completeness, but for several of
) 10 them not to be.
11 We think, as the Commission itself has noted, this 12 does not involve matters related to safety. We think 13 that's tremendously important. And we would urge that the J
- 14 Commission refrain from taking any actions to shut down i
15 units for non-safety reasons if there are valid reasons for 16 the unit to be allowed to remain in service for a short 17 period of time, and if there are public health and safety 18 benefits associated with keeping the unit in service.
i 19 CHAIRMAN PALLADINO: Sherwood, could you explain?
20 You say there are non-safety related issues. Is equipment l 21 qualification not a safety-related issue?
l 22 MR. SMITH: The Commission itself has found -- anc 23 I have the two volumes of the Federal Register with me, Mr.
24 Chairman -- that the equipment qualification on a generic 25 base is a matter not directly related to safety, to quote l
, I A
11 1 the Commission's exact words.
2 With respect to individual units, should there be 3 a safety question, that is a matter of individual
.i 4 enforcement. And if there were a safety question at the 5 Brunswick plant, we would not have been here, we would have i
6 shut it down. And I think the staff concurs in its 4
7 statement, which I have with me, that not only is it not a a
safety matter but there are health and safety benefits 9 associated with granting the extension.
10 CHAIRMAN PALLADINO: I'm a little bit confused.
11 In the short term, there might be, due to compensatory measures, no safety issue. But over the long haul some of l 12 i 13 these items appear to me to have safety relevance.
14' MR. SMITH: Well, it's the Commission itself, Mr.
i 15 Chairman -- I'm not seeking to be argumentative, I'm just 16 quoting from the Federal Register the Commission's public 1; statements that these matters on a generic basis are not
- 13 directly related to safety.
19 They may, as you point out, well be important to safety on a particular piece of equipment. But if safety 20 21 were a concern, if we had not demonstrated ample i 22 justification for continued operation, we would have shut 1
i, 23 down long before now, and we certainly would not be here ;
- 24 today.
I 25 With respect to the benefits in referring to the t
4 4
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- 12
! e. ,
,, I compensatory matters which you mentioned, Mr. Chairman, on 4
j 2 page 4 the staff lists these measures, " Enhanced drywell 3 3 leak detection criteria, additional personnel in the 4 reactor building, existing instrumentation for steam leak i, 5 detection. While these measures contribute to safety" --
6 the staff continues - "for the most part they exist as f 7 compensatory measures for other reasons."
4 8
But there is another benefit that is directly 9 related simply to the extension of time, and that is the
! 10 reduction of man rem exposure. If the extension of time is' 11 granted there will be.= conservatively speaking, additional 4
12 savings as we show on the chart of at least 100 man rem.
,, 13 As I said that, we believe, is a very conservative t
'" 14 estimate.
15 CHAIRMAN PALLADINO: Well, why don't you proceed?
16 MR. SMITH: Thank you.
- 17 As I said, Mr. Cutter will go into details of what i
i 18 work has been necessary to be done at Brunswick and what 19 has been done. And while system reliability and economics 4
20 are not the critical issues here, we think it's also 1 21 relevant to bring those before the Commission.
22 If our Brunswick Unit No. 2 is required to be out 23 of service over our winter peak, which it would be if we 1
24 were not granted the extension, and if we had a condition 25 similar to the condition last winter, this past January, a
a 4
4
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13 l
1 it's quite likely that our system and neighboring utilities 2 might not be able to carry the load in the area.
3 The economic savings associated with the granting i
4 of the extension in terms of reduced replacement power i
5 costs are in the many millions.cf dollars.
, 6 If I may, I'd like now to call on Mr. A1 Cutter, 7 our vice president for nuclear engineering and licensing, 8
and to say that Mr. Cutter has had over 25 years experience
- in nuclear engineering and design, and work. He has been 10 in the United States Navy. program, with Westinghouse 11 Carporation as well as with Carolina Power & Light Company.
12 MR. CUTTER: Mr. Smith, thank you very much, 13 gentlemen.
i t
14 What I would like to do is to focus on the blend i
l 15 of unique elements that come out of the Brunswick plant 1
! 16 design, and tie those unique elements into elements of our t
17 compliance schedule.
Is The staff recommendation acknowledges that there .
19 are unique elements in the Brunswick design. But it does i
20 not fully describe the impact that those unique elements 21 have had on our program.
22 I'd like to take the opportunity to highlight 23 those design elements not for the purpose of creating a
, 24 design lecture, certainly, but for the opportunity to 25 perhaps familiar 1:e you with how that complexity may come i
i i 1
- 14 i
I I about.
2 The environmental qualification work at Brunswick 3 has been rendered uniquely difficult because there are 4 plant design features which have increas6d the number of 4 5 components and caused a more severe environment in 6 auxiliary building areas.
7 In addition, those unique design elements have 8 rendered competing regulatory modifications uniquely 1
i 9 difficult.
10 Finally, in the area of implementation timing, I l
2 11 should note that in 1982 the company established a schedule i
I 12 for Brunswick Units 1 and 2 which would have brought both
_ _ _ 13 units into compliance with the rule by March of 1985 4
14 without the need for an extension on either plant.
15 Circumstances beyond our control making necessary 16 the rescheduling of the second refueling outage for 17 Brunswick Unit 2 resulted in an inability to obtain from ,
la cur suppliers all of the equipment necessary in a qualified 19 fashion to bring that unit into compliance.
20 COMMISSIONER BERNTHAL: What exactly where the a 21 circumstances beyond your control'
! 22 MR. CUTTER: Commissioner Bernthal, there are a I
23 series of events and that's basically the thrust of the
}
24 presentation. So, if I could ask your indulgence to go 25 through it, I would be glad to answer you.
I l
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. 15 1 COMMISSIONER BERNTHAL: All right.
2 COMMISSIONER ZECH: But also, I would like to ask
, 3 you -- I presume you are going to point out where you see, 4 where you emphasize that the uniquely difficult problems --
5 I mean, I'd like to know which ones are unique.
6 MR. CUTTER: Yes, sir.
COMMISSIONER ZECH: Are you going to point that 7
8 out?
9 MR. CUTTER: Yes, sir, i to COMMISSIONER ZECH: Thank you.
11 MR. CUTTER: That's the basis of the effort. n COMMISSIONER ZECH: All right.
12 MR. CUTTER: Brunswick has a number of unique 13 i 14 design features and before -- which relate primarily to the i
15 elements work that you are talking about -- include the 16 concrete encased torus; a system for the isolation of i
17 potential leakage from the reactor instrument lines; the l 13 combination of terminal block and lug material used in 19 el ectri cal circuitry inside containment, and the augmented 20 off-gas system which functions to reduce the gas release i 21 from the site to its lowest reasonably achieved.
'. COMMISSIONER ZECH: And these art all unique to
, 22 i
23 Brunswick.
24 MR. CUTTER: The specific application, the 25 concrete-encased torus, reactor instrument penetration i
f 9
--_,_,.,_w_.-.__ c--~ _ ,m._ _ - ,,--w- ,e-.~,. em.. ,-
It 16 r
- i. 1 system are elements which are unique to Brunswick. To my 2 knowledge, there is not another BWR in the world that has 3 the concrete-encased torus, and we are not 6aare of any L 4 other plant with a positive-acting reactor instrument 5 penetration system.
6 The other two items relate to the aspects of the 7 design in Brunswick, but they are certainly elements that
- 8 are present at other units.
(
9 CHAIRMAN PALLADINO: Well, then are they unique, 10 the terminal blocks? The staff doesn't quite agree with a
6 11 you that the terminal blocks, for example, are unique to 12 Brunswick.
, 13 MR. CUTTER: No, sir. We believe that the
~
J 14 majority of boiling water reactor plants did not utilize 15 terminal blocks in -line with electrical penetrations inside
- 16 the drywell. But we are aware that there are other units f
17 which have used them, i 18 What makes the Brunswick situation somewhat unique 19 is that our engineers have been unable to demonstrate the 20 qualification of the particular make of terminal blocks and 21 lug combination which we have. We are aware that there are 22 qualified terminal blocks. But our terminal blocks are not 23 among the set that meets the qualification requirements, 24 the documentation requirements.
25 COMMISSIONER ZECH: Have you worked with our staff i
- 17 3
2 1 to come to any determination in that regard 7 i*
2 MR. CUTTER: Yes, sir. We, of course, have 3 agreement from the staff on the justification for operation 3 4 of those terminal block and lug arrangements despite the 5
fact that the documentation doesn't totally certify the 6 leakage current situation.
t 7
We have attempted with staff assistance and using 8
consultants who are helping us in other aspects of the i 9 pecgram to identify qualification data for these terminal T
10 blocks. Unable to do so, we do have a fin and we are
- 1 implementing that fix. And I'll get into the details of 12 that in one of the subsequent slides.
COMMISSIONER ZECH: But are you saying that 13 14 working with the staff and other consultants you have not is been able to determine how to environmentally qualify this 16 equipment?
4 17 MR. CUTTER: Our solution to the environmental la qualification problem is to bypass the terminal block.
i 19 COMMISSIONER ZECH: Well, does the staff approve i
20 that?
21 MR. CUTTER: The qualified splice is approved, and
! 22
]
23 COMMISSIONER ZECH: When was that done?
24 MR. CUTTER: The qualified splice has been 25 available at least, I believe, since the 1981-92 time b
4 h
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2 COMMISSIONER ZECH: So could you have done it 3 between now and 19817 4 MR. CUTTER: We initiated that work in 1981.
5 Before the equipment qualification rule was issued in 1983, 6 we had completed 50 percent of that work; continued to try 7 to find a way to qualify the terminal blocks, and that i
8 work, in combination with the other work, is still on-9 going.
10 We have, of course, completed 100 percent of the 11 splicing on Unit 1 because Unit 1 has completed its 12 construction work in its outage, and have completed over 50
, , 13 percent of the work on Unit 2, with the rest of it to be 4
14 done in the next outage.
4 15 COMMISSIONER ZECH: Well, then I guess I don't i 16 understand your emphasis on this item. If you could have
~
i 17 done it since 1981, why haven't you done it?
18 MR. CUTTER: We have been working on it, but it is, 19 a consumer of resource. It.is competing work that adds to 20 the total effort which we have had to muster in bringing 21 the EQ program under control, and because it is a major
- 22 contributor of work effort and a consumer of resource, we 23 identify the unique aspects of i t.
24 I do not believe other plants have found it 25 necessary to perf orm wholesale splicing around terminal "7
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19 1 blocks, and that is a piece of, work that is different for 2 us.
COMMISSIONER BERNTHAL: Did I read correctly -- I 3
4 don't recall whether it was in our staff's paper or in one 5 of your documents, and I may not have the numbers exactly 6 right -- that you have been down, the plant has had outages 7 that have averaged something like 40 out of 52 weeks over 8
the last three years, per year over the last three years?
9 MR. CUTTER: Yes, sir. Since 1981, the Brunswick l 10 station has averaged 44 weeks of outage per year between 11 the two units.
a COMMISSIONER BERNTHAL: Oh, between the two. So, i 12 13 22 per unit per year.
14 MR. CUTTER: Per year. It's still --
15 COMMISSIONER BERNTHAL: Still almost six months a 16 year.
17 MR. CUTTER: Yes. I'm not aware, you know, of any
- la other dual-unit plant that has e:-: pended that much time to 19 doing outage work. I will illustrate subsequently some of 20 the elements of work that have been going on that have 21 caused this, i
22 You know, the bottom line is, we believe we have 1
23 had a substantial regulatory compliance effort in progress.
24 for-the last five years.
25 COMMISSIONER ZECH: But you are not saying the r
l 1 ,
l 3
_ _ , . . - , . , - _ , , ,.7 , m . , . , __ , . - - . . _ _ . _ _ , , , ,__m
20 I
I time has been a problem to you, then. In other words, time t.
2 has not been a problem.
3 MR. CUTTER: The amount of work necessary to be 4 done in the time, the fact that the 44 weeks of outage per 5 year has been taken doesn't leave a lot of time, additional 6 time to have been consumed during that five year period.
7 COMMISSIONER ZECH: But some of the things, I 8 would precume, might have been planned during the 44 weeks.
9 MR. CUTTER: I'd like to cover those, the elements iU ' of w o r '< that have been gone on and touch on these unique 11 elements, first to give you a feel for the fact that we
- 2 think our portion was perhaps greater --
_ _ 13 MR. CUTTER: Fine.
14 MR. CUTTER: -- than the average.
15 COMMISSIONER BERNTHAL: But let me see if I 16 understand. You are saying that most of that 44 weeks was 17 not spent on EO work, it was spent on other things?
13 MR. CUTTER: Yes, sir. And almost everything that 19 we have done during that period of time has either been 20 regulatory mandated work or reliability improvement work 21 that in almost every case enhances the safety of the 22 plant. That total set of work has been in conjunction with 23 EQ because EO is one of many regulatory mandated items.
24 COMMISSIONER ZECH: But you are also saying when l
25 you say that that at least it's your opinion that you have I
l i l
l l
l
21
- I applied a maximum effort to environmentally qualify all the 2 equipment that should have been qualified, and that you i 3 haven't been able to do it.
l 4 MR. CUTTER: Yes, sir. We have applied a 5 continuous effort to establish the qualification ,
6 documentation to support the equipment that we have at the 7 plant, and where we have been unable to do so, have 1 8 undertaken to either develop additional qualified equipment
- 9 or procure equipment that is qualified and replace what we 10 have had in order to establish the proper documentation i
11 program.
12 That work has been on-going since 1991 and has i
been essentially completed. Unit 1 is in compliance. Unit 13
(
4 14 2, 1,100 out of the 1,300 or so items, specific pieces of 15 equipment that need to be handled have been completed, and 16 the --
17 COMMISSIONER ZECH: Why have you been able to do 18 so much better on Unit I than Unit 27 19 MR. CUTTER: It's an outage sequence situation.
l We don't take the two units out simultaneously. The plant 20 21 staff would be severely diluted --
3 22 COMMISSIONER ZECH: I appreciate that, but is that 23 the only reason?
24 MR. CUTTER: We have had the same amount of work 25 to do on both units, and the sequence of the outages has i
- I
22 i r -
- _ 1 brought us to the situation. As an example, in doing some 2 review because the staff did mention the Hatch plant we, 3 like Hatch, as a two-unit station have one unit that is in 4 compliance and one unit which requires one more outage to 5 be in compliance.
6 Hatch *s refueling cycle brings them into a 7 refueling window November 30 this year. In discussion with 8 the Hatch people I've formed the conclusion that the amount 9 of work remaining at Hatch-1 and Brunswick-2 is pretty near 10 the same. There is about 200 items to be dene. It's going 11 to take one extended outage to do it.
12 In our case, our normal refueling outage cones due 13 in March, not in November. And if it were other than that, 14 if we had been on a 12-month cycle instead of an 18-month 15 cycle, we would not be in here because our outage would be 16 coming due at the time that the rule dictates compliance.
17 I'd like to point out some of the elements of the 18 concrete-encased torus that are unique.
19 CHAIRMAN PALLADINO: You know, you said that with 20 all these outages you were doing very diligent work. But, 21 as I recall, you still have not complied with fire 22 protection, Appendix R, that's off into the future; 23 recirculation line replacement, there has not even been a 24 commitment to it; there are questions on Appendi:, E with 25 regard to emergency planning. We don't have equipment
] .
4 ,.;
23 4
1 qualification done.
2 There may be other things that you were doing, but 4
- 3 I don't get a sense of great diligence on some of these 4 regulatory matters which you say were the basis for a good 5 deal of your outage.
4
. 6 MR.-CUTTER: . Chairman Palladino, we have more 7 regulatory work to do. We have submitted an amendment 8 request to the staff for an integrated schedule and have
' , ,9 submitted with it an integrated schedule showing a five-
.10 + year pl an which In'that five-year plan essentially ;
11 completes all known regulatory items.
12 We have had a significant number of items behind j 13 us and I will mentien in a moment as we go into the schedule some of those key elements to perhaps refresh your f 14
! 15 memory that it isn't only that which is yet in the future 16 that needs to be done.
i 17 COMMISSIONER BERNTHAL: Let me see if I understand, though, what the limiting factor was. Whatever, 18 i i 1
19 else it was that you were working on, are you saying you L ' 20 just didn't have enough people then to tackle the 4 .
21 environmental issues as well? In principle, you could have 22 cone them in parallel, I presume.
4 ,
23 Are you saying you don't have enough people, that 1
24 the expertice simply in numbers or perhaps the expertise, 25 the number of people or the correct expertise wasn't i
4 i
O .,_ _ . __, .__ _ - _ . . _ _ . , . . _ , . _ _ . . _ _ _ . . - _ _ . _ _ _ _ . , _ _ _ _ . . _ . . _ .
' 24 1( -
Or why couldn't it.have been done in parallel?
1 available?
2 MR. CUTTER: Some of it was done in parallel, 3 Commissioner Bernthal. The limitation is an effective 4 limitation on the number of personnel that can be managed 5 in an outage situation within the protected area on site.
6 One does not have the lu::ury of just adding resources, even 7 qualified and trained resources, without the added burden 8 of controlling their health physics, making sure that 9 radiation safety is observed. And these are things which 10 place practical limits on the numbers of people that could 11 be brought to bear.
12 COMMISSIONER BERNTHAL: How many do you have?
. _ 13 What is the number of people that you have in containment la who are qualified to go into containment?
15 MR. CUTTER: At the present time -- and Mr. Howe 16 may correct me if I mis-speak -- but I believe that during 17 the Unit 1 outage which we are just coming out of, that our la limitation was 2,500 people inside the protected area at 19 any one 24-hour period.
20 COMMISSIONER BERNTHAL: A lot of people.
21 MR. CUTTER: Yes, sir. And our experience over 22 this time period has been that we have utilized the maximum 23 resource that we could effectively manage to perform the 24 work.
25 Just touching a minute on some hardware. The i
.. _ . - - -_ _ -~ . . - . . ,. . . . - _ , - - _. .. --
- 25 I typical boiling water reactor has a steel torus. The steel i
2 torus is enclosed in a torus compartment. The Brunswick plant forms its torus in the concrete mass of the building 1
i I .3 4 i 4 with steel liner, and does not have an equivalent torus t
1 5 compartment.
6 The torus compartment is where in other plants the ,
, 7 steam line to the high pressure coolant injection turbine We do not have a compartment. It's necessary 8 is routed.
1, i . 9 at the Brunswick plant for the high pressure coolant a
i 10 injection steam line, a short section of it, to extend out j
4 11 into the reactor building en route to the HPCI room.
12 Because it's necessary to postulate a break in 13 that short section of steam line our reactor building is 14 exposed to a source of high-energy steam, which is not the ;
d I
- ;$ case for any other boiling water reactor design.
I Would that be the case if
! 16 CHAIRMAN PALLADINO:
i
. 17 that valve there were motor operated, it could be --
! 18 MR. CUTTER: Yes, sir, the valve is motor 1
19 operated.
l }
20 CHAIRMAN PALLADINO: It 157 t
21 MR. CUTTER: Yes, sir. And there are steam break i 22 identification logics which act to close the isolation f
- 23 valves. But this is a normally open valve because of the i
i i 24 safety nature of the injection system. So one has to I
25 calculate the likely time that in a single-failure event l ,
t t
i I -. _- -..-.- , -. - - _ _ . - - - . .
- 26 r
1 the lines would remain open venting steam, and that's the 2 source that we have used for our environmental profiles.
3 CHAIRMAN PALLADINO: So you are saying the mere 4 fact that that is motor operated doesn't alleviate your 5 environmental problem in the reactor building? ,
6 MR. CUTTER: No, sir, it keeps it from being more 7 severe than it would otherwise be.
8 The results of this exposure to the reactor 9 building have been difficulty in attaining qualified 10 equipment that meets the environmental profile for the 11 Erunswick project.
12 COMMISSIONER BERNTHAL: Let's see, the key feature
_ .. 13 there is not so much the encasement in concrete, I would 14 guess, as the presence of that second line. Is yours also 15 the only plant that has that particular feature with that 16 exposure to the reactor building?
l 17 MR. CUTTER: Yes, sir. Other plants route the l
l 18 line -- this is a simplified cut-away.
19 COMMISSIONER EERNTHAL: Sure.
20 MR. CUTTER: But on other plants the line connects 21 to the steam line typically 180 degrees around the torus 22 from the location of the high pressure coolant injection 23 system and runs that 100 degree parameter in the torus 24 compartment.
25 COMMISSIONER EERNTHAL: No other plant has that
l .
1 l .
a7 1 line exposed in the reactor building area' 2 MR. CUTTER: No, sir.
3 COMMISSIONER BERNTHAL: I see.
4 MR. CUTTER: There is equipment in the compartment 5 which is - the torus compartment -- which is exposed in 6 these plants. But that's a more linited set and typically 7 is similar equipment .n a pressurized water reactor.
COMMISSIONER BERNTHAL: Right. Thank you.
e 7 MR. CUTTER: Bob, can I have the next slide, 10 please?
11 The harsher environment gives us a situation where 12 the Erunswick peak often exceeds the qualified profile that i
13 the equipment vendor has subjected his equipment to.
14 Testing is an expensive proposition and typically 15 a vendor will balance his profile between a desire to 16 assure that his equipment passes and the desire to qualify 17 it for the largest number of customers, la The Brunswick peak often e::ceeded the vendor 19 profile and, indeed, that resulted in a number of items 20 which in the summer of 1984 when Brunswick-2 was completing 21 its second refueling outage, were not available on site 22 because they had not yet achieved the qualification status 23 to the Brunswick profile 24 Eecause the recutor building is exposed, there 25 were a larger number of items that were exposed as well,
l .
- gg I greater than the average for other plants.
2 There is a complicating factor in the torus work 3 that I would like to mention because it is one of the 4 reasons, one of the programs that we are completing now, 5 Chairman Palladino, that is a heavy work effort for 6 Brunswick.
7 And that is the torus improvements under the MARK 8 I program. As a unique plant with a rigid structural 9 concrete torus, our program was subject to more difficult to engineering and construction solution internal to the torus 11 than were the programs for steel torus plants.
12 The concrete torus gave us the benefit in external 13 structural stability. But as a result, it gives us higher i
14 loads because our torus doesn't flex. And without flexing l 15 we don't absorb energy, and the higher reflected energy has 16 to be dissipated in the internal structure.
17 We we have expanded the number and the complexity 18 of the internal modifications to the torus, 19 Further, our vendor experience difficulties in the 20 completion of the plant-unique analysis, there was a 21 generic analysis completed and each unit did a plant-unique 22 . calculation subsequently.
23 The plant-unique calculations for everybody else 24 essentially followed the same pattern because everybody has 25 a eteel torus. For the concrete torus, it was uniquely i
)/
- 29 l
1 different. As a result, we found it necessary to go back l into the torus and change work already accomplished. It 2
3 was necessary for us to go back in and modify supports 4 after they had been completed and to perform additional 5
structural modification not originally intended.
6 As a result, our Mark I torus program extended two 7 years beyond the originally planned completion schedule.
8 Unit 1 has just been completed in the outage that is now 9 ending. Unit 2 was completed in October of 1984 in i
10 accordance with the ordered completion date. That's one of 11 the reasons why the torus wort in 1984 got high priority as l
12 a safety-margin improvement issue, even though it diverted l
13 resources that might otherwise have been applied to other 14 activities such as equipment qualifications.
15 Our reactor instrument penetration system is to unique. It was initially designed as a more positive-17 acting active leak isolation system. Each of the reactor 13 i n,st rumen t lines has flow switches, pressure switches, 19 solenoid valves and air-operated valves to sense the 20 increased flow and take positive action -- in isolation 21 valves.
22 Most boiling water reactors have used self-23 actuating excess flow check valves. The reactor instrument 24 penetrotion system includes about 200 components which 25 re?,uire environmental qualification. These components are
- 30 r- m 1 in the reactor building outside the drywell, in the area 2 that has the uniquely stringent conditions imposed by the 3 effects of the concrete torus.
4 To limit the total effort in qualification, we 5 made a decision to replace the instrument penetration 6 system with excess flow check valves. That task is a .
7 difficult task, a complex task. It was the pacing task, 8 critical path, for the construction phase of the 311-week 9 outage that is presently ending at Brunswick 1. It will be 10 the pacing activity for setting the critical path for the 11 Unit 2 outage when we come into EQ compliance.
12 I thint we have really already covered the I
__ 13 terninal block issue. I think the key point is while some l __
14 of the units did have terminal blocks inside containment in 15 line with their electrical equipment, the combination of 16 block and lug material has evaded confirmation of 17 qualification to the degree necessary to meet the 18 requirements of the rule, and we are splicing those 19 critical leads in order to avoid dependence on the terminal 20 blocks.
21 And finally as a unique element, our augmented off-2 gas system that the Brunswick plant started up with was a 23 cryogenic system. It was a cryogenic system which was 24 designed to achieve =ero release. And this zero release 25 system which was a state-of-tho-art approach was oncouraged i
- . . - - ---- -- --a--. -- r- . - - - . . _ --
- 31 1 -- strongly urged, perhaps -- by the NRC at the time the 2 plant was being designed.
3 I think we are the only plant that started up and 4 placed a cryogenic system in service, and used it under 5 actual off-gas conditions. We found the system to 69 6 unreliable. A combination off operating difficulties with 7 the system and hydrogen detonations in the system led us to 8 take that system off line.
9 We were required to replace that system with a 10 mere reliable system and utilized the charcoal absorber 11 system that was used by most other boilina water reactors. s 1; Hcwever because wo had operated the plant, we were faced i3 with a major task to decommission the building and i 14 equipment containing this contaminated cryogenic treatment I system and replace it with a charcoal absorber 15 16 installation.
17 At the same time, we undertook a very comple'<
is arrangement of installing an off-gas hydrogen recombiner in i
19 the steam piping exiting from the condenser, a very 20 congested and in-line portion of the secondary system.
- 21 This required a substantial resource allocation.
l 22 The completion date for this work was mandated by 23 Commission order, again influencing the priority given to a l
24 system that would improve sefety margins in competition 25 with other activities that were going on at the same time.
r i
i
- 32 r
I We talked earlier about the number of weeks of 2 outage. I apologi:e for the difficulty of seeing the 3 slide. It lists the regulatory and reliability --
4 MR. SMITH: E>: cuse me , Mr. Cutter. Is that in the 5 material that has been distributedT I'm surv it's very 6 difficult for Mr. Plaine and Commisstoner Bernthal.
7 CHAIRMAN PALLADINO: Yes.
8 MR. CUTTER: Yes, that's Slide No. 12. It might 9 be easier to road it on the paper.
10 It's a crowded slide, bu' I thin 6 it's crowded 11 because of the omcunt o' work that we were doing. Had we 12 done less work, we could have had a neater looking slide, 13 but it wouldn't have depicted what was happening at the t
14 time.
15 The 44 weels a year since 1901 -- and this shows 16 '02 through '85 -- 46 weeks: 55 weet:s in 1983, and 50 weeks 17 in 1984 -- reactor weets of outage.
18 COMMIS510NER ZECH: You have emphasized earlier lo the uniqueness of the Brunswick plant. Could you point out 20 on that slide perhaps those items that are unique to 21 Brunswick' 22 MR. CUTTER: Yes, sir. Wor 6 in each of those 23 years on the MARU ! torus modifications was influenced by 24 the tcrus design and rendered more difficult and c o mp l e:: ,
25 and tool longer than it otherwise would have.
1 A
- 33 1
The equipment qualification work, the panotration 2 up-grade work that was donc in 1992 related to the terminal 3 blocks, and the other modification work has been rendered 4 more complex and difficult by the unique design elements.
5 The augmented off-gas modifications, completed for 6
Unit 1 in 1983 for Unit 1 and in 1984 for Unit 2, were unique elements of work. And in the reliability area as a 7
a plant that is.in a brackish water environment, we had 9 difficulties that had to be overcome, requiring significant 10 modification work in our service water piping and condenser 11 retubing relatively early in plant life, requiring the 12 installation of Titanium-2 -- tube sheet condensers.
COMMISSIONER ZECH: Is that unique though, do you 13 14 know?
MR. CUTTER: We looked at Hatch as an enample, and 15 16 Hatch as a fresh-water plant has not had similar 17 modifications.
Is COMMISSIONER ZECH: How about other plants? .
19 MR. CUTTER: There are other plants that have 20 changed condensers, yes, sir. !*m not aware of others who 21 have had the wall -- problems that we have had in the 22 service waters --
COMMISSIONER ZECH: It may not be entirely unique, 23 24 then, just at Drunswick.
25 MR. CUTTER: No, sir. I think that's correct.
v l .* 34 l
l e- -
l ;. 1 COMMISSIONER ZECH: All right.
l' 2 COMMISSIONER BERNTHAL: Have you ever costed out --
l 3 this is a little bit off the subject -- have you ever l
l 4 costed out the entire panoply of the changes that you l
5 made? You've got *82 through ~85 here, but let's say '80 6 to '85, a number of which appear to have been TMI-induced.
7 But what I'm really driving at is, presumably most 8 of these are, whether regulatory or other modifications, 9 that you have made on your own in design to improve the 10 plant and male it more reliable and safer, if you will.
11 Have you ever figured out what that total cost has 12 been in the last five years?
, , 13 MR. CUTTER: Yes, 1495 million has been spent in i
- - 14 the last five years on the Brunswick outages. That 13 includes the support of the operating people. It's not 16 broken out discreetly to the elements of work, but the 17 bottom-line bill for that period has been $495 million.
18 COMMISSIONER LERNTHAL: And that counts 19 replacement power and equipment 7 l
l 20 MR. CUTTER: No, sir.
21 MR. SMITH: No, not replacement power.
22 COMMISSIONER BERNTHAL: Strictly, that's hardware 23 and labor that you put in the plant.
24 MR. CUTTER: And personnel.
l 25 COMMISSIONER ROBERTS: Well, let me ask a question
(
- j
! l i i 1
. 35 I which is totally off the subject, but I just am curious.
2 On your augmented off-gas system, do you have a fuss with 3 your supplier over there?
4 MR. CUTTER: Yes, sir. But as is very typical 5 with nuclear plants, the warranty period on the equipment 6 from the time of the procurement until the time that the 4
7 plant goes in cervice and you actually put the equipment in a service very often expires. I'm not --
9 COMMISSIONER ROBERTS: So you had no recourse 10 against the designer of this equipment.
It MR. CUTTERt I don't believe we did.
I 12 COMMISSIONER ROBERTS: All right. That's
=
13 immaterial, I was just curious.
I 14 MR. CUTTER: But typically, on procured equipment 15 the warranties had expired.
! 16 The priorities that we put on this work were 17 strongly influenced by staff-mandated dates, and the j
18 resources that --
19 CHAIRMAN PALLADINO: Whose staff?
20 MR. CUTTER: NRC staff. And the resources placed 21 on the work that had the higher pay-off to safety 22 improvements.
23 CHAIRMAN PALLADINO: Yes, that comes back to the 24 question that Sherwood Smith raised --
and I guess I'm i
2$ waiting to jump on it -- the implication is that these are
36 l
- j. I not safety-related items that are going to be quallfted.
2 And then I had my staff go cut and get me in 3 print, in bigger letters, for me an extract from 10 CFR 1
50.49 where it says paragraph B, " Electric equipment 4
I 5 important to safety covered by this section is: 1, s3 f ety-6 related electric equipment. This equipment is that relied 7 upon to remain functional during and following design-basis 8
events to ensure 1) the integrity of the reactor coolant i
9 pressure boundaryt 2) the capability to shut down the 10 reactor, maintain it in a safe shut-down condition and, 3) 11 the capability to prevent or mitigate the consequences of 12 accidents that could result in potential off-site exposures
, 13 comparable to 10 CFR Part 100 guidelines."
i 14 And No. O, it covers "Non-safety related electric 1$ equipment whose failure under postulated equipment whose 16 failure under postulated environmental conditions could 17 prevent satisfactory accomplish" -- I guess that must be 18 accomplishment -- of safety functions on the safety-related 19 equipment."
20 And 3, "Certain post-accident mcnitoring 21 equipment."
22 And the implication that we have this equipment 2
23 qualification in place purely for some non-safety reason is 24 something 1 just can't buy. I need a further enplanation i
! 2$ of what you mean by saying it's not safety related.
l J
37 I
I 1 MR. SMITH: I'll be glad to. perhaps, because I l 2 was the one that made the statement --
3 CHAIRMAN PALLADINO: Well, it was made again here, 4 that there were more important " safety-related" items that 5 had to be oiven attention. Maybe they may have been more 6 important but the implication that these weren't s,afety-7 related still gives me a problem.
8 MR. CUTTER: No, sir. To make sure that I came 9 across clearly -- and I apologime if I did not -- the to concern I was e:: pressing in terms of priority is that you 11 have a relative irprovement to safety, an improvement to 12 margin of safety, which is different for different elements 13 of work.
14 That in the priorities that we were selecting, 15 having determined that we were justified safely for le continued operation with the specific components which you 17 are mentioning -- not taking away from their safety 13 significance, certainly -- but having a JCL in place that 19 improvements in the off-gas system which would release the 20 gas concentrations discharge, or the improvements in the
- i torus which would increase the margin of safety in the 22 torus, were elements that had a proximately more 23 significant impact on safety improvement than the 24 replacement of an EO item which had a valid JCL.
25 CHAIRMAN FALLADINO: Well, I got the implication
38 i
r i i that you were emphasi:Ing that these were safety related f 2 and the EO was not, and I tied it in with Sherwood Smith's 3 statement.
4 MR. CUTTER: No. I apologize for leading you off. ;
5 MR. SMITH: The clarification should be made, we e agree with that.
7 CHAIRMAN PALLADINO: But earlier it was stated 8 that this program is not safety related, and I just must' 9 take exception to that. I just wanted for the record to i
10 make clear that the equipment qualification program, there 11 is a strong relationship to safety as I read from 10 CFR t 12 50.49.
_ _. 13 Well, go ahead.
14 MR. CUTTER: During this same period, the 15 Brunswick improvement program was established. Its purpose t i
16 was to improve the plant operations and maintenance, and it [
l 17 achieved additional strength in our management structure, [
18 additional reduction in radiation exposure, and reinforced, ,
19 the discipline of operations and maintenance. l 20 It has been recognized as somewhat a model program i l
21 for industry, and I think that we have had visits from over (
22 20 utilities to review with us the activities, actions, and i t
23 impact of that improvement program.
24 This chart shows the Brunswick Unit 2 schedule as 25 it existed in late 1980 when, having achieved with the l
ese sr 39 i NRC staff an understanding of the work which was required 2
to come into conformance with the E0 program, we 3 established a schedule.
4 The first refueling schedule after March 1982 for Brunswick 2 had occurred, I guess, in April of '02. We had 5
6 scheduled the maintenance outage for 1983, and a second 7
refueling outage for December of 1984 to bring Unit 2 into 8
compliance with a refueling outage on Unit 1 in the early 9
'83 time frame and a second refueling outage just prior to to the end of '84, bringing Unit 1 into compliance.
11 So our plan at the time was to bring both units 12 into compliance without the need for an entension.
As a result of our experience with the Unit 1 13 14 outages, a 26-week planned refueltrg outage on Unit 1 was extended to 37 weels in order to provide additional time to 16 complete the paperwork, procedural changes, and training of 17 the operators to bring the plant back on line after a major 18 modification outage with the proper attention to operator 19 needs.
20 The extension of that outage, which is 37 weeks, a 21 subsequent four week forced cutage for -- on that unit, and 22 an eight-week outage for inspection of primary piping on 23 Unit 2 all caused the start of the Unit 2 maintenance 24 outage to be pushed out into 1404 2$
It was our desire to avoid having both units off i
I i
F
,. 40 i i 1 line at the same time, competing for the same resourcos, 2 and we kept Unit 2 operating, entending its scheduled 3 maintenance outage.
4 As a result of that maintenance outage moving into 5 the refueling window of 1984, and the poor burn which was 6 attained moving into the refueling core design, it was 7 necessary to refuel during the planned maintenance outage.
8 That had the effect of making our second refueling 9 outage after March 1982 occur nine months earlier on Unit 2 10 fthan we had anticipated when we established our plan for 11 comp 1tance.
12 As a result of the compliance outage coming nine
_ . _ , 13 months earlier, there were a number of items whose la procurement could not be attained in time for this cutago.
15 So it was necessary to ask the utaff for an eaeaption to 16 come up from this outage. And that exemption was granted.
17 The requested refueling that we are asking for a .
18 120-day delay from November 30 to the end of March in the 19 second outage which would have been required after the 20 first refueling, and represents the first opportunity to 21 install that equipment which could not be procured in timo 22 for the 1904 outage.
23 Thore is other EO work which was not limited by 24 the availability of equipment from the vendor. But that 25 work, tal en in conjunction with the other elements of wor 6-l
41 I scheduled for that outage, completion of the torus workt 2 completion of the augmented off-gas workt condenser 3 retubingt service water upgrade, dictated deferral since it 4 was necessary to have another outage of some of the 5
elements work for installation difficulties in the place.
6 We got off to an early start to achieve j 7 compliance. We have been committed from the start to a 8 quality program. Prior to the issuance of the rule in 9 1980, we had used in excess of 75 man-years of engineering 10 to establish our master list, to developed in detail the 11 qualification profiles for our buildings. To support the 12 field inspections that assured us that what was on our i3 mastor list was really in the plant.
I
\
14 We undertook an early effort to validate the 15 design-based work lists with name plate chects of what was 16 in the field.
17 In addition, we had initiated field modification 18 work, including 50 percent of the terminal block splicing
) 19 work, prior to the 1903 issuance of the rule.
i 20 COMMISGIONER ZECH: May 1 interrupt for just a i
21 second? You know, it's been my impression in reviewing 22 this that -- you say an early start to achieve compliance.
- 23 But it's been my impression that perhaps there may not have 24 been enough emphasis on equipmont Qualification early on.
2$
It looks life, certatnly, in recent months and t
- 42 I
1 years you have placed considerable emphasis on it. But l
, l 2 could you emphasi:e this a little bit? I see you are 3 giving me a lot of engineering man hours expended and a lot 4 of money expended.
5 But could you elaborate just a bit? My impression 6 has been that in the earlier years perhaps you might not 7 have been as aggressive. I would appreciate your 8 addressing that.
9 MR. CUTTER: Yes, sir. I was responsible for the l 10 engineering effort in 1980 and '81 in direct support of the 11 Brunswick plant. My people were the ones who were doing ,
12 the work. We utili:ed the services of our plant design
. . , 13 engineer --
14 COMMISSIONER ZECH: Did you have a plan, a written-15 down plan to ensure compliance? Did you have a plan that -
16 was written, you know, that was --
17 MR. CUTTER: Yes, sir. We set out our engineering 18 work plan to establish the data base and to comply with the ,
19 siibmittal requirements. If you were cast back to the '80- 4 20 81 time frame, there were a whole series of reports that 21 the licensees were required to put together to identify and 22 list all the equipments to establish data sheets for each 23 of the pieces of equipments to support with a description 24 of the qualification information the qualification r 25 justification.
-3
+
- 43 I. 1 So most of the effort in the early days went into 4
2 the development of the data base and presenting the i
3 information necessary to identify to the staff where we
- i. A i i i 4 were.- ,
} $
In mid-1981, we received our response from the :
' i
. 6 staff that gave their consultant's evaluation of our 7 program. And I would only say that there was a substantial l' '
difference of understanding between us and the staff as'to 8
i i i
i 9 what constituted a valid basis for concluding that 10 equipment was qualified because we had identified for 1,500 1
1
! 11 items per plant essentially nothing that was either not 4
l1 12 demonstrated to be qualified or that we had not been given i
i 13 indication from the supplier that we could get that [
j 14 equipment demonstration information. !
COMMISSIONER ZECH: In retrospect, do you feel the
! 13 I.
16 same way today as you did then? ,
l MR. CUTTER: No, sir. In retrospect -- and what 17 I h '
s i le we finally agreed to in terms of what it took to qualify it ~
i j 19 and demonstrate qualification of the equipment, nearly a l ,
l 20 hundred percent of what we said we had sufficient evidence ;
I !
i 21 for, required upgrade. i COMMISSIONER ZECH: I seo. k
! 22 i i
23 MR.. CUTTER: But the program in terms of j
1 24 complexity and understanding of what it would take to do it ,
] i l 25 in that 1981 to early '80 time frame as we came to grips l i
I L 1
1 l $
1 4
i I I
i-
- - , _ . . ~ . , _ _ - . . - - . _ . . _ , - - - . . - _ . . _ . - - , , . _ , - . . , , _ _ _ - - , - _ _ _ _ . . _ . _ , _ . . - , . _
- 44 I with Franklin Institute's technical evaluation reports, 2 exchanged arguments, justifications with the staff, brought 3 us into a new focus as to what it would take to achieve the 4 program.
$ And our cha'rt that I chowed on schedule is one 6 which was developed in late 1982 after we had an 7 understanding of what it would take, and we believed at 8 that time gavs us good assurance that we would be in 9 compliance --
10 COMMISSIONER ZECH: But had the staff in 1981 11 essentially given you their views that you have now 12 accepted, is that what you are telling me?
13 MR. CUTTER: The initial response, as I recall, i 14 from the technical evaluation report showed about half the 15 categories of equipment required additional demonstration 16 of qualification.
17 Over the next six to nine months in submitting to 18 the staff additional information in support of what we 19 thought was an appropriate case, other items were added to 20 the list requiring qualification, to the point where there ,
t 21 were, I think, only six cut of about 180 categories that 22 were considered by the staf f 's consultant to be f ully 23 demonstrated as qualified. And that was early that we 24 achieved that understanding.
25 At that point, we bent our efforts one-hundred l
l
4 .
45 a
i i percent to the task of demonstrating in accordance with the
' 2 criteria that we now understood to be guidance.
3 COMMISSIONER ZECH: It sounds like i t took almost J
4 two years, though, to kind of come to that understanding --
i 5 MR. CUTTER: Yes, sir. ,
1
' COMMISSIONER ZECH: -- and agreement. Okay, thank 6 ,
i 1 7 you.
MR. CUTTER: We've continued to apply diligent 8
' efforts to achieve compliance. We work consistently 9
l 10 amongst our two operating sites, three plants, and our new j 11 construction site to assure that everyone in the company c
12 gets the benefit of what each organization i s learning in
\ 13 regard to meeting the equipment environmental cualification j . 14 requirements.
1 i 15 Brunswick Unit 1 and Robinson Unit 2 are in i
j 16 compliance without the need for an extension. Harris Unit b '
1 will achieve compliance at stnet-up because what we are I
17 i a
la installing at the Harris plant i s being qualified and .
! 19 validated as it i s going in, and Brunswick Unit 2 right now 20 is i n compliance fully demonstrated for some 1,100 of the l
! 21 1,300 components that are in the plant.
22 We have spent over $24 million -- 22 this year and I
} 23 two more next year -- en environmental qualification of I i i 24 Brunswick alone.
l That's for two plants, two
! 25 COMMISSIONER ROBERTS:
s t
,-_ __.-_,,w ,. . _...*,e-.,,m_.---,.- ,,w-,-.,- z.m =_,._,-__w .w.r.m, e.-- ,_,-w,.,_,w y- . . , , -,.yy-, w.. wne.,,m.m--w,,w-4ymmm.-
.' 46 F
1 '
units?
2 MR. CUTTER: Yes, that's two units.
3 COMMISSIONER ROBERTS: How does that comaare with 4 other BWRs, or do you know? I mean, that might be an 5 indicator of your alleged uniqueness.
6 MR. CUTTER: Well, I know that Niagara Mohawk, I 7 think, has stated $6 million as the total cost in their 8 environmental qualification program. That's a number that 9 sticks --
10 COMMISSIONER ROBERTS: Si: million?
11 MR. CUTTER: Yes, str.
12 COMMISSIONER ROBERTS: And you are going to spend 13 appronimately twelve --
- - 14 MR. CUTTER: Per unit.
15 COMMISSIONER ROBERTS: -- per unit?
16 MR. CUTTER: Yes, sir. There are differences 17 plant to plant. Our Robinson plant requests substantially 18 less -- substantially less, perhaps a sixths as much.
19 A lot of the work that we are going to do in the 20 upcoming Unit 2 outage is a duplicate of work that we are 21 presently doing in Unit 1.
22 There are some real benefits to a duplicate outage
- 2) because when you have the time to incorporate the lessons 24 learned, you can achieve much better performance. That 25 performance translates into reduced time on the job and
- 7 4
._. _ _ _ _ _ _ _ - _ =. _ . _ _ _
' 47 1
4
! i 1
therefore reduced radiation exposure.
1 i 2 We want to incorporate the lessons learned from 3 that Unit I work into the engineering planning, l,
4 prefabrication planning, revised routings, other elements 5 of improvement for our Unit C outage.
l 6 The construction work was done for the Unit 1 i
+ outage. It's starting up. It's in the testing and 7
i 8 completion of check-out phase.
9 We have started incorporating the lessons 10 learned. But we have estimated that the additional time 11 between the completionuof the Unit 1 outage and the l 12 deferred start of the Unit 2 outage -- Unit I will be on 33 line mid-November, the four months as opposed to 14 essentially no time -- would permit a man-rem exposure 2
f is savings in excess of an additional 100 man rem.
i 16 COMMISSIONER ZECH: Could you explain that, l
I 17 please? ,
i 18 MR. CUTTER: Yes, sir. We have estimated from ,
', 19 prior experience and talking to other units that if you do i
20 duplicate work, you can often find ways to save on the 21 order of ten percent of the radiation exposure.
22 The total radiation exposure for the Brunswick-1
$ outage is approximately 2,400 man rem. That would say that 23 24 in terms of duplicate work we ought to be able to find 1
l 25 something over 200 man rem.
I 4
4 4
4
~. - . -. _ . -- .. ._.
48
- e- -
1 The folks at the plant are looking for that now, 4
2 and they are looking at the big ticket items because they 3 are the ones with the better pay-off. The additional time i
4 would allow us to get into that sort of second tier of i
5 smaller jobs, analyze them more aggressively, and get that 6 additional benefit.
I 7 COMMISSIONER ZECH: Thank you, i
! 8 MR. CUTTER: I think one other point I would like i
9 to make is that we are coming off an eight-month outage.
10 The staff at the plant has worked very hard. The 11 additional time between outages would provide a period to i 12 have the professional staff recover from an extended period
, , 13 of fatigue and stress before embarking on an additional f'- 14 eight-month outage.
15 That's the last slide that I have. I was going to 16 ask you if you had any questions, but I really --
i 17 CHAIRMAN PALLADINO: Yes, I do.
i 18 (Simultaneous conversation)
Could we return to Slide 6 on !
19 CHAIRMAN PALLADINO:
t i 20 the pipe --
21 MR. CUTTER: Bob, Slide 6,'please.
?,
22 CHAIRMAN PALLADINO: I think it's Slide 6. How i 1
1 i 23 big a line is that line going off there into the reactor 7 i
24 MR.-CUTTER: I think it's a ten-inch line.
i 25 CHAIRMAN PALLADINO: Ten-inch line. How long -- - f e
i
J *
. 49 4
id 1 I could you check that for me?
2 MR. CUTTER: Yes, sir.
l i 3 CHAIRMAN PALLADINO: I get the impression it might
! 4 be a four-inch line, but I don't know.
5 How long does it take -- you have two valves f
6 there, one inside the drywell and one outside the drywell.
7 How long does it take for those valves to close? You say i they are motor operated. In case of a break in the high 8
2 9 pressure coolant injection steam line --
I 10 MR. CUTTER: It is on the order of a minute, and 4
11 we will have --
12 CHAIRMAN PALLADINO: A minute?
13 MR. CUTTER: A minute, but we will have to verify i -
14 the time.
{
13 CHAIRMAN PALLADINO: And does enough activity gets 16 out such that this gives you such a big burden for 17 equipment qualification in the reactor building?
18 .MR. CUTTER: It is not a radiation exposure or 19 radioactivity situation. It is a high-energy steam i
20 temperature profile situation. In the confined space of
{
21 the HPCI room, the peak temperature is approximately 310 I
22 degrees. As one gets into the more open spaces and
- t 23 achieves elevations successively further away from the .
i steam line, that peak temperature goes down to the 240 to j 24
't 25 280 range in the elevations adjacent to the steam line, and i
I I
l
- - _ - .~
t
. l
.' '50
- p. ,
L 1 up in the higher elevations of the building --
I 2 CHAIRMAN PALLADINO: Is there a lot of equipment 3 right around? Let me talk about the reactor building.
4 There is a lot of equipment right around the steam line i
5 that would be impacted if there was a break there?,
6 MR. CUTTER: Yes, sir. That steam line is 7 shielded and protected with a concrete block structure that 8
in the event of a break would direct the steam upward.
9 But in the immediate vicinity of that area at that 10 elevation, all of our reactor instrument penetration 11 valves, the equipment which is mounted on the reactor 12 building side of the drywell, is all at that elevation, i
. . 13 The scram discharge --
14 CHAIRMAN PALLADINO: And what sorts of 15 temperatures would they see?
I 16 MR. CUTTER: The peak temperatures there would 17 transiently be on the order of the 240-280 range. I'm 18 looking at Pat to make sure I'm speaking correctly.
! 19 CHAIRMAN PALLADINO: Is there also equipment in 20 the -- what is that --
, 21 MR. CUTTER: In the high pressure coolant 22 injection room?
23 CHAIRMAN PALLADINO: Yes.
24 MR. CUTTER: Yes, sir, there is equipment in that 25 room. And the profile in that room i s not significantly 4
l l
es
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51 1
different for us than it is for any other BWR.
2 CHAIRMAN PALLADINO: I see.
3 MR. CUTTER: So we had not achieved -- we didn't 4 see a peak situation inside the room.
5 CHAIRMAN PALLADINO: So your unique situation is 6
because of a possible line break in a steam line and 7 equipment that is in the vicinity in the reactor building.
_a MR. CUTTER: Yes, sir.
9 CHAIRMAN PALLADINO: I would appreciate your 10 checking on the size of the line and how long it takes th'e 11 valves. And I notice you have two valves, so you don't 12 have a single failure to get you in trouble, it would take
, 13 two failures.
l' i !<
I had a few+other questions, but I don't want to interrupt your presentation any more. When you are ready.
15 MR. CUTTER: Mr. Smith can I pass --
16 ,
17 CHAIRMAN PALLADINO: What's that?
la MR. SMITH: Mr. Chairman, perhaps initially I 19 should refer back to my earlier comments with respect to 20 safety. It is the deadline that is not safety related but 4
\ directly related.
21 22 In fact work of the Commission reset for purposes 23 not directly related to safety, Volume 49 Federal Register 24 page 4557; and the statement continues, "The deadline was 25 not set as a safety matter or as a cut-off date beyond i
52 1
- r
- l. ' I which reactors could no longer operate if all their 2 equipment was not qualified.
3 "Rather, the purpose of the deadline was to ensure 4 licensee compliance with the environmental qualification 5 program. Accordingly, those proposed license amendments do 6 not involve the technical issues associated with the 7 qualification status," and so on.
8 If I spoke so quickly that I obscured the emphasis 9 on the word " deadline," that certainly should be in the 10 record. And, of course, we are here not because of any i
11 difference of opinion.with the staff as to what must be 12 done, or that it must' be done as e::peditiously as possible, 13 we are here because we believe from a regulatory standpoint 14 as well as a licensee standpoint, that it would be better 15 to complete the work beginning 120 days after November 30,
! 16 1985 rather than beginning November 30, 1985 and, as Mr.
17 Cutter pointed out, approximately 1,100 -- more than 1,100 18 of the items on Brunswick 2, the unit in question, have ,
19 been completed out of approximately 1,300.
20 So, 85 percent or more of the work has been done.
21 CHAIRMAN PALLADINO: Yes, I appreciate your
! 22 statement about the deadline, and we often recognize that i
, 23 there is an interim period in which you can operate safely, 24 especially with compensatory measures.
i 25 But there was a strong implication that I got that i
- m y i
I i
i l
t
. . . .. . . _ - . _ = _ . .
? 53 1 the CPU program had nothing to do with safety, and I just 2 want to dispel you of that, at least so far as my opinion 3 is concerned. And I think the Regs are very clear that the 4 intent is to improve safety, and we would like to get it 5 done just as soon as possible.
l 6
As a matter of fact, the history of compliance l
7 with a number of regulations -- and I can pick Appendix R 8 Particularly -- the period has extended longer than it 9
takes to construct one of these plants even at the slow to schedule that some of the plants have been constructed at.
t
- 11 So, it is important to get compliance and get some I
12 compliance on a reasonable time basis, notwithstanding 13 those statements.
14 MR. SMITH: Yes. And in conclusion, Mr. Chairman,
~15 we would say that the purpose of the deadline is being 4
16 accomplished. The_ purpose of urging expeditious compliance 17 with the rule and requirements is being accomplished I 18 because most of the units in the country will be able to 19 meet the deadline.
20 As shown on slide -- yes, this slide. If you look 21 at the schedule, we had'a plan by which we hoped to be able
. 22 -- the original plan -- to achieve full compliance within a 23 schedule that would end before the deadline of November 24 30. Because it was necessary to extend a Brunswick 1 unit 25 outage, that led to a change in the necessary schedule for I
t
- 54 I
L 1 Brunswick Unit No. 2, so that it was not possible, the 1
2 equipment wasn't available, other reasons mitigated against f
3 it, completing this work during the second refueling outage 4 for Brunswick Unit No. 2.
5 _The staff also, in its letter, commented in the 6 middle of page 4, that the granting of the extension of 7 time would not put an undue risk to the public health or a
8 safety. We think that's tremendously important.
Yes, and that's because of 9 CHAIRMAN PALLADINO:
10 the compensatory measures. It doesn't say that we don't l
11 want this done for sa4ety reasons and we don't want it done 12 properly -- and promptly.
MR. SMITH: No, absolutely not. We want it done a_ 13
< - 14 for the very reasons that you stated, safety reasons, and a
15 to do it as promptly as possible. If we were able to have 16 done it more quickly, nothing would have been more desirous 17 from our own standpoint to meet our own goals and la objectives.
4 19 But the staff differentiates between whether 20 continued operation would pose a risk to public health and safety and the compensatory measures. The staff says they l 21
}
22 have also reviewed the following commensurate measures.
23 So, even at the compensatory measures we think it would 24 have been reasonable to make the request.
25 However, simply for the savings of 100 man rem, if
' ( i 1
l i - - - - _ . . _ . _
~_ - - _ _ . . . . - - -. _
- 55 1
one has the opportunity to save 100 man rem and not impose 2 an undue risk on public health and safety and finish a 3 program within 120 days, which has been a very extended 4 program, we sube.it that that's something the Commission 5
should consider and I trust that they will consider. ,
CHAIRMAN PALLADINO: Yes. Anyhow, a 120-day 6
7 period, you can take that and reflect it in terms of probability over the life of a plant. But when you talk 8
9 cumulative years, it gets to be a far more significant 10 part. Okay, enough on that point.
11 How many items are there now that you have to 12 qualify? I don't mean individual' pieces, but staff 13 indicated something, 50 or 53 items.
MR. CUTTER: Yes, sir. The staff has a listing 14 1
15 of, I think, 53. We have grouped them into 29 16 justification for continued operation packages and the 17 staff has subdivided several of those to get the 53 number.
, is I CHAIRMAN PALLADINO: Do you need an outage to a
19 accomplish all of those equipment qualifications, or can 20 some be done as you go along?
21 MR. CUTTER: We have attempted to install and do 22 all of the EQ items that we could do with the plant on 23 line, with the plant on line.
24 CHAIRMAN PALLADINO: You mean there are no more i
25 that could be done with the plant operating?
i
}
6 l
. 56 I
F.
L 1 MR. CUTTER: The remaining 187 items, individual 2 items, require plant outage to install.
3 CHAIRMAN PALLADINO: So you are saying on November 6
4 30 you will.have just as many as you have today.
5 MR. CUTTER: Yes, sir, barring unscheduled 6 outages. We shut Unit 2 down for Hurricane Gloria and in 7 the process of having to do some maintenance work prior to 8 comir;g up, we were able to install and change out, I think, 9 three limitorque operators that were on the list. So I 10 think accurately, right now, we have 184 instead of 187, 11 and 28 JCOs instead of 29.
12 But to the extent that an outage opportunity
_ , 13 presents itself, we would do that.
L 14 CHAIRMAN PALLADINO: But you are saying none of 15 the items can now be done, none of the remaining items can 16 be done with the plant on line.
17 MR. CUTTER: That's correct, sir.
18 CHAIRMAN PALLADINO: How firm is your October 15 19 date? What I'm getting at is, we are hearing you today. ,
20 The only working day between now and the 15th is tomorrow 21 and then we have a number of Commissioners traveling. Is 22 it such a firm date that -- well, what is the consequence 23 if the Commission took a little bit longer?
24 MR. SMITH: Well, Mr. Chairman, the October 15 25 date, I believe, was a date that was not a date which we 5
1 l
- 57 l f
' first suggested. We need a decision as quickly as possible 1
2 and if I may say, just as we think the November 30 date
! 3 should not be sacred -- and I put it in quotes -- if I
~t 4 4 regulation. indicates that substance rather than form is i 5 important.
6 From our, standpoint, we are going to be ready to i 7
do whatever the Commission directs us to do whenever they tell us to do it. It is a benefit for us, obviously, 't o 8
j 9 know as soon as possible. But whatever the Commission to tells us, whether it's October 15 or whenever the 11 Commission can do it in an orderly fashion afterwards, we 12 will be able to do whatever the Commission tells us to do. <
j3 CHAIRMAN PALLADINO: I get the impression, though,
]
t 14 that there was something more firm about that October 15 f
15 date than you are implying now. That if you didn't get a 16 decision by October 15, you_couldn't plan for fuel 17 procurement.
18 MR. SMITH: We will have to change our plans, and j 19 Mr. Cutter can go into the details.
20 MR. CUTTER: We have a requirement to make a l 21 commitment on the fuel reload design on October 15, and the 22 impact-of that design commitment is one that would govern I
23 whether or not we would.have a reload based on our i 24 anticipated burn-up between now and November 30, or an
- 25 anticipated burn-up between now and March 30.
i I
?
4 i
4
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- 58
/ 1 So, the October 15 d. ate is the date that we had 2 used in discussion with the staff, indicating that we did l
3 have a decision due at that point. I think, as with 4 anything else,, we will make the prudent decision on that P
5 date that we have to make and if we don't have the answer i i
i 6 to allow us to prove with or to make the decision with 4
r 1
7 certainty, then we'll make i t under uncertai nty and take
! 8 the financial consequences.
b I'm not suggesting the 9 CHAIRMAN PALLADINO:
10 Commission is going to dilly-dally in reaching a decision.
I 11 But there are constraints on the time we have and also, it 12 may be~ desirable for us to see the pattern en others before 13 ' we make this decision. But I will press for a decision if f- 14 I can get it.
r 15 COMMISSIONER BERNTHAL: You know, we are not
' 16 getting the point-very well, it seems to me. I understood i
i 17 that there was -- and I see no reason for the utility to be
. 18 shy about this. I understood that there was substantial 19 economic consequence to the utility if we fail to make a 20 decision here by the 15th.
I i
21 If that's not the case, then say so, so --
- . 22 MR. SMITH
- That is the case. We realire it's ;
23 beyond our control. We would very much like to have it.
i 24 COMMISSIONER BERNTHAL: That's true.
25 MR. SMITH: But when the Chairman says there is l
a 4 i i
J
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--, . , , . . - - - - - . - . . - - . - *+, , , , . , , , , , , . - . - - - , - , - , , - ,-,-.n - , , - , , - ~ - - - - . , , , - . , - , - - - , _ - .n-,-,-..,--,- , - - - - - ,
- 59 1 only one working day in which to make it, I don't know what I other priority work the Commission has to do. We very much 2
3 desire a decision, but we have to leave that up to you, and
?
whatever you decide, we'll bear the consequences, j 4
f 5 COMMISSIONER BERNTHAL: What happened to Friday? r 6 CHAIRMAN PALLADINO: Guite a few people are ,
7 traveling. Commissioner Roberts --
COMMISSIONER BERNTHAL: That's not their fault, i' 8 i
j 9 that's our fault.
CHAIRMAN PALLADINO: It's still one working day. <
10 b
11 I won't be here.
12 COMMISSIONER BERNTHAL: But then I'm still not i getting a. straight answer. Are there substantial economic
- f. 33 14 consequences to the licensee if we fail to act by the i
i '
15 15th? If there are not, then it's less likely that you (
16 will get an answer by then.
'(
17 As I say, I see no reason why the Commission t
la cannot or should not make an attempt to provide you an answer by then if that's the case. If it's not the case, f 19 20 then we are more likely to take our time, I would say.
21 MR. HOWE: The 15th is our window. We have been ' (
I 22 getting a lot of pressure from our fuel supplier to have
) i this answer sooner. We have explained our circumstances. l f 23
)
24 To be very up-front with you, which is what you [
i 25 apparently are seeking, my estimation would be if we don't l l
l i
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. - - _ _ - _ _ . . . - ~ _ - .-.. ._ - ._..- - .--. _ . - ._.__ _ - - . . . . _ _ ~ . .- .
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- 60 i
- j. 1' have an answer on the 15th, it's going to cost us 51.5 {'
2 million.
3 COMMISSIONER BERNTHAL: That's in line with what I I 4 thought we were told earlier. ;
'l I 5 Well, I can say for my part, Mr. Chairman.,I'm i
I 6 certainly prepared to vote by the 15th. Now, if that's not 7 possible --
I Well, I'm going to try to 8 CHAIRMAN PALLADINO:
i 9 vote myself. ,
10 COMMISSIONER BERNTHAL: Today is the 9th, that's I li si: days and I should think -- I don't see a lot changing i
i 12 between now and the 15th.
i MR. CUTTER: Chairman Palladino, Mr. Howe has
- i. 13 i
14 confirmed with the plant site that steam line is a ten-inch j
15 diameter line.
J
- 16 CHAIRMAN PALLADINO
- It is.
t
! 17 MR. CUTTER: And the closure time for each of the t
f 18 motor-operated valves is 50 seconds.
- . 19 CHAIRMAN PALLADINO
- Fifty seconds.
i
! 20 Okay, can I go on?
I i
1 21 COMMISSIONER BERNTHAL: It seems to me whichever t
j 22 way this thing goes, if we can do it, we should try and l
23 expedite our decision. One way or another, it seems to me,
! 24 they deserve to know.
1 25 CHAIRMAN PALLADINO: Yes. I just was trying to I
j 1 ,
4 l
O
- 61 1
find out how much fle::ibility we 'iad, what the consequences 2
were because like you had to put off something because you 3
had to do something else earlier, that's the situation 4 which we are --
MR. SMITH: Yes, sir. Mr. Palladino, let me put 5
this $4.5 million into context. We want most of all to 6
7 avoid the 100 man rem exposure and to have the window for 8
our people to stop and take full advantage of the lessons g learned from Unit 1, more than the dollars.
to And if we knew that a decision on the 15th or 11 midnight the 14th would be negative but we waited until 12 noon on the 16th, we might get a policy decision, we would incur the $4.5 million penalty willingly. I think that 13 t But we hope that it may not 14 would be a wise trade-off.
15 take that long.
16 The items in summary that have been shown on our 17 chart, of course, the rule itself provides for an extension 18 in exceptional cases and the Commission now will decide 19 what is an exceptional case and whether we qualify.
20 Two of our three operating units are in compliance 21 and this has entailed a great deal of work on our part.
Brunswick Unit 2 is an exceptional case. The Georgia Power 22 23 Hatch unit has been mentioned.
24 We have gone into a great deal of work comparing 25 Brunswick with Hatch, particularly because Hatch was
m
- 62 F. I mentioned in the staff letter, and we have here with us 2 today Mr. Len Gucwa who is the chief nuclear engineer and 3 manager of nuclear engineering for Georgia Power Company if 4 there are any further questions with respect to differences 5 between Hatch and Brunswick.
6 COMMISSIONER ROBERTS: Well, I do have a 7 question. How much did it cost Georgia Power at Hatch on a 8
unit basis to come into compliance?
9 MR.-SMITH: They have finished one unit and they 10 will start the next unit in December. Mr. Gucwa can il probably respond to that.
12 MR. GUCWA: My name is Len Gucwa of Georgia Power ,
1 13 Company. I'm afraid I don't have a real good dollar number
-- 14 but, as was pointed out earlier, the scope of effort in EO 15 is quite similar between Brunswick and Hatch.
16 We are looking at like 1,200 items per unit. We 17 have completed Hatch-2. There is a question of one item on 18 Hatch-2. But the dollar numbers I'm familiar with are in.
19 the same range or above what was represented by Carolina 20 Power & Light.
21 MR. SMITH: And I figure it was $24 million for 22 the two units.
23 Mr. Gucwa, you heard the discussion of_the 24 differences between the two units. Were, in your opinion, 25 those discussions accurate and correct?
4 d
. 63
' 1 MR. GUCWA: Yes, sir, they were. We still have 2
about C00 items on Hatch-1 to go, and we will do those 3 items when we shut down November 30.
4 MR. SMITH: Continued safe operation has been looked at by the staff. We believe the staff ought to 5
6 confirm that we do have a solid and sound environmental 7 qualification program.
8 We believe we have made a diligent effort to 9
achieve compliance. We talked about the unique design and to complications. The scheduling impact we have reviewed, and 11 we have also reviewed the public health and economic i 12 effects if the extension is or is not granted.
33 With that, Mr. Chairman and members of the 14 Commission, we would conclude our presentation, but we 15 remain for purposes of answering any questions the 16 Commission may have.
17 CHAIRMAN PALLADINO: Okay, thank you. Yes, I have 18 a few questions, if I may start.
19 In the staf4 paper the conclusion was reached that 20 it would be reasonable to expect that CPLL was aware of the 21 problems caused by the unique elements of the Brunswick 22 design at or near the inception of the EQ program.
23 Therefore, if CP&L had desired, these difficulties 24 could have been factored into the assessment of resources --
25 the assessment of resources needed to accomplish this work.
64 F
( 1 I wonder if you would comment on your impression 2 on the accuracy of that statement, or any other comment you 3- may wish to make.
4 MR. CUTTER: Yes, sir, Chairman Palladino. The 5 work, as with many other programs, develops over a period 6 of time as one begins to understand the nature of the task 7 and, as I mentioned earlier and Commissioner Zech 8 questioned, it took us about a year and-a-half to come to 9 an appreciation of what the magnitude of the work tasks 10 were in the numbers of items which required qualification.
11 And we undertook at that time to the extent that 12 the limitations on access to the plant and realistic
, 13 practical limitations on the numbers of people that could 14 be put to work, to resolve the EO issues along with the 15 other regulatory tasks that were in front of us at the same 16 time.
17 I do not believe that the addition of 18 significantly more resource would have brought us into 19 compliance with the rule by the end of the second refueling 20 outage, which was the October '84 start-up of Unit 2 21 because the-best we have been able to attain from vendor 22 performance still left us with approximately 80 items that 23 would not be delivered to the plant until the end of'84, 24 early '85. And additional resources would not have 25 improved that element of the work.
7
l .-
- 65
1 CHAIRMAN PALLADINO: Well, I guess I'm a little 2 bit confused. I can recogni:e that some of the work came 3
about because of at least your unique feature in the 4 reactor building.
But other utilities are not talking -- even those 5 ,
t 6
who are asking for exemptions -- aren*t talking of 50 7
different i tems, they are talking one, two, with a 1
8 multiplicity of components that go with the items.
t 9
And somehow your numbers are so much greater than t f
i ic all the others, it does not suggest an early start with due 11 diligence to get the equipment qualification requirements 12 met.
MR. CUTTER: The number perhaps can be 33 14 misleading. The total number of items to be accomplished
^
l 15 if one were to start to count not with what's left to be
- 16 done but start the count at the other end and say, what have you accomplished, would show that between Brunswick
[
1 17
- 18 Units 1 and 2 that 2,400 elements have been completed.
I ig The effort that has been applied'has been impacted i 20 by the unique elements, both in terms of special
- 21 environmental profiles causing uni que vendor development 22 programs which could not be accomplished in the period of i
23 time.
24 The reactor instrument penetration system with its 25 elements of work represents an outage of comparable i
i s t
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. 66 I
i i critical path length to a reactor coolant pipe change-out.
2 Our Unit 1 outage, which was paced by the reactor 3 instrument penetration valve replacement, was about the 4 same length, 31 weeks, as the Hatch Unit 2 outage during 5 which they replaced primary system pipe.
6 I think that the staff is accurate in its 7 statement that these elements are unique. I do not think a that the staff has the information available to it in terms 9 of the knowledge of the management process and problems and
'O the numbers of people involved to draw a conclusion based, 11 in fact, on whether or not additional resources presumably 12 could have been put to use without it having taken
__ 13 resources away from other work that we were under order to ,
14 complete, or other strong regulatory pressure to complete.
15 It's kind of all of a piece, and it's very hard to 16 single out and say, well, you know, had we known that 17 environmental qualification was the higher priority, 18 perhaps we should have been seeking a year's extension on 19 the MARK I torus program; or perhaps we should have been 20 seeking an extension on the augmented off-gas program.
21 CHAIRMAN PALLADINO: Yes, there are a number of 22 programs. I don't want to appear to be overly critical, 23 but I read that Appendi:: R modifications you don't see for 24 another few years, 1990 and perhaps beyond, I don't 25 remember.
1 l
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l l
l
- 67 l
l' i You have a recirculation pipe problem. Most other
- BWRs, if not all of them, have either made a commitment or j I
+
i 3 made replacement, and I don't think you have even made a j 4 commitment. :
5 The whole ball of wax does not give a feeling of ,
j 1
4 6 confidence that you are exercising the diligence and l ;
- 7 planning that would bring about earlier compliance to some l j 8 of these things. And that's why I asked you to comment' on ;
l the staff's conclusion because I think they may not have l
- 9 1 l 10 all the detailed knowledge you have, but they certainly !,
t 11 have made inspections.
12 The SALP ratings which you referred to go are very
( good now, vere not so good for these periods '81, '82,
! 13
- 14 *83. As a matter of fact, I think the '83 one were almost ,
all threes for the. Brunswick plants, which doesn't speak l 15 I !
! 16 too well for the plant.
Y j_ 17 Well, there is another conclusion that the staff ,
18 draws in its paper,that the CPLL arguments may be valid ,
19 today, but that the previous licensee decisions related to 20 the EQ program led to these difficulties. I guess that's i
l 21 in substantiation of their earlier comment.
i i
22 Let me see if other Commissioners have questions.
i Well, I'd just like to make a ;
l 23 COMMISSIONER ZECH:
i l 24 comment, Mr. Chairman. I think we have stated at various
' o 25 times during the afternoon on the safety issue, and I think t
i i
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. . . _ . . _ _ . . _ _ . . , . . , ~ . . - . _ . _ _ _ _ ._ ._., ._.-_ __ __ .._ _ - _ _
68 r
.. 1I it's clear we have emphasized - I think Mr. Smith 2 emphasi:ed it here recently.
3 But I think as I understand it, the staff position 4 was and did conclude that continued operation of the 5 facility until March 30, 1986, which is their requested 6 e::tensi on date, as I understand, an extension to that time 7 would not present undue rlst to the public health and 8 safety. I think that's kind of an important statement to 9 male sure it's clear.
10 Ycu know, as far as I'm concerned, the Commission 11 here in 1984 gave very clear guidance to the staff that we 12 wanted a rather tough policy on environmental 13 qualification, and we expected them to carry out that 14 policy and get the word out. And I think they have done 15 that.
16 The November 30 date, at least in my opinion, was 17 not really so arbitrary. It seemed to be a date that would la allow this long-time program to come to fruition. I think 19 we emphasi:ed at that time to the staff that we expected i
20 any exemptions to be very exceptional circumstances, rare 21 cases, things like that.
22 And, of course, the judgment we are going to have 23 to make is, does the Brunswick situation meet that " rare 24 cases," and have you indeed, you know, met every effort to 25 comply and has it been Lind of an effort that you have 7
I
l .
i ,* 69 1
1 given your best shot at.
2 I think -- at least it's my opinion that certainly 3
in recent months and years that you have indeed tried to 4 come at this program with a certain amount of I 5 aggressiveness and integrity, and I commend you for that.
i
! 6 I don't feel quite as confident about the years past. Of course, I wasn't here, I don't know. But I can !
7 i
only read what I have been presented. Perhaps it may not l 8
, i I'
9 have been as aggressive, although I understand from Mr. t 1
Cutter the different difficulties of understanding this l
}- 10 '
t I
- 11 pecgram and getting a grasp cn it. .
1 I I can only surmise that you have made a good f 12 i
33 effort to get together with the staff, but there were 14 misunderstandings. But I must say, there is a certain uncertainty, at least in my own mind, as to how ,
16 aggressively that program was factored into your 17 priorities.
13 I think that certainly your presentation today has r
. 19 been very forthright and very factual, and you have I
f 20 presented us, I believe, in a very commendable manner -- at ,
21 least it's been very helpful to me to see and understand i
i 22 the problems you are presenting to us.
23 I have not decided in my own mind what to do yet.
l- 2J I want to think about it some more. I will do that. I 25 think we should try to make a reasonable decision, ,
j i
(
I
.' 70 I recogni:ing that we have asked the staff to come up with a 2 tough policy which I think was appropriate, and the staff 3 has carried out that guidance, I think, very well.
4 In any case, it's my view that your request should 5 be acted on as promptly as we can. I personally must give 6 it moire thought, and I think it's a close call. But I 7 will do my best to think.it through and will be prepared, 8 Mr. Chairman, as soon as I can to give a response.
9 COMMISSIONER ROBERTS: I'd like to make an 10 observation which has nothing to do with this particular 11 request, and I don't indulge in self-flagellation.
12 This Commission never distinguishes itself when it
_ , 13 sets specific dates, and we have never seem to be able to 14 remember that.
15 CHAIRMAN PALLADINO: Well, the industry doesn't 16 distinguish itself either when it doesn't try to make the 17 dates.
la COMMISSIONER ROBERTS: I'm not going to argue with 19 that statement.
20 CHAIRMAN PALLADINO: Okay, good. All right, thank 21 you.
22 COMMISSIONER BERNTHAL: Let me make a brief 23 comment. One of them I wanted to make earlier, actually, 24 and it's slightly off the subject.
25 But when you showed this Brunswick outage work
_ y l
\
71 l j' I scope with this long list of modifications that have been 1
2 made, many of them with the prefix TMI, I was just kind of }
hoping that the folks from the press over at the table thee 4
3 4 would note that since TMI there has been a bit of a quiet i i
f 5 revolution that's been underway in this country.
4 l
6 This country in one sense had the misfortune, I J
guess, of being first in this business. There have been a l 7
! a lot of saf ety modifications made and, as we heard, a lot of 4
money has been spent on it.
9 j
10 This is a BWR MARK'I, which is one of the older 11 design SWRs, one of the designs that, as we recall from the l 12 source term work, still needs to have a finalized
! 33 probabilistic risk assessment evaluation done.
1 14 But I think the point shouldn't be lost of what i i 15 has happened in this country in the last five years or so.
i 1 16 This particular licensee is here today telling us that they ,
I
! 17 have. spent 22 out of 52 weeks a year over the last three
! I
! 18 years making modifications -- to get back to your point, h ',
19 Mr. Chairman -- that clearly do have safety relevance and l
\
l 20 significance.
- y. '
It's just a small point that I want not to be lost l 21
\
22 in the midst of all of this particular decision and the r l
23 decision on the extension that has been requested here.
1 i l 24 I have one other relevant observation to make i
that, I have to say, troubles me somewhat. And that's,
, 25
- i l
i l !
k i
i._..__....___._..__.,-
li 1
- 72 i
- f. I next-door to you you have a utility, a rather larger 2 utility called the Tennessee Valley Authority, that has had 3 manifest difficulties over the last six months or so, as 4 you'know, and has taken the very difficult step of shutting 5 down all its plants, in large part to conform exactly to 6 this environmental qualification issue.
7 I can't tell you exactly what that says to me, but 8 it does give one some pause, and I think you can understand 9 that. It is true that they have the lu::ury of not having a 10 State Public Utility Commission, I guess Congress fills 11 that role for the Tennessee Valley Authority. But I think 12 that's an element of this decision that the Commission also
_ , 13 is faced with by comparison now.
14 I also want to think about this a little bit more, 15 and I appreciate your coming up today, and I can assure you 16 that I fully intend to make a decision on this by the 15th, 17 so you'll have at least my decision on it one way or 18 another by that date. ,
19 That's all I have to say right now, Mr. Chairman.
20 MR. SMITH: Mr. Chairman, may I make one comment 21 in response?
22 With respect to the mention of TVA, I would like 23 to say as a neighboring utility that whatever assistance 24 and effort can be provided in order to complete whatever 25 needs to be done we have offered to render, as have others, i i 1
l l
l
..J
l
, i I
- 73 i I and I have confidence that they will be able to correct i
2 whatever, problems they have.
! 3 Their units, I believe, are out not just because j I
i 4 of environmental qualification but because of safety 5 matters. And were ours a safety matter, were we in the 6
situation where the staff could not find as they found that 7
continued operation would not impose an undue risk for 8 public health and safety, then we would not b,e asking for 9 this extension.
10 I think that makes a great deal of difference 4
11 because in 1982 we did make the decision to take both units
- 12 out of service for an extended period of time under 13 regulatory pressure to do certain work that we acknowledged 14 needed to be done. And we worked very diligently, and we
.( And it was a very serious 15 suffered that economic penalty.
16 one in the light of the state regulatory situation.
17 If there was a safety problem, we would do exactly
- 18 the same thing, no question about it.
ig COMMISSIONER BERNTHAL: Okay, fair enough. I r
20 think certainly what you say is true, particularly with i
respect to Brown's Ferry. I think at Sequoyah it's pretty 21
! 22 much EQ that has caused them in that case to shut down.
23 But you are right on Brown's Ferry, there are other issues 24 involved there.
25 MR. CUTTER: Sir, if I might comment on Sequoyah.
t f
9
.' 74 i
E. 1 I think at least to the extent that I have seen 2 descriptions written, the issue at Sequoyah is a lack of l 3 confidence on the part of TVA in what their documentation 4 shows.
5 COMMISSIONER BERNTHAL: Documentation, that's 6 absolutely right.
7 MR. CUTTER: And not knowing where they are, as 4
8 opposed to having demonstrated a justified --
9 COMMISSIONER BERNTHAL: That's exactly right.
i f 10 That's right.
11 CHAIRMAN PALLADINO: Sherwood. I want to give l
12 careful thought to this. I still am concerned that you
_ _ 13 have had long outages each year on your Brunswick plants 14 but still are a long way from achieving some of the 4
1 15 regulatory objectives that the Commission has set forth in 16 the last few years, whereas other plants have done it.
17 I still am having trouble understanding why you 18 have not been able to do these things while the other 19 plants have been able to do it, and they have actually had 20 less or lower outages.
i 21 MR. SMITH: I think, Mr. Chairman, one needs to 22 get back to the early days of the design, and this plant 23 was designed before 1970. It was one of the very early 24 BWRs, MARK Is, and we did put in the augmented off-gas 25 system. To my knowledge, I think only two other plants t
- i 1
4 1
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- - - - . , , ~ > - , - - - , , - - .
75 l
sought to do that, one Dresden unit and one Quad Cities 4
- 1 2 unit. Both of them realized before the plants went into 3 operation that that augmented off-gas system, cryogenic 4 system, wouldn't work. They took it out and corrected it.
We were further along, finished. Tried to operate 5
6 it. I think the early days are days that one must look at l 7 very carefully. And I think our conduct should be judged, '
iT 8
as all licensees, with a very tough and difficult 9 standard. We acknowledge that.
10 But if you look at where we started,and the work
+ 11 that we had to do over the last few years and compare that 12 with what's left, we think that the picture is more 13 reasonable. And if there is a way to do any of the work l 14 that we had to do more quickly and more rapidly, I assure 15 you, we want to do it.
16 CHAIRMAN PALLADINO: When did this plant, Unit 2, 17 come into operation?
Is MR. SMITH: It came in in March of 1975, I
, 19 believe. It was 1975 and the second unit came in in 1977.
20 I think it was fall of '75 and spring of '77.
21 CHAIRMAN PALLADINO: ' 'ol l , we appreciate your 22 coming in and giving us thi s i nf or .r.aci on. I don't mean to 23 close out on it if Commissioners have other questions.
1 24 COMMISSIONER BERNTHAL: I had one thing, Joe, that i
i 25 I guess I have to address to the staff in the wake of this j 1
i
,_ _ _ _ _ . ~ _ , . _ _ _ _ . , . . _ - . ~ _ _ . _ . ,_ _.-
. 76 I
- f. 1 meeting.
2 I don't recall that they made very much of the 3 fact that, as we have heard here today, the temperature 4 qualification requirement for this plant is substantially 5 higher than in other plants because of this line that's 6 exposed to the reactor building.
7 In fact, I'm just paging through here again. I 8 don't see that mentioned anywhere.
9 CHAIRMAN PALLADINO: No, I don't think it's in 10 there.
11 COMMISSIONER BERNTHAL: I would like to know from 12 our staff -- and you can do it informally or in writing,
- 13 however you wish -- the extent of the difficulties, the ,
14 additional difficulty in qualifying to that higher 15 temperature. I think we are talking about 300 degrees 16 versus 200 roughly, or something like that.
17 MR. SMITH: Excuse me.
18 COMMISSIONER BERNTHAL: Yes?
19 MR. SMITH: Mr. Bernthal, on page 3 it's a 20 parenthetical reference. But there is a series of 21 paragraphs under the underlying heading, " Unique Elements 22 of Plant Design" --
23 COMMISSIONER BERNTHAL: Right, right.
24 MR. SMITH: There the second sentence. I believe.
25 "The first condition results in broader scope of equipment i
77 I and in qualification temperatures higher than for other 1 2 MARK Is."
3 COMMISSIONER BERNTHAL: Okay. But they didn't say 4 how much higher, and it seems.to me a hundred degrees is, 5
at least on a relative scale going from 200 to 300, is a 3,
6 significant difference.
7 I would like to see a little bit more elaboration 8 on that point. I can imagine -- I don't know whether it's true but I can imagine -- that that could be tougher. And
\ 9 I'd like to know whether that point is in fact unique. If 10 11 I could get some information on that.
12 MR. CUTTER: Commissioner Bernthal, in l
13 clarification. The 300 degrees is a temperature achieved 14 in the high pressure coolant injection room.
15 COMMISSIONER BERNTHAL: Right.
16 MR. CUTTER: Out in the reactor building, the i
17 temperatures would be between 240 and 280 --
18 COMMISSIONER BERNTHAL: Okay.
19 MR. CUTTER: -- in the higher areas. And the i,
+
3 20 problem is not a problem of. equipment survival because 21 typically that temperature difference doesn't really impact 22 significantly on the stress on the equipment. !
~
23 The problem is that the typical vendor profile was 24 established around a lower temperature, and so you are left
> 25 with a piece of equipment that you can analy e and say will l 4
78 4
work, but you can't prove it until you run the additional 1
- I 2 tests or do something to --
3 COMMISSIONER BERNTHAL: So you are saying that --
4 I'm extrapolating a little bit here -- but are you saying 5 that in many cases where the data e::isted for some pieces 6 of equipment or identifical pieces of equipment from a 7 given vendor at 200, let's say..they simply weren't there 8 for 300; is that --
9 MR. CUTTER: Yes, sir.
10 CHAIRMAN PALLADINO: Or for whatever the 11 temperature. .
12 COMMISSIONER BERNTHAL: Yes. I'd like to hear the 13 staff's side of that story if they would give it to me, 14 please. That's all.
15 MR. DENTON: I don't know that we can answer it 16 fully, but'we do have a member from the Equipment 17 Qualification Branch here and, as I understand the 18 question, how much of an increased challenge does this 19 higher temperature pose.
20 COMMISSIONER BERNTHAL: That's right. That's 21 right, yes.
22 MR. SHEMANSKI: Paul Shemanski from the NRC staff, 23 Equipment Qualification Branch 24 The impact, in my opinion, is not significant. I 25 agree it is higher, 300 degrees, but there are --
i I
.-. . . . . . - - - - - _ . --c
++
79
,o i 1 CHAIRMAN PALLADINO: How much?
2 MRi SHEMANSKI: We are talking in the neighborhood 3 of appro::imately 300 degrees, which is not unreasonable 4 from an equipment qualification testing standpoint. There 5 are many equipments out there which are qualified and have 6 been qualified to temperatures in excess of 300 degrees.
I
~7 So, I don't see that as a major stumbling block .
8 from an equipment qualification standpoint.
COMMISSIONER BERNTHAL: Well, "many," yes. But 9
can you compare it with other utilities? Is'this the.only 10 i
11 utility that had to carry out qualification of those higher 12 temperatures? And the implication we just heard is that 1
13 there is a substantial number of equipment items that i
^
14 vendors may have qualified at 200. And granted, you might f
l 15 carry out the test yourself, but they seem to be saying t
! 16 that'a lot of other utilities didn't have to do it
~
t 4 17 themselves because the vender had already done it at a f 18 lower temperature. l 19 But in their case.that wouldn't apply, and i 20 therefore they had to carry out the tests themselves. .
21 MR. SHEMANSKI: Two-hundred degrees is a very low i
22 qualification temperature. Typically, for inside 23 centainment for a LOCA or main steam-line break, we are i
24 tal king about temperatures in the neighborhood of 300 o3 25 degrees, 350.
i
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- 80 i
! 1 So I don't feel personally that 300 is a terrible 2 problem from an environmental qualification testing 3 standpoint.
4 MR. CUTTER: I think I would agree with Mr.
5 Shemanski, 300 degrees absolutely from an environmental 6 temperature testing standpoint is not great.
7 But he's got apples and oranges on the table. He 8 is comparing the kinds of temperatures that equipment is 1
9 qualified to inside containment to the equipment which we 10 had in the reactor building in an area that is not normally 11 environmentally stressed and therefore did not have a ready 12 basis similar to equipments utilized inside containment.
13 We submitted a letter to the staff in summer of 14 1985, July 6 -- excuse me, 1934 -- July 6, 1984, in which 15 we detailed the specific elements of equipment which could 16 not be available from vendors in time for the start-up of 17 the 1984 outage.
18 In our first attachment, we identify 60 pressure 19 switches and, if I might read just briefly from the 20 submittal which we made to the staff.
21 There were two vendors with potential replacement 22 switches -- I'll not mention the vendor names. One had an 23 environmental profile which enveloped the Brunswick plant 24 but did not meet our specification requiremer.ts for 25 accuracy in contact load ratings.
l l l '
i f
I
1 r
' =
81 i
I
], 1 The other vendor met our electrical and functional i 2 characteristics but did not have qualification testing i
3 which enveloped our temperature profile.
I 4 At that time, the vendor identified to us that I
i 5 they had confidence that the equipment would pass if they were to test it at the higher profile. We proceeded to 6
7 contract with them to test it in a period of roughly 22 weeks after testing. But at that time the supplier gave us 8
9 an e:<pected date for receiving these switches of February i
10 1985, which was significantly after the October '84 start-j Tl up dato.
12 We are talking about the ne::t outage for that unit l
to get that equipment installed. So I think just a biased 13 14 sample perhaps, but a sample of-one item we have submitted 15 to the staff that demonstrates, I think, the point that we i
T l 16 are making, that we did have a problem in reaching the
- 17 confirmed documented qualification status that we were la working to reach for equipments in the reactor building
! subject to the uniquely high profile.
19 20 CCMMISSIONER SERNTHAL: For a class of equipment 21 that most other utilities did not have to qualify at a very 22 high temperature in the reactor building.
- 23 MR. CUTTER
- Yes, sir.
24 . COMMISSIONER BERNTHAL: Well, maybe rather than 25 peciong this, if staff could give me a little more detail.
4 3
y 82 F
f_ 1 I guess you have heard the other side of the story.
2 MR. DENTON: Well, I think we agree with a lot of 3 what was said about that, that this equipment which was 4 unique here was not being qualified at al l other BWRs to 5 that higher temperature.
6 I think at the same time the staff is saying, 7 however, tests that qualified to that high level weren 't 8 all that uncommon and could have been done.
9 I'think what we are really grappling with is, the 10 Commission has set a very stringent standard to do 11 everything possible to come into compliance. And I guess I 12 would remind the Commission, this is the seccnd extension.
. 13 I granted an extension past the March 31 deadline ,
" 14 which was the original deadline the Commission set, in 15 order to give them time to come into compliance.
16 So I think we did not dig greatly into a lot of 17 these issues, could they have done more, or into their 18 management program. We were really trying to make a broad, 19 judgment against your standard. Was it due entirely to 20 circumstances beyond their control, which is a very 21 stringent standard.
22 CHAIRMAN PALLADINO: I'd like to make a comment 23 about this business of deadlines and dates. When I came on 24 the Commission, we were occupied with fire protection and I 25 was a party to giving an entension on that time frame. But
, i.
, 80 l
1 it was an e:: t en s i on without teeth.
2 And now I see that even though many people have 3
already begun to comply, you are going out to 1990, and '
4 that's a long time from the time we were thinking about.
5 Now we are putting a deadline with some teeth in 6
it, and I want to make sure that what we do is going to get 1
7 compliance on these issues. And that's going to be an 8 important item for me to debate in my own mind.
9 But I don't want to leave you with the impression 10 that I'm very -- overcome by the statement that says, well, 11 the deadlines are arbitrary. there is really no safety 12 issue. We can do it any time.
13 I think that's why we have been in such trouble on 14 some of these things that need to be done because over the 15 long haul they are safety issues. And whilo we might 16 accept that for a period of time there is no undue risk to 17 the health and safety of the public when we take 18 compensatory measures, it doesn't comfort me greatly that 19 these things aren 't getting done in a timely fashion.
20 But I will give due consideraticn to your 21 presentation, and I will ask my colleagues if they possibly 22 can vote so that we can give you an answer by the 15th, I 23 would encourage them to do that. I will certainly try to 24 do that by myself.
25 Commi ssi oner Assel sti ne is out of the country. We I
t
.' 84 r-L 1 may be able to get some indication of how he feels. But if 2 we all happen to side on one side, then we can give you
-3 some indication. If we happen to be split, maybe we can 4 still give you some indication that we are split.
5 COMMISSIONER ROBERTS: Hell, I don't want to I'm not so sure you and I are so far apart l 6 prolong this. ,
7 on it. I think you met deadlines. My difficulty is, I'm a reaching out several years in advance without knowing what 9 may occur in the intervening period of time. And that's my 10 only comment.
11 CHAIRMAN PALLADINO: I appreciate it.
12 COMMISSIONER ROBERTS: I'm not taking issue with
. 13 the fact that when we set deadlines, we expect people to
" - 14 make them. That's not what I mean.
15 CHAIRMAN PALLADINO: I appreciate that.
COMMISSIONER BERNTHAL: I know it's 4 o' clock, but 16 17 as long as we have these people here, since Sherwood Smith, 18 I think, a is tuned in to a good deal of industry 19 leadership thinking on some of these issues, I'm curious 20 and I'd like to inquire.
21 If we are going to have deadlines with teeth in 22 them -- if you can divorce this situation for a moment, I'd 23 like to ask a general question.
24 One of the things we try to do that I honestly, 25 for one, thought was a good idea and thought we should have r- ,
l -
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- 85
}' i done earlier -- at least in this area and perhaps in fire 4
2 protection as well -- is develop a system of escalating 3 penalties if a utility was found not to be in conformance I
4 with one or another requirement.
5 I kind of felt in retrospect we should have,done 6 that on fire protection. So, we thought we had hit on a --
7 CHAIRMAN PALLADINO: I think we did it on sirens.
t COMMISSIONER BERNTHAL: Well, sirens came before 8
i l 9 my time.
i 10 CHAIRMAN PALLADINO: Yes, we had an escalated l
I 11 enforcement progran and it worked.
COMMISSIONER BERNTHAL: But if we don't do that, 12 T
f 13 if you don't have something like that -- I thought this was a fair system of enforcement. I have since heard opinions
, 14 i$ that differ somewhat.
f, 16 How would you suggest that we would best carry out 17 an enforcement program with teeth in it? If it's not kind e
i
! is of a time-dependent, escalating monetary enforcement what 19 should we do, have a drop dead, shut you down date? We 20 can't shut you down by a percentage of full power very well. What do we do? It's an honest question and you can 21 22 give as candid an answer as you like.
! 23 (Laughter) 24 COMMISSIONER ROBERTS: (Inaudible)
MR. SMITH: Mr. Bernthal, it's a question that I
) 25 l
86 I
! I know is before the Commission frequently and the 2 Commission, I believe, has a task force that's chaired, I 3 think, by Admiral Dennis Wilkinson --
4 COMMISSIONER BERNTHAL: We do indeed.
5 MR. SMITH: -- that's studying this whole 6 question.
7 With respect to the current issue, the deadline, 8 of course, has very long and sharp teeth, shut-down, that 9 is achieving, I think, what the purposes of the rule were 10 stated to be because there has been an extra effort, a re-11 doubling of effort. I think everything humanly possible 12 around the industry is being done to meet these deadlines.
_ _ _ , 13 And I can't say that categorically because I haven't 14 studied every situation.
15 But I know what the industry executives say and 16 feel about this. From the standpoint of a general system, 17 I think that if you look at 1980 when there was concern 18 expressed at the congressional level with regard to whether 19 or not the system of fines that were icw in comparison with 20 their economic impact on the licensee where it appeared to 21 perhaps some of the industry critics that the level of 22 fines was not high enough, to force the company to take the 23 unit out of service and do some modification.
24 The use of smaller fines on a step-up basis 25 somehow might be misinterpreted. I think it might be
' > misinterpreted as, "Well, here we are again back in the pre-
--_ . , ..- - . - ___ - ._. -.-. -- .. . _ - . _ . . . . ~ _ . - - - . - _ _- -
t I f i 87 l
't
,'" I fall of 1980 when we had fines that were $5,000 a day 1
instead of up to $100,000." So I think one must keep that f 2 i
I 3 in mind.
4 Th'en I think, secondly, the training that goes on
]
at these plants, these people are trained, and trained, and
! 5 i
i, 6 retrained to meet the requirements; meet the regulations; !
t meet your tech specs meet whatever the company policy is.
7 l 8 And if you sought to impose in that training a system o'f, 1
9 "Well, if you don *t meet the requirements then the first i
i 10 time there is a small fine, and the second day there is a t 11 large fine." I'm afraid it would be counter-productive to i 12 your training. I'm afraid i t would tend to lessen the 13 impact of your training.
! 14 Secondly, from the standpoint of just your 1^
1 )$ operations, your perception by the public you serve and
)
! 16 your state regulators, for a utility to be operating out of h
! 17 compliance with NRC regulations and be subject to a fine, t i
i 18 whether the fine is $10 or $1,000, or $100,000 is usually ,
t
) The public concern and the state 19 lost on the public. ,
l t i
I 20 regulatory concern arises over the fact that here the 21 utility is operating out of compliance.
)
22 So these are the difficulties in using a step 1 23 system of fines. I think the system of points has been i
24 under consideration. That if there are certain violations l e i 25 or certain deadlines missed, then the utility accumulates 4
i k
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- 89 I
- f. 1 so many points for that, and if you reach a certain level 2 of points, then something happens.
3 I'm not prepared to recommend that today because I 4 haven't had an opportunity to put in enough study. But I
$ think that type of approach might be better than the series 6 of small fines and, if I may, I'll reflect on this further 7 and provide any information that I can that will be 8 helpful. ,
9 COMMISSIONER BERNTHAL: Yes. Not to prejudge or 10 preempt the work of the study panel, I have come back a 11 number of times to this idea of points, and I have to say 12 it has real attractions for me. But let's leave that for 13 now.
14 CHAIRMAN PALLADINO: Okay, any other comments?
15 Well, we thank you all, and we'll try to reach a 16 decision as soon as we possibly can.
17 MR. SMITH: Thant. you for your time, Mr. Chairman.
18 CHAIRMAN PALLADINO: We stand adjourned.
19 (Whereupon, at 4:10 p.m., the meeting of the 20 Commission was adjourned.)
21 22 23 24 25 i i
1 CERTIFICATE OF OFFICIAL REPORTER 2
3 4
5 This is to certify that the attached proceedings 6 before the United States Nuclear Regulatory Commission in the 7 matter of: COMMISSION MEETING S
9 Name of Proceeding: Meeting with Carolina Power and Light Company on Environmental Qualification to Exemption Request for Brunswick Nuclear Station (Public Meeting) 11 Occket No.
12 Place: Washington, D. C.
ta cate: Wednesday, October 9, 1985 14 15 were held as herein appears and that this is the original 16 transcript thereof for the file of the United States Nuclear 17 Regulatory Commission.
13 ,
(signature) g g%
(Typed Name of Reporter) Mary C. Simons 20 21 22 23 Ann Riley & Associates, Ltd.
24 25 1
~
Carolina Power & Light Comoany Brunswick Unit 2 l Request For Extension of November 30
- Environmental Qualification Deacline I
i SHERWOOD H. SMITH JR.
Chairman / President i ED UTLEY i
Senior Executive Vice President i
PAT HOWE Vice President Brunswick Nuclear Project AL CUTTER Vice President Nuclear Engineering & Licensing SHERWOOD ZIMMERMAN Manager Nuclear Licensing 1
i Factors Justifying Extension
- Rule provides for " extension in exceptional cases"
- 2 of 3 CP&L operating units in compliance o Brunswick Unit 2 is an exceptional case
- Continued safe operation is assured i
e Solid Environmental Qualification program
- Diligent effort to achieve compliance
- Unique plant design complicated effort l
- Scheduling impact
- Public health and economic benefits l
- 2
Health and Safety Benefits i
e ALARA savings
- Additional 100 man-rem savings achievable o incorporate lessons learned from duplicate Unit 1 outage work 3
l l
i Whyis BrunstNick-2 Not Yet Complete
- With Environmental Qualification?
- Environmental Qualification work uniquely difficult
- Competing regulatory modifications uniquely difficult o implementation timing 1
4
i Unique Brunswick Design Features I
i e concrete encased torus e Reactor instrument penetration system o Terminal blocks inside containment o Augmented off-gas system 5
Typical BWR Design t.f. -
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Effects of Concrete Encased Torus
- on Environmental Qualification o High energy HPCl/RCIC line routed through
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reactor building rather than torus compartment 4
I J
e Harsher environment Typical vendors profile 200 degrees F to 220 l
i degrees F
- Brunswick peak often exceeded vendor profile o Expanded Scope Approximately 2,600 individual devices
- Greater number than average Boiling Water Reactors 7
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O Effects of Concrete Encasec Torus on Mark I Modifications o Designed to enhance external structural stability
- Expanded number and extent of internal modifications o Vendor difficulties in the completion of the plant unique analysis
> o Mark I torus program extended two years beyond originally planned completion schedule
- Unit 1 - currently being completed Unit 2 - completed October 1984
- Diverted resources which could have been devoted to Environmental Qualification
r Reactor Instrument l . enetration System 3
i
! o initially designed as an enhanced active leak isolation system j
o Unique to Brunswick
- Most Boiling Water Reactors use a system of self actuating excess flow check valves o Reactor instrument penetration system includes approximately:
- 42 flow switches per unit
- 87 limit switches per unit
- 25 pressure switches per unit
- 157 solenoid valves per unit e in lieu of qualification, the Company elected to replace the system with excess flow check valves f
e Accounts for approximately 300 items per unit which j were not a problem for most Boiling Water Reactors 9 I
l
i Terminal Blocks inside Containment i
!
- Initially designed to enhance maintenance
- Somewhat unique in use of terminal blocks inside I containment Many other Boiling Water Reactors use terminal blocks outside containment o Qualification of many terminal blocks could not be demonstrated Hundreds of individual safety circuit splices added
, to each unit's Environmental Qualification program o Required placing each unit in a shutdown condition to allow disabling of individual safety systems to install quallfled hard splices
, 10
i Augmented Off-Gas System o initially designed to achieve zero release e Unique cryogenic system at Brunswick j - Only one to be operated under plant off-gas
- conditions
~
Unreliable o Relocated off-gas hydrogen recombiners e Cryogenic system replaced with charcoal adsorber system as used at most Boiling Water Reactors e Required a substantial resource allocation, coincident with Environmental Qualification, not encountered by other utilities it
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j Brunswick Outa0e Work Scope ;
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issa issi nd: Iw, Weets of Outage "iti- '5
, $0 3
! Reginatory m% EQ Penetration upgrades EQ Penstrations EO Moshenahons j Seisnue Support heads TRAI PASS AOG Mais Lo t.t.,J.tw tu s TAAS Post Accessent Sampamg Sys TRAS Contnant H2 Masueurs Torus hdeguly Mods Iwe Peutection M was '
TRAI Contwint Rad Georutors T RAI Suppression Pool Mosators An.alog Inst Aeods PAask i Torus Moess Ttel Conessant H2 Roonstors Augmented Ost Gas Maahtecaleons Sessndc Supports IGSCC 18iSi t l TRA8 Content Wer Lol teonstors AAark I Torus RAods Conhnr. Isolation Wosk IIF A Relay 14 cpl.4rnwnts I Turbane Skig Went Atorwoors CRD Seismec St.ppusts Stby tal Control Heat Tr.ne CRD Rehwes t one Capping Feedmaser Noute Csachmg Scrane Desctsarge Volume Mixts Feed. vater Noute Insp j Mart i Torus RAods Fire Protechon IGSCC lanp/Repasrs Fwe Psotecleon Fue Protection i
1 4 Reenatuesy am- Aar c_ , _ ;.; Tie-In Condeme, Retnamig Condenser P+tubeng 5,c Wie Ps6d9Ife9ade I RCS Recsc Pasep Ugwp.ute Rctr Fred Pun 9 Shaft Rga nel heawn Turtune Blade Rept.acenwne Tustane I ow P.s ssuse a DugdaL Analog naada on RPS & ECCS D9t# Analog Mais on f4PS S I CCS SVC was Sptem Repaws notor H.3 Jar cuwns Compeete RWCU System Atods Fdner His,Eateaction Shvi Pasawg Cnc Wir Sptem Envwon-Serse Water Pipsig Upgrade Seewece Water Papsim; Ugvade nwrital Mods L ateacteoss Sieam Pepe RAml Rctr feed Pump Turtnew i Bixbet & Deaptwagm Apk mt 1
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4 1
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, Brunswick Improvement Program
' s Purpose improve plant operations and maintenance o Achievements l
Strengthened management structure Reduced radiation exposure to ALARA Reinforced discipline of operations and maintenance l
Recognized as a model program for industry e Resource impact Every on-site organization Corporate support organization I
13 l _
Brunswick Unit 2 Schedule impact Original Plan E3 L impJ L4OI (1st Refueling) (Maintenance) (2nd Refueling)
Actual Outages r: Era I! _, 4 er - ] [,.m;.*,m y m (1st Refueling) (Maintenance and 2nd Relucling) (Requested Refueling)
Note: Brunswick Unit 1 in Conipliance 1982 1983 1984 1985 1986 .
E i R R R I f I R R ,g J R R R 1J B R R R R R g,I a a i a ij g I t I R R R R R R R R R 9 9 f f f I A f R R R la
Early Start to Achieve Comoliance I
j e Committed to a quality program o Over S5 million spent prior to final Environmental Qualification rule Compiled master list of approximately 1,500 items per unit
- Performed field inspections to ensure master list accurately reflected as-built conditions
- Developed qualification information
- Performed field modifications including over 50 percent of the terminal block splicing work in the drywell prior to 1983 e in excess of 147,500 engineering man-hours expended prior to 1983 15
4 j
Continued Diligence to Achieve Compliance e Steady, consistent approach to Environmental Qualification o Brunswick Unit 1 and Robinson Unit 2 Achieved compliance without extension e Harris Unit 1 Achieve compliance at startup e Over S24 Million will be spent on Environmental Qualification at Brunswick alone 4
16
1
. l l
Health anc Safety Benefits o ALARA savings
- Additional 100 man-rem savings achievable o incorporate lessons learned from duplicate Unit 1 outage work o Minimize professional staff fatigue and stress 17 i
i ii ghhhhphhghh(h(hph[p(l[ghp(N h h TPANSMITIAL 'IO: / X/ Docunent Cbntrol Desk, 016 Phillips M
h ADVANCED COPY 'IO: / / 'Ihe Public Document Itxn j j cc: C&R FFCH: SIrY OPS BRAtOI tachs.
papers)
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! 1%eting
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